Appendix A

Appropriate Use Findings

Appendix B

Compatibility 

Determinations

Appendix C

Implementation

Appendix D

Wilderness Review 

Inventory Phase

Appendix E

BIDEH

Appendix F

Statement of Compliance

Appendix G

Intergrated Pest 

Management Plan

Appendix H

Glossary of Terms and 

Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment Ratios

Appendix L

Ecology Work Group and 

State and Transition Model

Appendix M

Climate Change

Appendix N

Common and Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix Q

NWR Visitor Survey

Appendix R

Improving Aquatic Health

Appendix S

Response to Comments

Greater sandhill crane

©Brendan Lally

Appendices

Refuge staff conducting research

©Barbara Wheeler

Appendix A 

Appropriate Use Findings

Appendix A

Appropriate Use Findings

Appendix B

Compatibility Determinations

Appendix C

Implementation

Appendix D

Wilderness Review

Appendix E

BIDEH

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-1 

Appendix A. Appropriate Use Findings 

The Appropriate Refuge Uses Policy (603 FW 1), finalized in 2006, outlines the process that the 

Service uses to determine when general public uses on refuges may be considered. Uses proposed for 

a National Wildlife Refuge must first be found appropriate and compatible. The appropriate use 

review occurs prior to applying the compatibility screening. Compatibility determinations are found 

in Appendix B. 

Public uses previously defined as wildlife-dependent uses under the National Wildlife Refuge 

System Improvement Act of 1997 (hunting, fishing, wildlife observation and photography and 

environmental education and interpretation) are generally exempt from appropriate use review. Other 

exempt uses include refuge management activities and situations where the Service does not have 

adequate jurisdiction to control the activity. State fish and wildlife agency activities are not subject to 

this policy when they: 

1. Directly contribute to the achievement of refuge purpose(s), refuge goals, and the 

Refuge System mission, as determined by the refuge manager in writing, 

2. Are addressed in a document such as a Regional or California/Nevada Operations 

Office (CNO) memorandum of understanding or a comprehensive conservation plan 

(CCP), or

3. Are approved under national policy.

Other existing, proposed, or requested public uses are required to undergo the appropriateness screen. 

Appropriate use policy provides refuge managers with a consistent procedure to screen and document 

decisions concerning public uses, with the use of the following questions: 

(a) Do we have jurisdiction over the use? 

(b) Does the use comply with applicable laws and regulations (Federal, state, tribal, and 

local)? 

(c) Is the use consistent with applicable executive orders and department and Service 

policies? 

(d) Is the use consistent with public safety? 

(e) Is the use consistent with goals and objectives in an approved management plan or 

other document? 

(f) Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

(g) Is the use manageable within the available budget and staff? 

(h) Will this be manageable in the future within existing resources? 

(i) Does the use contribute to the public’s understanding and appreciation of the refuge’s 

natural or cultural resources, or is the use beneficial to the refuge’s natural or cultural 

resources? 

(j) Can the use be accommodated without impairing existing wildlife-dependent 

recreational uses or reducing the potential to provide quality, compatible, wildlifedependent recreation into the future? 

Uses marked “no” for questions (a) or (b) are not evaluated further. Uses that are illegal, inconsistent 

with existing policy, or unsafe (“no” to (b), (c), or (d)) may not be found appropriate. 

When a use is determined to be appropriate, a refuge manager must then decide if the use is 

compatible before allowing it on a refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-2 Appendix A. Appropriate Use Findings 

The following forms show which uses have been determined appropriate and which have been 

determined not appropriate. Narrative answers for findings follow each form. Interpretation of two of 

the questions on the form, (e) and (f), are explained below: 

 Question (e) on the appropriate uses form (Is the use consistent with goals and objectives in 

an approved management plan or other document?) is interpreted as follows: The approved 

management plan in question is interpreted as the CCP. 

 Question (f) (Has an earlier documented analysis not denied the use or is this the first time 

the use has been proposed?) was checked yes if this is the first time the use has been formally 

considered in a planning process. Question (f) was also checked yes if there is no 

documentation of the use being denied in an earlier planning process. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-3 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-4 Appendix A. Appropriate Use Findings 

Appropriate Uses Justification, Attachment 1 

Date: November 2, 2011

Refuge: Malheur National Wildlife Refuge (Refuge)

Use: Commercial Tours and Photography 

Summary: Commercial tours and photography uses on the Refuge cover a broad range of resourcebased activities, including birding, geology, plant identification, art and visual interpretation, music, 

sound recording, and other similar non-consumptive activities. These uses usually occur in areas 

open to the public, using the same facilities associated with non-commercial recreational uses. 

For findings listed on FWS Form 3-2319, and if deemed necessary, a justification has been provided 

below. 

a. Do we have jurisdiction over the use? 

All of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over collections within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, state, tribal, and local)? 

Any proposed activities would comply with all applicable laws and regulations and any restrictions 

or qualifications that are required to comply with law and regulations would be specified in the 

special use permit (SUP). 

c. Is the use consistent with applicable executive orders and department and Service policies? 

Under U.S. Fish and Wildlife Service (USFWS) Policy (50 CFR 29.1), a commercial recreational use 

is a use that generates revenue or that results in a commodity that is or can be sold for income or 

revenue. 

The Appropriate Use Policy (603 FW 1) specifically references commercial uses of this kind. The 

policy states that “Commercial uses of a refuge may be considered appropriate if they are a refuge 

management economic activity (see 50 CFR 25.12), if they directly support a priority general public 

use, or if they are specifically authorized by statute ... An example of a commercial use that may be 

appropriate is a concession-operated boat tour that facilitates wildlife observation and interpretation.” 

d. Is the use consistent with public safety? 

Through SUP review, the Refuge will ensure that each project is consistent with public safety. If 

necessary, stipulations to ensure public safety will be included in the project’s SUP. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

The use is consistent with Goal 7 in the CCP. Requests would be approved in instances where they 

can provide meaningful biological and cultural significance and public appreciation of natural 

resources. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-5 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This use had a determination completed in 1994. Use was determined to be compatible. 

g. Is the use manageable within available budget and staff? 

The use is manageable with available budget and staff. 

h. Will this be manageable in the future within existing resources? 

The proposed activity at current levels would be manageable in the future with existing resources 

(see above). 

i. Do the uses contribute to the public’s understanding and appreciation of the Refuge’s natural 

or cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources? 

The proposed use would contribute to the public’s understanding and appreciation of natural and/or 

cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see Section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

The Refuge will ensure that the activities will not impair existing or future wildlife-dependent 

recreational use of the Refuge during individual project review, prior to issuing SUPs. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-6 Appendix A. Appropriate Use Findings 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-7 

Appropriate Uses Finding, Attachment 1 

Date: November 2, 2011 

Refuge: Malheur National Wildlife Refuge 

Project: Grazing and Haying. 

Summary: Livestock grazing and haying have occurred in the past at Malheur Refuge and are proposed 

to be used in the future as tools to provide optimum conditions for wildlife (specifically, foraging areas 

for waterfowl, waterbirds, and shorebirds; pairing habitat for waterfowl; nesting habitat for shorebirds; 

and nesting habitat for certain passerines) and, where possible, to improve biological integrity (native 

plant diversity; hereafter, restoration) in Refuge plant communities. These actions would be undertaken 

by private parties under cooperative agreement.

For each of the findings listed on FWS Form 3-2319, a brief narrative response has been provided 

below. 

a. Do we have jurisdiction over the use? 

All proposed activities would take place within Refuge boundaries and under the supervision of 

Refuge staff. 

b. Does the use comply with applicable laws and regulations (Federal, state, tribal, and local)? 

The proposed activities would comply with all applicable laws and regulations and would be spelled 

out in each Cooperative Land Management Agreement (CLMA). 

c. Is the use consistent with applicable executive orders and department and Service policies? 

Under USFWS Policy (50 CFR 29.1), grazing and haying under the circumstances applicable at the 

Refuge are considered refuge management economic activities. “Refuge management economic 

activity” refers to a refuge management activity on a National Wildlife Refuge, which results in 

generation of a commodity that is or can be sold for income or revenue or traded for goods or 

services. Examples include farming, grazing, haying, timber harvesting, and trapping. 

The Appropriate Use Policy (603 FW 1) specifically states that “Commercial uses of a refuge may be 

considered appropriate if they are a refuge management economic activity ....” 

The proposed use would provide high-quality forage for migrating waterfowl and cranes within close 

proximity to high-quality roosting habitat. The use of a private cooperator to graze Refuge meadows 

helps provide high-quality forage and removes thatch that would be left behind if mowing were used 

as the only management technique. Other methods such as prescribed fire may remove thatch and 

mimic natural processes. Given the difficulty in using prescribed fire for meadow management, 

grazing is consistent with the Service’s Biological Integrity, Diversity, and Environmental Health 

Policy (601 FW 3). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-8 Appendix A. Appropriate Use Findings 

d. Is the use consistent with public safety? 

The proposed use is consistent with public safety and generally occurs in areas not accessible to the 

public. Some waterfowl/upland bird hunting does take place in areas where livestock are being used, 

but hunters are advised to avoid these highly visible treatment areas. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

The proposed use is consistent with Goal 4 of the CCP; recommendations in the 2009 Wildlife and 

Habitat Management Review (USFWS 2010); and the 1990 Blitzen Valley Management Plan (Rule 

1990). 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This use had a determination completed in 1994. Use was determined to be compatible. 

g. Is the use manageable within available budget and staff? 

The proposed use is manageable with available budget and staff. The use of cooperators may save 

staff time and resources. Force account management of this nature would prove to be highly costprohibitive to the Service. 

h. Will this be manageable in the future within existing resources? 

The proposed use would be manageable in the future with existing resources and may save staff time 

and resources (see above). 

i. Do the uses contribute to the public’s understanding and appreciation of the Refuge’s 

natural or cultural resources, or is the use beneficial to the Refuge’s natural or cultural 

resources? 

The proposed use is beneficial to the Refuge’s natural resources because haying and grazing would 

help achieve Refuge purposes by providing many waterfowl, waterbird, shorebird, and landbird with 

high-quality food sources as well as nesting and fledging habitat. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see Section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

Haying and grazing operations may occasionally conflict with the experiences of some Refuge 

visitors. However, such impacts would be expected to be minor to moderate at the Refuge due to the 

seasonal differences in uses. Refuge visitation peaks during spring, when little grazing or haying will 

likely occur. Growing-season mowing and grazing will not occur at a scale that would disrupt or 

significantly impact wildlife viewing opportunities enjoyed by Refuge visitors. During the fall when 

haying and rake-bunch grazing operations are active, wildlife observation and photography visitation 

drops. Hunting use increases during this season but is concentrated in the Buena Vista Unit and 

around Malheur Lake, where little or no haying or grazing occurs. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-9 

References 

Rule, M., G. Ivey, and D. Paullin. 1990. Blitzen Valley Management Plan. Malheur National 

Wildlife Refuge. Princeton, OR. 169 pp. 

USFWS (U.S. Fish and Wildlife Service). 2010. Malheur National Wildlife Refuge, Wildlife and 

Habitat Management Review. June 1-5, 2009. Unpublished report. Available at Refuge 

Headquarters. 52 pp. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-10 Appendix A. Appropriate Use Findings 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-11 

Appropriate Uses Finding, Attachment 1 

Date: November 2, 2011 

Refuge: Malheur National Wildlife Refuge 

Use: Plant Gathering of Culturally Important Plants

Summary: Culturally important plants that grow in the wetlands, marshes, and riparian areas have been 

collected by members of the Burns Paiute Tribe for generations. Culturally important plant collection 

involves taking hand cuttings from live plants (e.g., willow whips) or plants that have reached senescence 

(cattails and bulrush). Plant materials are collected in small amounts and plant mortality does not occur as 

a result of these activities. 

For findings listed on FWS Form 3-2319, and if deemed necessary, a brief narrative response has 

been provided below. 

a. Do we have jurisdiction over the use? 

All of the proposed activities would take place within Refuge boundaries. The Refuge has 

jurisdiction over collections within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, state, tribal, and local)? 

Any proposed collection activities would comply with all applicable laws and regulations and any 

restrictions or qualifications required to comply with law and regulations would be specified in an 

SUP. 

c. Is the use consistent with applicable executive orders and department and Service policies? 

The Appropriate Use Policy (603 FW 1) specifically references Native American ceremonial, 

religious, medicinal, and traditional gathering of plants. The policy states that the Service “will 

review specific requests and provide reasonable access to Native Americans to refuge lands and 

waters for gathering plants for ceremonial, religious, medicinal, and traditional purposes when the 

activity is appropriate and compatible or when existing treaties allow or require such access.” 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project’s SUP. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

Plant gathering by tribal members is consistent with Goal 10 in the CCP. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-12 Appendix A. Appropriate Use Findings 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This use had a determination completed in 1994. Use was determined to be compatible because of 

the infrequent use. 

g. Is the use manageable within available budget and staff? 

Currently, the Refuge receives fewer than six requests per year for this activity, and it is manageable 

with available budget and staff. 

h. Will this be manageable in the future within existing resources? 

If use remains at current levels, the use would be manageable in the future with existing resources 

(see above). 

i. Do the uses contribute to the public’s understanding and appreciation of the Refuge’s natural 

or cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources? 

Collection activities would be approved in instances where they can provide meaningful cultural 

significance and public appreciation of natural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

Persons collecting plants may occasionally flush wildlife from areas used by hunters, wildlife 

observers, photographers, anglers, or environmental education groups, but this conflict would be 

expected to be minimal. The Refuge will ensure that collection activities would not significantly 

impair existing or future wildlife-dependent recreational use of the Refuge during individual project 

review, prior to issuing each SUP. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-13 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-14 Appendix A. Appropriate Use Findings 

Appropriate Uses Finding, Attachment 1 

Date: November 2, 2011 

Refuge: Malheur National Wildlife Refuge 

Project: Research, scientific collecting, and surveys 

Summary: The Refuge receives or initiates requests for scientific research on Refuge lands and 

waters. Research topics cover a variety of biological, physical, archeological, and social issues and 

concerns to address Refuge management information needs or other issues not related to refuge 

management. This compatibility determination refers to research, collecting, or surveys conducted by 

non-USFWS entities. This may include other Federal, state, tribal, and private entities, or their 

contractors. Research proposals must be accompanied by a detailed study plan. Proposals will be 

reviewed and granted special use permits on a case-by-case basis. 

For each of the findings listed on FWS Form 3-2319, a brief narrative response has been provided 

below. 

a. Do we have jurisdiction over the use? 

The Refuge has jurisdiction over those research projects that are sited within Refuge boundaries. 

b. Does the use comply with applicable laws and regulations (Federal, state, tribal, and local)? 

Any proposed research activity would comply with all applicable laws and regulations and any 

restrictions or qualifications that are required to comply with laws and regulations would be specified 

in the SUP. 

c. Is the use consistent with applicable executive orders and department and Service policies? 

The Appropriate Use Policy (603 FW 1) specifically references research. Under this policy, the 

Service actively encourages cooperative natural and cultural research activities that address Service 

management needs, and encourages research related to the management of priority general public 

uses. According to the policy, research that directly benefits refuge management has priority over 

other research. 

Through the review of individual projects, the Refuge would ensure that project proposals are 

consistent with other applicable policies. 

d. Is the use consistent with public safety? 

Through individual project review, the Refuge will ensure that each project is consistent with public 

safety. If necessary, stipulations to ensure public safety will be included in the project plan.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-15 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

The proposed use is consistent with Goal 13 of the CCP. Research activities would be approved in 

instances where they can provide meaningful data that may contribute to Refuge management and 

public appreciation of natural resources. 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

This use had a determination completed in 1994. The use was determined to be compatible. 

g. Is the use manageable within available budget and staff? 

Currently, the Refuge typically receives fewer than six requests per year for this activity, and it is 

manageable with available budget and staff. 

h. Will this be manageable in the future within existing resources? 

Research activity is expected to increase over the next 15 years. Projected levels of research activity 

would be manageable in the future with existing resources. 

i. Do the uses contribute to the public’s understanding and appreciation of the Refuge’s natural 

or cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources? 

Completed research projects would provide information useful for the management of the Refuge’s 

natural or cultural resources. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see Section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

Researchers may occasionally flush wildlife from areas used by hunters, wildlife observers, 

photographers, anglers, or environmental education groups, but this conflict would be expected to be 

minimal. 

The Refuge will ensure that research activities would not significantly impair existing or future 

wildlife-dependent recreational use of the Refuge through SUP stipulations, as needed for each 

project. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-16 Appendix A. Appropriate Use Findings 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-17 

Appropriate Uses Finding, Attachment 1 

Date: November 2, 2011 

Refuge: Malheur National Wildlife Refuge (Refuge) 

Project: Farming 

Summary: The cooperative program would include between 80 to 1,000 acres to support objectives 

described in the CCP using appropriate farming practices. Crops would include wheat, barley, rye, 

oats, or similar crops known to have wildlife forage value. 

Cropland management would be carried out by cooperative farmers under agreement with the 

Refuge. The resulting crop would be shared by the cooperator and the government. To benefit 

wildlife, the Refuge share would be left in the field where it would be available to wildlife. 

Since cereal grains are favored by cranes and some waterfowl as a high-carbohydrate food, the 2009 

Wildlife and Habitat Management Review (USFWS 2010) recommended continuing crop production 

to benefit cranes. 

For each of the findings listed on FWS Form 3-2319, a brief narrative response has been provided 

below. 

a. Do we have jurisdiction over the use? 

All proposed activities would take place within Refuge boundaries and under the supervision of 

Refuge staff. 

b. Does the use comply with applicable laws and regulations (Federal, state, tribal, and local)? 

The proposed activities would comply with all applicable laws and regulations and would be spelled 

out in the Cooperative Farming Agreement (CFA). 

c. Is the use consistent with applicable executive orders and department and Service policies? 

Under USFWS Policy (50 CFR 29.1), farming under the circumstances applicable at the Refuge are 

considered refuge management economic activities. “Refuge management economic activity” refers 

to a refuge management activity on a national wildlife refuge that results in generation of a 

commodity that is or can be sold for income or revenue or traded for goods or services. Examples 

include farming, grazing, haying, timber harvesting, and trapping. 

The Appropriate Use Policy (603 FW 1) specifically states that “Commercial uses of a refuge may be 

considered appropriate if they are a refuge management economic activity ....” 

The proposed use would provide high-energy and readily available foods for migrating waterfowl 

and cranes within close proximity to other natural food sources and high-quality roosting habitat. 

Crops provide wildlife with easily accessible high-energy foods, are more digestible than many 

native plants, and can reduce foraging time required to meet caloric demands (Alisauskas and 

Ankney 1992; Baldassare and Bolen 2006). Because these conditions cannot be met by singularly 

managing natural foods, the production of non-genetically modified crops is consistent with the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-18 Appendix A. Appropriate Use Findings 

Service’s Biological Integrity, Diversity, and Environmental Health Policy (601 FW 3) and will help 

achieve Refuge purposes. 

d. Is the use consistent with public safety? 

The proposed use is consistent with public safety and would be sited in areas closed to the general 

public. 

e. Is the use consistent with goals and objectives in an approved management plan or other 

document? 

The proposed use is consistent with Goal 3 in the CCP and with recommendations in the 2009 

Wildlife and Habitat Management Review conducted by the Service (USFWS 2010) and the 1990 

Blitzen Valley Management Plan (Rule 1990). 

f. Has an earlier documented analysis not denied the use or is this the first time the use has 

been proposed? 

The use has been ongoing for many years. 

g. Is the use manageable within available budget and staff? 

The proposed use is manageable with available budget and staff. The use of cooperators may save 

staff time and resources and increase the reliability of successful crop production. 

h. Will this be manageable in the future within existing resources? 

The proposed use would be manageable in the future with existing resources and may save staff time 

and resources (see above). 

i. Do the uses contribute to the public’s understanding and appreciation of the Refuge’s natural 

or cultural resources, or is the use beneficial to the Refuge’s natural or cultural resources? 

The proposed use is beneficial to the Refuge’s natural resources because crop production would help 

achieve Refuge purposes by providing migrating waterfowl and cranes with a high-energy, easily 

accessible food source in close proximity to natural foods and roosting sites. 

j. Can the use be accommodated without impairing existing wildlife-dependent recreational 

uses or reducing the potential to provide quality (see Section 1.6D, 603 FW 1, for description), 

compatible, wildlife-dependent recreation into the future? 

The proposed use will not impair existing or future wildlife-dependent recreational use of the Refuge. 

A maximum of 1,000 acres (approximately 0.5percent of the Refuge area) would be used for crop 

production. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix A. Appropriate Use Findings A-19 

References 

Alisauskas, R.T. and C.D. Ankney. 1992. The cost of egg laying and its relationship to nutritional 

reserves in waterfowl. Pages 30-61 in: B.D.J. Batt, A.D. Afton, M.G. Anderson, C.D. 

Ankney, D.H. Johnson, J.A. Kadlec, and G.L. Krapu, eds. Ecology and management of 

breeding waterfowl. Minneapolis: University of Minnesota Press. 

Baldassare, G.A and E.G. Bolen. 2006. Waterfowl ecology and management. Hoboken, NJ: John 

Wiley and Sons, Inc. 

Rule, M., G. Ivey, and D. Paullin. 1990. Blitzen Valley Management Plan. Malheur National 

Wildlife Refuge. Princeton, OR. 169 pp. 

USFWS. 2010. Malheur National Wildlife Refuge, Wildlife and Habitat Management Review. June 

1-5, 2009. Unpublished report. Available at Refuge Headquarters. 52 pp. 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

A-20 Appendix A. Appropriate Use Findings 

This page left blank intentionally. 
Anglers on Blitzen River

©Barbara Wheeler

Appendix B

Compatibility Determinations

Appendix B

Compatibility Determinations

Appendix C

Implementation

Appendix D

Wilderness Review

Appendix E

BIDEH

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-1 

Appendix B. Compatibility Determinations 

Introduction 

The compatibility determinations (CDs) developed during the comprehensive conservation plan 

(CCP) planning process evaluate uses as projected to occur under the management direction 

described in the CCP. The evaluation of funds needed for management and implementation of each 

use also assumes implementation as described under the management direction. 

Uses Evaluated at This Time 

The following section includes full CDs for all refuge uses that are required to be evaluated at this 

time. According to Service policy, CDs will be completed for all uses proposed under a CCP that 

have been determined to be appropriate. Existing wildlife-dependent recreational uses must also be 

reevaluated and new CDs prepared during development of a CCP. According to the Service’s 

compatibility policy, uses other than wildlife-dependent recreational uses are not explicitly required 

to be reevaluated in concert with the preparation of a CCP, unless the conditions of the use have 

changed or unless significant new information related to the use and its effects has become available, 

or the existing CDs are more than 10 years old. However, the Service planning policy recommends 

preparing CDs for all individual uses, specific use programs, or groups of related uses associated 

with the management direction. Accordingly, the following CDs are included in this document for 

public review. 

Table B-1. Summary of Compatible Use Determinations 

# Refuge Use Page Appropriate? Compatible? Year Due for 

Reevaluation 

B.1 Wildlife Observation, 

Photography, and Interpretation 

B-4 N/A Yes 2027 

B.2 Environmental Education B-20 N/A Yes 2027 

B.3 Waterfowl Hunting B-29 N/A Yes 2027 

B.4 Upland Game Hunting B-44 N/A Yes 2027 

B.5 Fishing B-61 N/A Yes 2027 

B.6 Commercial Tours and 

Photography 

B-72 Yes Yes 2022 

B.7 Grazing and Haying B-80 Yes Yes 2022 

B.8 Plant Gathering of Culturally 

Important Plants 

B-109 Yes Yes 2022 

B.9 Research, Scientific Collecting, 

and Surveys 

B-114 Yes Yes 2022 

B.10 Farming B-121 Yes Yes 2022 

Compatibility: Legal and Historical Context 

Compatibility is a tool refuge managers use to ensure that recreational and other uses do not interfere 

with wildlife conservation, the primary focus of refuges. Compatibility is not new to the Refuge 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-2 Appendix B. Compatibility Determinations 

System and dates back to 1918 as a concept. As policy, it has been used since 1962. The Refuge 

Recreation Act of 1962 directed the Secretary of the Interior to allow only those public uses of refuge 

lands that were “compatible with the primary purposes for which the area was established.” 

Legally, refuges are closed to all public uses until officially opened through various administrative 

actions, including CDs. Regulations require that adequate funds be available for administration and 

protection of refuges before opening them to any public uses. However, wildlife-dependent 

recreational uses (hunting, fishing, wildlife observation, photography, interpretation, and 

environmental education) are to receive enhanced consideration and cannot be rejected simply for 

lack of funding, unless the refuge has made a concerted effort to seek out funds from all potential 

partners. Once found compatible, wildlife-dependent recreational uses are deemed the priority public 

uses at a refuge. If a proposed use is found not compatible, the refuge manager is legally precluded 

from approving it. However, a use found not compatible may be modified such that it can be found 

compatible. Economic uses that are conducted or authorized by the refuge also require CDs. 

Under compatibility policy, uses are defined as recreational, economic/commercial, or managementrelated uses of a refuge by the public or a non–Refuge System entity. Uses generally providing an 

economic return (even if conducted for the purposes of habitat management) are also subject to CDs. 

The Service does not prepare CDs for uses where the Service does not have jurisdiction. For 

example, the Service may have limited jurisdiction over refuge areas where property rights are vested 

by others; where legally binding agreements exist; or where there are treaty rights held by tribes. In 

addition, aircraft overflights, emergency actions, some activities on navigable waters, and activities 

by other Federal agencies on “overlay Refuges” are exempt from the compatibility review process. 

New compatibility regulations, required by the National Wildlife Refuge System Improvement Act 

of 1997 (Improvement Act), were adopted by the Service in October 2000 (U.S. Fish and Wildlife 

Service [USFWS] 2000). The regulations require that a use must be compatible with both the mission 

of the System and the purposes of the individual refuge. This standard helps to ensure consistency in 

application across the Refuge System. The Act also requires that CDs be in writing and that the 

public have an opportunity to comment on most use evaluations. 

The Refuge System mission emphasizes that the needs of fish, wildlife, and plants must be of 

primary consideration. The Improvement Act defined a compatible use as one that “ ... in the sound 

professional judgment of the Director, will not materially interfere with or detract from the 

fulfillment of the mission of the System or the purposes of the Refuge.” Sound professional judgment 

is defined under the Improvement Act as “ ... a finding, determination, or decision, that is consistent 

with principles of sound fish and wildlife management and administration, available science and 

resources ....” Compatibility for priority wildlife-dependent uses may depend on the level or extent 

of a use. 

Court interpretations of the compatibility standard have found that compatibility is a biological 

standard and cannot be used to balance or weigh economic, political, or recreational interests against 

the primary purpose of the Refuge (Defenders of Wildlife v. Andrus [Ruby Lake Refuge]). 

The Service recognizes that CDs are complex. For this reason, refuge managers are required to 

consider “principles of sound fish and wildlife management” and “best available science” in making 

these determinations (House of Representatives 1997). Evaluations of the existing uses on Malheur 

National Wildlife Refuge are based on the professional judgment of Refuge and planning personnel 

including observations of Refuge uses and reviews of appropriate scientific literature. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-3 

In July 2006, the Service published its Appropriate Refuge Uses Policy (603 FW 1). Under this 

policy, most proposed uses must also undergo a review prior to compatibility. Uses excepted from 

the policy include the Big Six uses and uses under reserved rights—see the policy for more detail. 

Appropriate uses reviews are included in Appendix A. 

References 

Defenders of Wildlife v. Andrus (Ruby Lake Refuge I). Case 2098 (D.D.C. 1978). Environmental 

Reporter 11:873. 

House of Representatives. 1997. Report 105-106 on National Wildlife Refuge System Improvement 

Act. Available at: http://www.fws.gov/Refuges/policiesandbudget/HR1420_part1.html. 

USFWS (U.S. Fish and Wildlife Service). 2000. Compatibility regulations. Available at: 

http://www.fws.gov/Refuges/policymakers/nwrpolicies.html. Accessed June 23, 2011. 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-4 Appendix B. Compatibility Determinations 

B.1 Wildlife Observation, Photography, and Interpretation 

Compatibility Determination 

RMIS Database Uses: Wildlife Observation; Photography (wildlife); Interpretation 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

This CD examines wildlife observation, wildlife photography, and interpretation as described under 

the management direction of the Malheur Refuge CCP. There is substantial overlap between 

activities associated with wildlife observation, wildlife photography, and interpretation on the 

Refuge, and as such these uses are evaluated together in this CD. Associated uses include hiking, 

motorized boating (electric), and non-motorized boating. Horseback riding, cross-country skiing, and 

bicycling also may occur incidental to these uses, but at very low levels (<5 visits per year per 

activity); they are analyzed as part of this CD. 

Program Offerings: Under the management direction, the uses will continue to occur primarily 

informally as self-guided activities. However, in addition, monthly, docent-led tours will be 

established to diversify the visitor experience and opportunities for these uses, including kayaking or 

canoeing tours on Malheur Lake by Refuge staff and/or qualified volunteers.

Location of Use: Visitors typically engage in wildlife observation, wildlife photography, and 

interpretation uses at the Refuge Headquarters, along Center Patrol Road on the Auto Tour Route, 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-5 

and at a number of historic and interpretive sites, including Benson Pond, the historic Sodhouse 

Ranch, Buena Vista Overlook, Krumbo Reservoir, and the historic P Ranch. The historic Sodhouse 

Ranch is a significant resource for colonial nesting great blue herons and cormorants and winter 

roosting for bald eagles; the site will continue to be closed for the majority of the year to prevent 

disturbance, but it is open to the public from August 15 through October 15, after peak wildlife 

activity has subsided and before bald eagles roost in the winter. Krumbo Reservoir provides habitat 

for migrating loons in early spring and fall, and eared grebes during winter nesting season. Under the 

management direction, Krumbo Reservoir will be opened to year-round wildlife observation, 

photography, and interpretation. Non-motorized boats or boats with electric motors will be allowed 

on Krumbo Reservoir to support these uses. Other areas on the Refuge will be occasionally visited 

during docent-led tours.

Associated Facilities: A network of pull-offs, viewpoints, kiosks, overlooks, and hiking trails that 

vary in length from less than 1 mile to 11 miles will support these uses. The management direction 

provides more opportunities for developed wildlife observation, photography, and interpretation 

programs and structured visitor experiences with enhanced facilities and improved access. An 

enlarged visitor contact station/gift shop and office will be developed at Refuge Headquarters, as 

well as a seasonal contact station at the P Ranch. Additional developed visitor amenities (including 

restrooms, vault toilets, picnic tables, and shelters), new interpretive panels, vehicle pull-outs, 

viewing overlooks and elevated viewing platforms, and permanent photography blinds will be 

constructed throughout the Refuge at specific strategic public use locations. 

Access: As is the case currently, use will be permitted for vehicles on public roads; on foot along 

roads open to motorized vehicles and designated hiking trails; and, occasionally, for boats. Except for 

docent-led tours (which will occur monthly and during special events), which may venture farther 

afield, public access will remain confined to roads and trails. Road access will be expanded by 

opening the Boat Landing Road to the Malheur Lake airboat launch site near Refuge Headquarters 

and the East Canal Road to the confluence of Bridge Creek with the East Canal. Additional loop, 

spur, and Americans with Disabilities Act (ADA) trails will be created, resulting in a total of 44 

miles of roads and 17 miles of trails open to public access under the CCP. In contrast to current 

management, occasional canoe/kayak access via docent-led tours will be encouraged on Malheur 

Lake. 

Number of Visitors and Seasonal Patterns: Wildlife observation, photography, and interpretation 

are expected to remain the most popular activities on Malheur Refuge over the life of the CCP. An 

estimated 93 percent of Refuge visitors engage in bird-watching and other forms of wildlife 

observation. Current annual visits associated with wildlife observation are estimated at 61,000. 

Annual visits associated with interpretation are estimated at 52,000, and annual visits associated with 

wildlife photography are also estimated at 52,000 (visits are tabulated separately). Wildlife 

observation, photography, and interpretation occur year-round on the Refuge, but peak during spring 

migration (March to May) and fall migration (September). The remainder of the year, the Refuge 

may see less than 100 visitors per month. As a result of the emphasis on enhanced facilities, 

expanded access, and more special events and programs under the CCP, these uses will be expected 

to grow over 15 years to 82,000 visits per year for wildlife observation, 71,000 visits per year for 

photography, and 71,000 visits per year for interpretation (visits are tabulated separately). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-6 Appendix B. Compatibility Determinations 

Availability of Resources 

Availability of resources for administering and managing wildlife observation, photography, and 

interpretation under the CCP are detailed in Table B-2. 

Table B-2. Costs to Implement the Use 

Category One-time 

Expenses ($) 

Recurring 

Expenses ($/year) 

Welcome and Orientation (W&O) 

Update existing W&O panels and develop new panels at four 

locations $120,000 $500

Maintain existing and develop two new vault toilets $50,000 $5,000

Maintain existing and develop new visitor amenities, including 

accessible picnic tables, trash cans, and shelters $7,500 $5,000

Construct enlarged visitor contact station and gift shop $250,000 $10,000

Rehabilitate George Benson Memorial Museum facility $50,000 

Establish seasonal contact station at P Ranch $45,000 $3,000

Develop modern media W&O materials, maintain website, etc. $1,000

Wildlife Observation, Photography, Interpretation 

Conduct docent-led canoe/kayak tours on Malheur Lake $100,000 $15,000

Advertise, train volunteers, and conduct other monthly landbased docent tours monthly, plus special events $50,000 $5,000

Provide new non-ADA trails and develop new trail signage $72,000 $2,000

Provide new ADA trails at Sodhouse Ranch, Benson Pond, P 

Ranch $225,000 $2,000

Construct wildlife-viewing overlook at Krumbo Reservoir $40,000 $1,000

Construct four elevated viewing platforms $220,000 $4,000

Provide three photography blinds $30,000 $1,000

Maintain historical landscapes for birding $1,000

Develop new interpretive panels $45,000 $1,000

Administer and manage programs $55,000

Transportation 

Raise and surface Center Patrol Road $1,200,000 $100,000

Develop additional vehicle pull-offs $52,500 

Improve vehicle access along East Canal Road $90,000 

Improve vehicle access at Boat Landing Road, including pulloffs $45,000 

Maintain Krumbo Lane $10,000

Develop parking areas to assist with public use programs $150,000 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-7 

Category One-time 

Expenses ($) 

Recurring 

Expenses ($/year) 

Overall road maintenance (public roads, pull-offs, parking areas) $20,000

Total $2,792,000 $241,500

Wildlife observation, photography, and interpretation are the biggest programs on the Refuge and 

attract the most visitors and visits. The Refuge has one full-time equivalent (FTE) position dedicated 

to the visitor services program as a Visitor Services Manager, with a majority of time spent on 

administering and managing the wildlife observation, photography, and interpretation program. 

There are two additional FTE positions supporting cultural resources programs and law enforcement 

needs. Other Refuge staff assist in trail and parking area maintenance, facility and road maintenance, 

sign posting, and construction projects. The Refuge has a strong volunteer base, and the visitor center 

and tours are generally staffed by volunteers during the high visitation months from May to 

September. 

Some capital projects may currently lack funding, but the Refuge will develop partnerships and seek 

additional funding resources over the next 15 years as necessary to complete projects. Based on the 

availability of resources, the Refuge will have sufficient funds for managing current and expected 

levels of uses associated with wildlife observation, photography, and interpretation. Exact costs will 

be developed during design and implementation. 

Welcome and orientation facilities, signage, access trails, and other transportation resources are used 

for multiple purposes across programs, including environmental education, hunting, and fishing. 

Program-specific facilities and resources are included in the appropriate CDs. 

Anticipated Impacts of the Uses 

General Impacts Expected from the Scientific Literature

A general assessment of impacts resulting from wildlife observation, photography, and interpretation 

uses has been compiled from the literature and is briefly summarized below. 

Disturbance Intensity (Frequency, Distance, etc.): Human activities on recreational lands, trails, 

and other access points can result in direct effects on wildlife. Disturbance responses can depend 

upon the activity type, recreationists’ behavior, and the distance, duration, frequency, predictability, 

timing, and visibility of the use (Knight and Cole 1995). Disturbance to migrant shorebirds on 

eastern coastal bays was found to increase as the total number of disturbances and recreationists 

increased and the distance from the disturbance decreased (Burger 1986). Flushing, especially 

repetitive flushing, can strongly impact patterns of many bird species. Migratory birds have been 

observed to be more sensitive than resident species to disturbance (Klein 1989), and in the case of the 

eastern coastal migrant shorebirds, the percentage of observed shorebirds that were flushed and did 

not return increased by 53 percent from 1982-2002, suggesting that the birds were not adapting to the 

presence of people by habituation and were being affected in the long-term (Burger et al. 2004). 

Nest predation for songbirds (Miller et al. 1998), raptors (Glinski 1976), colonial nesting species 

(Buckley and Buckley 1976), and waterfowl (Boyle and Samson 1985) tends to increase in areas 

more frequently visited by people, where disturbance flushes birds away from their nests and creates 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-8 Appendix B. Compatibility Determinations 

vulnerabilities during nesting seasons. Frequency is a major factor, and songbirds have been found to 

alter behavior after repeated human disturbance, particularly red-winged blackbirds, goldfinches, and 

American robins, which became much more aggressive toward humans who repeatedly visited their 

nests (Knight and Temple 1986a, 1986b, 1986c). 

Set-back distances for public use facilities have been found to be important in limiting human 

disturbance to wildlife. In Florida, 15 species of colonial waterbirds nesting at 17 colonies were 

exposed to three different human disturbance mechanisms in order to determine recommended setback distances for protecting mixed-species nesting assemblages (Rodgers and Smith 1995). In 

general, a recommended set-back distance of about 100 meters (328 feet) for wading bird colonies 

and 180 meters (590 feet) for mixed tern/skimmer colonies was found to be adequate to effectively 

buffer sites from human disturbance caused by approach of pedestrians and motor boats (Rodgers 

and Smith 1995). In Nebraska, roosting sandhill cranes avoided sites near human disturbance features 

at 500 meters (m [1,640 feet]) from nearest paved road, 400 m from nearest gravel road, and 400 m 

from a single dwelling structure (Norling et al. 1992). Conversely, wildlife tends to habituate best to 

disturbance that is predictable, as indicated by sandhill cranes in Florida and in Nebraska that nested 

within 400 m of highways, railroads, mines, and power lines, which provided predictable background 

disturbance (Dwyer and Tanner 1992; Norling et al. 1992). 

Group Size: Disturbance impacts to wildlife related to visitor group size is not a well-documented 

research area; however, a few studies have analyzed these impacts. Most animals flee from humans, 

and large groups of people may represent greater perceived risk of predation (Geist et al. 2005). 

Remacha et al. (2011) analyzed visitor group size influences on the number and variety of birds 

observed during guided educational tours in a forested area in central Spain, with group sizes ranging 

from 7 to 20 people. The study showed that increasing visitors’ group size has an impact on wildlife, 

as large groups were associated with decreased bird numbers; additionally, the study found that birds 

may demonstrate reduced tolerance not only by reducing their frequency of occurrence but also by 

reducing the number of individuals when faced with large groups of visitors. The study concluded 

that reducing the size of visitors’ groups helps to minimize the negative impacts on wildlife and also 

allows visitors to watch more wildlife (Remacha et al. 2011). 

Another study by Beale and Monaghan (2004) on human disturbance effects to seabird colonies at St. 

Abbs Head National Nature Reserve in Scotland examined the variation in nesting success for two 

birds, kittiwakes (Rissa tridactyla) and guillemots (Uria aalge), as a function of different disturbance 

regimes, including varying the average number of people per hour and people load, which takes into 

consideration the number of visitors and their distance from the nest. Human disturbance was found 

to have a significant negative effect on the nesting success in both species of birds. Increasing visitor 

numbers by 8.5 percent resulted in a 22 percent increase in the failure rate of kittiwakes, and a 13 

percent increase in the failure rate for guillemots. Beale and Monaghan concluded that perhaps the 

most likely explanation is that nesting birds perceive people to be a potential predator and show 

appropriate anti-predator physiological responses, which interfere with energy resources available for 

nesting. The results showed that safe distances, or buffer zones, depend on the numbers of people 

visiting an area, and that both numbers and distance matter in determining disturbance effects. 

In addition to group size, loudness has also been found to be an important variable in determining 

whether birds altered their behavior. A study was conducted at the Arthur B. Marshall Loxahatchee 

National Wildlife Refuge in Florida between 1992 and 1994 to observe how people affect foraging 

birds at the Refuge (Burger and Gochfeld 1991). Variation in feeding behavior was largely explained 

by whether people were present, the number of people present, and the amount of noise made by the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-9 

people (Burger and Gochfeld 1991). For all species, time devoted to feeding and number of strikes or 

pecks decreased while people were present and as the noise made by people increased; interestingly, 

loudness was found to be more important than the number of people present (Burger and Gochfeld 

1991). Noise level is not necessarily correlated with number of people present, but larger groups 

might be more prone to producing noise than small groups or individuals. 

Conversely, a study analyzing the impacts of groups of cross-country skiers to elk in Yellowstone 

National Park found that the number of skiers did not impact the elk once they were already 

disturbed by the first skier, and instead the amount of winter range used by skiers and the number of 

days involved seemed to be more important than skier numbers (Cassierer et al. 1992). Literature 

suggests that organizing visitors in small numbers is recommended for groups, but also spreading out 

visits and locations of visits is recommended to mitigate disturbance across the landscape. 

Impacts of Pedestrian (Hiking) vs. Vehicular Access: It is widely accepted that wildlife is 

frequently more sensitive to disturbance from people on foot than in vehicles (Skagen 1980; Grubb 

and King 1991; MacArthur et al. 1982; Pease et al. 2005). Numerous studies have confirmed that 

people on foot can cause a variety of disturbance reactions in wildlife, including flushing or 

displacement (Erwin 1989; Fraser et al. 1985; Freddy 1986; Pease et al. 2005), heart rate increases 

(MacArthur et al. 1982), altered foraging patterns (Burger and Gochfeld 1991), and even, in some 

cases, diminished reproductive success (Boyle and Samson 1985).

A study on seven species of dabbling ducks at the Back Bay National Wildlife Refuge found a 

significant difference between vehicular (diesel truck and electric passenger tram) and non-vehicular 

(pedestrian and bicyclist) treatments in the number of ducks that were flushed. In this study, 90 

percent of the birds showed an observable response to non-vehicular treatments, of which 43 percent 

flew; the proportion of ducks that flew was greatest when they were located less than 100 m from the 

disturbance (Pease et al. 2005). In a review of several studies of the reaction of waterfowl and other 

wetland birds to people on foot, it was found that distances greater than 100 m in general did not 

result in a behavioral response (DeLong 2002). Mule deer in sagebrush-grassland habitat in Utah 

showed a 96 percent probability of flushing at 100 m from the line of movement of off-trail 

recreationists, with the percentage not dropping to 70 percent until the perpendicular distance 

increased to 390 m (Taylor and Knight 2003). 

Wildlife photography in particular can be a more disturbing activity because photographers are more 

likely to leave vehicles and wander off-trail, approach wildlife, and remain close for an extended 

period of time to capture a detailed photograph, as observed at Ding Darling National Wildlife 

Refuge and other places (Klein 1993; Morton 1995; Dobb 1998). This may also apply to the 

experience of the user, as avid wildlife viewers tend to intentionally seek out rare or spectacular 

species and/or are more eager to use the most viewing opportunities in the limited amount of time 

(e.g., bird listing) and thus potentially pose a larger negative impact to wildlife (Knight and Cole 

1995). People engaged in wildlife observation and photography react to the presence of birds and 

thus are generally more unpredictable on foot depending on excitement level, curiosity, and desire to 

observe closely. 

Impacts of Cross-country Skiing: In two different studies of winter recreation impacts to wildlife in 

Yellowstone National Park, Aune (1981) and Cassirer (1990) found that, except for coyotes, all 

wildlife species observed (mostly big game) reacted more quickly to an approaching skier than to a 

snowmobile, and the flight distance was generally greater from skiers. Bison were found to respond 

dramatically to skiers who were off established trails. In another study, elk began to move when 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-10 Appendix B. Compatibility Determinations 

skiers approached to within 15 m in an area heavily used by humans year-round, and within 400 m in 

an area where human activity is much lower (Cassirer et al. 1992). 

Boating Impacts: Recreational boating can alter bird distribution, reduce the use of particular 

habitats or entire areas by waterfowl and other waterbirds, alter feeding behavior and nutritional 

status, and cause premature departure from areas due to the noise and speed of boats (Knight and 

Cole 1995; Knapton et al. 2000). Canoes and kayaks can cause significant disturbance effects based 

on their ability to penetrate into shallower marsh areas (Speight 1973; Knight and Cole 1995). In the 

Ozark National Scenic Riverway, green-backed heron activity declined on survey routes when 

canoes and boat use increased on the main river channel (Kaiser and Fritzell 1984). Canoes or slowmoving boats have also been observed to disturb nesting great blue herons (Vos et al. 1985). 

Huffman (1999) found that non-motorized boats within 30 m (98 feet) of the shoreline in south San 

Diego Bay caused all wintering waterfowl to flush between the craft and shore. However, compared 

to motorboats, canoes and kayaks appear to have less disturbance effects on most wildlife species 

(Jahn and Hunt 1964; Huffman 1999; DeLong 2002).

The total number of boats and people can be an inappropriate measure of recreational intensity 

because the presence of a single boat might be just as disturbing as that of many (Tuite et al. 1983; 

Knight and Knight 1984). Even a low level of boating activity affects the duration and pattern of use 

by wildlife (Bratton 1990). 

Bicycling Impacts: In a Canyonlands National Park study comparing the effects of trail bikes, hikers, 

and vehicles to bighorn sheep behavioral responses, distances moved, and duration of responses, 

Papouchis et al. (2001) found that hikers caused the most severe responses in desert bighorn sheep 

(animals fled in 61 percent of encounters), followed by vehicles (17 percent fled) and mountain 

bikers (6 percent fled), apparently because hikers were more likely to be in unpredictable locations 

and often directly approached sheep. However, Taylor and Knight (2003), who found no difference 

in effects between hikers and bikers (see below), noted that Papouchis et al. compared the responses 

of sheep approached directly and off-trail by hikers with those of sheep approached tangentially on a 

road or trail by mountain bikers and vehicles. Generally, wildlife exhibit a stronger response to 

humans that approach them directly and to humans located off designated trails. 

In a Utah study comparing mountain biking and hiking disturbance to mule deer, antelope, and bison, 

both on- and off-trail, Taylor and Knight (2003) found little difference between the responses to 

hiking or biking. However, their results did show differences in species and based on whether the 

activity takes place on or off the trail. They did suggest that, because bikers travel faster than hikers, 

they may cover more ground in a given time period than hikers, thus having the opportunity to 

disturb more wildlife per unit of time. 

Horseback Riding Impacts: Impacts related to horseback riding include exotic plant seed dispersal in 

horse coats, forage, and manure (Beck 1993; Hammitt and Cole 1987); soil compaction and erosion 

(Bainbridge 1974; Hendee et al. 1990; Hammitt and Cole 1987); stream sedimentation (Wilson and 

Seney 1994); trail widening (Whittaker 1978); vegetation trampling (Nagy and Scotter 1974; Weaver 

and Dale 1978; Whittaker 1978); and direct wildlife disturbance (Owen 1973). 

Vegetation and soil compaction and erosion impacts can be much more pronounced from horses than 

hikers (Bainbridge 1974; Hendee et al. 1990; Hammitt and Cole 1987), with soil compaction as much 

as 1,500 psi (pounds per square inch) exerted on the soil surface with each step (Hendee et al. 1990). 

Hikers tend to flatten vegetation while horses tend to chum up soil, thus cutting plants off at the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-11 

rootstalk (Whittaker 1978). Hoof action tends to dig up and puncture the soil surface (McQuaid-Cook 

1978), which could cause greater sediment loss than any other form of recreational trail use and 

increase the potential for disturbance-tolerant vegetation establishment. Trail widening is also a 

consideration as horses tend to walk on the down slope sides of trails (Whitson 1974), creating a 

much wider area of disturbance and increasing trail maintenance problems. This can increase the 

spread of previously established exotics by providing loose, disturbed soil for germination and 

spreading reproductive plant structures. 

Wildlife disturbance relative to horseback riding has been poorly studied, with most references using 

other activities such as hiking and cross-country skiing to infer horseback riding impacts. Only one 

study identified disturbance tolerance of waterfowl to horseback riders and found that horseback 

riders could approach geese up to a distance of 150 feet. This is compared to suggested hiking trail 

distances of 250 feet (Miller et al. 1998) and boat buffers ranging from 250 to 900 feet (depending on 

type of boat, whether motorized, and species impacted; Burger et al. 1999). The 150-foot approach 

distance offered by Owen (1973) is consistent with observations suggesting that horseback wildlife 

observers can approach wildlife at closer distances than through other form of travel. Many wildlife 

species appear to be habituated to livestock and thus are less likely to flee when approached through 

this method. However, any form of approach is expected to cause some disturbance, which will vary 

according to the species affected and the type, level, frequency, and duration of disturbance, as well 

as the time of day or year that it occurs. 

Disturbance from Dogs: Dogs elicit a greater response from wildlife than people on foot alone 

(MacArthur et al. 1982; Hoopes 1993). In the case of birds, the presence of dogs may flush 

incubating birds from nests (Yalden and Yalden 1990), disrupt breeding displays (Baydack 1986), 

disrupt foraging activity in shorebirds (Hoopes 1993), and disturb roosting activity in ducks (Keller 

1991). For mule deer in Colorado, the presence of a dog resulted in a greater area of influence, alert 

and flush distance, and distance moved than when a pedestrian was alone (Miller et al. 2001). Many 

of these authors indicated that dogs with people, dogs on leash, or loose dogs provoked the most 

pronounced disturbance reactions from their study animals. Indirectly, domestic dogs can potentially 

introduce various diseases and transport parasites into wildlife habitats (Sime 1999). 

Refuge-specific Impacts 

This section evaluates the likely impact at the Refuge, considering the scientific studies discussed 

above and considering the uses within the context of Malheur Refuge. 

Over 130 species of birds nest in the Refuge, and unusual or rare birds, particularly passerines, can 

often be seen during the spring migrations. Malheur Refuge provides some of the most significant 

habitat and resources for migratory birds on the Pacific Flyway. If not adequately protected, 

especially during the migration and nesting seasons, bird populations could be impacted by regular 

disturbance and flushing from feeding, resting, or nesting areas. 

Loss of Habitat from Facility Construction: Under the management direction of this CCP, new 

facilities constructed for wildlife observation, photography, and interpretation, as well as facilities 

supporting welcome and orientation, will result in 10 acres of habitat loss, which is a fraction of a 

percentage of the Refuge. A large number of facilities will be associated with already developed 

sites, but as a result of enhanced opportunities in the P Ranch Unit, in particular, a majority of the 

habitat loss (approximately 6.5 acres) will be associated with wet meadow habitat. Overall, habitat 

loss from new facilities is considered negligible across the landscape. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-12 Appendix B. Compatibility Determinations 

Vegetation, Soil, and Water Impacts: Pedestrian access to the Refuge creates the highest potential 

for direct disturbance or damage to vegetation and soil, as foot travel associated with these uses could 

potentially result in temporary or minor vegetation trampling and soil compaction. People can also be 

vectors for invasive plants by moving seeds from one area to another. The threat of invasive plant 

establishment will always be an issue requiring regular monitoring and treatment. However, under 

the management direction of the CCP, self-guided visitor access for wildlife observation, 

photography, and interpretation will be limited to roads, 18 miles of trails, and developed sites. No 

impacts from these uses are expected to water resources. Habitat and soil impacts related to 

horseback riding will be minor, as the use is mostly incidental and occurs at very small numbers (<5 

visits a year). Horseback riding is limited to Center Patrol Road. 

In addition to the self-guided opportunities along trails, roads, and developed sites, the Refuge will 

offer up to 20 docent-led tours a year to areas that may be away from established public roads or 

trails, including tours for special events. Docent-led tours may create potential for additional impacts 

to vegetation and soil, but limitations on group size, the likelihood that tours will visit a variety of 

different locations over time, and the relatively infrequent offerings of these types of visits mean that 

the likely impacts to soils and vegetation will be minor within the context of the Refuge as a whole. 

Disturbance-related Impacts: Many of the studies noted above analyze disturbance impacts to 

wildlife from human presence. However, at Malheur Refuge, visitors most often access and explore 

the Refuge by vehicle, thus minimizing pedestrian disturbance to resources, which as noted above, 

can be larger than disturbance from vehicles. Vehicles act as a blind, shielding wildlife from humans, 

and the Refuge encourages this practice in their visitor brochure and in visitor interactions with 

volunteers and staff. Center Patrol Road allows visitors to see a diversity of habitats and wildlife 

while largely concentrating the impacts of visitors to a single road through the Refuge. Given 

previously cited studies, wildlife tends to be most disturbed by human presence at distances less than 

100 m (328 feet). Assuming a wildlife distance buffer zone of 200 m on all Refuge roads open to 

public use, the total impact of disturbance from visitors on open Refuge roads and trails is 

approximately 9,800 acres, or 5 percent of the Refuge. Disturbance to habitat will vary depending on 

the location of the road or trail, and, based on calculations, the majority of habitats that will be 

disturbed from Refuge roads and trails will be wet meadow at 28 percent, which includes a number 

of public use sites (salt desert scrub at 25 percent and sagebrush-steppe at 11 percent of total acreage 

disturbed). In the long-term, even if visitor numbers increase more than expected due to program and 

facility development, disturbance impacts from wildlife observation, photography, and interpretation 

will pose minimal impact to Refuge wildlife, because users will be concentrated on the designated 

roads, trails, and public facilities described above, leaving wildlife thousands of acres of undisturbed 

sanctuary. 

Impacts at Specific Sites: Docent-led tours will also include opportunities for group kayaking or 

canoeing on Malheur Lake, which has the potential to cause disturbance to wildlife using this 

resource and habitat, including sandhill cranes using the lake as a staging area in the fall migration 

season. Careful scheduling of the tours around sensitive wildlife seasons and resource areas, limiting 

the group size to a manageable and sustainable size, and providing public education to inform 

visitors of ethical and least intrusive methods to wildlife viewing and photography will reduce 

impacts. 

Under the management direction of the CCP, opportunities will also be expanded at Krumbo 

Reservoir for wildlife observation, including electric and non-motorized boating, outside of the 

fishing season, except when the water ices over. Increasing access to the Reservoir could have 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-13 

potential impacts to birds during the winter nesting season at Krumbo Reservoir as well as Krumbo 

Swamp and Otter Pond along the Krumbo Access Road. The number of birds using the Reservoir 

during the winter is less than 400 birds on any given day and less than 100 birds during the coldest 

part of the season; most birds have migrated farther south during the winter. The Reservoir is 184 

acres, which is less than 20 percent of the total 1,004 acres of available open water wintering habitat 

in this part of the Refuge, leaving at least 820 acres of open water for wintering bird use including 

Boca Lake, Benson Pond, and East or West Knox Pond. Additionally, the number of visitors to the 

Reservoir during the winter months will be significantly lower than in the spring, summer, or fall 

months. With the low number of birds present, low visitor use levels, and availability of additional 

wintering habitat and sanctuary, it is expected that year-round access at Krumbo Reservoir will have 

minor impacts. Wildlife surveys and monitoring will be conducted to ensure disturbance stays at a 

minimum. 

Pet Impacts: Pet impacts are expected to be minor in relation to wildlife observation, photography, 

and interpretation use, since all pets must be kept leashed and stay on designated public use roads 

and trails while on the Refuge. Horses must also stay on public use roads. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; Oregon Department of Fish and Wildlife [ODFW] 

2011). It is unclear at this time if the Refuge population is part of the Great Basin distinct population, 

which is the Federal candidate species or if they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

wildlife observation, photography, and interpretation uses and facilities will be negligible. These uses 

will continue to occur at public sites and on designated roads and trails, away from sensitive habitat 

and resources and outside of breeding areas and seasons. The greater sage-grouse is not known to 

breed on the Refuge. Incidental use of the east side of the south Blitzen Valley by sage-grouse has 

been reported during the late summer when visitor numbers and activities are lower. Wildlife 

observation, photography, and interpretation uses will be minimal in the areas of Mud and Bridge 

Creek, where frog populations are known to occur and thus will not impact the spotted frog 

populations. If uses result in unacceptable adverse effects to candidate species or habitats, the Refuge 

will impose restrictions to mitigate disturbance. 

Impacts to Other Priority Public Uses: Wildlife observation, photography, and interpretation 

generally result in little disturbance to other visitors. Conflicts between hunters and these activities 

will be minimal due to the seasonal differences in uses. Hunting on the Refuge occurs at a time of 

year when visitors engaged in wildlife observation, photography, and interpretation are fewer in 

number. Under the management direction of this CCP, hunting will be open on the southern portion 

of Malheur Lake at Boat Landing Road where docent-led kayaking or canoeing tours will also occur. 

To minimize safety conflicts between hunters and non-hunters, docent-led tours on the southern 

portion of Malheur Lake will occur prior to the hunting season so there is no overlap between uses. 

Other hunting areas are not open to self-guided wildlife observation, photography, or interpretation 

and thus this use should not conflict with hunting. There is no conflict expected between anglers or 

environmental education participants and wildlife observers or photographers. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-14 Appendix B. Compatibility Determinations 

Infrastructure: No significant effects to roads, trails, or other infrastructure from the wildlife 

observation, photography, and interpretation programs are foreseen. Normal road, trail, and facility 

maintenance will continue to be necessary. Additional facility construction or upgrade, if needed, is 

addressed in the Availability of Resources section. 

Public Review and Comment 

Extensive opportunities were provided for stakeholder engagement through the collaborative CCP 

planning process. Appendix J details the collaborative involvement undertaken during the 

development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

 Visitors will be restricted to designated trails, sites, or facilities as determined by Refuge 

staff. Use is open daily from dawn to dusk. Camping, overnight use, swimming, and fires will 

be prohibited. 

 Motorized vehicles, bicycles, horseback riding, and cross-country skiing will be authorized 

on Center Patrol Road and Krumbo Lane, and vehicles must observe posted speed limits. 

 Pets must be kept leashed while on the Refuge, and will be only permitted on open Refuge 

roads. Pet owners will be expected to clean up after their pets and properly dispose of any 

waste. 

 The Refuge will require advance reservations for groups in need of staff and volunteer 

participation to avoid conflicts with other groups and management activities. 

 Docent-led tours will be limited to 20 tours a year and 15 participants maximum per group. 

All tours will be led by Refuge staff or qualified volunteers. Tour-goers will be instructed to 

stay on-trail, in designated program boundaries, and observe extra precautions if visiting 

closed areas. 

 Improved trail signage will be developed to inform and guide visitors on name, length, 

difficulty, and destination. 

 Seasonal closure at Sodhouse Ranch will be maintained. 

 Elevated observation platforms, overlooks, trails, and blinds may be constructed to help 

reduce negative visitor impacts to wildlife, soils, vegetation, and hydrology. 

 Collection of natural objects, such as plants, animals, minerals, antlers, and cultural resources 

are prohibited. 

 If disturbance to wildlife or damage to habitat reaches unacceptable levels, the Refuge will 

limit uses in areas where unacceptable impacts occur. Monitoring will be conducted to ensure 

that high-quality habitat for wildlife feeding, resting, and breeding is maintained. 

Justification 

Wildlife observation, photography, and interpretation receive enhanced consideration in the CCP 

planning process, and are considered priority public uses when determined compatible. Although 

these activities can result in disturbance to wildlife, they will occur on a small percentage of Refuge 

acres. There is a sufficient amount of undisturbed habitat available to Refuge wildlife for escape and 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-15 

cover, and wildlife populations will find sufficient food resources and resting places. The relatively 

limited number of individual plants and animals expected to be adversely affected will not cause 

wildlife populations to materially decline. The physiological condition and production of Refuge 

species will not be impaired, their behavior and normal activity patterns will not be altered 

dramatically, and their overall welfare will not be negatively impacted. Thus, allowing wildlife 

observation, photography, and interpretation to occur under the stipulations described above will not 

materially detract or interfere with the purposes for which the Refuge was established or the Refuge 

Mission. Wildlife observation, photography, and interpretation programs complement the Refuge 

Purpose, vision, and goals, and help fulfill the mission of the National Wildlife Refuge System. 

Mandatory Reevaluation Date 

 09/2027 Mandatory 15-year Reevaluation Date (for priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Aune, K.E. 1981. Impacts of winter recreationists on wildlife in a portion of Yellowstone National 

Park, Wyoming. M.S. thesis. Montana State University, Bozeman, MT. 

Baydack, R.K. 1986. Sharp-tailed grouse response to lek disturbance in the Carberry Sand Hills of 

Manitoba. Colorado State University. Ph.D. dissertation. Fort Collins, CO. 

Bainbridge, D.A. 1974. Trail management. Ecological Society of America Bulletin 55:8-10. 

Beale, C.M. and P. Monaghan. 2004. Human disturbance: people as predation-free predators? 

Journal of Applied Ecology 41:335-343. 

Beck, K.G. 1993. How do weeds affect us all? Proceedings of the Eighth Grazing Lands Forum 

December 2, 1993:5-13. Washington, D.C. 

Boyle, S.A. and F.B. Samson. 1985. Effects of non-consumptive recreation on wildlife: A review. 

Wildlife Society Bulletin 13:110-116. 

Bratton, S. 1990. Boat disturbance of ciconiiformes in Georgia estuaries. Colonial Waterbirds 

13(2):124-128. 

Buckley, P.A. and F.G. Buckley. 1976. Guidelines for protection and management of colonially 

nesting waterbirds. North Atlantic Regional Office, National Park Service. Boston, MA. 52 

pp. 

Burger, J. 1986. The effect of human activity on shorebirds in two coastal bays in northeastern 

United States. Environmental Conservation 13:123-130. 

Burger, J. and M. Gochfeld. 1991. Human activity influence and diurnal and nocturnal foraging of 

sanderlings (Calidris alba). Condor 93:259-265. 

Burger, J., B. Harrington, J. Rodgers, and H. Smith. 1999. Minimum recommended set-back (RS) 

distances for various disturbances approaching directly towards waterbirds to prevent 

flushing. 

Burger, J., C. Jeitner, K. Clark, and L.J. Niles. 2004. The effect of human activities on migrant 

shorebirds: successful adaptive management. Environmental Conservation 31 (4):283-288. 

Cassirer, E.F. 1990. Responses of elk to disturbance by cross-country skiers in northern Yellowstone 

National Park. M.S. thesis. University of Idaho, Moscow, ID. 

Cassirer, E.F., D.J. Freddy, and E.D. Ables. 1992. Elk responses to disturbance by cross-country 

skiers in Yellowstone National Park. Wildlife Society Bulletin 20:375-381. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-16 Appendix B. Compatibility Determinations 

DeLong, A.K. 2002. Managing visitor use and disturbance in waterbirds—a literature review of 

impacts and mitigation measures. Appendix L (114 pp.) in: Stillwater National Wildlife 

Refuge Complex final environmental impact statement for the comprehensive conservation 

plan and boundary revision. Volume II. Department of the Interior, U.S. Fish and Wildlife 

Service, Region 1. Portland, OR. 

Dobb, E. 1998. Reality check: The debate behind the lens. Audubon 100:44-51:98-99. 

Dwyer, N.C. and G.W Tanner. 1992. Nesting success in Florida sandhill cranes. Wilson Bulletin 

104:22-31. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee uplands of southwest Idaho: Implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pp. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

Erwin, R.M. 1989. Responses to human intruders by birds nesting in colonies: Experimental results 

and management guidelines. Colonial Waterbirds 12:104-108. 

Fraser, James D., L.D. Frenzel, and John E. Mathisen. 1985. The impact of human activities on 

breeding bald eagles in north-central Minnesota. Journal of Wildlife Management 49:585-

592. 

Freddy, D.J. 1986. Responses of adult mule deer to human harassment during winter. Pages 286 in: 

R.D. Comer, T.G. Baumann, P. Davis, J.W. Monarch, J. Todd, S. VanGytenbeek, D. Wills, 

and J. Woodling, eds. Issues and technology in the management of impacted western 

wildlife: Proceedings of a national symposium. Thorne Ecological Institute, Boulder, CO. 

Geist, C., J. Liao, S. Libby, and D.T. Blumstein. 2005. Does intruder group size and orientation 

affect flight initiation distance in birds? Animal Biodiversity and Conservation 28.1:69-73. 

Glinski, R.L. 1976. Birdwatching etiquette: The need for a developing philosophy. American Bird 

30(3):655-657. 

Grubb, T.G. and King, R.M. 1991. Assessing human disturbance of breeding bald eagles with 

classification tree models. Journal of Wildlife Management 55:500-511. 

Hammitt, W.E., and D.N. Cole. 1987. Wildland recreation: Ecology and management. New York: 

John Wiley. 

Hendee, J.E., G.H. Stankey, and R.E. Lucas. 1990. Wilderness management. Golden, CO: North 

American Press. 

Hoopes, E.M. 1993. Relationship between human recreation and piping plovar foraging ecology and 

chick survival. M.S. thesis. University of Massachusetts, Amherst, MA. 106 pp. 

Huffman, K. 1999. San Diego South Bay survey report: Effects of human activity and watercraft on 

wintering birds in South San Diego Bay. USFWS report. San Diego, CA. 

Jahn, L.R. and R.A. Hunt. 1964. Duck and coot ecology and management in Wisconsin. Wisconsin 

Conservation Department Technical Bulletin No. 33. 212 pp. 

Kaiser, M.S. and E.K. Fritzell. 1984. Effects of river recreationists on green-backed heron behavior. 

Journal of Wildlife Management 48:561-567. 

Keller, V. 1991. Effects of human disturbance on eider ducklings Somateria mollissima in an 

estuarine habitat in Scotland. Biological Conservation 58:213-228. 

Klein, M. L. 1989. Effects of high levels of human visitation on foraging waterbirds at J. N. “Ding” 

Darling National Wildlife Refuge. Final research report. Cooperative Fish and Wildlife 

Research Unit. University of Florida, Gainesville. 

Klein, M.L. 1993. Waterbird behavioral responses to human disturbances. Wildlife Society Bulletin. 

21:31-39. 

Knapton, R., S. Petrie, and G. Herring. 2000. Human disturbance of diving ducks on Long Point Bay, 

Lake Erie. Wildlife Society Bulletin 28 (4):923-930. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-17 

Knight, R.L. and S.K. Knight. 1984. Responses of wintering bald eagles to boating activity. Journal 

of Wildlife Management 48(3):999-1004. 

Knight, R.L. and S.A. Temple. 1986a. Methodological problems in studies of avian nest defense. 

Animal Behavior 34:561-566. 

Knight, R.L. and S.A. Temple. 1986b. Nest defense in the American goldfinch. Animal Behavior 

34:887-897. 

Knight, R.L. and S.A. Temple. 1986c. Why does intensity of avian nest defense increase during the 

nesting cycle? Auk 103:318-327. 

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. Pages 51-69 in: R.L. Knight 

and K.J. Gutzwiller, eds. Wildlife and recreationists: Coexistence through management and 

research. Covelo, CA: Island Press. 

MacArthur, R.A., V. Geist, and R.H. Johnston. 1982. Cardiac and behavioral responses of mountain 

sheep to human disturbance. Journal of Wildlife Management 46:351-358. 

McQuaid-Cook, J. 1978. Effects of hikers and horses on mountain trails. Journal of Environmental 

Management 6:209-212. 

Miller, S.G., R.L. Knight, and C.K. Clinton. 2001. Wildlife responses to pedestrians and dogs. 

Wildlife Society Bulletin 29:124-132. 

Miller, S.G., R.L. Knight, and C.K. Miller. 1998. Influence of recreational trails on breeding bird 

communities. Ecological Applications 8:162-169. 

Morton, J.M. 1995. Management of human disturbance and its effects on waterfowl. Pages F59-F86 

in: W.R. Whitman, T. Strange, L. Widjeskog, R. Whittemore, P. Kehoe, and L. Roberts, eds. 

Waterfowl habitat restoration, enhancement, and management in the Atlantic Flyway. Third 

edition. Environmental Management Committee, Atlantic Flyway Council Technical Section, 

and Delaware Division of Fish and Wildlife, Dover, DE. 1,114 pp. 

Nagy, J.A.S. and G.W. Scotter. 1974. A quantitative assessment of the effects of human and horse 

trampling on natural areas, Waterton Lakes National Park. Canadian Wildlife Service. 

Edmonton, Alberta. 145 pp. 

Norling, B.S., S.H. Anderson, and W.A. Hubert. 2002. Roost sites used by sandhill crane staging 

along the Platte River, Nebraska. Great Basin Naturalist 52(3):253-261. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

Owen, M. 1973. The management of grassland areas for wintering geese. Wildfowl 24:123-130. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Pease, M.L., R.K. Rose, and M.J. Butler. 2005. Effects of human disturbances on the behavior of 

wintering ducks. Wildlife Society Bulletin 33(1):103-112. 

Papouchis, C.M., F.J. Singer, and W.B. Sloan. 2001. Responses of desert bighorn sheep to increased 

human recreation. Journal of Wildlife Management 65:573-582. 

Remacha, C., J. Pérez-Tris, and J.A. Delgado. 2011. Reducing visitors’ group size increases the 

number of birds during educational activities: Implications for management of nature-based 

recreation. Journal of Environmental Management 92(6):1564-1568. 

Rodgers, Jr., J.A. and H.T. Smith. 1995. Set-back distances to protect nesting bird colonies from 

human disturbance in Florida. Conservation Biology 9(1):89-99. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-18 Appendix B. Compatibility Determinations 

Sime, C.A. 1999. Domestic dogs in wildlife habitats. Pages 8.1-8.17 in: G. Joslin and H. Youmans, 

coordinators. Effects of recreation on Rocky Mountain wildlife: A review for Montana. 

committee on effects of recreation on wildlife, Montana chapter of The Wildlife Society. 307 

pp. 

Skagen, S.S. 1980. Behavioral responses of wintering bald eagles to human activity on the Skagit 

River, Washington. Pages 231-241 in: R.L. Knight, G.T. Allen, M.V. Stalmaster, and C.W. 

Servheen, eds. 1980. Proceedings of the Washington Bald Eagle Symposium. Seattle, WA. 

Speight, M.C.D. 1973. Outdoor recreation and its ecological effects: A bibliography and review. 

Discussion papers in conservation 4. University College London. 35 pp. 

Taylor, Audrey R. and Richard L. Knight. 2003. Wildlife responses to recreation and associated 

visitor perceptions. Ecological Applications 13:951-963. 

Tuite, C.H., M. Owen, and D. Paynther. 1983. Interaction between wildfowl and recreation at 

Llangorse Lake and Talybont Reservoir, South Wales. Wildfowl 34:48-63. 

Vos, D.K., R.A. Ryder, and W.D. Graul. 1985. Response of breeding great blue herons to human 

disturbance in north central Colorado. Colonial Waterbirds 8(1):13-22. 

Weaver, T. and D. Dale. 1978. Trampling effects of hikers, motorcycles, and horses in meadows and 

forests. Journal of Applied Ecology 15:451-457. 

Whitson, P.D. 1974. The impact of human use upon the Chisos Basin and adjacent lands. National 

Park Service (NPS) Scientific Monograph Series 4. NPS 117. (Supt. of Dots. no. 129.80:4). 

92 pp. 

Whittaker, P.L. 1978. Comparison of surface impact by hiking and horseback riding in the Great 

Smoky Mountain National Park. Report 24, Southeast Region. Atlanta, GA. 32 pp. 

Wilson, J.P. and J.P. Seney. 1994. Erosional impact of hikers, horses, motorcycles, and off-road 

bicycles on mountain trails in Montana. Mountain Research and Development 14(1):77-88. 

Yalden, P.E. and D. Yalden. 1990. Recreational disturbance of breeding golden plovers (Pluvialis 

apricarious). Biological Conservation 51:243-262. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-19 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-20 Appendix B. Compatibility Determinations 

B.2 Environmental Education Compatibility Determination 

RMIS Database Uses: Environmental education (not conducted by Refuge System staff or 

authorized agents); Environmental Education (teaching teachers or group leaders); Environmental 

Education (teaching students) 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

This CD examines environmental education (EE) on the Refuge as described in the management 

direction in this CCP. This CD addresses on-site EE programs and educational programs associated 

with non-profits and educational institutions. 

Program Offerings: EE at the Refuge is currently conducted on- and off-site and is led by Refuge 

staff and qualified volunteers. The on-site EE program has been formally correlated with Oregon 

State Educational Standards and with local school district curricula for elementary levels 

kindergarten through fifth grade, as well as secondary and university levels. Under the management 

direction of the CCP, the program will continue with ongoing collaborative efforts with local and 

regional EE initiatives to facilitate on- and off- Refuge EE for over 500 students annually, with the 

focal audience of local first and third grade students. 

In addition to supporting local schools, the Refuge will continue to support environmental education 

and natural resource–based programs on the Refuge led by a variety of non-profits and educational 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-21 

institutions. Currently, these groups include: Audubon Society chapters; high schools; public and 

private universities; and community colleges. The same or similar organizations will be expected to 

continue to participate in EE on the Refuge. Under the management direction in the CCP, non-profit 

groups and educational institutions will be required to apply for a special use permit before engaging 

in EE on the Refuge. 

The off-site EE program will be associated with established events and special programs, and the 

Refuge will continue to participate in and support local, regional, and national events and education 

modules. 

Location of Use and Associated Facilities: The on-site program for local schools occurs outdoors at 

the Refuge Headquarters and inside the George Benson Memorial Museum. Under the management 

direction of the CCP, an outdoor learning area and outdoor learning shelter at the Refuge 

Headquarters will be constructed to assist with existing EE program efforts, to provide the 

opportunity for more experiential learning, and to support EE programs during periods of inclement 

weather. 

EE programs associated with non-profits and educational institutions occur on foot or in vehicles in 

areas open to the public, and use the same facilities as wildlife observation, photography, and 

interpretation programs. Due to the large size of the Refuge, these programs are mainly conducted in 

vehicles, with occasional stops at public sites to allow groups to observe and learn about wildlife 

outside the vehicle. 

Number of Visits and Seasonal Patterns: An estimated 700 visits per year are made to the Refuge 

currently by local students for EE programs. EE for local students is currently facilitated by Refuge 

staff. EE activity conducted for non-local visitors (mostly adult visitors) is estimated to total 

approximately 6,700 visits per year. Most of the non-local EE is thought to be facilitated through 

universities, Malheur Field Station, or other non-profit groups. Based on past history, the majority of 

classes will be expected to visit the Refuge between April and June (spring migration season) under 

the CCP, although the classes may visit at any time of year. Groups may include up to 100 students. 

Class visits will be rotated to spread out the visits across different days and throughout the season to 

reduce the number of students on the Refuge at one time. 

Non-profit groups and educational institutions will continue to conduct programs during the spring 

and fall migrations to make the most of the opportunity to observe and experience the wide variety of 

wildlife on the Refuge. Educational institutions occasionally bring groups during the summer for 

special programs, like geology and field biology classes. Due to the long distances travelled by many 

of these groups to get to the Refuge, the programs associated with these groups are generally multiday and occur over the weekend, with groups staying overnight off-Refuge. 

As a result of continued emphasis on EE under the management direction of the CCP, this use is be 

expected to grow over 15 years to 800 visits by local students and 9,000 visits by non-local persons 

per year.

Availability of Resources 

Availability of resources for administering and managing EE under the CCP are detailed in Table B3. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-22 Appendix B. Compatibility Determinations 

Table B-3. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Construct outdoor EE shelter at Refuge Headquarters $80,000 $1,000

Provide outdoor learning area at Refuge Headquarters $25,000 $1,000

Administration and management of program (curriculum 

development, initiatives, special events, coordination) $14,000

Equipment and materials $2,000

Total $105,000 $18,000

The EE program works closely with area schools and regional and statewide partners to teach and 

engage students of all ages on Refuge resources, both on-site and off-site. The Refuge has one FTE 

position dedicated to the EE program as a Visitor Services Manager. Additional Refuge staff 

supports topic-specific programs like carp awareness and cultural resources. Other Refuge staff 

assists in maintenance of EE facilities; the EE program uses many of the same facilities and 

resources as the wildlife observation, photography, and interpretation program, including trail and 

parking area maintenance, facility and road maintenance, sign posting, and construction projects 

(USFWS 2011). 

Some EE projects may currently lack funding, but the Refuge will develop partnerships and seek 

additional funding resources over the next 15 years as necessary to complete projects. Based on the 

availability of resources, the Refuge will have sufficient funds for managing current and expected 

levels of the EE program. Exact costs will be developed during design and implementation. 

Anticipated Impacts of the Use 

General Impacts Expected from the Scientific Literature

A general assessment of impacts resulting from EE uses has been compiled from the literature and is 

briefly summarized below. 

Disturbance Impacts: In general, impacts that could occur from EE programs will be similar to those 

expected from wildlife observation, photography, or interpretation activities, especially those 

expected from larger groups using the site (USFWS 2011). Such impacts would be expected to 

include temporary damage to vegetation resulting from trampling, disturbance to nesting birds, and 

disturbance to feeding or resting birds or other wildlife in the proximity. EE programs generally 

accommodate groups of participants, and studies have shown that increasing group size has an 

impact on wildlife (Beale and Monaghan 2004; Remacha et al. 2011). In addition to group size, 

loudness has also been found to be an important variable to disturbance of wildlife, and loudness of 

people present can be more important than the number of people present (Burger and Gochfeld 1991. 

Studies showed that reducing group size, allowing safe distances, and reducing noise levels help 

minimize negative impacts on wildlife (Burger and Gochfeld 1991; Beale and Monaghan 2004; 

Remacha et al. 2011). 

An unpublished study examined the effect of EE site activities at Blackhorse Lake on the Turnbull 

National Wildlife Refuge (Jose 1997). The study was designed to compare waterfowl presence and 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-23 

behavior patterns between the times EE activities were occurring and the times when EE classes were 

not on-site. The study results indicated that fewer waterfowl were present in the study area when EE 

classes were on-site as compared to the control times. The study also found more shore flights 

undertaken by birds when EE classes were on-site. Redheads displayed the highest number of flight 

responses, followed by mallards. Ruddy ducks almost never flew but had the highest increase in 

directional swimming away from the EE classes. The study recommended that sites heavily used by 

smaller-bodied birds, such as ruddy ducks, buffleheads, and teals, not be used as EE sites. 

Conservation Benefits: EE provides indirect beneficial impacts for visitors engaged in EE programs 

and activities. One study found that animal-oriented activities have an impact on the knowledge and 

attitudes of students involved in EE. Direct instruction methods in which children examined the 

anatomical and behavioral characteristics of live spiders and snakes promoted a positive attitude 

toward these animals (Kress 1975; Kellert and Westervelt 1983). Eighth graders engaged in wildlifeoriented activities were found to be more likely to recognize the importance of lower forms of animal 

life and preserving endangered species, and to have greater tolerance for predators (LaHart 1978). 

Another study concluded, “If one were to try to change attitudes, education without an experiential 

component might not be very effective” (Baird and Tolamn 1982, p. 12). 

Refuge-Specific Impacts 

This section evaluates the likely impact at the Refuge itself, considering the scientific studies 

discussed above and considering the uses within the context of Malheur Refuge. 

Loss of Habitat from Facility Construction: Under the CCP, new facilities constructed for EE will 

result in 0.25 acre of habitat loss, which is a fraction of a percentage of the Refuge; thus, habitat loss 

from new facilities is considered negligible. 

Vegetation, Soil, and Water Impacts: Collection of resource samples for study (i.e., mud, water, 

plants) will be primarily focused at the Refuge Headquarters, and samples will be used on-site. 

Collection will be of materials needed to enhance hands-on learning and investigation and will be 

designed as part of structured activities and lessons guided by teachers and Refuge staff and 

volunteers. These activities will be an integral part of the EE philosophy, and their impacts will be 

minimal. Some additional trampling will also occur from larger group sizes, but impacts will be 

concentrated at public sites. To minimize trampling along the east side of the Display Pond, a 

hardened site may be developed. Impacts to water resources are expected to be negligible. 

Disturbance Impacts: Under the management direction of the CCP, the construction of an outdoor 

learning area and shelter at the Refuge Headquarters will have short-term disturbance impacts. 

Maintenance of facilities and equipment related to EE could also result in very local disturbance 

depending on time and place of need. 

Disturbance to wildlife could occur from EE programs, as with any group, if birds near EE activities 

will be disturbed by human presence. The EE program will continue to be small, and will generally 

support groups of 10 to 30 participants at any one time, although occasionally multiple groups visit 

the Refuge at the same time. A special use permit (SUP) will be required for EE programs on the 

Refuge to ensure groups understand Refuge regulations, the purpose and mission of the Refuge and 

Refuge System, and to help the Refuge gather use information. For special permission into closed 

habitat/wildlife areas, an SUP will be required, and will be approved on a case-by-case basis. All 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-24 Appendix B. Compatibility Determinations 

participants involved in EE will be instructed in ethical wildlife observation etiquette to view wildlife 

with minimal disturbance. 

Table B-4 details the SUP requirements under the CCP for environmental education. 

Table B-4. Special Use Requirements for Environmental Education 

Access to Open Areas Access to Closed Areas Access to Hunting Areas Access to Fishing Areas 

 Special use permit 

 No fee 

 Special use permit 

 No fee 

 No entry during 

hunting season 

 Special use permit 

 No fee 

 Special use permit 

 No fee 

 Special use permit 

 No fee 

 No entry during 

hunting season 

 Special use permit 

 No fee 

Participation in EE programs is growing throughout Oregon, with the Service’s Connecting People 

with Nature initiative, and nationally with the America’s Great Outdoors initiative. With this 

growing emphasis, future program participation and associated effects will be expected to be higher 

than present. The EE program could have increased impacts on Refuge habitats and wildlife, but a 

majority of EE activities will be conducted at the Headquarters or along roads and trails open to the 

public. 

It is not expected that EE will cause any additional short-term, long-term and/or cumulative and 

indirect/secondary impacts other than those detailed above. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). It is unclear at this time if the Refuge 

population is part of the Great Basin distinct population, which is the Federal candidate species or if 

they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

EE uses and facilities will be negligible. These uses will continue to occur at public sites and on 

designated roads and trails, away from sensitive habitat and resources and outside of breeding areas 

and seasons. The greater sage-grouse is not known to breed on the Refuge. Incidental use of the east 

side of the south Blitzen Valley by sage-grouse has been reported during the late summer when 

visitor numbers and activities are lower. EE uses do not generally occur at Mud Creek and Bridge 

Creek outside of the fishing season and thus will not impact the spotted frog populations. Groups 

participating in EE on the Refuge will be required to apply for an SUP, and stipulations for reducing 

impacts to candidate species will be further covered by the permit. EE will also assist in raising 

awareness and preventing undue impacts to these species. If the use results in unacceptable adverse 

effects to candidate species or habitats, the Refuge will impose restrictions to mitigate disturbance. 

Impacts to Other Priority Public Uses: EE generally results in little disturbance to other visitors. 

Some additional crowding at the Refuge Headquarters or along public roads and trails may occur 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-25 

with EE groups, but the EE programs will consist of structured activities and will be carefully 

scheduled to ensure groups are spread out and not impacting other programs or events. 

Infrastructure: No significant effects to roads, trails, or other infrastructure from EE programs are 

foreseen. Normal road, trail, and facility maintenance will continue to be necessary. Additional 

facility construction or upgrade is addressed in the Availability of Resources section. 

Public Review and Comment 

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

Special Use Permit 

 An SUP will be required for groups engaging in EE on the Refuge. No fee will be charged 

for EE groups. 

 A standard permit form stipulating dates, times, and locations of use will be made available 

prior to the visit on the Refuge’s website or by mail. 

 SUPs for areas open to the public grant permissions to open areas for up to 1 year under the 

same use stipulations before renewal. 

 Special permission requests to closed habitat/wildlife areas or other special considerations 

(e.g., access to Refuge after normal public visitation hours, setting up temporary equipment, 

requiring additional resources or staff) will be granted on a case-by-case basis with no 

renewal. 

 The SUP is required to be readily available while conducting the permitted use on the 

Refuge. 

 Requests must demonstrate intent to enhance education, appreciation, and/or understanding 

of the Refuge and the National Wildlife Refuge System. Failure to abide by any part of the 

SUP or regulations will be considered grounds for immediate revocation of the permit and 

could result in denial of future permit requests. 

General Stipulations 

 On-site EE programs will be conducted at Refuge Headquarters or along roads and trails 

open to the public. 

 Class size will be limited to 30 participants at a time. 

 Refuge staff will instruct all groups in behavior etiquette and ways to reduce wildlife and 

habitat disturbance during a “welcome” session. 

 Collection of resource samples for study (i.e., mud, water, plants) will be restricted to the 

Refuge Headquarters, and samples will be used on-site. Collection will be of materials 

needed to enhance hands-on learning and investigation and will be designed as part of 

structured activities and lessons. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-26 Appendix B. Compatibility Determinations 

 Periodic monitoring and evaluation of Refuge Headquarters and EE programs will be 

conducted to assess if objectives are being met and the resource is not being unacceptably 

degraded. 

Justification 

EE receives enhanced consideration in the CCP process, and is considered a priority public use when 

determined compatible. By limiting the size of groups, providing structured activities, and providing 

closed areas for wildlife away from human disturbance, this program will limit disturbances to 

wildlife. There is sufficient undisturbed habitat available to Refuge wildlife for escape and cover, and 

wildlife populations will find sufficient food resources and resting places. The relatively limited 

number of individual plants and animals expected to be adversely affected will not cause wildlife 

populations to materially decline, the physiological condition and production of Refuge species will 

not be impaired, their behavior and normal activity patterns will not be altered dramatically, and their 

overall welfare will not be negatively impacted. The use of SUPs allows the Refuge Manager to 

continually adjust the activity to any significant new or changing conditions on the Refuge as needed, 

and to facilitate outreach and coordination of activities with EE groups. Thus, allowing EE to occur 

under the stipulations described above will not materially detract or interfere with the purposes for 

which the Refuge was established or the Refuge System mission. 

EE contributes to the mission of the Refuge System by providing wildlife-oriented educational 

benefits to visitors. EE programs on Refuge lands are inherently valuable to the USFWS because 

they will enhance the public’s knowledge of the Refuge and its resources, and expand the number of 

visitors who engage in the Refuge’s conservation mission. EE on-site and off-site is an important part 

of the Refuge’s vision and goals. 

Mandatory Reevaluation Date 

 09/2027 Mandatory 15-year Reevaluation Date (for priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Baird, D.D. and R.R. Tolamn. 1982. Attitudes of high school students and biology teachers towards 

animals. Unpublished manuscript. Field Museum of Natural History, Division of Mammals. 

Chicago, IL. 

Beale, C.M. and P. Monaghan. 2004. Human disturbance: people as predation-free predators? 

Journal of Applied Ecology 41:335-343. 

Burger, J. and M. Gochfeld. 1991. Human activity influence and diurnal and nocturnal foraging of 

sanderlings (Calidris alba). Condor 93:259-265. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-27 

Jose, J. 1997. Evaluation of the effect of environmental education classes on waterfowl behavior. 

Unpublished report. Biology 454 class, Eastern Washington University. Cheney, 

Washington. 

Kellert, S.R. and M.O. Westervelt. 1983. Children’s attitudes, knowledge, and behaviors towards 

animals. Washington, D.C.: U.S. Fish and Wildlife Service (U.S. Government Printing 

Office: 1983 0-405-522/1101). 

Kress, S.W. 1975. A study of the modification of children’s negative attitudes towards animals. 

Ph.D. dissertation. Cornell University, Ithaca. 

LaHart, D.E. 1974. The influence of knowledge on young people’s perceptions about wildlife. Final 

project report to the National Wildlife Federation, College of Education. Florida State 

University. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_ 

Candiadate_species_Backgrounder.pdf [sic]. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Remacha, C., J. Pérez-Tris, and J.A. Delgado. 2011. Reducing visitors’ group size increases the 

number of birds during educational activities: Implications for management of nature-based 

recreation. Journal of Environmental Management 92(6):1564-1568. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

USFWS. 2011. Compatibility determination for wildlife observation, photography, and 

interpretation. Malheur National Wildlife Refuge. Princeton, OR. 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-28 Appendix B. Compatibility Determinations 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-29 

B.3 Waterfowl Hunting Compatibility Determination 

RMIS Database Use: Hunting (waterfowl) 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

Program Offerings: This CD examines waterfowl hunting on designated units of the Refuge as 

described in the management direction of the CCP. Under the CCP, the Refuge would offer 

waterfowl hunting in two units: the Malheur Lake Unit and the Buena Vista Unit. The total 

waterfowl hunt area under the CCP will measure approximately 63,100 acres or 33 percent of the 

Refuge. Staggered hunt openings will provide the equivalent of two “opening weekends” at the 

Refuge. 

A youth waterfowl hunt will be promoted, and the Refuge will support reasonable waterfowl hunting 

opportunities in the Buena Vista Unit for disabled hunters. Species available for take include ducks, 

geese, and coots. To increase hunter success during the hunting season, the use of well-trained 

hunting dogs will be encouraged by the Refuge for prey retrieval. 

Location of Use, Associated Facilities, and Access: 

Malheur Lake Unit: Malheur Lake Unit is currently located on the north side of Malheur Lake, east 

of Highway 205 and west of Cole Island Dike (approximately 26,000 acres or 14 percent of the 

Refuge). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-30 Appendix B. Compatibility Determinations 

Under the management direction of the CCP, the allowable hunt area on the lake will be expanded to 

include an area on the south side of Malheur Lake east of the Sodhouse Farms (a private inholding) 

eastern dike and west of Cole Island Dike (approximately 4,600 acres), creating two hunt units on the 

lake: the North Malheur Lake Unit and the South Malheur Lake Unit. The opening on the North 

Malheur Lake Unit will remain the same as the state waterfowl season, which is generally from the 

end of September to mid-October. Access will be improved to the North Malheur Lake Hunt Unit by 

refurbishing the Saddle Butte lake access with an all-weather road. Existing walk-in access from 

Highway 205 and the Lawen access will remain. The north hunt boundary will be redefined to reflect 

the actual huntable acreage west of Cole Island Dike, and to protect significant resources on Malheur 

Lake. 

The South Malheur Lake Unit will have special date regulations from the fourth Saturday of October 

to the end of the regular state waterfowl season and will include a fourth access point at the airboat 

launch site near Refuge Headquarters with expanded parking and a refurbished boat launch. A nohunt buffer zone around the airboat launch site and proposed observation tower will be enforced. 

This will bring the North and South Malheur Lake Units to a total of 27,100 acres under the CCP. 

See Map 3b. 

Buena Vista Unit: The Buena Vista Hunt Unit, currently open only for upland game hunting, will 

also be opened to waterfowl hunting under the CCP, adding 36,000 acres of waterfowl hunt area to 

the waterfowl hunt program. A special date regulation will apply from the fourth Saturday of October 

to the end of the regular state pheasant season. Boats will not be permitted in this hunt unit; however, 

the hunt unit will provide a walk-in hunting experience where hunters could set up temporary decoys 

or jump-shoot if opportunities present themselves. 

Like other Refuge users, hunters rely on roads, parking lots, pull-offs, trails, and dikes while using 

the Refuge. 

Number of Visits and Seasonal Patterns: In 2010-2011, an estimated 85 visits were made to the 

Refuge to engage in waterfowl hunting activities. Waterfowl hunting is the smallest use of all the 

priority public uses on the Refuge. With improvements made to habitat management, access, and 

enhanced hunting opportunities, the number of waterfowl hunting visits is expected to grow over 15 

years to 180 visits per year. 

Availability of Resources 

Availability of resources for administering and managing the waterfowl hunting program under the 

CCP are detailed in Table B-5. 

Table B-5. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Improve Saddle Butte access road $130,000 

Open new ADA-accessible boat launch and parking area on 

Malheur Lake at the end of Boat Landing Road $150,000 

Develop new publications and signage for hunt program $2,000 $1,000
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-31 

Table B-5. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Staff administration and management (programmatic, law 

enforcement, regulations, and information) $5,000

Facility maintenance $2,000

Total $282,000 $8,000 

Administering the waterfowl hunt program does not require significant staff time, equipment, or 

funding. Still, to maintain a quality hunting experience, access trails, parking lots, signs, and other 

facilities are maintained annually. The Refuge has one FTE Visitor Services Manager and one FTE 

position for law enforcement that patrols the Refuge during hunting season to ensure compliance 

with Federal, state, and Refuge conditions. The majority of the staff time spent administering this 

program will fall mostly on the law enforcement position. Other Refuge staff assists in maintenance 

of hunting facilities like access roads and parking lots; in general, the waterfowl hunt program uses 

many of the same facilities and resources as the wildlife observation, photography, and interpretation 

program, including trail and parking area maintenance, facility and road maintenance, sign posting, 

and construction projects (USFWS 2011). Additional costs and staff time will include updating and 

printing hunting brochures and developing new publications for the hunt program. 

Some hunt program enhancements may currently lack funding, but the Refuge will develop 

partnerships and seek additional funding resources over the next 15 years as necessary to complete 

projects. Based on the availability of resources, the Refuge will have sufficient funds for managing 

current and expected levels of waterfowl hunting. Exact costs will be developed during design and 

implementation. 

Anticipated Impacts of the Use 

General Impacts Expected from the Scientific Literature

A general assessment of impacts resulting from waterfowl hunting uses has been compiled from the 

literature and is briefly summarized below. 

Direct Impacts to Hunted Wildlife: Sport hunting involves the direct take of wildlife designated as 

huntable game species by regulation. In addition to loss of target individuals, additional birds are 

sometimes crippled or killed and not retrieved. 

Hunting causes disturbance to feeding and resting waterfowl as well as non-target species due to 

noise (shotgun), movement, vehicular traffic, and use of dogs for hunting activities. It can also alter 

behavior, population, structure, and distribution patterns of wildlife (Owens 1977; Raveling 1979; 

White-Robinson 1982; Thomas 1983; Bartlet 1987; Madsen 1985; Cole and Knight 1990; Dooley et 

al. 2010). Disturbance levels from hunting activity outside Chincoteague NWR were found to be 

high enough to force wintering black ducks into a pattern of nocturnal feeding within surrounding 

salt marsh and diurnal resting within Refuge impoundments (Morton et al. 1989a, 1989b). Unhunted 

populations have been documented to behave differently from hunted ones (Wood 1993). Although 

disturbance from hunting is noted to have effects directly on wildlife, the U.S. Department of the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-32 Appendix B. Compatibility Determinations 

Interior (U.S. DOI) concluded that hunting disturbance has less of an impact compared to the direct 

mortality caused by hunting (2009). 

There appears to be an inverse relationship between the number of birds using an area and hunting 

intensity (DeLong 2002). In California, the number of northern pintails on Sacramento NWR nonhunt areas increased after the first week of hunting and remained high until the hunt season was over 

in early January (Heitmeyer and Raveling 1988). Following the close of hunting season, ducks 

generally increased their use of the hunt area; however, use was lower than before the beginning of 

the hunting season. Prolonged and extensive disturbances may cause large numbers of waterfowl to 

leave disturbed areas and migrate elsewhere (Madsen 1995; Paulus 1984). 

Sanctuaries or non-hunt areas have been identified as the most common solution to disturbance 

problems caused by hunting (Havera et al. 1992). In Denmark, hunting disturbance effects were 

experimentally tested by establishing two sanctuaries, and over a 5-year period, these sanctuaries 

became two of the most important staging areas for coastal waterfowl; numbers of dabbling ducks 

and geese increased 4- to 20-fold within the sanctuary (Madsen 1995). 

Disturbance from Dogs: Dogs elicit a greater response from wildlife than people on foot alone 

(MacArthur et al. 1982; Hoopes 1993). The presence of dogs may disrupt foraging activity in 

shorebirds (Hoopes 1993) and disturb roosting activity in ducks (Keller 1991). Many of these authors 

indicated that dogs with people, dogs on leash, or loose dogs provoked the most pronounced 

disturbance reactions from their study animals. In effect, off-leash dogs increase the radius of human 

recreational influence or disturbance beyond what it would be in the absence of a dog. Indirectly, 

domestic dogs can also potentially introduce various diseases and transport parasites into wildlife 

habitats (Sime 1999). 

Refuge-specific Impacts 

This section evaluates the likely impact on Refuge resources specifically, considering the scientific 

studies discussed above and considering the use within the context of Malheur Refuge. It also 

considers the cumulative effect of Refuge hunts on regional and flyway populations of target species. 

NEPA considerations by the Service for hunted migratory game bird species have been addressed 

nationally. In August 2009, a Draft Supplemental Environmental Impact Statement: Issuance of 

Annual Regulations Permitting the Hunting of Migratory Birds (hereafter abbreviated as SEIS 2009) 

was released (U.S. DOI 2009). Annual NEPA considerations for waterfowl hunting frameworks are 

covered under a separate Environmental Assessment and Finding of No Significant Impact. 

Harvest Management—Regulatory Procedures: The hunting of waterfowl in the United States is 

based upon a thorough regulatory setting process that involves numerous sources of waterfowl 

population and harvest monitoring data. Waterfowl populations throughout the United States are 

managed through an administrative process known as flyways, of which there are four (Pacific, 

Central, Mississippi, and Atlantic). Oregon is included in the Pacific Flyway. A review of the 

policies, processes, and procedures for waterfowl hunting is covered in a number of documents.

Because the Migratory Bird Treaty Act stipulates that all hunting seasons for migratory game birds 

be closed unless specifically opened by the Secretary of the Interior, the Service annually 

promulgates regulations (50 Code of Federal Regulations [CFR] 20) establishing the Migratory Bird 

Hunting Frameworks. The frameworks are essentially permissive, in that hunting of migratory birds 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-33 

would not be permitted without them. Thus, in effect, annual Federal regulations both allow and limit 

the hunting of migratory birds. 

The Migratory Bird Hunting Frameworks provide season dates, bag limits, and other options for 

states to select from, which should result in the level of harvest determined to be appropriate based 

upon Service-prepared annual biological assessments detailing the status of migratory game bird 

populations. In North America, the process for establishing waterfowl hunting regulations is 

conducted annually. In the United States, the process involves a number of scheduled meetings 

(Flyway Study Committees, Flyway Councils, Service Regulations Committee, etc.) in which 

information regarding the status of waterfowl populations and their habitats is presented to 

individuals within the agencies responsible for setting hunting regulations. In addition, public 

hearings are held and the proposed regulations are published in the Federal Register to allow public 

comment. 

For waterfowl, annual assessments used in establishing the Frameworks include the Breeding 

Population and Habitat Survey, which is conducted throughout portions of the United States and 

Canada. This survey is used to establish an annual Waterfowl Population Status Report. In addition, 

the number of waterfowl hunters and resulting harvest are closely monitored through both the 

Harvest Information Program (HIP) and the Parts Survey (Wing Bee). Since 1995, such information 

has been used to support the adaptive harvest management (AHM) process for setting duck-hunting 

regulations. Under AHM, a number of decision-making protocols determine the choice (package) of 

pre-determined regulations (appropriate levels of harvest) that comprise the framework offered to 

states that year. Each state’s wildlife commission then selects season dates, bag limits, shooting 

hours, and other options from the Pacific Flyway package. Their selections can be more restrictive, 

but cannot be more liberal than AHM allows. Thus, the level of hunting opportunity afforded each 

state increases or decreases each year in accordance with the annual status of waterfowl populations. 

Season dates and bag limits for National Wildlife Refuges open to hunting are never longer or larger 

than the state regulations. In fact, based upon the findings of an environmental assessment developed 

when a Refuge opens a new hunting activity, season dates and bag limits may be more restrictive 

than the state allows. Each National Wildlife Refuge considers the cumulative impacts to hunted 

migratory species through the Migratory Bird Frameworks published annually in the Service’s 

regulations on Migratory Bird Hunting. 

Population and Harvest Data: The following analysis of hunting effects on the Refuge uses data on 

harvest and population, comparing the number of birds taken at various scales with the estimated 

population size. Since hunting occurs in the fall and winter, the mid-winter population index is used 

to compare take to population. The index is provided by the 2010 Pacific Flyway Data Book, which 

tracks waterfowl harvests and status, and hunter participation and success in the Pacific Flyway and 

United States (Collins and Trost 2010). The Pacific Flyway is one of the major north-south routes of 

travel for migratory birds in the Americas along the West Coast, and the Refuge is part of the flyway 

route. The data is provided at a variety of scales: Pacific Flyway, State of Oregon, and Survey Unit 

69-3 S, which includes Klamath, Lake, and Harney counties, providing a good view of regional 

populations (Collins and Trost 2010). Although the Refuge receives the majority of its birds during 

the spring and fall migration months, the mid-winter index provides an example of bird populations 

that may be present regionally during the Refuge hunting season. 

Wintering Populations: Recent mid-winter waterfowl survey counts for ducks and geese in the 

Pacific Flyway, the State of Oregon, and regional Survey Unit 69-3 S are presented in Table B-6. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-34 Appendix B. Compatibility Determinations 

These numbers only represent an index, not an absolute population number. Oregon hosts only a 

small percentage of wintering waterfowl; within the Pacific Flyway, the majority of waterfowl winter 

in California. At Malheur, the main wintering species include: Canada geese, mallards, common 

goldeneye, bufflehead, and common and hooded merganser; coots are smaller in number. Most 

waterfowl species migrate away from the Refuge by mid-November with peaks during October. The 

Refuge has a low number of wintering birds, usually less than 3,000 birds reported during counts. 

The mid-winter population index from the Pacific Flyway Council is not reported for Malheur 

Refuge. 

Fall Populations: Counts were conducted on the Refuge during the 1970s to 1990s to gather 

information on fall use days of ducks and geese. Between 1975 and 1981, the counts captured ducks 

and geese on Malheur Lake only; counts were Refuge-wide between 1982 and 1990, which assumed 

90 percent of fall use still on Malheur Lake. From 1991 to 1997, counts did not specify location of 

populations, so it is hard to determine if they represent Malheur Lake, Harney Lake, or Refuge-wide 

counts, and thus do not provide a reliable source. The fall population counts from the 1970s to 1990s 

represent population numbers from mid-September through mid-December on the Refuge. Although 

dated, the counts provide the best available data for fall bird populations over time on the Refuge. 

(Paullin et al. 1977; Horton et al. 1983; Littlefield 1983) 

Area harvest information is not available at the regional or Refuge level, as it is not consistently 

tracked by the Pacific Flyway Council, ODFW, or the Refuge. The Pacific Flyway provides harvest 

data at the flyway, state, and regional levels. The Refuge harvest numbers are estimated by Refuge 

staff, but are only an estimate. 

Estimated Harvest Mortality: Hunting results in mortality to waterfowl, and these numbers are 

tracked at different scales. See Table B-6 for harvest estimates at different scales in 2009. The 

estimated future harvest of ducks and geese on the Refuge due to hunting under current management 

and future CCP management is also captured. 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-35 

Table B-6. Harvest and Population at Flyway, State, and Survey Unit Scales: Ducks, Geese1, and 

Coots

Area 

Area 

Harvest 

2009 

Breeding 

Population 

2010 

Mid-winter 

Population 

Index 

2010 

Average 

Fall Count 

1982-19902

Estimated Harvest3 

Ducks Current 

Management 

Future 

Management 

Pacific Flyway 3,225,718 980,298 4,620,523 No change 

State of 

Oregon 422,001 219,876 349,654 No change 

Survey Unit 

69-3 S4

Not 

available 14,173 No change 

Malheur NWR Est. <100 25,593 <100 <250

Geese Current 

Management 

Future 

Management 

Pacific Flyway 425,739 1,522,908 No change 

State of 

Oregon (total 

season) 

60,901 125,447 No change 

Survey Unit 

69-3 S3

Not 

available 13,024 No change 

Malheur NWR Est. <150 6,253 <150 <200 

Coots Current 

Management 

Future 

Management 

Pacific Flyway 35,564 606,642 No change 

State of 

Oregon (total 

season) 

2,124 13,585 No change 

Survey Unit 

69-3 S3

Not 

available 100 No change 

Malheur NWR Est. <50 Not 

available <50 <100

1 Source: Collins and Trost 2010. 

2 From Refuge-wide population counts, averaged from available data from Harney Basin Study Reports. 3 Klus 2001; Megan and Bodeen 2011. 

4 Survey Unit 69-3 S is a unit that the Pacific Flyway Council uses for mid-winter surveys that includes Klamath, Lake, and 

Harney counties, which includes Malheur Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-36 Appendix B. Compatibility Determinations 

Although in Table B-6, harvest in 2009 appears to represent more than the actual mid-winter survey 

for ducks at the state level, it is important to remember that to make any kind of comparison between 

the seasonal harvest and some population level, an estimate of the number of birds available for 

harvest in Oregon would be needed. The mid-winter count represents simply a snapshot at one point 

during mid-winter, and thus can underestimate total wintering populations. The duck harvest in 

Oregon accounted for approximately 13 percent of the Pacific Flyway duck harvest in 2009. 

Similarly, the goose harvest in Oregon accounted for approximately 14 percent of the Pacific Flyway 

goose harvest in 2009. 

Direct Mortality Stemming from Refuge Hunts: Refuge-specific harvest data is not available at this 

time, but per communication with Refuge staff and ODFW, hunter numbers and harvest numbers are 

generally very low and do not exceed more than 250 waterfowl harvested annually. With expanded 

access to the South Malheur Lake Unit and the opening of the Buena Vista Hunt Unit for waterfowl 

hunting under the CCP, the number of harvests will be expected to increase to 550 waterfowl 

annually. These estimated harvests represent a tiny fraction of a percent of the total mid-winter 

population of wintering waterfowl in the Survey Unit and State of Oregon, and an even smaller 

fraction of the Pacific Flyway population. Under the CCP harvest estimation, the waterfowl 

harvested will be less than 2 percent of the mid-winter survey population in the Survey Unit 69-3 S 

(Klamath, Lake, and Harney counties). From available data provided in the Harney Basin Study 

Reports, the duck and goose harvested will be between 1 percent and 4 percent of fall counts at 

average 1982-1990 levels. Coot populations have been increasing over the last 50 years, from 

600,000 birds in 1955 to 1.6 million birds in 2005. American coot harvest in Oregon during 2005 

was 1,500 birds taken by 200 hunters. As the flyway coot population continues to remain high, these 

birds are underutilized and, with liberal bag limits, can provide increased hunting opportunity. The 

overall impacts from the harvest estimates will be minor to negligible. 

Historical data demonstrates that Malheur Lake was once an extremely productive area for 

waterfowl, with annual waterfowl production estimates from 1942 to 1980 averaging over 51,000 

birds, of which ducks constituted over 95 percent, or over 48,000 ducks produced annually. In 1948 

alone, 146,950 ducks were produced (Cornely 1982), suggesting that these high levels of production 

resulted in high-quality waterfowl hunting. After 1980, population data is not readily available; 

however, Refuge staff believe production has been decreasing over the years due to lake level 

fluctuations and invasive carp. As management activities work to control carp in Malheur Lake over 

the next 15 years, it is expected that the number of nesting birds in this area will increase and 

consequently the number of hunters and harvests will also increase. There are many unknowns in 

carp control, and an accurate estimate of waterfowl to be harvested under this scenario cannot be 

predicted at this time. 

The Buena Vista Hunt Unit will considerably increase the acreage open to waterfowl hunting to 

63,000 acres; however, the expected number of waterfowl hunters after opening weekend will be 

small, thus mitigating against hunter competition and disturbance issues. Additionally, spreading out 

opening weekend for waterfowl hunting between the hunt units over two weekends will help reduce 

conflicts between hunters and allows additional protection for staging sandhill cranes. 

Given the small amount of the estimated take and the distribution of the hunt units, the hunt program 

as designed is not expected to adversely affect the Refuge’s ability to sustain optimum population 

levels for maintaining populations of migratory waterfowl. As the health of Malheur Lake improves 

and the hunt program grows over the 15-year time frame of the CCP, the hunt program will be 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-37 

revisited with ODFW guidance to determine what the appropriate level of harvest would be with 

growing population projections. 

Disturbance to Target Wildlife: Hunting could result in redistribution of waterfowl and waterbirds at 

the Refuge. Disturbance effects associated with hunting were examined in the SEIS 2009 for 

waterfowl and some other migratory bird species. On the basis of a review by Dahlgren and 

Korschgen (1992), the SEIS 2009 noted that disturbance has its most pronounced detrimental effect 

during the nesting period. Hence the SEIS 2009 noted that hunting-related disturbance does not have 

any pronounced population level effects (U.S. DOI 2009). 

Impacts to Non-Target Wildlife: Non-hunted wildlife would include any non-target waterfowl and 

other birds; small- and medium-sized mammals; reptiles; amphibians; and invertebrates. 

Occasionally, non-target species are illegally killed by hunters by accident or intentionally, or are 

disturbed by hunter presence or noise. The free-roam hunting opportunity and use of temporary 

blinds at the Buena Vista Unit could increase habitat disturbance in areas not currently accessed. 

The cumulative effects of disturbance to non-hunted birds under the CCP management direction are 

expected to be moderate to minor for the following reasons. Hunter education courses are required 

for youths. Hunting seasons do not coincide with nesting seasons; thus, reproduction will not be 

reduced by hunting. Disturbance to the foraging or resting activities of migrating or resident birds 

might occur, and will increase with the new access for boats at the South Malheur Lake Unit and the 

opening of the Buena Vista Hunt Unit to waterfowl hunters. However, even with these changes, 

hunting is still expected to involve a small numbers of participants. On North Malheur Lake Unit, 

due to the long walk-in distances and difficulties and inconsistencies of getting boats out on the lake, 

many hunters hunt the shoreline rather than using boats on Malheur Lake, thus limiting the area 

disturbed on that side. The Buena Vista Unit will remain a walk-in hunt, but prohibiting overnight 

camping will decrease the likelihood of hunters roaming long distances in the Buena Vista Unit and 

other hunt units. 

Waterfowl can be an important food resource for bald eagles in winter. On the Refuge, bald eagle 

presence is low during the winter, and the majority of the population is found during the spring. 

During waterfowl hunting season, there will be adequate food resources available on Malheur Lake 

and the wetlands for any bald eagles on the Refuge at this time. Furthermore, hunting pressure is 

generally low overall, and there will be no expected competition between hunters and bald eagles for 

waterfowl. 

Disturbance to other taxa will be unlikely or negligible for the following reasons. Encounters with 

reptiles and amphibians, invertebrates, and small mammals in the early fall will be few and should 

not have cumulative negative effects on Refuge populations. Refuge regulations further mitigate 

possible disturbance by hunters to non-hunted wildlife. Vehicles will be restricted to public roads and 

the harassment or taking of any wildlife other than the game species legal for the season will not be 

permitted. 

Dogs will increase the level of disturbance to target and non-target species, but this impact is 

expected to be minor, especially to migratory wildlife, and is encouraged to support the use. Dogs 

will be required to be under the close control of their owners while on the Refuge. 

Sandhill cranes stage on the southern portion of Malheur Lake and in the Buena Vista wetlands until 

mid-October. Under the CCP, a late season opener for the southern portion of Malheur Lake and the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-38 Appendix B. Compatibility Determinations 

Buena Vista Unit will allow sufficient protection of the sandhill cranes until they migrate south, thus 

mitigating any hunting-related impacts to sandhill cranes. Other birds using the area may be 

disturbed by noise and human presence; however, since most birds will have already migrated 

through the area by the time hunting begins, disturbance levels will be expected to be minor overall. 

Outreach with hunting brochures and timely information on the website will help educate hunters on 

hunting opportunities, regulations, and ethical hunter behavior. 

Loss of Habitat from Facility Construction: Saddle Butte access road will be upgraded but will 

follow the same route. Construction of the boat launch at Boat Landing Road will result in 0.5 acre of 

habitat loss, which is a fraction of a percentage of the Refuge. Thus, habitat loss from new facilities 

is considered negligible. No additional new facilities will be added to support this use separate from 

general visitor use facilities described in the CD for wildlife observation, photography, and 

interpretation. 

Vegetation, Soil, and Water Impact: Since access to waterfowl hunting areas is walk-in, associated 

foot travel from accessing Malheur Lake and the Buena Vista Unit for hunting could potentially 

result in temporary and minor vegetation trampling. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). It is unclear at this time if the Refuge 

population is part of the Great Basin distinct population, which is the Federal candidate species, or if 

they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

waterfowl hunting uses and facilities will be negligible. The greater sage-grouse is not a hunted 

species on the Refuge. Hunting is not allowed south of the Buena Vista Unit where sage-grouse have 

been observed, and there have been no occurrences of spotted frogs in the area encompassed by the 

Buena Vista or Malheur Lake Hunt areas. Public education will assist in raising awareness and 

preventing undue impacts to these species. If uses result in unacceptable adverse effects to candidate 

species or habitats, the Refuge will impose restrictions to mitigate disturbance. 

Impacts to Other Priority Public Uses: Hunting has the potential to disturb Refuge visitors engaged 

in other priority public uses; however, given the season during which hunting occurs, the likelihood 

of conflicts is low. The Malheur Lake airboat launch site near the Refuge will be opened to other 

uses during hunting season; however, the number of visitors to the Refuge during this season is 

drastically lower than in other seasons and hunting regulations will be established to provide a nohunt buffer zone around the airboat launch site and observation tower. Although Center Patrol Road 

is the most popular attraction during the migration seasons, use is also very light during hunting 

season, and state regulations also prohibit shooting from, on, and across roads. Fishing along the 

Blitzen River from Sodhouse Lane to Boat Landing Road will conclude prior to the hunting season 

opening. Generally, winter use on the Refuge is only a fraction of the use during the spring and fall 

seasons.

Infrastructure: No significant effects to roads, trails, or other infrastructure from the hunting 

program are foreseen. Normal road, trail, and facility maintenance will continue to be necessary. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-39 

Additional facility construction or upgrade, if needed, is addressed in the Availability of Resources 

section. 

Other Effects: There could be some indirect beneficial impacts of Refuge hunting. Refuge hunting 

can contribute to wildlife and habitat conservation and provide educational and sociological benefits. 

The hunting community in general remains the largest support base for funding land acquisitions in 

the Refuge System through the purchase of Duck Stamps. Waterfowl hunting at the Refuge is a “Big 

Six” use and helps meet the Refuge’s goals of wildlife-dependent recreation for all visitors. 

Additionally, providing youth hunting opportunities is an important initiative in the Fish and Wildlife 

Service, and enhancing this opportunity on the Refuge helps address a public desire to see more 

hunting opportunities for youth. 

Public Review and Comment 

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

 Only federally approved nontoxic shot may be used or be in possession while hunting on the 

Refuge. 

 Vehicles will be allowed only on maintained public roadways. Parking will be allowed only 

within one vehicle length of the roadway. Hunters will be instructed to not block dike and 

field accesses. 

 Overnight parking, camping, and campfires will not be permitted on the Refuge. 

 Access will be walk-in only. Electric motorized boating or non-motorized boating will be 

permitted on Malheur Lake during the waterfowl hunt season. 

 Hunting dogs are strongly encouraged to increase hunter success and retrieval rate. Dogs 

must be kept under close control. 

 Seasonal hunting closures may occur to protect waterfowl populations when the Malheur 

Lake water level drops below 10,000 acres. 

 Hunting closures will be in effect near Refuge Headquarters, Buena Vista Station, and the 

Malheur Field Station. Shooting from or across public roads or road right-of-ways is 

prohibited. 

 Law enforcement patrols will ensure safety and minimize conflicts with other priority public 

uses by providing information about hunting boundaries and seasons to the general public 

and those using other Refuge programs. Information will be provided at interpretive kiosks, 

on the Refuge website, and in Refuge offices. 

Justification 

Under the National Wildlife Refuge System Administration Act, as amended, waterfowl hunting is a 

wildlife-dependent recreational activity, which receives enhanced consideration in the CCP planning 

process and is to be encouraged on National Wildlife Refuges if compatible with refuge purposes. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-40 Appendix B. Compatibility Determinations 

Despite the direct and indirect impacts associated with sport hunting of waterfowl, waterfowl 

populations are unlikely to be affected significantly by the hunting program on the Refuge. 

Waterfowl population objectives and allowable harvests are determined on a flyway basis using an 

established annual regulatory process. Limited hunt seasons at the Refuge in significant wildlife 

areas, and no hunt zones, ensure that wintering and migrating waterfowl, as well as non-target 

species, will find adequate food and rest areas on the Refuge even in the midst of the hunting season. 

Thus, allowing waterfowl hunting to occur under the stipulations described above will not materially 

detract or interfere with the purposes for which the Refuge was established or the Refuge System’s 

mission. 

Mandatory Reevaluation Date 

 09/2027 Mandatory 15-year Reevaluation Date (for priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Bartlet, G.A. 1987. Effects of disturbance and hunting on the behavior of Canada goose family 

groups in east central Wisconsin. Journal of Wildlife Management 51:517-522. 

Cole, D.N. and R.L. Knight. 1990. Impacts of recreation on biodiversity in wilderness. Proceedings 

of Wilderness Areas: User Impacts, April 19-20, 1990; Utah State University. Logan, UT. 

Collins, D. P. and R.E. Trost. 2010. 2010 Pacific Flyway data book: Waterfowl harvests and status, 

hunter participation and success in the Pacific Flyway and United States. U.S. Fish and 

Wildlife Service Division of Migratory Bird Management. Available at: 

http://www.pacificflyway.gov/Documents/Pf_databook.pdf. 

Cornely, J.E. 1982. Waterfowl production at Malheur National Wildlife Refuge, 1942-1980. U.S. 

Fish and Wildlife Service. Pages 559-571 in: Kenneth Sabol, ed. Transactions of the FortySeventh North American Wildlife and Natural Resources Conferences. Washington, D.C. 

Dahlgren, R.B. and Carl E. Korschgen. 1992. Human disturbances of waterfowl: an annotated 

bibliography. USFWS Resource Publication 188. Jamestown, ND: Northern Prairie Wildlife 

Research Center Online. Available at: 

http://www.npwrc.usgs.gov/resource/literatr/disturb/index.htm (Version 16 Jul 1997). 

DeLong, A.K. 2002. Managing visitor use and disturbance in waterbirds—a literature review of 

impacts and mitigation measures. Appendix L (114 pp.) in: Stillwater National Wildlife 

Refuge Complex final environmental impact statement for the comprehensive conservation 

plan and boundary revision. Volume II. Department of the Interior, U.S. Fish and Wildlife 

Service, Region 1. Portland, OR. 

Dooley, J.L., T.A. Sanders, and P.F. Doherty, Jr. 2010. Mallard response to experimental walk-in and 

shooting disturbance. Journal of Wildlife Management 74(8):1815-1824. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

Havera, S.P., L.R. Boens, M.M. Georgi, and R.T. Shealy. 1992. Human disturbance of waterfowl on 

Keokuk Pool, Mississippi River. Wildlife Society Bulletin 20:290-298. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-41 

Heitmeyer, M.E. and D.G. Raveling. 1988. Winter resource use by three species of dabbling ducks in 

California. Unpublished final report to Delta Waterfowl and Wetlands Research Station, 

University of California-Davis. 201 pp.

Hoopes, E.M. 1993. Relationship between human recreation and piping plovar foraging ecology and 

chick survival. M.S. thesis. University of Massachusetts, Amherst, MA. 106 pp. 

Horton, S.K., C.D. Littlefield, D.G. Paullin, and R.E. Vorderstrasse. 1983. Migratory bird 

populations and habitat relationships in Malheur-Harney lakes basin, Oregon: final report. 

U.S. Fish and Wildlife Service, Portland Field Office. Portland, OR. 

Keller, V. 1991. Effects of human disturbance on eider ducklings Somateria mollissima in an 

estuarine habitat in Scotland. Biological Conservation 58:213-228. 

Klus, R. 2011. Personal communication between Rod Klus, Oregon Department of Fish and Wildlife, 

and Maren Murphy, Conservation Planning Assistant, Division of Planning and Visitor 

Services, Region 1, USFWS. May, 2011. 

Littlefield, C.D. 1983. Malheur-Harney lakes basin study, Oregon. Report No. 3:1979-1981.U.S. Fish 

and Wildlife Service and Malheur National Wildlife Refuge. Princeton, OR. 

MacArthur, R.A., V. Geist, and R.H. Johnson. 1982. Cardiac and behavioral responses of mountain 

sheep to human disturbance. Journal of Wildlife Management 46:351-358. C.W. Servheen, 

eds. 1980. Proceedings of the Washington bald eagle symposium; Seattle, WA. 

Madsen, J. 1985. Impact of disturbance on field utilization of pink-footed geese in West Jutland, 

Denmark. Biological Conservation 33:53-63. 

Madsen, J. 1995. Impacts of disturbance on migratory waterfowl. Ibis 137:S67-S74. 

Megan, J. and T. Bodeen. 2011. Personal communication between John Megan, Law Enforcement 

Officer, Malheur National Wildlife Refuge, Tim Bodeen, Project Leader, Malheur National 

Wildlife Refuge, and Maren Murphy, Conservation Planning Assistant, Division of Planning 

and Visitor Services, Region 1, USFWS. May, 2011. 

Morton, J.M., A.C. Fowler, and R.L. Kirkpatrick. 1989a. Time and energy budgets of American 

black ducks in winter. Journal of Wildlife Management 53(2):401-410. 

Morton, J.M., R.L. Kirkpatrick, M.R. Vaughan, and D.F. Stauffer. 1989b. Habitat use and 

movements of American black ducks in winter. Journal of Wildlife Management 53:390-400. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_ 

Candiadate_species_Backgrounder.pdf [sic]. 

Owens, N.W. 1977. Responses of wintering brant geese to human disturbance. Wildfowl 28:5-14. 

Paulus, S.L. 1984. Activity budgets of nonbreeding gadwalls in Louisiana. Journal of Wildlife 

Management 48:371-380. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Paullin, D.G., C.D. Littlefield, and R.E. Vorderstrasse. 1977. Malheur-Harney lakes basin study, 

Oregon. Report no. 1: A summary of biological data for calendar years 1975 and 1976. U.S. 

Fish and Wildlife Service. Portland, OR. 

Raveling, D.G. 1979. The annual cycle of body composition of Canada geese with special reference 

to control of reproduction. Auk 96:234-252. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-42 Appendix B. Compatibility Determinations 

Sime, C.A. 1999. Domestic dogs in wildlife habitats. Pages 8.1-8.17 in: G. Joslin and H. Youmans, 

coordinators. Effects of recreation on wildlife, Montana chapter of The Wildlife Society. 307 

pp. 

Thomas, V.G. 1983. Spring migration: the prelude to goose reproduction and a review of its 

implication. Pages 73-81 in: H. Boyd, ed. Fourth Western Hemispheric Waterfowl and 

Waterbird Symposium. Ottawa, Canada: Canadian Wildlife Service. 

U.S. DOI. 2009. Draft supplemental environmental impact statement: issuance of annual regulations 

permitting the hunting of migratory birds. Department of Migratory Bird Management, U.S. 

Fish and Wildlife Service. Portland, OR. 

USFWS. 2011. Compatibility determination for wildlife observation, photography, and 

interpretation. Malheur National Wildlife Refuge. Princeton, OR. 

White-Robinson, R. 1982. Inland and salt marsh feeding of wintering brent geese in Essex. Wildfowl 

33:113-118. 

Wood, A.K. 1993. Parallels between old-growth forest and wildlife population management. Wildlife 

Society Bulletin 21:91-95. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-43 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-44 Appendix B. Compatibility Determinations 

B.4 Upland Game Hunting Compatibility Determination 

RMIS Database Use: Hunting (upland game) 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

Program Offerings: This CD examines sport hunting for upland game on designated units of the 

Refuge as described in the management direction of the CCP (for more detail, see Hunt Plan, 

Appendix P). Under the CCP, the Refuge will offer upland game hunting in three units: the Malheur 

Lake Unit, the Buena Vista Unit, and the Boundary Hunt Unit. 

The total acreage open to upland game hunting under the management direction will be 49,000 acres, 

or 27 percent of the Refuge; however, regulations will vary by unit, as described below.

Location of Use, Associated Facilities, and Access: 

Malheur Lake Unit: Upland game hunting is currently open on the North Malheur Lake Unit, east of 

Highway 205 and west of Cole Island Dike. It currently measures 14,000 acres based on the average 

low water line of the lake. Current federal regulations (50 CFR 32.56) indicate that the Refuge allows 

hunting of pheasant, quail, partridge, chukar, and rabbit in accordance with State regulations, 

concurrent with the State pheasant season. Access is walk-in only from Lawen and Saddle Butte 

roads on the north side of the lake, and there is one access point on Highway 205 at the Narrows. 

Upland game hunting occurs on the edge of the lake and not on the actual lake itself. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-45 

Under the CCP, rabbit will be dropped from the species allowable; all other allowable species will 

remain the same. In addition, the boundary of the Malheur Lake Unit will be redefined to reflect the 

actual huntable acreage and to protect significant resources on the lake, reducing the unit to an 

average of 13,000 acres based on the typical low water line. Additionally, access will be improved by 

refurbishing the Saddle Butte lake access with an all-weather road. A youth upland game youth hunt 

will be promoted on the Malheur Lake Unit, on the State-designated weekend, generally in 

September each year. All other aspects of the hunt, including harvest season and other regulations, 

will remain the same. 

Buena Vista Unit: The Buena Vista Hunt Unit, which totals 36,000 acres, is one of the most popular 

hunting areas in Harney County for ring-necked pheasants. Federal regulations (50 CFR 32.56) 

indicate that the Refuge allows hunting of pheasant, quail, partridge, chukar, and rabbit within this 

Unit. The State season opens in mid-October, but the Buena Vista Hunt Unit currently has a later 

season opening to reduce conflicts with fall staging sandhill cranes. 

Under the CCP, rabbit will be dropped from the species allowable; all other allowable species will 

remain the same. In addition, the opening date will change from the current third Saturday of 

November to the fourth Saturday of October to provide more quality opportunities for upland game 

hunting earlier in the season while still ensuring a buffer for migrating sandhill cranes (sandhill 

cranes have usually migrated farther south by the middle of October). All other aspects of the upland 

game hunts will remain the same as they currently are. 

Boundary Hunt Unit: The Boundary Hunt Unit includes the strip of land west of State Highway 205 

and south of Foster Flat Road (2,122 acres), and an area bordering Krumbo Creek upstream of 

Krumbo Reservoir (504 acres). Both pieces of this unit border Bureau of Land Management (BLM) 

land. An uneven and generally unmarked boundary has contributed to difficulties in distinguishing 

the boundary between Refuge lands and BLM lands, so these areas have traditionally been managed 

to align with BLM hunt regulations (which conform to State regulations)1

. Federal regulations (50 

CFR 32.56) indicate that the Refuge allows hunting of “all upland game species” in the Boundary 

Unit section west of Highway 205 during authorized State seasons; however, only deer and 

pronghorn are specifically mentioned in the regulations as allowable for this area, and the area 

identified for pronghorn and deer harvest includes only the western portion of the Boundary Unit 

(i.e., the Krumbo Creek area is excluded). Pheasant, quail, partridge, chukar, coyote, and rabbit are 

mentioned elsewhere in the regulations as upland game species available “in designated areas” but 

these areas are not described in the CFR. The Refuge has managed the hunt to include all of these 

species within the Boundary Unit. 

State regulations define coyote and rabbit as predatory animals; coyotes are also defined as 

unprotected mammals. However, some rabbits are protected by the State and are not allowable for 

hunting. 

Under the CCP, the Boundary Hunt Unit species allowable and areas will remain the same, with the 

following exceptions: 

 Rabbit species allowable for take within this unit will be defined specifically as black-tailed 

jackrabbit (Lepus californicus) and Nuttall’s cottontail (Sylvilagus nuttallii). 

 

1

 State regulations do treat Federal refuges differently from other federal lands in at least one way. State rules (OR 

635-050-0210) specifically bar hunting or trapping of fur-bearing mammals or unprotected mammals (both are 

defined in OR 635-050-0050) on “Federal refuges.” 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-46 Appendix B. Compatibility Determinations 

 The Krumbo Creek area will be included as an area where deer and pronghorn may be 

hunted. 

Number of Visitors and Seasonal Patterns: In 2010-2011, an estimated 850 visits were made to the 

Refuge to engage in upland game hunting activities in all three units, which accounts for over 90 

percent of Refuge hunting visits. With improvements made to habitat management and access, and 

enhanced hunting opportunities, the number of upland game hunting visits is expected to grow over 

15 years to 1,000 visits per year. 

Harvest Management: Harvest and season regulations for upland game will be fully consistent with 

the State’s regulations, via ODFW’s 2010-2015 Upland Game Bird Hunting Season Framework

(ODFW 2010c). Hunting seasons and daily bag/possession limits have been established to maximize 

hunting opportunities over the next 5 years. The Refuge may manage under stricter, but not under 

more liberal, regulations. Note that trapping (an allowable method under State rules to take coyote 

and rabbit) will not be permitted under this CD. 

Availability of Resources 

Availability of resources for administering and managing the upland game hunting program under 

the CCP are detailed in Table B-7. 

Table B-7. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Administration and management (programmatic, law 

enforcement, information) $2,000

Total $0 $2,000

Administering the upland game hunt program does not require significant staff time, equipment, or 

funding. The Refuge has one FTE Visitor Services Manager and one FTE position for law 

enforcement that patrols the Refuge during hunting season to ensure compliance with state and 

Federal regulations and Refuge conditions. The majority of the staff time spent administering this 

program will fall mostly on the law enforcement position. Other Refuge staff assists in maintenance 

of general hunting facilities like access roads and parking lots that are included under the waterfowl 

hunt program (USFWS 2011a); in general, the upland hunt program uses many of the same facilities 

and resources as the wildlife observation, photography, and interpretation program, including trail 

and parking area maintenance, facility and road maintenance, sign posting, and construction projects 

(USFWS 2011b). Additional costs and staff time will include updating and printing hunting 

brochures and developing new publications for the hunt program. 

Some hunt program enhancements may currently lack funding, but the Refuge will develop 

partnerships and seek additional funding resources over the next 15 years as necessary to complete 

projects. Based on the availability of resources, the Refuge will have sufficient funds for managing 

current and expected levels for upland game hunting. Exact costs will be developed during design 

and implementation. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-47 

Anticipated Impacts of the Use 

General Impacts Expected from the Scientific Literature

A general assessment of impacts resulting from upland game hunting uses has been compiled from 

the literature and is briefly summarized below. 

Direct Impacts to Hunted Wildlife: Sport hunting involves the direct take of wildlife that are 

designated as huntable game species by regulation. In addition to loss of individual target species, 

additional birds are sometimes crippled or killed and not retrieved. 

Hunting causes disturbance to feeding and resting waterfowl as well as non-target species due to 

noise (shotgun), movement, vehicular activity, and use of dogs for hunting activities. It can also alter 

behavior, population, structure, and distribution patterns of wildlife (Owens 1977; Raveling 1979; 

White-Robinson 1982; Thomas 1983; Bartlet 1987; Madsen 1985; Cole and Knight 1990; Dooley et 

al. 2010). 

Disturbance from Dogs: Dogs elicit a greater response from wildlife than people on foot alone 

(MacArthur et al. 1982; Hoopes 1993). The presence of dogs may disrupt foraging activity in 

shorebirds (Hoopes 1993) and disturb roosting activity in ducks (Keller 1991). Many of these authors 

indicated that dogs with people, dogs on leash, or loose dogs provoked the most pronounced 

disturbance reactions from their study animals. In effect, off-leash dogs increase the radius of human 

recreational influence or disturbance beyond what it would be in the absence of a dog. Indirectly, 

domestic dogs can also potentially introduce various diseases and transport parasites into wildlife 

habitats (Sime 1999). 

Species-specific Impacts: Upland Birds

This section evaluates the likely impact on Malheur Refuge resources specifically, considering the 

scientific studies discussed above and considering the uses within the context of Malheur Refuge. It 

also considers the effect of Refuge hunts on target species. 

Population and Harvest Data: Population data of upland game birds is provided by ODFW through 

surveys of upland game bird production inventories. These inventories are typically conducted during 

the last half of July or the first half of August on established routes throughout Oregon. ODFW 

biologists record the species observed, the gender of birds observed (if possible), number of chicks 

observed, and number of chicks in complete broods, which produces a production index (number of 

chicks/adult). As they formulate an index and are not a full population sample, these survey 

techniques detect an unknown proportion of the population; consequently, the numbers cannot be 

used to provide an estimate of the total population. However, the data collected can be used to 

generate population trends, and the greater the increase in birds for a given year, the more likely 

ODFW biologists will be to count more birds (ODFW 2010a). 

Harvest data of upland game birds is reported by hunters to ODFW annually, although harvest data at 

the Refuge level is not available. ODFW conducts annual harvest surveys to determine statewide 

hunter effort and take for upland birds. These surveys randomly select hunters for surveying and 

generally occur via telephone during hunting seasons. The hunters report by harvest unit, and Harney 

and Malheur counties are combined into one harvest unit, Area 7 (ODFW 2010b). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-48 Appendix B. Compatibility Determinations 

Estimated Harvest Mortality: The following analysis of upland bird game hunting uses data on 

population indices and harvests at a variety of scales. Species analyzed include ring-necked 

pheasants, California quail, and chukar partridge. Table B-8 captures ODFW’s upland game bird 

production inventories for 2004-2008 and 2009, and the 2009-2010 season upland game harvest data 

from the random telephone survey. The estimated harvest of upland game birds on the Refuge due to 

hunting under current management and future (CCP) management is also captured. 

Upland game bird populations can vary greatly from year to year, and the production indices only 

represent a proportion of known upland game birds. In 2009, the production indices for ring-necked 

pheasant, California quail, and chukar partridge were all near or above the previous 5-year average 

from 2004-2008, particularly pheasants and California quails (ODFW 2010a). This suggests that 

upland game bird populations are relatively stable. 

Based on harvest data collected from ODFW’s annual telephone survey from the 2009-2010 season, 

upland game bird harvest in Harney and Malheur counties included 39 percent of pheasant hunted 

statewide, 42 percent of California quail hunted statewide, and 59 percent of chukar partridges 

hunted statewide. As the surveys are recorded by harvest unit, it is impossible to disaggregate the 

harvest information to determine the number of harvests in Malheur County or Harney County alone, 

or even at the Refuge level (Budeau 2011, personal communication). Based on the availability of 

habitat to support upland game birds in Malheur County, particularly pheasants, it is highly likely 

that a majority of upland game birds harvested in this unit are actually in Malheur County rather than 

Harney County, which the Refuge is located in (Budeau 2011, personal communication). Still, 

pheasants harvested in Harney County are most likely harvested on the Refuge because of the high 

quality of hunt available on the Refuge and the limited suitable habitat off-Refuge (Budeau 2011, 

personal communication). This pattern is likely true for other upland game birds too. Based on this 

information, the number of harvests at the Refuge-scale is expected to be considerably less than 

harvests reported at the harvest unit scale.

Table B-8. Upland Game Bird Population Index and Estimated Harvest 

Area 

Production 

Index 

(chicks/adult) 

2004-20081 

Production 

Index 

(chicks/adult) 

20091 

Number of 

Harvests 

2009-20102,5 

Estimated Refuge Harvest3 

Ring-necked Pheasant Current 

Management 

Future 

Management 

Oregon State 3.6 3.6 33,720 No change 

High Desert6 3.3 3.8 No change 

Harney County 1.54 04 12,989 No change 

Malheur NWR Not available Not available <250 <300

California Quail Current 

Management 

Future 

Management 

Oregon State 2.2 2.1 38,684 No change 

High Desert6 1.9 1.8 No change 

Harney County 2.54 4.24 16,165 No change 

Malheur NWR Not available Not available <150 <200
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-49 

Area 

Production 

Index 

(chicks/adult) 

2004-20081 

Production 

Index 

(chicks/adult) 

20091 

Number of 

Harvests 

2009-20102,5 

Estimated Refuge Harvest3 

Chukar Partridge Current 

Management 

Future 

Management 

Oregon State 2.4 2.7 57,628 No change 

High Desert6 2.0 2.1 No change 

Harney County 1.74 1.74 33,744 No change 

Malheur NWR Not available Not available <75 <107

1

 ODFW 2010a 

2 ODFW 2010b 

3 Klus 2011; Megan and Bodeen 2011 

4 Production index is for Harney County only. 

5 Number of harvests was reported for ODFW’s Harvest Unit 7, which includes both Harney and Malheur counties combined. 6 High Desert refers to the combined ODFW district/field offices for Mid-Columbia, Deschutes, Ochoco, Klamath, Lake, Harney, 

and Malheur. 

7 Chukar partridge hunt will essentially be eliminated on the Refuge due to the transfer of the Boundary Hunt Unit to Bureau of 

Land Management. 

Under the CCP, estimated harvest for upland game birds will not likely increase from current levels 

because the program will not markedly increase. An earlier season opening (extended hunt season 

overall) will provide additional hunting opportunities during the season and may increase hunters’ 

harvest rates, but the harvest is small overall. The estimated Refuge harvest of <510 upland game 

birds will constitute about 1 percent of the entire harvest in Harney and Malheur counties based on 

2009-2010 season. Given the wide range of upland game birds and 49,000 acres available to hunt on 

the North Malheur Lake Unit and Buena Vista Unit, it is expected that the overall upland game bird 

hunting pressure under the CCP will be low; about 100 hunters come out for opening weekend and 

that number continues to drop throughout the season. Additionally, given the small number of the 

estimated take and the distribution of the hunt units, the hunt program as designed is not expected to 

adversely affect the Refuge’s ability to sustain optimum population levels for maintaining 

populations of upland game birds. 

Population-specific Impacts: Coyotes

Refuge-specific data on past coyote harvest are not available. According to a recent ODFW report 

(Hiller 2011), coyote populations have increased substantially in both abundance and distribution 

during the past several decades. Hiller further reports that southeastern Oregon leads harvest by both 

trappers and hunters, with Harney County having 486 coyotes taken by hunters and 276 coyotes 

taken by trappers in 2010 (Table B-9). However, by Oregon Revised Statute (ORS 610.002), coyotes 

are classified as predatory animals (which may be taken without permit, limits, or reporting on 

private lands); therefore, the report likely underestimates coyotes hunted or trapped for control 

purposes on private lands. In eastern Oregon, coyotes are the second-most common animal trapped, 

second only to muskrat (Hiller 2011). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-50 Appendix B. Compatibility Determinations 

Table B-9. Reported 2010 Coyote Harvest on the Refuge, County, Region, and State 

Area Trapping Hunting 

Number 

Reported as 

Taken 

Percent of State 

Reported 

Harvest 

Number 

Reported as 

Taken 

Percent of 

State 

Reported 

Harvest 

Refuge Not allowable 0 Unknown1 Unknown 

Harney County 276 9% 486 21% 

Eastern Oregon 2,498 78% 1,997 83% 

State of Oregon 3,220 100 2,277 100% 

Source: Hiller 2011. 

1

Although the take rate is unknown, the Refuge law enforcement officer estimates that 10-12 hunters per year 

pursue coyote or rabbit within the Boundary Unit. 

Gese (2005) examined a variety of coyote population parameter responses under exploitation and 

compared these with responses under no exploitation, as part of a 7-year study. In the experimental 

area, coyote removal rate was estimated at 44 percent to 61 percent and 51 percent to 75 percent, in 

each of 2 years of removal. The study found that home range sizes remained the same in both the 

experimental and control areas. Litter sizes increased significantly in the removal area 2 years after 

the beginning of the removal. However, litter sizes were confounded by changes in the prey base. 

Litter size was significantly related to rabbit abundance, while rodent abundance was less of a factor. 

Accounting for changes in both prey abundance and coyote density, litter size was significantly 

related to total prey abundance per coyote. 

Given the data above and the study by Gese, it is unlikely that coyote harvest on Malheur Refuge is 

negatively impacting coyote populations. 

Population-specific Impacts: Pronghorn

The Boundary Unit is located at the eastern edge of the State of Oregon Juniper Hunt Unit 71. 

Population data were not reported for 2009 or 2010, but in 2008, ODFW (2010d) reported that aerial 

counts averaged 2.1 pronghorn per mile for this unit. This compares with a statewide average of 2.8 

pronghorn per mile for 2008. 

Hunt data are available for 2009 for both statewide harvest and local unit harvest and are presented in 

Table B-10. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-51 

Table B-10. Reported 2009 Pronghorn Harvest on the Refuge, State Hunting Unit, and State 

Scales 

Number Reported 

as Taken 

Percent of State Reported 

Harvest 

Refuge Unknown1 Unknown 

Juniper Unit 702 5% 

State of Oregon 1,4243 100% 1 Although the Refuge harvest number is unknown, the Refuge law enforcement officer estimates that approximately half of 

the hunters with tags for the late-season muzzleloader hunt concentrate along the Boundary Unit. 2

 Pronghorn data from 2009 (ODFW 2010d). 

3

 Pronghorn data from 2009 (ODFW 2010d). (Also available at: 

http://www.dfw.state.or.us/resources/hunting/big_game/controlled_hunts/docs/hunt_statistics/11/PRONGHORN_HARV_Tre

nd_1950-2010.pdf.) 

Data are not available at the Refuge or unit level to estimate population impact or trends from 

hunting. In addition, since population data are gathered and presented as a linear estimate 

(animals/mile), it is not possible to directly calculate the density of animals per unit area or the total 

number of animals within a unit. However, linear survey data for pronghorn presented back to 1945 

(ODFW 2010d) allow trend analysis (at least at the State level), which permits some conclusion 

about whether populations may be increasing or decreasing. Since 1978, pronghorn at the State level 

have increased at an average rate of approximately 2 percent per year, as illustrated in Figure B-1. 

Source: ODFW 2010d 

Figure B-1. Pronghorn population trends for the State of Oregon, 1978-2009. 

Given overall population trends as well as the percentage of pronghorn taken in the local State 

hunting unit, it is unlikely that Refuge harvest, if projected at current levels for the next 15 years, will 

negatively impact pronghorn populations. 

 

y = 0.0251x + 2.6829

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

1978 1983 1988 1993 1998 2003 2008

Figure B.1 Pronghorn Population Trends ‐ State of Oregon,

1978‐2009

Average pronghorn

per mile (statewide)

Linear (Average

pronghorn per mile

(statewide))
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-52 Appendix B. Compatibility Determinations 

Population-specific Impacts: Deer 

The Boundary Unit is located within the State of Oregon Juniper Unit. Although overall harvest of 

deer within the Boundary Unit area during the several open seasons is unknown, it is estimated that 

during one of the open hunts (the late-season muzzleloader hunt), approximately half of the 10 tagholders use the Boundary Hunt Unit (Megan 2011) (Table B-11). 

Table B-11. Reported 2009 Deer Harvest on the Refuge, State Hunting Unit, and State Scales 

Number Reported 

as Taken 

Percent of State Reported 

Harvest 

Refuge Unknown1 Unknown 

Juniper Unit 1022 0.5% 

Eastern Oregon total 20,9802 100% 1 Although the Refuge harvest number is unknown, the Refuge law enforcement officer estimates that approximately half of the 

hunters with tags for the late-season muzzleloader hunt concentrate along the Boundary Unit. 2

 Pronghorn data from 2009 (ODFW 2010d). 

Mule deer across the West and in Oregon are declining in population, and are below current 

management objectives in Oregon. Populations have dropped by about a third statewide since 1980 

(Whittaker 2011) after having reached a peak in the 1950s and 1960s (ODFW 2011b). Deer 

populations in the State unit encompassing the Refuge (Steens Mountain Unit) have dropped by 

approximately two-thirds in the last 30 years. Data for populations in the Steens Mountain Unit 

(which encompasses the Refuge and is just east of the Juniper Unit) are shown in Figure B-2. ODFW 

(2011b) attributes the primary causes of the observed decline to the combined effects of drought and 

severe winters, coinciding with an increased number of predators. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-53 

Source: ODFW 2011b. 

Figure B-2. Mule deer population trend, Steens Mountain Unit, 1980-2009. 

Continuing to allow mule deer harvest on the Boundary Hunt Unit will continue an incremental level 

of pressure on a declining population. However, given that the Boundary Unit constitutes a small 

fraction of the area of the Juniper Unit, and harvest within the Juniper Unit is less than 1 percent of 

the eastern Oregon harvest, the additional local and regional population pressure stemming from 

hunting on the Boundary Unit is expected to be negligible to minor. The State of Oregon (ODFW 

2011b) has identified a number of strategies to boost mule deer populations, none of which include 

reduced hunting in the Juniper Hunt Unit. 

Population-specific Impacts: Nuttall’s Cottontail and Jack-tailed Jackrabbit 

An estimated 10 to 12 hunters use the Boundary Hunt Unit to pursue rabbit and/or coyote each year 

(Megan 2011). Statewide statistics on rabbits harvested are not available; however, ODFW (date 

unknown) states that rabbit hunting is the third most popular type of hunting activity in the United 

States, behind wild turkey and deer hunting. 

Population estimates for local rabbit populations are unavailable; however, a study done in Central 

Oregon in 1972-1973 that used monthly censuses in a shrub-juniper scabland habitat (McKay and 

Verts 1978) reported that Nuttall’s cottontail population densities ranging from 6.6 to 254.4 animals 

per 100 ha (2.6 to 103 animals/100 acres), with marked seasonal fluctuations. 

Lagomorphs are capable of extremely high productivity; a doe jackrabbit produces 2 to 6 young 

every 6 weeks during the breeding season, from February to June. The young born in February 

become sexually mature by early summer. As a result, lagomorphs are very important prey for a 

number of predators. Black-tailed jackrabbits naturally undergo 10- to 11-year population cycles. 

0

2000

4000

6000

8000

10000

12000

1980 1984 1988 1992 1996 2000 2004 2008

Estimated Population

Year

Estimated

Population
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-54 Appendix B. Compatibility Determinations 

Without better local data on harvest and population, only general conclusions are possible, based on 

reasonable assumptions and life history information. Currently, a small number of hunters is thought 

to hunt rabbits within the Boundary Hunt Unit, and hunting levels in the unit are expected to change 

little over the next 15 years. If habitat conditions remain stable (jackrabbits are sensitive to reduction 

in population with wildfire [Kochert et al. 1999]), hunting of jackrabbits and rabbits is likely to have 

a negligible effect on local or regional rabbit populations. 

Other Refuge-specific Impacts

Impacts to Non-Target Wildlife: Non-hunted wildlife would include any non-target birds; small- and 

medium-sized mammals; reptiles; amphibians; and invertebrates. Occasionally, non-target species 

are illegally killed by hunters by accident or intentionally, or are disturbed by hunter presence or 

noise. 

The cumulative effects of disturbance to non-hunted birds under the management direction are 

expected to be minor for the following reasons: hunter education courses are required for youths; 

hunting seasons do not coincide with the nesting season, so reproduction will not be reduced by 

hunting; and disturbance to the foraging or resting activities of migrating or resident birds might 

occur, but hunting is still expected to involve a small numbers of participants. The North Malheur 

Lake Unit and Buena Vista Unit will have walk-in access. 

Disturbance to other taxa will be unlikely or negligible for the following reasons: encounters with 

reptiles and amphibians, invertebrates, and small mammals in the early fall will be few and should 

not have cumulative negative effects on Refuge populations; Refuge regulations further mitigate 

possible disturbance by hunters to non-hunted wildlife; and vehicles will be restricted to public roads 

and the harassment or taking of any wildlife other than the game species legal for the season will not 

be permitted. 

Sandhill cranes stage on the southern portion of Malheur Lake and in the Buena Vista wetlands until 

mid-October. Under the CCP, a late season opening for the Buena Vista Unit will allow sufficient 

protection of the sandhill cranes until they migrate farther south, and thus mitigate any huntingrelated impacts to sandhill cranes. Other birds using the area may be disturbed by noise and human 

presence; however, since most birds have already migrated during the fall, disturbance levels will be 

minor overall. Outreach with hunting brochures and timely information on the website will help 

educate hunters on hunting opportunities, regulations, and ethical hunter behavior. 

Waterfowl can die from toxic lead shot if they eat even very small amounts of spent lead shots; shot 

pellets deposited during fall hunting seasons can later be ingested by waterfowl and other wildlife 

feeding in wetland areas where hunting occurs. On Malheur Refuge, only federally approved 

nontoxic shot is allowed for upland game hunting to eliminate this hazard for waterfowl. Nontoxic 

shot is defined by USFWS as any shot type that does not cause sickness and death when ingested by 

migratory birds, and includes shots made of steel, bismuth, tungsten-iron, or tungsten-polymer. 

Dogs will increase the level of disturbance to target and non-target species, but this impact is 

expected to be minor, especially to migratory wildlife, and necessary to support the use and ensure 

successful harvests. Dogs will be required to be under the close control of their owners while on the 

Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-55 

Loss of Habitat from Facility Construction: No additional new facilities will be added to support 

this use in addition to the general visitor use facilities described in the CD for wildlife observation, 

photography, and interpretation. 

Vegetation, Soil, and Water Impacts: Foot travel associated with accessing the hunt units could 

potentially result in temporary and minor vegetation trampling. Based on past Refuge history and 

trends, hunting usually involves very small numbers of hunters; thus, the effect to vegetation will 

likely be negligible. No impact is expected to soil or water resources as a result of this use. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). However, it is unclear at this time if 

the Refuge population is part of the Great Basin distinct population, which is the Federal candidate 

species, or if they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

upland game hunting uses and facilities will be minor to negligible. The greater sage-grouse is not a 

hunted species on the Refuge, although disturbance may result from noise related to hunting 

activities during the hunting season, which overlaps with the most recent seasonal observations of 

sage-grouse on the Refuge. Hunting is not allowed south of the Buena Vista Unit, and there have 

been no occurrences of spotted frogs in the Blitzen River Valley north of Knox Ponds. Additionally, 

frogs will most likely be hibernating during the winter, and hunting season ends prior to breeding 

season. Public education will assist in raising awareness and preventing undue impacts to these 

species. If uses result in unacceptable adverse effects to candidate species or habitats, the Refuge will 

impose restrictions to mitigate disturbance. 

Impacts to Other Priority Public Uses: The phased opening weekends between the north Malheur 

Lake Hunt Unit and the Buena Vista Hunt Unit will help reduce hunter competition and conflicts. 

Additionally, hunting numbers generally decrease over the hunting season after opening weekends, 

further reducing impacts of the hunting season. 

Hunting has the potential to disturb Refuge visitors engaged in other priority public uses; however, 

given the season during which hunting occurs, the likelihood of conflicts is low. Although Center 

Patrol Road is the area most used by other visitors during the migration seasons, use is very light 

during hunting season. State regulations also prohibit shooting from on and across roads. This is 

expected to mitigate any overlap conflicts between hunting and other uses in the Buena Vista Unit. 

Infrastructure: No significant effects to roads, trails, or other infrastructure from the hunting 

program are foreseen. Normal road, trail, and facility maintenance will continue to be necessary. 

Additional facility construction or upgrade, if needed, is addressed in the Availability of Resources 

section. 

Other Effects: There could be some indirect beneficial impacts of Refuge hunting. Refuge hunting 

can contribute to wildlife and habitat conservation and provide educational and sociological benefits. 

The hunting community in general remains the largest support base for funding land acquisitions in 

the Refuge System through purchase of Duck Stamps. Upland game hunting at the Refuge provides a 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-56 Appendix B. Compatibility Determinations 

priority public use and helps meet the Refuge’s goals of wildlife-dependent recreation for all visitors. 

Additionally, providing youth hunting opportunities is an important initiative in the USFWS, and 

enhancing this opportunity on the Refuge helps address a public desire to see more hunting 

opportunities for youth.

Public Review and Comment 

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

 Only federally approved nontoxic shot may be used or be in possession while hunting on the 

Refuge. 

 Vehicles will be allowed only on maintained public roadways. Parking is allowed only within 

one vehicle length of the roadway. Hunters will be instructed to not block dike and field 

accesses. 

 Overnight parking, camping, and campfires will not be permitted on the Refuge. 

 Hunting dogs are strongly encouraged to increase hunter success and retrieval rate. Dogs 

must be kept under close control. 

 Hunting closures will be in effect near Refuge Headquarters, Buena Vista Station, and the 

Malheur Field Station. Shooting from or across public roads or road right-of-ways will be 

prohibited. 

 Law enforcement patrols will ensure safety and minimize conflicts with other priority public 

uses by providing information about hunting boundaries and seasons to the general public 

and those using other Refuge programs. Information will be provided at interpretive kiosks, 

on the Refuge website, and in Refuge offices. 

Justification 

Under the National Wildlife Refuge System Administration Act, as amended, upland game hunting is 

a wildlife-dependent recreational activity that receives enhanced consideration in the CCP planning 

process and is to be encouraged on National Wildlife Refuges if compatible with refuge purposes. 

Despite the direct and indirect impacts associated with sport upland game hunting, upland game 

populations are unlikely to be affected significantly by the hunting program on the Refuge. Upland 

game population objectives and allowable harvests are determined by the State of Oregon. Limited 

hunt seasons, two weekend openings, and no-hunt zones ensure that upland game, as well as nontarget species, will find adequate food and rest areas on the Refuge even in the midst of the hunting 

season. Thus, allowing upland game hunting to occur under the stipulations described above will not 

materially detract or interfere with the purposes for which the Refuge was established or the Refuge’s 

mission. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-57 

Mandatory Reevaluation Date 

 09/2027 Mandatory 15-year Reevaluation Date (for priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Bartlet, G.A. 1987. Effects of disturbance and hunting on the behavior of Canada goose family 

groups in east central Wisconsin. Journal of Wildlife Management 51:517-522. 

Budeau, D. 2011. Personal communication between Dave Budeau, Upland Game Bird Coordinator, 

ODFW, and Maren Murphy, Conservation Planning Assistant, Division of Planning and 

Visitor Services, Region 1, USFWS. May, 2011. 

Cole, D.N. and R.L. Knight. 1990. Impacts of recreation on biodiversity in wilderness. Natural 

Resources and Environmental Issues. Vol. 0, Article 6. Available at: 

http://digitalcommons.usu.edu/nrei/vol0/iss1/6. 

Dooley, J.L., T.A. Sanders, and P.F. Doherty, Jr. 2010. Mallard response to experimental walk-in and 

shooting disturbance. Journal of Wildlife Management 74(8):1815-1824. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog. 

Gese, E.M. 2005. Demographic and spatial response of coyotes to changes in food and exploitation. 

Proceedings of the Wildlife Damage Management Conferences 131. Available at: 

http://digitalcommons.unl.edu/icwdm_wdmconfproc/131. 

Hiller, T. 2011. 2010-2011 Oregon furbearer program report. Oregon Department of Fish and 

Wildlife. Salem, OR. Available at: 

http://www.dfw.state.or.us/resources/hunting/small_game/docs/2011_furbearer_report.pdf. 

Hoopes, E.M. 1993. Relationship between human recreation and piping plovar foraging ecology and 

chick survival. M.S. thesis. University of Massachusetts, Amherst, MA. 106 pp. 

Keller, V. 1991. Effects of human disturbance on eider ducklings Somateria mollissima in an 

estuarine habitat in Scotland. Biological Conservation 58:213-228. 

Klus, R. 2011. Personal communication between Rod Klus, Oregon Department of Fish and Wildlife, 

and Maren Murphy, Conservation Planning Assistant, Division of Planning and Visitor 

Services, Region 1, USFWS. May, 2011. 

Kochert, M.N., K. Steenhof, L.B. Carpenter and J.M. Marzluff. 1999. Effects of fire on golden eagle 

territory occupancy and reproductive success. Journal of Wildlife Management 63:773-780. 

MacArthur, R.A., V. Geist, and R.H. Johnson. 1982. Cardiac and behaviorial responses of mountain 

sheep to human disturbance. Journal of Wildlife Management 46:351-358. 

McKay, D.O. and B.J. Verts. 1978. Estimates of some attributes of a population of Nuttall’s 

cottontails. Journal of Wildlife Management 42(1):159-168. 

Madsen, J. 1985. Impact of disturbance on field utilization of pink-footed geese in West Jutland, 

Denmark. Biological Conservation 33:53-63. 

Megan, J. 2011. Personal communication between John Megan, Refuge Law Enforcement Officer, 

USFWS, and Sharon Selvaggio, Conservation Planner, Division of Planning and Visitor 

Services, Region 1, USFWS, December, 2011. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-58 Appendix B. Compatibility Determinations 

ODFW (Oregon Department of Fish and Wildlife). 2010a. 2009 Oregon upland game bird production 

inventories. Available at: 

http://www.dfw.state.or.us/resources/hunting/upland_bird/population/index.asp, 

http://www.dfw.state.or.us/resources/hunting/upland_bird/docs/2002-

2009_population_inventory.pdf. 

ODFW. 2010b. 2009-10 season Oregon upland game bird expanded harvest by harvest unit. 

Available at: http://www.dfw.state.or.us/resources/hunting/upland_bird/harvest/index.asp, 

http://www.dfw.state.or.us/resources/hunting/upland_bird/docs/2009_10_Upland_Harvest.pd

f. 

ODFW. 2010c. 2010-2015 Oregon upland game bird hunting season framework. Available at: 

http://www.dfw.state.or.us/resources/hunting/upland_bird/docs/2010-

2015_Oregon_Upland_Game_Bird_Hunting_Season_Framework.pdf.

ODFW. 2010d. 2010 big game statistics. Oregon Department of Fish and Wildlife. Salem, OR.

Available at: 

http://www.dfw.state.or.us/resources/hunting/big_game/controlled_hunts/docs/hunt_statistics

/10/2010_big_game_statistics.pdf.

ODFW. 2011a. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

ODFW. 2011b. Mule deer initiative. Oregon Department of Fish and Wildlife. Salem, OR. Available 

at: 

http://www.dfw.state.or.us/resources/hunting/big_game/mule_deer/docs/Mule_Deer_Mgmt_

Plan_Final.pdf. 

ODFW. Date unknown. How to hunt rabbit. Available at: 

http://www.dfw.state.or.us/resources/hunting/docs/Howtohuntrabbit.pdf. 

Owens, N.W. 1977. Responses of wintering brant geese to human disturbance. Wildfowl 28:5-14. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Raveling, D.G. 1979. The annual cycle of body composition of Canada geese with special reference 

to control of reproduction. Auk 96:234-252. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

Servheen, C.W, eds. 1980. Proceedings of the Washington Bald Eagle Symposium. Seattle, WA. 

Sime, C.A. 1999. Domestic dogs in wildlife habitats. Pages 8.1-8.17 in: G. Joslin and H. Youmans, 

coordinators. Effects of recreation on wildlife, Montana chapter of The Wildlife Society. 307 

pp. 

Thomas, V.G. 1983. Spring migration: the prelude to goose reproduction and a review of its 

implication. Pages 73-81 in: H. Boyd, ed. Fourth Western Hemispheric Waterfowl and 

Waterbird Symposium. Canadian Wildlife Service, Ottawa, Canada. 

USFWS. 2011a. Compatibility determination for waterfowl hunting. Malheur National Wildlife 

Refuge. 

USFWS. 2011b. Compatibility determination for wildlife observation, photography, and 

interpretation. Malheur National Wildlife Refuge, Princeton, OR. 

White-Robinson, R. 1982. Inland and salt marsh feeding of wintering brent geese in Essex. Wildfowl 

33:113-118. 

Whittaker, D. 2011. Management actions implementing Oregon’s mule deer initiative. Oregon 

Department of Fish and Wildlife briefing. Available at: 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-59 

http://www.dfw.state.or.us/resources/hunting/big_game/mule_deer/docs/January_2011_MDI

_Briefing.pdf.   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-60 Appendix B. Compatibility Determinations 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-61 

B.5 Fishing Compatibility Determination 

RMIS Database Use: Fishing (general) 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

This CD examines recreational fishing in designated areas of the Refuge as described in the 

management direction of the CCP. A commercial carp fishery was found compatible on the Refuge 

in 2009 and is not examined in this CD (USFWS 2009). 

Program Offerings: Fishing currently occurs at Krumbo Reservoir and the South Loop along the 

Blitzen River and its tributaries. Species allowable for take are redband trout, rainbow trout, 

largemouth bass, and carp. Rainbow trout and largemouth bass occur in Krumbo Reservoir, and 

redband trout, other native fish, and carp occur in the Blitzen River. All fishing is permitted by 

angling only. Table B-12 shows the following regulations for sport fishing as related to the Refuge 

under the 2011 ODFW Sport Fishing Regulations. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-62 Appendix B. Compatibility Determinations 

Table B-12. ODFW Regulations for Sport Fishing for 20111

Species Regulations 

Krumbo Reservoir2 

Trout (rainbow)  Open fourth Saturday of April to October 31 

 Catch: 5 per day, 2 daily limits in possession 

 Length: 8-inch minimum length 

 Bait: Artificial only 

Largemouth bass  Open fourth Saturday of April to October 31 

 Catch: 5 per day, 2 daily limits in possession 

 Length: No more than 3 over 15 inches in length 

 Bait: Artificial only 

Blitzen River Mainstem, East Canal, and Tributaries Upstream and Including Bridge Creek 

(South Fishing Loop) 

Trout (redband)  Open May 28-Oct. 31, 2 per day 

 Open Jan. 1-May 27 and Nov. 1-Dec. 31, catch and release for trout 1

 Source: ODFW 2010. 

2

 Krumbo Reservoir falls under the same ODFW regulations as lakes, except for its special fishing dates. 

Location of Use, Associated Facilities, and Access 

Krumbo Reservoir: Krumbo Reservoir is 184 acres in size. It is not a natural water body and has 

historically been managed for irrigation and fishing activities. ODFW annually stocks Krumbo 

Reservoir with sterilized rainbow trout; in 2010, ODFW stocked 13,100 rainbow trout in Krumbo 

Reservoir. The area is equipped with a number of public use facilities, including picnic tables for 

lunch-time activities, parking, and restrooms, making the Reservoir a big attraction for families with 

children. Access to the site is via vehicle by Krumbo Lane. Once at the Reservoir, anglers may fish 

from any shoreline area and an informal trail circles the reservoir for this purpose. In addition, a boat 

launch permits boating access on the Reservoir itself. Boats with electric motors and non-motorized 

boats will continue to be authorized for use on Krumbo Reservoir, except when the water begins to 

ice over. 

South Fishing Loop: The South Fishing Loop near P Ranch includes the Blitzen River mainstem, 

East Canal, and tributaries upstream, including Bridge Creek. This unit is open year-round, although 

different regulations apply in different seasons, as indicated in Table B-12. This is a popular fly 

fishing area for locals and out-of-area users. Under the CCP, drive-in access along the East Canal 

Road to the confluence of the East Canal with Bridge Creek will be opened in order to improve 

fishing opportunities and to accommodate vehicle access to Granddad Reservoir on Bureau of Land 

Management lands. People may continue to use this road as a hiking trail if they wish. In addition, 

the River Trail, a pedestrian trail, is available to access this area. A new pedestrian crossing at Bridge 

Creek will be constructed to improve fishing access west of East Canal. 

Headquarters Fishing Unit: Additionally, under the CCP, the Refuge will provide a new seasonal 

stream fishing opportunity at the Headquarters Fishing Unit along the Blitzen River from Sodhouse 

Lane north to the Boat Landing Road bridge near Refuge Headquarters, accessible by a fishing trail 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-63 

along the dike. At the new Headquarters Fishing Unit, use of bait will be allowed and regulations for 

catch limits will be defined by ODFW based on state regulations. At the Headquarters Unit, fishing 

will only be available August 1 to September 15 to mitigate conflicts with migrating birds. 

Other Facilities: The Refuge will also provide informational kiosks at strategic entrance points and 

additional signage to enhance visitors’ knowledge of fishing regulations and provide directional and 

program information. 

Number of Visitors and Seasonal Patterns: At Malheur National Wildlife Refuge, an estimated 

1,300 visits in 2011 were for fishing activities. With increased fishing access and additional fishing 

opportunities, the number of fishing visits is expected to grow over 15 years to 1,750 visits per year. 

Under the CCP, the Reservoir and Krumbo Lane will be opened year-round to access for fishing, 

wildlife observation, boating, and hiking, which represents a big increase from the current open 

season of April to October. However, the majority of the use will likely continue to occur during 

spring and fall when the weather and water are cool, and year-round fishing will eliminate any 

pressures and crowding associated with fishing season opening day. Fishing use on the South Loop 

of the Blitzen River typically peaks in late spring when the water runoff from Steens Mountain 

settles and the water clears. The South Loop Fishing Unit and the new Headquarters Fishing Unit 

will be seasonal fishing opportunities as outlined above. 

Availability of Resources 

Availability of resources for administering and managing the fishing program under the CCP are 

detailed in Table B-13. 

Table B-13. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Develop fishing brochure $1,500 $2,000

Develop outdoor fishing information kiosks $60,000 

Build 2-3 new pedestrian crossings and complete development 

of loop trail at South Fishing Loop $275,000 

Open new seasonal bank fishing opportunity along the Lower 

Blitzen River with fishing trail, two bridges, parking, and 

portions that meet ADA standards 

$275,000 

Replace Krumbo Reservoir floating platform and maintain 

facilities $35,000 $2,000

Fishing program administration and management 

(programmatic, law enforcement, information) $6,000

Total $646,500 $10,000 

Administering the fishing program does not require significant staff time, equipment, or funding. The 

Refuge has one FTE Visitor Services Manager, and one FTE position for law enforcement that 

patrols the Refuge during fishing season to ensure compliance with state and Federal regulations and 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-64 Appendix B. Compatibility Determinations 

Refuge conditions. The majority of the staff time spent administering this program will fall mostly on 

the law enforcement position. Other Refuge staff assists in maintenance of fishing facilities like 

access roads, trails, kiosks, and platforms; in general, the fishing program uses many of the same 

facilities and resources as the wildlife observation, photography, and interpretation program, 

including trail and parking area maintenance, facility and road maintenance, sign posting, and 

construction projects (USFWS 2011b). Additional costs and staff time will include developing and 

printing fishing brochures and constructing new kiosks for the fishing program. 

Some fishing program enhancements may currently lack funding, but the Refuge will develop 

partnerships and seek additional funding resources over the next 15 years as necessary to complete 

projects. Based on the availability of resources, the Refuge will have sufficient funds for managing 

current and expected levels for fishing. Exact costs will be developed during design and 

implementation. 

Anticipated Impacts of the Use 

General Impacts Expected from the Scientific Literature

A general assessment of impacts resulting from fishing uses has been compiled from the literature 

and is briefly summarized below. 

Disturbance to Wildlife: Fishing as a solitary and stationary activity tends to be less disturbing to 

wildlife than hunting or motorized boating (Tuite et al. 1983). Fishing has the potential to cause 

disturbance to birds and other wildlife using open waters and tributaries where fishing occurs. 

Fishing activities may influence the composition of bird communities, as well as the distribution, 

abundance, and productivity of waterbirds (Tydeman 1977; Bouffard 1982; Bell and Austin 1985; 

Bordignon 1985; Edwards and Bell 1985; Cooke 1987; Bouffard and Hanson 1997). Anglers often 

fish in shallow, sheltered bays and creeks that birds prefer, which can negatively impact distribution 

and abundance of waterfowl, grebes, and coots (Cooke 1987). Increases in anglers and associated 

shoreline activity have been found to discourage waterfowl from using otherwise suitable habitat 

(Jahn and Hunt 1964). When compared to non-fishing days and/or non-fishing rivers, anglers 

influenced the numbers, behavior, and diurnal distribution of avian scavengers present at sites along 

the Skagit and Toutle rivers in Washington, disrupted feeding, and increased energy expenditure 

through avoidance flights (Knight and Knight 1984; Knight et al. 1991). 

Stream Fishing Impacts: Shoreline activities related to stream fishing, such as human noise, will 

cause some birds to flush and go elsewhere. Waterbirds and waterfowl in particular use shorelines 

seasonally for resting, feeding, and nesting. Anglers often use vehicles to gain access to angling sites 

and remain there for long periods of time. Furthermore, anglers frequently show long periods of 

inactivity interspersed with short periods of rapid movements, which has the potential to disturb 

nearby wildlife (Bell and Austin 1985).

Boating Impacts: Boating associated with fishing can alter bird distribution, reduce the use of 

particular habitats or entire areas by waterfowl and other waterbirds, alter feeding behavior and 

nutritional status, and cause premature departure from areas due to the noise and speed of boats 

(Bouffard 1982; Kaiser and Fritzell 1984; Korschgen et al. 1985; Havera et al. 1992; Ward and 

Andrews 1993; Knight and Cole 1995; Knapton et al. 2000). On the Missouri’s Ozark Scenic 

Riverways, herons often left the river for areas of dense habitat or less productive tributaries when 

the number of recreationists increased (Kaiser and Fritzell 1984). The level of disturbance to 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-65 

waterfowl has been found to vary considerably based on watercraft type. A study by Havera et al. 

(1992) showed waterfowl took flight and flushed farther in response to hunting and fishing craft, 

while few flushed because of barges. On the Upper Mississippi River, which includes the Upper 

Mississippi River National Wildlife and Fish Refuge, birds were found to be more sensitive to boats 

with outboard motors (Korschgen et al. 1985). In addition, trampling of vegetation and deposition of 

sewage or other chemicals from recreation has been found to impact freshwater plants and wildlife 

(Liddle and Scorgie 1980). 

Off-Road Vehicle Impacts: Wildlife can be impacted when they are disturbed and flushed from 

feeding, resting, or nesting areas vulnerable to loud noise and activity from off-road vehicles. In 

addition, temporary disturbance to habitat could impact nesting and foraging resources available for 

wildlife. In general, disturbance impacts of off-road vehicles are related to the intensity of use or use 

characteristics, in combination with the level of fragility of the affected environment. A majority of 

the off-road vehicle uses are in coordination with the grazing and haying program, and use for fishing 

is only a minor subset (USFWS 2011a). 

Refuge-specific Impacts 

This section evaluates the likely impact at the Refuge itself, considering the scientific studies 

discussed above and considering the uses within the context of Malheur Refuge. 

Disturbance-related Impacts from Reservoir Fishing: Krumbo Reservoir is one of the most heavily 

used areas on the Refuge. During the spring and fall, disturbance, especially near the parking lot and 

boat launch, undoubtedly prevents use by a variety of waterfowl and waterbirds. However, the 

Refuge maintains numerous other ponds and flooded areas in the spring and into summer and 

therefore spring/summer disturbance is of negligible concern, given the Refuge context. 

Previous research has shown that the level of disturbance to waterfowl varies considerably based on 

watercraft type. To limit disturbance impacts to wildlife, only non-motorized boating and electric 

motorized boating will be allowed on Krumbo Reservoir. The use of non-motorized and electric 

motorized boating minimizes noise associated with boating and prevents the spread of oil and gas 

residue associated with diesel- and gas-powered motorized boats. It also reduces the speed with 

which anglers can travel on the Reservoir. 

Under the CCP, Krumbo Reservoir and Krumbo Lane will be opened year-round to access, except 

when the water ices over. A concern raised by some is that increasing wintertime access to the 

Reservoir could have potential impacts to wintering waterfowl that use Krumbo Reservoir and 

Krumbo Swamp and Otter Reservoir along Krumbo Lane. There are limited open-water resources 

available on the Refuge during winter as most areas are dry or have frozen. The number of birds 

using the Reservoir during the winter is typically less than 400 birds on any given day, and there are 

less than 100 birds during the coldest part of the season (J. Dastyck, personal communication); most 

birds have migrated farther south during the winter. The Reservoir comprises around 20 percent of 

the total 1,004 acres of available open water wintering habitat on the Refuge, leaving 820 acres 

(more than 80 percent) of open water wintering habitat including Boca Lake, Benson Reservoir, and 

East Knox Reservoir. Given this and the likelihood that the number of visitors to the Reservoir 

during the winter months will be significantly less than in the spring, summer, or fall months, the 

disturbance impact to wintering birds is expected to be minor. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-66 Appendix B. Compatibility Determinations 

ODFW annually stocks Krumbo Reservoir with triploid rainbow trout, meaning they are sterilized 

and never develop normal eggs or sperm and are unable to reproduce. This will continue under the 

CCP. Sterilization negates the risk of any genetic reproduction and modification with native redband 

trout, thus creating a negligible impact on the native fishery. Additionally, Krumbo Reservoir is 

dammed, which prevents rainbow trout from migrating into the Blitzen River. Largemouth bass are 

also present in Krumbo Reservoir from historical stocking, but are not currently stocked and are a 

self-sustaining population; native redband trout are not found in the Reservoir, as Krumbo Creek 

water levels are not high enough to maintain a sustainable native population for spawning. Genetic 

studies have occurred in the Blitzen River for any evidence of introgression of redband trout with 

hatchery rainbow trout and there has been no strong evidence indicating this in the Blitzen population 

of redband, specifically in Bridge and Mud creeks (ODFW 2005). 

With the low number of birds present, low visitor use levels, and availability of additional wintering 

habitat and sanctuary, it is expected that year-round access at Krumbo Reservoir will have negligible 

impacts. Wildlife surveys and monitoring will be conducted to ensure disturbance stays at a 

minimum. 

Disturbance-related Impacts from Stream Fishing: Stream fishing allows anglers direct access to a 

portion of the Blitzen River, East Canal, and Mud and Bridge Creeks. Under the CCP, the South 

Loop along the East Canal will change from walk-in only access to include drive-in access up to the 

confluence of the East Canal with Bridge Creek. This has the potential to increase disturbance to 

wildlife to moderate levels, as it is expected this change will attract more anglers to the fishing area 

and disperse users across a wider stretch of the river (compared to present). The River Trail on the 

west bank of the Blitzen River will remain walk-in access. 

Under the CCP, a new seasonal stream fishing opportunity at the Headquarters Fishing Unit from 

Sodhouse Lane to the Boat Landing Road bridge near Headquarters will be opened. This will 

increase the amount of stream fishing along the Blitzen River by nearly 1 mile for a total of 14 miles 

on the Refuge. This could increase the potential for disturbance to resting and feeding waterbirds and 

waterfowl, as well as impacts to shoreline habitat and vegetation. However, the new fishing area will 

only be open seasonally from August 1 to September 15 after birds have fledged and moved on. 

Given this, and because generally, the fishing pressure along the Blitzen River is low, it is anticipated 

that with the limitations included in the CCP, disturbance to wildlife will be minor. 

A new pedestrian crossing at Bridge Creek will be constructed under the CCP to enhance access to 

fishing west of East Canal along Bridge Creek. The bridge will increase the number of anglers in an 

area that was previously hard to access. Construction of the trail enhancements will be done in a way 

to reduce impacts to wildlife and resources. 

Direct Mortality to Target Species (Take): Fishing will result in direct take of target fish. Harvest is 

coordinated with ODFW to avoid excess pressure on populations. Fishing will be permitted by 

angling only and will be restricted to artificial flies and lures in streams, except in the Headquarters 

Fishing Unit where use of bait will be allowed. 

Barbed hooks will be permitted to increase the success of take. Some impacts may come from barbed 

hooks to native redband trout populations, but this is expected to be minor as redband trout do not 

occur in Krumbo Reservoir and fishing pressure on the Blitzen River is generally low. Outreach with 

fishing brochures, informational panels, and public education on best fishing practices will help 

educate anglers on fishing regulations and ethical behavior. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-67 

Loss of Habitat from Facility Construction: Under the CCP, new panels constructed for fishing will 

result in 0.5 acre of habitat loss, which is a fraction of a percentage of the Refuge; thus, habitat loss 

from new facilities is considered negligible. No additional new facilities will be added to support this 

use separate from general visitor use facilities (USFWS 2011b). 

Vegetation, Soil, and Water Impacts: Some vegetation, soil, and water impacts will be anticipated 

from bank fishing and access to water along the Krumbo Reservoir and Blitzen River shorelines 

where anglers access the areas by foot. Impacts will also be anticipated as a result of allowing vehicle 

access on East Canal. However, trail enhancements along the South Loop may also benefit the 

surrounding habitat by concentrating users on a formal trail instead of social trails that are not 

regulated. 

The developed parking and concrete boat ramp at Krumbo Reservoir potentially carries stormwater 

runoff and toxins from vehicles into the Reservoir, although these facilities also contribute positively 

to habitat conservation by concentrating visitors on hardened surfaces and decreasing impacts to 

vegetation and soil adjacent to the fishing area. An undeveloped pedestrian fishing trail circles the 

perimeter of the Reservoir, potentially causing impact to shoreline habitat (USFWS 2011b). 

Additional impacts related to public use at the Reservoir include a certain amount of litter and 

general garbage left at shoreline fishing sites. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). It is unclear at this time if the Refuge 

population is part of the Great Basin distinct population, which is the Federal candidate species, or if 

they belong to the Oregon population. 

Impacts to Columbia spotted frogs will be expected to increase under the CCP with expanded stream 

fishing access for anglers along the South Fishing Loop of the Blitzen River and its tributaries, and 

the construction of a new pedestrian crossing at Bridge Creek to access a portion of fishable area 

west of East Canal. Public tramping along the shoreline during the April to May frog breeding season 

has the potential to disturb/dislodge egg masses. It is anticipated that disturbance from anglers 

accessing the shoreline will be sporadic, and impacts will be minor due to generally low levels of 

fishing activity and the patchy occurrences of Columbia spotted frogs on the Refuge. Public 

education or use of interpretation will assist in raising awareness and preventing undue impacts to 

this species. Informational panels and additional signage will also be posted at the South Fishing 

Loop to inform anglers of proper fishing practices. If stream fishing results in unacceptable adverse 

effects to candidate species or habitats, the Refuge will impose restrictions on stream fishing to 

mitigate disturbance. 

Impacts to Other Priority Public Uses: Fishing generally results in little disturbance to other visitors. 

Both fishing and hunting will use Boat Landing Road to access the Blitzen River; however, the uses 

occur at different seasons, with fishing from August 1 to September 15 and hunting opening on the 

fourth Saturday of October. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-68 Appendix B. Compatibility Determinations 

Infrastructure: No significant effects to roads, trails, or other infrastructure from fishing are 

foreseen. Normal road, trail, and facility maintenance will continue to be necessary. Additional 

facility construction or upgrade, if needed, is addressed in the Availability of Resources section. 

Public Review and Comment 

Various opportunities were provided for the public to engage with the CCP planning process. 

Appendix J details public involvement undertaken during the development of the CCP. 

Determination: 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

General Stipulations 

 Use is open daily from dawn to dusk. Camping, overnight use, swimming, and fires are 

prohibited. 

 All fishing on the Refuge will require an appropriate state license and tag, and all fishing will 

be consistent with applicable state and Refuge regulations. 

 Fishing on the Refuge will be permitted by angling only and will be restricted to artificial 

flies and lures in streams, except in the Headquarters Fishing Unit where use of bait will be 

allowed. Only catch-and-release fishing is allowed in the South Fishing Loop from January 1 

to May 27 and November 1 to December 31. No discharge of weapons will be allowed on the 

Refuge, and the use of bows and arrows, crossbows, and spear guns will be prohibited. 

 The Refuge will provide information on fishing and access at appropriate sites and through 

printed brochures. Information will also include current migratory bird and Refuge 

regulations, as well as maps of closed areas. 

 The Service shall maintain public use facilities to minimize waste problems on shorelines. 

 ODFW will continue to monitor harvest by anglers and routinely adjust regulations to ensure 

that overall populations of game species remain healthy into the future. 

 Law enforcement patrols will be conducted to ensure compliance with fishing regulations. 

Justification 

Fishing receives enhanced consideration in the CCP planning process and is considered a priority 

public use when determined compatible. Providing a quality fishing program contributes to achieving 

the Refuge’s goals. The fishing opportunities and anticipated level of use, as described, were 

determined to not materially detract from the ability of the Refuge to meet its purposes, despite the 

potential impacts that fishing and supporting activities (boating) can have on wildlife and habitats. 

Only electric boating or non-motorized boating will be allowed for Reservoir fishing, thus lessening 

the disturbances to waterfowl and other wildlife. The combination of closed areas, seasonal use areas, 

minimally used areas, and seasonal high-use areas allows sport fishing and high-quality fish and 

wildlife habitat to co-exist on the Refuge by dispersing uses throughout different areas and different 

seasons. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-69 

It is anticipated that wildlife, primarily waterbirds, will find sufficient food resources and resting 

places such that their abundance and use of the Refuge will not be measurably lessened; fishing 

pressure will not cause fish stocks to decline; fish stocking with sterilized triploid rainbow trout will 

not cause genetic modification to the native redband trout fishery; the physiological condition and 

production of waterfowl and other waterbirds will not be impaired; behavior and normal activity 

patterns will not be altered dramatically; and overall wildlife welfare will not be negatively impacted. 

Mandatory Reevaluation Date 

 09/2027 Mandatory 15-year Reevaluation Date (for priority public uses) 

NEPA Compliance for Refuge Use Decision: 

 X Environmental Impact Statement and Record of Decision 

References 

Bell, D.V. and L.W. Austin. 1985. The game-fishing season and its effects on overwintering 

wildfowl. Biological Conservation 33:65-80. 

Bordignon, L. 1985. Effetti del disturb antropico su una popolazinoe di germane reale Anas 

platyrhynchos. (Effects of human disturbance on a population of mallard Anas 

platyrhynchos.) Avocetta 9:87-88. 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Bouffard, S. and M.A. Hanson. 1997. Fish in waterfowl marshes: Waterfowl managers’ perspective. 

Wildlife Society Bulletin 25:146-157. 

Cooke, A.S. 1987. Disturbance by anglers of birds at Graftham Water. ITE Symposium 19:15-22. 

Edwards, R.W. and D.V. Bell. 1985. Fishing in troubled waters. New Science 1446:19-21. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

Havera, S., L. Boens, M. Georgi, and R. Shealy. 1992. Human disturbance of waterfowl on Keokuk 

Pool, Mississippi River. Wildlife Society Bulletin 20:290-298. 

Jahn, L.R. and R.A. Hunt. 1964. Duck and coot ecology and management in Wisconsin. Wisconsin 

Conservation Department Technical Bulletin 33:1-212. 

Kaiser, M. and E. Fritzell. 1984. Effects of river recreationists on green-backed heron behavior. 

Journal of Wildlife Management 48(2):561-567. 

Korschgen, C., L. George, and W. Green. 1985. Disturbance of diving ducks by boaters on a 

migrational staging area. Wildlife Society Bulletin 13:290-296. 

Knapton, R., S. Petrie, and G. Herring. 2000. Human disturbance of diving ducks on Long Point Bay, 

Lake Erie. Wildlife Society Bulletin 28 (4):923-930. 

Knight, R.L. and S.K. Knight. 1984. Responses of wintering bald eagles to boating activity. Journal 

of Wildlife Management 48(3):999-1004. 

Knight, R.L., D.P. Anderson, and N.V. Marr. 1991. Responses of avian scavenging guild to anglers. 

Biological Conservation 56:195-205. 

Knight, R.L. and D.N. Cole. 1995. Wildlife responses to recreationists. In: R.L. Knight and K.J. 

Gutzwiller, eds. Wildlife and recreationists. Covelo, California: Island Press. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-70 Appendix B. Compatibility Determinations 

Liddle, M.J. and H.R.A. Scorgie. 1980. The effects of recreation on freshwater plants and animals: A 

review. Biologlical Conservation 17:183-206. 

ODFW. 2005. 2005 Oregon native fish status report, Volumes I and II. Available at: 

http://www.dfw.state.or.us/fish/ONFSR/report.asp. 

ODFW. 2010. 2011 Oregon sport fishing regulations: Southeast zone. Available at: 

http://www.dfw.state.or.us/resources/fishing/. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_

Candiadate_species_Backgrounder.pdf [sic]. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

Tuite, C.H., M. Owen, and D. Paynther. 1983. Interaction between wildfowl and recreation at 

Llangorse Lake and Talybont Reservoir, South Wales. Wildfowl 34:48-63. 

Tydeman, C.F. 1977. The importance of the close fishing season to breeding bird communities. 

Journal of Environmental Management 5:289-296. 

USFWS. 2009. Compatibility determination fishing-commercial (common carp). Malheur National 

Wildlife Refuge. Princeton, OR. 

USFWS. 2011a. Compatibility determination for grazing and haying. Malheur National Wildlife 

Refuge. Princeton, OR. 

USFWS. 2011b. Compatibility determination for wildlife observation, Photography, Interpretation. 

Malheur National Wildlife Refuge, Princeton, OR 

Ward, D. and J. Andrews. 1993. Waterfowl and recreational disturbance on inland waters. Upper 

Mississippi National Waterfowl Refuge. British Wildlife 4 (4):221- 229. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-71 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-72 Appendix B. Compatibility Determinations 

B.6 Commercial Tours and Photography Compatibility 

Determination 

RMIS Database Uses: Photo/Video/Film or Audio Recording (commercial); Wildlife Observation 

Guiding/Outfitting 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of Use 

This CD addresses non-consumptive commercial uses related to photography and wildlife/nature 

observation. This determination does not address consumptive uses such as commercial guiding for 

hunting and fishing, nor activities not related to natural, historical, or cultural subjects. Additionally, 

a variety of non-profits and educational institutions engage in natural resource– and EE-based 

activities on the Refuge. Although this use is similar in nature to the commercial recreational use, 

non-profit and EE-based activities are covered under the CD for EE (USFWS 2011a). 

By regulation, the Service may only authorize public or private economic use of the natural resources 

of any National Wildlife Refuge where it is determined that the use contributes to the achievement of 

the National Wildlife Refuge’s purposes or the National Wildlife Refuge System’s mission (50 CFR 

29.1). Refuge System policy on management of specialized uses (5 RM 17) states that when 

monetary gain (profit) is the objective of a refuge recreational use, the use is to be managed as an 

economic use. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-73 

Commercial photography is a visual recording (motion or still) by firms or individuals (other than 

news media representatives) who intend to distribute their photographic content for money or other 

consideration, including the creation of educational, entertainment, or commercial enterprises as well 

as advertising audio-visuals for the purpose of paid product or services, publicity, and commercially 

oriented photo contests (Service Manual 605 FW 5). This typically involves taking still photographs 

or recording wildlife sounds and images related to a Refuge’s wildlife and resources. Commercial 

tours and guiding are activities conducted by private organizations or businesses using National 

Wildlife Refuges. These uses are considered beneficial when they support and extend public 

appreciation and understanding of wildlife, natural habitats, and the mission of a Refuge and the 

National Wildlife Refuge System. 

Commercial photography and observation uses on Malheur National Wildlife Refuge cover a broad 

range of resource-based activities and tours, including birding, geology, plant identification, art and 

visual interpretation, music, sound recording, and other similar non-consumptive activities. These 

uses will usually occur in areas open to the public, using the same facilities associated with noncommercial recreational uses (USFWS 2011b). Users typically engage in guiding and commercial 

photography at Refuge Headquarters, along Center Patrol Road and at a number of historical and 

interpretive sites, including Benson Pond, the historic Sodhouse Ranch (when opened), Buena Vista 

Overlook, Krumbo Reservoir, and the historic P Ranch. 

Commercial photography on the Refuge is most often conducted by individuals, while commercial 

tours are generally conducted in groups; both uses will be expected to occur at smaller levels than 

non-commercial photography and wildlife observation. These uses may occur year-round on the 

Refuge, although the best time of year for wildlife photography and observation is during the spring 

and fall migrations (March to May and September). Activities related to other natural resources (e.g., 

geology) may occur at other times of the year depending on the program. These uses may be 

conducted in vehicles on public roads and on foot on designated hiking trails and roads. Due to the 

large size of the Refuge, uses are mainly conducted in vehicles with occasional stops at public sites 

to allow users to photograph or view outside the vehicle. 

Under the CCP, an SUP will be required for all commercial uses on the Refuge as described under 

the Stipulations Necessary to Ensure Compatibility section in this document. 

Availability of Resources 

Under the CCP, user fees will be collected for issuing SUPs to commercial photographers and 

commercial tours requesting permission to go into a closed habitat/wildlife sanctuary. If any special 

resources (such as transportation, access to restricted areas, or guide service) are provided by the 

Refuge staff, these costs will be added to the standard fee for issuing an SUP. Availability of 

resources for administering and managing commercial recreational uses under the CCP are detailed 

in Table B-14. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-74 Appendix B. Compatibility Determinations 

Table B-14. Costs to Implement the Use 

Category One-time 

Expense ($) 

Annual Expense 

($/year) 

Administration and management of SUPs $5,000 

Offsetting revenues ($100 for SUP into closed areas) ($2,400)

Total $2,600 

Commercial photography and wildlife guiding use the same facilities and resources as the noncommercial wildlife observation, photography, and interpretation program, including trail and 

parking area maintenance, facility and road maintenance, sign posting, and construction projects 

(USFWS 2011b). The Refuge has one FTE position dedicated to administering the commercial 

recreational uses program as a Visitor Services Manager, in addition to the Refuge Manager who has 

to approve the SUPs. There is an additional FTE position for any law enforcement needs. Other 

Refuge staff assists maintenance and construction. The majority of the costs associated with the 

commercial recreational uses program will be administrative time and costs for SUPs; SUPs are also 

included under EE but total cost for permits is reflected here. Based on the availability of resources, 

the Refuge will have sufficient funds for managing current and expected levels of these uses 

associated with wildlife observation, photography, and interpretation. Exact costs will be developed 

during design and implementation. 

Anticipated Impacts of the Use 

General Impacts

In general, impacts that will occur from commercial recreational uses will be similar to those 

expected from non-commercial uses; however, commercial recreational uses could be more 

disturbing than non-commercial uses because commercial uses tend to occur in groups of people. 

This effect is explored in this CD. 

Impacts that could occur from commercial recreational uses will be similar to those expected from 

non-commercial wildlife observation and photography activities, especially those expected from 

larger groups (USFWS 2011b). Such impacts will be expected to include temporary damage to 

vegetation resulting from trampling, disturbance to nesting birds, and disturbance to feeding or 

resting birds or other wildlife in the proximity. Commercial recreational uses generally accommodate 

groups of participants, and studies have shown that increasing group size has an impact on wildlife 

(Beale and Monaghan 2004; Remacha et al. 2011). In addition to group size, loudness has also been 

found as an important variable to disturbance of wildlife, and the loudness of people present can be 

more important than the number of people present (Burger and Gochfeld 1991). Studies showed that 

reducing group size, allowing safe distances, and reducing noise levels helps minimize negative 

impacts on wildlife (Burger and Gochfeld 1991; Beale and Monaghan 2004; Remacha et al. 2011). 

Refuge-specific Impacts

Commercial recreational uses at the Refuge occur in areas open to the public and, for the most part, 

are expected to use the same facilities and resources as non-commercial uses (USFWS 2011b). The 

administration of this use will allow occasional access into closed areas, subject to review and 

approval of an SUP. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-75 

As the literature demonstrates, the number of people visiting a site can influence disturbance to 

wildlife. Larger group sizes customary of tours will likely increase some disturbance to wildlife on 

the Refuge during sensitive times of the day or seasons, particularly during the spring and fall 

migrations when the Refuge supports substantially more wildlife. There could be additional crowding 

along Center Patrol Road or at public use sites, which will increase vegetation trampling and 

localized impacts to habitats. Groups requesting special permission to access a habitat/wildlife 

sanctuary area not normally visited by the public could further increase impacts to sensitive wildlife. 

Individual commercial photographers will be expected to have the same minor impacts as noncommercial photographers, although filming or recording that involves additional equipment and setup could have additional impacts on habitats and wildlife due to heavy equipment and/or increased 

sound levels. Overall the impacts are expected to be minor due to the large size of the Refuge, the 

availability of sanctuary closed to the public, and the small number of commercial groups and 

commercial photographers that visit the Refuge throughout the year. 

To ensure commercial recreational uses are conducted in a manner compatible with the Refuge’s 

purposes and the National Wildlife Refuge System’s mission, an SUP will be required for all forprofit commercial uses occurring on the Refuge. This is expected to benefit both the users and the 

Refuge as it will aid users in understanding Refuge regulations and the purpose and mission of the 

Refuge and Refuge System. At the same time, it will provide the Refuge a tool for managing uses; 

protecting natural and cultural resources; reducing user conflicts; and gathering use information. The 

SUP will also create an opportunity for communication and outreach between the Refuge staff and 

commercial photographers or tour groups to increase knowledge and awareness of the Refuge’s 

habitat and wildlife, and disseminate information to users on ethical photography and wildlife 

observation behavior. Table B-15 details the special use permit requirements under the CCP. 

Table B-15. Special Use Requirements for Commercial Recreational Uses 

Who Access to 

Open Areas 

Access to 

Closed Areas 

Access to 

Hunting Areas 

Access to 

Fishing Areas 

Commercial 

Photographers 

 SUP 

 No fee 

 SUP 

 Fee required 

 No entry during 

hunting season 

 SUP 

 No fee 

Commercial Tour 

Groups 

 SUP 

 No fee 

 SUP 

 Fee required 

 No entry during 

hunting season 

 SUP 

 No fee 

It is not expected that commercial photography and wildlife observation will cause any additional 

short-term, long-term and/or cumulative and indirect/secondary impacts other than those detailed 

above. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). But it is unclear at this time if the 

Refuge population is part of the Great Basin distinct population, which is the Federal candidate 

species, or if they belong to the Oregon population. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-76 Appendix B. Compatibility Determinations 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

commercial recreational uses will be negligible and will not be expected to increase disturbance to 

candidate species any more than non-commercial uses. Uses will continue to occur primarily at 

public sites and on designated roads and trails away from sensitive habitat and resources, and outside 

of breeding areas and seasons. Users will be required to apply for an SUP, and stipulations for 

reducing impacts to candidate species will be further covered by the permit. Public education or use 

of interpretation will assist in raising awareness and preventing undue impacts to these species. If 

uses result in unacceptable adverse effects to candidate species or habitats, the Refuge will impose 

restrictions to mitigate disturbance. 

Impacts to Other Priority Public Uses: Commercial recreational uses generally result in little 

disturbance to other visitors. However, larger groups may cause crowding on roads and at public 

sites, which could impact the experiences of individuals and non-commercial users. Some tours may 

inadvertently flush game being pursued by bird hunters, but this conflict will be expected to be 

minimal as hunting areas will not be open to non-hunters during hunting seasons. There will be no 

conflict expected between anglers, non-commercial wildlife observers, or photographers. Careful 

scheduling with EE groups will be done to reduce any conflicts between groups and uses. 

Impacts to Infrastructure: No significant effects to roads, trails, or other infrastructure from 

commercial photography and wildlife observation programs are foreseen. Normal road, trail, and 

facility maintenance will continue to be necessary. Additional facility construction or upgrade, if 

needed, is addressed in the Availability of Resources section.

Public Review and Comment 

Various opportunities were provided for the public to engage with the CCP planning process. 

Appendix J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

General Stipulations 

 Visitors are restricted to designated trails, sites, or facilities as determined by Refuge staff. 

Use is open daily from dawn to dusk. Camping, overnight use, swimming, and fires are 

prohibited. 

 Motorized vehicles will be limited to designated public roads and parking lots and must 

observe posted speed limits. 

 Commercial photographers should ensure proper credit is given to the Refuge and the 

Service. 

 Collection of natural objects such as plants, animals, minerals, antlers, and cultural resources 

are prohibited. 

 If disturbance to wildlife or damage to habitat reaches unacceptable levels, the Refuge will 

limit uses in areas where unacceptable impacts occur. Monitoring will be conducted to ensure 

that high-quality habitat for wildlife feeding, resting, and breeding is maintained. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-77 

Special Use Permit 

 An SUP will be required for all commercial photography and wildlife/nature tours and 

guiding on the Refuge. Guiding for hunting and fishing is not allowed on the Refuge. 

 A standard permit form stipulating dates, times, and locations of use will be made available 

prior to the visit on the Refuge’s website or by mail. 

 SUPs for areas open to the public grant permissions to open areas for up to 1 year under the 

same use stipulations before renewal, and no fee is charged for the permit. 

 Special permission requests to closed habitat/wildlife sanctuary areas or other special 

considerations (e.g., access to the Refuge after normal public visitation hours, setting up 

temporary equipment, requiring additional resources or staff) will require an SUP and permit 

fee, and will be granted on a case-by-case basis with no renewal. 

 The SUP will be required to be readily available while conducting the permitted use on the 

Refuge. 

 Requests must demonstrate a means to enhance education, appreciation, and/or understanding 

of the Refuge and the National Wildlife Refuge System. Failure to abide by any part of the 

SUP or regulations will be considered grounds for immediate revocation of the permit and 

could result in denial of future permit requests. 

Justification 

By allowing commercial guiding and photography uses to occur under the stipulations described 

above, it is anticipated that wildlife species that could be disturbed during the use will find sufficient 

resources and resting places such that their abundance and use of the Refuge will not be measurably 

lessened. Additionally, it is anticipated that use of SUPs will provide the Refuge a tool for managing 

uses, protecting natural and cultural resources, reducing user conflicts, and mitigating disturbance 

impacts. The SUP will also create an opportunity for communication and outreach between the 

Refuge staff and commercial photographers or tour groups to increase knowledge and awareness of 

Refuge regulations and ethical photography and wildlife observation behavior. Thus, the use will not 

materially interfere with or detract from the Refuge System’s mission or the purposes for which the 

Refuge was established. 

This activity contributes to the mission of the USFWS. Commercial guiding provides visitors an 

organized and educational opportunity to view wildlife safely under the use stipulations. 

Additionally, commercial photography, through educational wildlife media, creates end products that 

may provide an educational opportunity to a much broader distribution of people who may not have 

the opportunity to visit and personally view the Refuge’s wildlife and resources. The media products 

produced by these commercial operations will also be beneficial in promoting the mission of the 

National Wildlife Refuge System. 

It is determined that commercial photography and wildlife observation within the Refuge as 

described herein, will not materially interfere with or detract from the purposes of the Refuge or the 

mission of the National Wildlife Refuge System. The stipulations outlined above will minimize 

potential impacts relative to wildlife/human interactions. The commercial recreational uses program 

is intended to foster a better understanding of Refuge wildlife and resources, and in turn build a 

public that is more knowledgeable about, and involved in, resource stewardship. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-78 Appendix B. Compatibility Determinations 

Mandatory Reevaluation Date 

 09/2022 Mandatory 10-year Reevaluation Date (for all uses other than priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Beale, C.M. and P. Monaghan. 2004. Human disturbance: people as predation-free predators? 

Journal of Applied Ecology 41:335-343. 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

ODFW (Oregon Department of Fish and Wildlife). 2011. Greater sage-grouse backgrounder. 

Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Remacha, C., J. Pérez-Tris, and J.A. Delgado. 2011. Reducing visitors’ group size increases the 

number of birds during educational activities: Implications for management of nature-based 

recreation. Journal of Environmental Management 92(6):1564-1568. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

USFWS (U.S. Fish and Wildlife Service). 2011a. Compatibility determination for environmental 

education. Malheur National Wildlife Refuge. Princeton, OR. 

USFWS. 2011b. Compatibility determination for wildlife observation, photography, and 

interpretation. Malheur National Wildlife Refuge. Princeton, OR. 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-79 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-80 Appendix B. Compatibility Determinations 

B.7 Grazing and Haying Compatibility Determination 

RMIS Database Uses: Grazing; Haying or Ensilage 

Refuge Name: Malheur National Wildlife Refuge 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd et seq.]). 

Description of the Use 

Purpose and Intent of Haying and Grazing as a Management Tool at Malheur Refuge

This CD examines haying and grazing as described in the management direction of the CCP. 

Livestock grazing and haying have been used in the past at Malheur Refuge and will be used in the 

future as tools to provide optimum conditions for wildlife (specifically, foraging areas for waterfowl, 

waterbirds, and shorebirds; pairing habitat for waterfowl; nesting habitat for shorebirds; and nesting 

habitat for certain passerines) and, where possible, to improve biological integrity (native plant 

diversity; hereafter, restoration) in Refuge plant communities. A complete description of how grazing 

and/or haying is likely to result in these outcomes is contained in the section of this CD titled 

Anticipated Impacts of the Use. 

Policies Pertaining to Use of Haying and Grazing on National Wildlife Refuges

Administration Act: Almost one hundred years after its establishment, the U.S. Fish and Wildlife 

Service’s National Wildlife Refuge System received organic (i.e., foundational) legislation that 

provided policy direction and management standards applicable to all refuges. This statute, the 

National Wildlife Refuge System Improvement Act of 1997 (P.L. 105-57) amended the National 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-81 

Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-668ee). In sharp contrast to 

the organic legislation of other Federal land management systems (e.g., National Forests 

administered by the U.S. Forest Service and Public Lands administered by the U.S. Bureau of Land 

Management), legislation pertaining to the NWR System states that it is not a multiple-use 

management system and is not managed for commodity production or on the basis of sustained-yield 

economic principles. Refuges are managed first and foremost for fish, wildlife, plants, and their 

habitats (Section 5, House Report 105-106). This is often referred to as the “Wildlife First” 

management mandate. 

The Improvement Act also established a three-tiered hierarchy for management activities that occur 

on Refuge System lands. The first tier involves management actions that specifically assist the 

Refuge in fulfilling the purpose for which it was established (e.g., for migratory birds and other 

wildlife) and the Refuge System mission, including the conservation, management, and restoration of 

fish, wildlife, plants, and their habitats. The second and third tiers involve wildlife-dependent public 

uses (i.e., hunting, fishing, wildlife observation and photography, and environmental education and 

interpretation) and general public uses. 

Management tools (such as grazing, haying, pest management, or burning) that help refuges achieve 

established refuge purposes become first-tier management priorities, when properly authorized 

through signed management plans and CDs. When management tools such as grazing and haying are 

not specifically used on a refuge to help achieve established refuge purposes, then these activities fall 

into the third, lowest priority tier. 

Compatibility: All uses on National Wildlife Refuges must be deemed “compatible.” A compatible 

use is one that in the “ ... sound professional judgment [of the Refuge Manager], will not materially 

interfere with or detract from the fulfillment of the mission of the System or the purposes of the 

Refuge” (603 FW 2.6 B). Among other things, a CD involves evaluation of a proposed use’s effects 

upon refuge fish, wildlife, plants, and their habitats; potential conflicts with other refuge uses, 

especially wildlife-dependent public uses; indirect, future, and cumulative effects; precedent-setting 

implications; maintenance and monitoring costs; and off-refuge opportunities to exercise the use in 

question. 

Regulations: There are specific USFWS regulations that address economic uses of refuges. In 50 

CFR 29.1, it is stated, in part, that “ ... we may only authorize public or private economic use of the 

natural resources of any national wildlife refuge, in accordance with 16 U.S.C. 715s, where we 

determine that the use contributes to the achievement of the national wildlife refuge purposes or the 

National Wildlife Refuge System mission.” This regulatory standard is in addition to the 

compatibility requirement. Grazing livestock and harvesting hay are listed in the regulations as 

example uses to which this provision applies. 

Use Details

Habitats Subject to These Tools: The primary habitat types where grazing and haying will be used 

are wet meadows (meadow habitats with standing surface water during the growing season), and reed 

canarygrass areas (an undesirable exotic wet meadow grass that has spread to dominate some Refuge 

fields). Livestock grazing may also be used when necessary to maintain or restore2

 other habitat 

 

2

 The term “restoration” is used generally in this document to specify an alteration of plant community dynamics 

such as plant species diversity, composition, etc., in order to meet wildlife habitat needs. It does not necessarily 

mean a return to conditions that may have existed at a certain time in history. Because many communities are novel 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-82 Appendix B. Compatibility Determinations 

types (e.g., to transition undesirable plant communities to more native species and improve future 

habitat conditions).3

 

Area Treated Annually: As a starting point of implementing the CCP, approximately 12,000 to 

15,000 acres across the Refuge’s 20,000 to 25,000 acres of wet meadow habitat type (see Appendix 

K) will be treated in initial calendar years. Actual treatment levels will vary on a field-to-field basis 

depending on area-specific objectives of focal species. For example, higher levels of treatment will 

typically occur to provide conditions most favorable for sandhill crane foraging and bobolink nesting 

(e.g., southern Blitzen Valley) and idle conditions will dominate where use of grass meadows for 

waterfowl nesting is emphasized (e.g., north of Warbler Pond in the Double-O Unit). Application of 

these treatments may be adjusted as more information is gleaned through inventory and monitoring 

activities and analyzed by Refuge staff, the Ecology Work Group, and other collaborators (Appendix 

I). 

Habitats that will not be Subject to Grazing/Haying and/or Will be Protected from 

Grazing/Haying: Objectives developed for cold and hot spring, dune, playa, riparian shrub, riverine 

and associated riparian zone, sagebrush lowland, sagebrush-steppe, and salt desert scrub habitat types 

do not include strategies recommending the use of haying and/or grazing as a part of land 

management within the CCP. The exception to this could be when a shift in community attributes is 

desired within a specific area of a particular habitat to meet overall wildlife objectives. One example 

may be the use of early growing season livestock grazing as a tool to reduce reproduction and 

influence the soil seed bank of cheatgrass before conducting a seeding effort to enhance native plant 

diversity on-site.4

Overview of the Four Treatment Types 

Four treatment types will take place on the Refuge (i.e., rake-bunch grazing (RBG), grazing, haying, 

and mowing) during two pronounced periods (dormant versus growing season). Mowing is a pretreatment that occurs prior to both RBG and haying. 

a) Dormant Season Haying and Rake-bunch Grazing 

Desired Vegetation Condition: Dormant season hay only (HO) grazing and RBG will be used to 

meet desired characteristics of wet meadows across the Refuge as specified in Objective 4a (see 

Chapter 2), with grass/sedge/rush stubble heights of less than 6 inches by October 1. Haying and 

RBG treatments during this time also play a vital role in maintaining site vigor by preventing 

excessive litter accumulation from hindering plant species diversity and expression (Foster and Gross 

1998; Xiong et al. 2003). Plant species composition and the response of those species to site-specific 

conditions that may change annually due to climate or refuge management have a significant 

influence on biomass production and subsequent litter production. Spatial RBG and HO treatments 

will be adjusted on an annual basis to account for these dynamics according to information gleaned 

from inventory and monitoring efforts. 

 

(i.e., made up of either native and non-native species or native species outside historical spatial distributions), a 

return to such a state may not be preferable to the Service or the Pacific Flyway because such a shift may 

compromise the regional availability of suitable wetlands for waterfowl, waterbirds, etc. 

3

 See Appendix K for further discussion on the decision-making process for habitat manipulation within the CCP. 

4

 Interested public are encouraged to provide input and participate in discussions with the Ecology Work Group. 

Semi-annual meetings discussing habitat management and associated inventory, monitoring, and research are open 

to the public (Appendix K). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-83 

Timing of Treatment: The majority of wet meadow habitats under the “dormant season” program 

will be mowed beginning August 10 when most meadow plant species are mature (quiescent) and 

preparing to enter into senescence (when aboveground biomass dies). From a wildlife standpoint, 

postponing mowing until this time reduces mortality rates of crane colts and other late-maturing 

species; mowing before this date is discouraged under the Greater Sandhill Crane Management Plan 

(Central Valley Population) (Pacific Flyway Council 1997). 

Mowing will be followed either by RBG or HO treatment. RBG is a form of treatment where 

meadow hay is mowed and raked into windrows, but left in place to be consumed by livestock during 

the late fall and winter. RBG will take place beginning September 1 and may continue through 

January 31. Refuge staff will annually direct permittees in the amount of rake-bunch feed to prepare 

and its location before or during the August haying season. No windrows remain under HO, as all 

mowed vegetation is baled and removed from the Refuge. 

Ancillary Equipment and Infrastructure Necessary for the Use: HO and RBG treatments require 

the use of equipment normally used for general haying activities (e.g., tractor, swather or rotary 

mower, rake) with the addition of balers for HO and specialized rakes for bunching windrows for 

RBG. All-terrain vehicles (ATVs) and horses are necessary for moving cattle efficiently across 

designated fields. RBG and experimental grazing treatments also require necessary infrastructure for 

livestock management, including permanent wells and associated stock tanks and 

permanent/temporary fences. Additional fencing requirements are expected to be minimal. Power 

lines are currently specifically associated with two wells in the northern Double-O Unit and two 

wells in Diamond Swamp. All other wells are serviced via generators or power lines serving outlying 

residences (e.g., Diamond, Frenchglen). 

b) Short-duration, High-intensity Experimental Dormant Season Grazing 

This treatment may take place in fields that would otherwise be rake-bunch grazed or mowed. In 

recent discussions with past refuge biologists5

 it was expressed that this may be useful in providing 

litter management necessary for species such as the bobolink while retaining some vertical structure. 

Timing and equipment used will be similar to RBG (except that no mowing equipment will be used). 

Any haying or grazing prior to these dates will be pursued under the growing season program. 

c) Growing Season Hay Only and Growing Season Grazing Treatments 

Desired Vegetative Condition: Growing season HO and the use of livestock in treating uncut 

vegetation (grazing) will be used to meet desired characteristics of wet meadows across the Refuge 

as specified in Objective 4a (see Chapter 2) by encouraging successional shifts in plant community 

composition where designated attributes (i.e., >75% cover of perennial grasses, rushes, and sedges; 

15-20% cover of forbs such as lupine, clover, and cinquefoils; <20% cover of reed canarygrass; <5% 

cover of noxious weeds) are not being met and maintaining desired habitat heterogeneity at larger 

spatial scales (e.g., conditioning reed canarygrass monocultures for fall migrating waterfowl or 

encouraging a compositional shift from a reed canarygrass association to that of aquatic sedge). 

Growing season HO will be used as needed in an effort to control/eradicate noxious weed 

populations in meadows that have exceeded designated site-specific thresholds based on plant 

community attributes and associated abiotic resources (e.g., soil type). HO will be effective in 

 

5

 This conversation took place during an organized Refuge management review involving current Refuge staff and 

the following former biologists: John Cornely, Gary Ivey, David Johnson, David Paullin, and Michael Rule. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-84 Appendix B. Compatibility Determinations 

preventing the maturation of viable weed seed (e.g., mid-June), thus reducing further enhancement of 

the soil seed bank in this instance. An example of this is the mowing of pepperweed in mid-June, 

prior to the production of viable seed.

Timing of Treatment: “Growing season” treatments will typically occur April through August, but 

may extend past the period of senescence depending on site-specific objectives. Manipulation of 

vegetation during the growing season can have negative effects on wildlife due to 

disturbance/displacement. Littlefield (1989) documented sandhill crane nest desertion and trampling 

with spring and summer grazing. Therefore, growing season treatments will be pursued when the 

need for a shift in vegetative community attributes or structural heterogeneity is necessary within a 

particular unit to meet overall long-term meadow habitat objectives. 

Ancillary Equipment and Infrastructure Necessary for the Use: Growing season grazing may use 

existing dormant season infrastructure, but will most commonly use electric fencing and/or other 

temporary fencing to control livestock movement. Temporary water will be provided as needed. 

Livestock Trailing

When the movement of livestock is necessary, routes will be carefully selected to prevent damage to 

cultural resources, sensitive soils, wildlife habitat availability and integrity, and plant community 

health. A description of prescribed livestock movement will be included within individual 

cooperative land management agreements (CLMAs) (see below). 

Corrals

Corrals facilitating livestock movement on- and off-Refuge (Diamond and Nine Mile) by Refuge 

permittees are also used by BLM permittees using neighboring BLM allotments. The existing 

cooperative agreement placing responsibility of all maintenance of related infrastructure on the BLM 

will be extended. 

Administration of the Use 

Cooperative Land Management Agreements: The two programs using haying and grazing (dormant 

season and growing season) will be treated separately and will differ in the types of agreements that 

are used. Both programs will use CLMAs as authorized under 50 CFR 29.2. These agreements will 

allow Refuge staff and permittees to effectively work together to meet habitat objectives (e.g., feeder 

ditch maintenance, noxious weed management). 

Dormant Season CLMAs: The CLMAs for dormant season treatments (i.e., haying and RBG) will 

be 5 years in duration,6

 will designate acreages of use, and will allow payment in the form of services 

(permittee labor and equipment or cost of contractor) or the financing of field management activities 

such as noxious weed control. The labor involved in installing and maintaining field fences 

(permanent or electric) is a condition of the permit and will not be deducted from the bill, although 

materials will be provided by the Refuge. A percentage of each invoice will go toward funding (1) 

noxious weed management and (2) a third-party entity that will be active in Refuge land management 

research, inventory, and monitoring. Designated acres will involve target habitats within field 

 

6

 The duration of dormant season CLMAs may be adjusted in subsequent agreement cycles on a case-by-case basis 

if it is demonstrated that the 5-year timeframe does not prove adequate (either too short or too long) in 

understanding plant community trends and the Refuge’s ability to respond appropriately to community dynamics. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-85 

management units (e.g., Oliver Springs Field) and CLMAs will designate necessary rotations if a 

complex of fields is included in the agreement. 

Existing permittees7

 will be provided an identified acreage in which vegetation management 

activities will take place. If objectives pertaining to individual units within this acreage are not being 

achieved as determined through the state-and-transition model (STM) process, adjustments will be 

made within the areas included in the agreements. 

The overall treatment of each CLMA land base will be analyzed annually by the Ecology Work 

Group, and appropriate changes to the CLMA agreement will be made at the end of the contract 

period. This provides opportunities each year to make changes based on habitat trends within the 

conditions expressed in the CLMA. If inventory, monitoring, and analysis reveal that the conditions 

of individual agreements are not sufficient for meeting or maintaining habitat objectives at the 

conclusion of the 5-year CLMA time frame, then the nature of the specific CLMAs may either be 

altered (e.g., replacing RBG with HO) upon renewal or the Refuge may choose not to renew them. 

This 5-year timeline recognizes the need to observe plant community trends in order to gain deeper 

understanding of treatment effects. Considerations involving operational changes within CLMAs 

may necessitate an alteration of this time frame. An example of operational considerations includes 

whether the physical management of individual CLMAs is consistent with habitat objectives (e.g., 

are non-target habitats being impacted?). Changes based on physical management can take place at 

any time during the life of the CLMA if problems are not able to be readily addressed within the 

conditions expressed in individual CLMAs. Permittees and interested public will have the 

opportunity to participate in semiannual Ecology Group reviews of the Inventory and Monitoring 

Program, thus enabling all interested parties to fully engage. 

Growing Season CLMAs: Growing season treatments (e.g., successional plant community 

management, creation of shifting mosaic of successional stages) will use annual CLMAs to 

maximize flexibility in response to changing needs as driven by research or specific management 

goals addressing particular management issues (e.g., encouraging one suite of plant species at the 

expense of another). Annual CLMAs will be applied in designated areas, will specify the objective 

vegetation condition, and will be subject to monitoring to evaluate the treatment prior to renewal. 

Exchange of services and other aspects of annual CLMAs are the same as those of 5-year CLMAs. 

Cooperators who are able to demonstrate flexibility in providing livestock and associated labor 

(intensive herding, etc.) to allow site-specific treatments on an annual basis will be sought for annual 

CLMAs. If unforeseen circumstances take place (e.g., weather-related phenomena), mid-year 

modifications to CLMAs may take place if the rationale is documented through the Ecology Work 

Group process. Further information regarding oversight of habitat responses related to CLMAs 

through the state-and-transition model and the Ecology Work Group is found in Appendix L. The 

costs of administering and managing the haying and grazing program under the CCP are detailed in 

Table B-16. 

 

7

 Permittees currently possessing annual haying and grazing Special Use Permits (SUPs) will be issued 5-year 

CLMAs upon implementation of the CCP. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-86 Appendix B. Compatibility Determinations 

Table B-16. Costs to Implement the Use 

Category and Itemization One-time Expenses($) Recurring Expenses ($/yr) 

Administrative support $0 $35,000 

Materials and equipment $0 $0 

Offsetting revenues/services $0 $170,000 

Total expenses for the complex $0 −($135,000) 

Ecology Work Group Role: As discussed in Chapter 2 of the Refuge’s CCP, regular assessment and 

modification will be made possible through the Malheur STM framework. This involves the 

development of site-specific management strategies (using a combination of tools) to meet vegetative 

objectives (such as desired structural and successional characteristics) as laid out in the STM. The 

Ecology Work Group, consisting of ecologists and wildlife biologists representing agencies, 

academia, and other ecologists, will assist the Service in the development of the model and will 

provide recommendations for annual modifications to the model and associated habitat management 

strategies based on continuous inventory and monitoring. The structure of this information gathering 

and land management decision process is designed to provide transparency in the Refuge’s decisionmaking process. 

Anticipated Impacts of the Uses 

Grazing/Haying Effects to Wildlife 

Table B-17 lists the wildlife species that depend on treated meadows for particular life history stages. 

Wet meadows can provide both nesting and foraging sites for avian species. Both are discussed 

below.

Spring Foraging Habitat During Migration: The primary reason for treating wet meadows is to 

improve foraging conditions, especially during the pairing season. Wet meadows receive high use by 

foraging birds in the spring when they are treated with grazing, haying, or burning. These treatments 

provide short-stubble habitat, which allows early warming of soil and water and early availability of 

new green sprouts and invertebrates for birds to eat in the spring. This short structure proves valuable 

as a foraging area for waterfowl, waterbirds, and shorebirds. Important species such as sandhill 

cranes, white-faced ibises, and many waterfowl focus their foraging on these areas. 

While much of the migrant waterfowl use occurs on the Refuge lakes, many migrant birds are 

attracted to the hayed and grazed meadows after they are flooded in the spring. Treated meadow 

vegetation (mowed, grazed, burned) provides high-protein browse and invertebrate foods for a large 

variety of birds and other wildlife during the early spring period, when high-protein foods are needed 

for egg-laying. Theoretically, treated meadow sites receive more solar radiation, resulting in early 

warming of soils and earlier availability of important invertebrates for food (Rule et al. 1990). These 

treated meadow sites on Malheur Refuge generally support high waterfowl and crane use during the 

early spring period. In particular, the Double-O Unit receives very high use in March and April by 

migrating snow geese, Ross’ geese, ducks, and sandhill cranes, and is very important to these species 

during dry years, because little feeding habitat is available elsewhere in the basin (David and Ivey 

1995). Therefore, Malheur Refuge plays a critical role in providing energy for migrating birds within 

the Pacific Flyway, and management of wet meadows by haying and grazing is a means of providing 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-87 

much needed energy for these birds to continue migration and replenish their nutritional reserves. 

Successful reproduction upon arriving at breeding grounds depends on the quality and quantity of 

food acquired at such stopovers (Davidson and Evans 1988; Ricklefs 1974). 

Nesting Habitat for Waterfowl and Waterbirds: Pairing and Pre-Nesting: A study of Malheur 

Refuge land use in relation to spring waterfowl pair use was initiated by Gary Ivey in 1988. Paired 

plots of different land use were established, and waterfowl were counted weekly during April and 

May using a four-wheeled motorcycle, which flushed nearly all birds within each transect; therefore, 

detectability was considered close to 100 percent for all land use types. One set of plots comparing 

RBG and idle management was established in 1990. A preliminary analysis of data from these two 

paired, 800-heactare plots showed duck numbers to be, on average, six times higher in April and two 

times higher in May on the grazed plot in comparison to the idle plot. Also, Canada goose counts 

were 17 times higher on the grazed plot versus the idle plot (Ivey, unpublished data). Duck pairs used 

wetlands that had been treated (burned, grazed, or mowed) earlier in the season than wetlands with 

idle vegetation, which showed increased pair use later in the season. Theoretically, treated areas 

receive more solar radiation, and therefore, frozen soils thaw much earlier than non-treated areas, 

resulting in earlier plant growth and earlier availability of invertebrate foods (Rule et al. 1990). The 

new plant growth and invertebrates are sources of protein, which is very important to breeding 

waterfowl and other birds for egg-laying, as described by Eldridge and Krapu (1988).

The past Refuge strategy has been to treat most of the wet meadow habitat with haying and/or winter 

livestock grazing to reduce the attractiveness of these habitats for nesting ducks, because early 

nesting species like mallards often nest in wet meadows before irrigation water is present and many 

of their nests get flooded during irrigation and with flood events—as such, nests generally don’t float 

like they do in marsh vegetation. Often, mallards will select alternate overwater nesting sites and 

build floating nests in marsh vegetation. Most ducks, geese, and cranes select marsh sites for nesting 

within large, wet meadow areas of the Refuge (e.g., Units 11 and 12). Refuge studies of duck nest 

success have documented much higher success for ducks nesting over water in marsh plant 

communities than for ducks nesting in meadows or uplands (Malheur Refuge, unpublished data). 

Although some species focus primarily on nesting in meadow habitats (e.g., cinnamon teal, northern 

pintail, short-eared owl), treating the wet meadow sites encourages these species to nest in dry 

meadow (which are sub-irrigated), upland (e.g., sagebrush lowlands, salt desert scrub), or marsh 

habitats by managing wet meadows for low structure in early spring. 

Shorebird Nesting and Migratory Habitat: Shorebirds and other migratory species that depend on 

wetland stopovers in North America are being challenged by a rapidly changing landscape. For 

example, in the Great Plains of North America, 90 percent of the wetlands in some areas have been 

lost to agricultural development since the early 1900s (Ducks Unlimited 1994; U.S. Department of 

the Interior 1994). Furthermore, wetlands may be altered in the future by global warming (Houghton 

et al. 1990; Poiani and Johnson 1991). Such large-scale habitat changes raise concerns about 

maintaining an adequate network of stopover habitats in the future (Farmer and Parent 1996). 

Nine species of shorebirds regularly breed at Malheur Refuge, including snowy plovers, long-billed 

curlews, Wilson’s phalaropes, American avocets, and black-necked stilts, which are all priority 

species in the Intermountain West Regional Shorebird Plan (Oring et al. 2000). Estimates of breeding 

populations of common species in the Harney Basin from 1975 to 1978 are provided by Horton et al. 

(1983). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-88 Appendix B. Compatibility Determinations 

The short structure of treated meadows is attractive to nesting shorebirds such as Wilson’s snipe, 

Wilson’s phalarope, American avocet, and black-necked stilts, as well as some ground-nesting 

passerine birds such as bobolink and savannah sparrow. 

Most shorebird species select very short cover or barren sites for nesting (Eldridge 1992). Little 

information has been published on management of breeding shorebirds in the Intermountain West. 

However, a Malheur Refuge study of ground-nesting birds in the Double-O Unit found that in all 

cases, shorebirds used shorter and sparser vegetation than ducks, primarily nesting in 

bluegrass/creeping wildrye associations (Foster 1985). In these habitats, Foster found high densities 

of nesting shorebirds when they were livestock-grazed and high densities of nesting ducks when they 

were untreated; he recommended using livestock grazing or mowing to enhance attractiveness of that 

vegetation type to nesting shorebirds. Other authors have also identified that essential habitat for 

breeding shorebirds can be provided through grazing, mowing, or prescribed burning (Eldridge 1992; 

Helmers 1992). Therefore, to provide short cover needs in areas of the Refuge important for 

shorebird nesting (e.g., the north end of the Double-O Unit), wet meadow vegetation should be 

treated with livestock grazing, mowing, or burning after the breeding season (Ivey et al. in prep.). 

Greater Sandhill Cranes: Greater sandhill cranes are considered a “Sensitive Species” in Oregon 

and are also a “Strategy” species in the Oregon Conservation Strategy (ODFW 2006). These birds 

are members of the Central Valley Population and their management needs are addressed in a Pacific 

Flyway plan (Pacific Flyway Council 1997). They are also identified as a priority species in the 

Intermountain West Waterbird Conservation Plan (Ivey and Herziger 2006). Malheur Refuge 

supports a significant portion of Oregon’s population of breeding greater sandhill cranes, with over 

20 percent of the state’s pairs found there during surveys in 1999 (Ivey and Herziger 2000). 

Three essential ingredients for a crane nesting territory were outlined by Littlefield and Ryder 

(1968); a feeding meadow, nesting cover, and water. Territories averaged 43 acres at Malheur Refuge 

and contained irrigated meadow for feeding and flooded marsh cover for nesting. An ideal territory 

contains a shallow marsh with residual emergents in close proximity to foraging meadows (Littlefield 

and Ryder 1968). Feeding cranes have a preference for mowed meadow habitats when compared 

with unmowed (Littlefield 1975). 

Only 8 percent of the crane nests documented on the Refuge have been in meadow vegetation (Rule 

et al. 1990). The primary importance of meadows to cranes is for feeding and brooding young. Radio 

telemetry studies conducted on the Refuge showed that the wet meadow zone adjacent to uplands is a 

preferred area for crane chick brooding (Littlefield 1985). This preference is assumed to be 

associated with invertebrate abundance and availability. Generally, cranes are attracted to intensely 

treated meadows (mowed, burned, or rake-bunched grazed) for feeding during early spring. These 

intensive treatments remove ground cover, allowing solar radiation to warm the soil, causing earlier 

green-up of vegetation and earlier invertebrate availability (Epperson et al. 1999; Rule et al. 1990). 

Cranes initiate nesting when their territories are adequately flooded and the females have consumed 

enough protein to begin egg-laying. Cranes nest early in fields that are irrigated early and later in 

fields that are flooded late. Nest initiation is also affected by land use treatments because treatments 

that remove ground cover (burning, grazing, haying) result in earlier soil warm-up and availability of 

protein-rich invertebrate foods. Cranes nest earliest in burned areas, followed by mowed and grazed 

areas, and they nest latest in idle areas (Littlefield 2010, personal communication). A study was 

conducted at Ash Creek Wildlife Area in California, where habitat is similar to the Blitzen Valley’s 

(Epperson et al. 1999). That study compared bird use on hayed (previous summer) versus idle plots 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-89 

and documented significantly higher numbers of individuals and species of birds as well as 

significantly higher numbers of sandhill cranes on hayed plots during June and July. The study also 

reported that cranes in hayed plots spent significantly more time foraging and less time in vigilant 

behaviors as haying likely increased their ability to see approaching predators. They reported that 

because vegetation was less dense in the hayed plots, travel, foraging, and vigilance by cranes would 

be more efficient and the reduced litter and vegetation cover enhanced the ability of cranes to find 

and capture prey, supporting the idea that providing short-stubble habitat benefits cranes and other 

wildlife foraging. 

An evaluation of Refuge crane nest success from 1990 to 1998 revealed that success was lower the 

season following a burn, declined with nest initiation date, and was higher in deeper water sites. It 

also revealed that haying, livestock grazing, or predator control did not influence success during 

those years (Ivey and Dugger 2008). The study found no evidence for haying, grazing, or idle 

treatment effects on crane nest success, which is similar to the findings of a study at Grays Lake 

National Wildlife Refuge in Idaho (Austin et al. 2002). The significance of higher nest success for 

early nests suggests that providing early water and ideal foraging habitats (treated meadows) can 

encourage early nesting, leading to increased success. Also, haying and grazing of wet meadows can 

encourage cranes to nest in the deeper marsh sites, where success is higher. 

Bobolink Habitat: Bobolinks are identified as a focal species in the Partners in Flight conservation 

plan for eastern Oregon and Washington (Altman and Holmes 2000), and Malheur Refuge supports 

the largest local breeding population of bobolinks in the western United States. Bobolinks are a wet 

meadow–dependent landbird species and tend to nest in shorter vegetation types. 

Malheur Refuge bobolink populations were monitored annually from 1984 to 1998 (Malheur Refuge, 

unpublished data). A preliminary review of the data indicates that bobolinks select treated wet 

meadows in suitable areas of the Refuge with a high composition of forbs such as cinquefoils and 

clovers. Such fields that were placed in idle status were abandoned by bobolinks, and the data 

suggest that they respond positively to haying, grazing (dormant season), and burning treatments. 

Other studies support their preference for grazed or hayed areas. Johnson (1997) reported that if 

habitat is not maintained, use by bobolinks significantly declines, and that bobolink use peaked 1 to 3 

years after burns and began to decline about 5 years post-burn. Several authors report that bobolinks 

respond positively to burning or mowing treatments (Bollinger and Gavin 1992; Dechant et al. 2003; 

Herkert 1991, 1994; Johnson 1997; Madden 1996; Madden et al. 1999; Renfrew and Ribic 2001). A 

Saskatchewan study reported that bobolink abundance was higher in mowed tame hayland than in 

idle native grassland (Dale et al. 1997). Recommendations for bobolinks in the Great Plains provided 

by Dechant et al. (1999) include providing hayland areas and delaying mowing as much as possible. 

Therefore, managing Refuge wet meadow sites where habitat is suitable for bobolinks (based on past 

surveys) using haying, RBG, and burning is appropriate to provide breeding habitat for this species. 

Table B-17. Wildlife Species that Depend on Treated Meadows for Particular Life History 

Stages 

Wildlife Species Use of Treated Wet Meadow 

American avocet Nesting/foraging 

Black-necked stilt Nesting/foraging 

Bobolink Nesting/foraging 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-90 Appendix B. Compatibility Determinations 

Wildlife Species Use of Treated Wet Meadow 

Canada goose Foraging 

Mallard Foraging 

Sandhill crane Foraging 

Savannah sparrow Nesting 

White-faced ibis Foraging 

Wilson’s phalarope Nesting/foraging 

Wilson’s snipe Nesting/foraging 

Effects of Treatment Timing to Breeding Birds: Early mowing of vegetation has conflicted with 

production and maintenance objectives by destroying nests, killing incubating hens, killing young 

before fledging, and exposing nests and young to predators. Mowing could potentially impact any 

bird that nests or rears young in wet meadow habitats. Young cranes have the habit of lying still in 

meadow vegetation rather than moving away at the approach of a swather. Delaying Refuge haying 

dates until August 10 (as is practiced currently) will minimize mowing conflicts. 

Grazing livestock, haying, and mowing during the growing season may disturb/displace nesting 

activity for that year from a particular field unit, but at any one time will only impact a small 

percentage of the available wet meadow habitats available within the Refuge.8

 

Reed Canarygrass: Although this species actually occurs in plant communities within the wet 

meadow habitat type, it is significant enough to merit attention in this discussion. Large areas of 

robust reed canarygrass stands are essentially biological deserts in terms of wildlife use, as they 

quickly become too tall and rank and exclude most species. Currently about 6,000 acres9

 of the 

Refuge wet meadow communities are dominated by such stands. Intensive treatments such as haying 

and grazing to keep the stubble height as short as possible will greatly improve wildlife use of these 

areas, and they should be treated annually until they are restored to more desirable and diverse 

communities. 

Effects from Fences and Infrastructure: Electrical lines are a direct mortality source for cranes and 

other wildlife. Power line strikes are a major mortality factor for larger birds such as cranes and 

trumpeter swans as well as many other birds. 

The Refuge has removed a vast majority of lines not associated with rural power distribution. Orange 

plastic spheres and reflective tags placed on some existing power lines where mortalities have 

occurred in the past have reduced collisions significantly. The stipulation below to bury the electric 

lines should mitigate somewhat against these hazards. 

Fencing can interfere with the movement of wildlife or create entanglements, leading to mortality or 

altered movements for birds and mammals (Christianson 2009). In a 1-year study in Colorado and 

Utah surveying 1,046 kilometers (km) of fences, Harrington and Conover (2010) measured ungulate 

 

8

 If a 500-acre wet meadow is used for habitat treatment within the growing season, this only accounts for 2 percent 

of this meadow habitat type being impacted. 

9

 Locations of reed canarygrass monocultures is being mapped during the 2011 field season as specific wet meadow 

plant communities are identified spatially. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-91 

mortality rates at 0.25 mortalities/km for the wire fences studied, with 0.08 mule deer mortalities/km, 

0.11 pronghorn mortalities/km, and 0.06 elk mortalities/km. Mortalities were highest in August, 

when fawns were weaned, and juveniles were eight times as likely as adults to suffer mortality. 

In past years, biologists have found several chicks killed from fence entanglement, as well as many 

deer and antelope, at Malheur Refuge (Ivey 2011). Avian fence collisions are most common in areas 

where fences cross marshes. However, the Refuge now uses smooth wire as the bottom wire on all 

fences, and this is placed at a standard height to minimize impacts to pronghorn antelope. 

Observations at the Refuge have confirmed that with these adaptations most pronghorn cross under 

the fences rather than through them. In addition, bird flight patterns have been considered when 

building fences, and many fence lines have been moved or removed to minimize the number of bird 

strikes. Therefore, though some fence impacts should be expected, overall, infrastructure effects from 

grazing will be relatively minor. 

Effects to Other Wildlife (small mammals, large mammals, fish, herps, inverts): There will be 

negative impacts to some small mammals, reptiles, and amphibians. Not only are these species 

subject to mortality from machinery, but the conversion of tall pasture grasses to mowed grasses 

results in habitat loss. However, at any one time, approximately 40 percent of the wet meadow 

habitat will be in an idle (untreated) condition, which allows for habitat use by species dependent on 

this condition. 

Disturbance Effects: The use of noise-producing equipment such as ATVs, tractors, swather or 

rotary mowers, rakes, and other potential equipment may cause localized disturbance to wildlife 

during the period of the equipment use. Oregon law restricts noise emissions from ATVs to 99 dB 

(OPRD 2011). In general, use of equipment will occur in the fall and thus occurs outside of the 

sensitive breeding period. In addition, most of the areas that will be accessed with equipment will be 

dry at this time of year, with reduced wildlife densities. 

Potential for Injury: Based on Malheur data, 75 percent of sandhill crane chicks are fledged by 

August 10. The remaining 25 percent unfledged chicks (typically five chicks per year) are vulnerable 

to haying mortality. Haying attracts coyotes and other predators, and unfledged chicks around hayed 

fields tend to be taken by predators (Ivey 2011). The stipulations outlined below should help reduce 

risk of mortality for the remaining chicks. 

Effects to Vegetation: Short-term and Long-term 

Wet Meadow Plant Community Composition: Wet meadows are ideally dominated by native grasses 

(e.g., American sloughgrass, spike bentgrass), sedges, rushes, and native forbs and are commonly 

found interspersed within marsh and upland complexes. On the Refuge, wet meadows are currently 

dominated by introduced pasture species such as smooth brome, meadow foxtail, orchardgrass, reed 

canarygrass, and various clovers. Because meadows hosting a larger percentage of grasses provide 

more tonnage and higher nutrition for livestock, forage species such as timothy and smooth brome 

were introduced (decades ago). Other species were either introduced to the area in contaminated hay 

grown in other areas (e.g., meadow foxtail) or were purposefully planted because native meadow 

plants were generally believed to be less resilient, productive, and responsive to intensive land 

management. As a result, the diversity of native plants in some of these areas has decreased 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-92 Appendix B. Compatibility Determinations 

substantially, and restoration is emphasized in land management objectives 4A, 4B, and 4D, which 

strive to improve the biological integrity of plant communities.10 

Differentiating between Riparian and Wet Meadow Habitats: The CCP distinguishes between 

riparian and wetland habitat management. As laid out in Goal 3 of Chapter 2, livestock grazing will 

not generally occur in areas designated “riparian” (e.g., streamside riparian zones and riparian 

woodlands). For this reason, issues such as stream bank integrity, willow propagation and 

enhancement, cattle distribution concerns relating to the inclusion of riparian areas in upland 

paddocks, and so on, are not addressed in this analysis. 

Wet meadows and woody riparian areas are managed for different wildlife objectives. The former 

provides habitat for pairing/nesting/foraging waterfowl, waterbirds, shorebirds, and so on, while the 

latter is managed for willow-dependent landbirds. The different habitat requirements of yellow 

warblers and bobolinks illustrate this point well. Yellow warblers require large, dense willow stands 

while bobolinks seek out large, open, treated meadows for nesting. Wet meadow and riparian habitat 

types do have much in common, however, and these commonalities (e.g., plant community 

composition, plant species response to defoliation) will be addressed below. 

How a plant community responds to defoliation is greatly affected by the compounding influences of 

its environment (e.g., climate) as well as the physiology of individual plant species and the influence 

this has on fitness at the individual plant and community levels. Unfortunately, as discussed earlier, 

many individual species have not been studied to an extent that would be helpful in truly 

comprehending how individuals and composite communities will respond to various management 

scenarios. 

It is also important to note that studies pertaining to rangelands, mixed-grass and tall-grass prairies, 

woodlands, and narrow riparian meadows may or may not be relevant to the habitats being 

considered at Malheur Refuge. Basic principles can and do apply to all the above-mentioned systems, 

but one must be careful how conclusions are drawn when premises are built on habitat types that are 

different than the Refuge’s wet meadows. A vast majority of the research that is cited below has 

taken place in riparian areas adjacent to streams or in small riparian meadows west of the Rocky 

Mountains or within laboratory environments. 

The Dominant Role of Hydrology in the Expression of Plant Communities: A driving factor that 

separates wet meadows from other habitat types often discussed in grazing-related literature is 

hydrology. An overview of existing literature indicates that water table characteristics (i.e., soil 

moisture availability) are the most important factors influencing the composition and distribution of 

plant species in mesic and wet meadows (e.g., Allen-Diaz 1991; Dwire et al. 2006; Henszey et al 

1991; Martin and Chambers 2001, 2002; Perata and Alpi 1993; Rumburg and Sawyer 1965; 

Stringham et al. 2001). Thus it is critical to consider the underlying influence of hydrology whenever 

plant community responses to livestock grazing are being considered. Ultimately, the net effect of 

any disturbance (e.g., flood irrigation, grazing) is often a function of its interaction with other 

disturbances. 

Considering the influence of anaerobic conditions on plant communities, Dwire et al. (2006) found 

that small changes in water-table depth could result in either a short-term shift in species dominance 

or the ultimate replacement or loss of certain species. Water sedge (Carex aquatilis) can readily 

 

10 The reader is referred to Chapter 2 of the Refuge CCP for further elaboration of these objectives. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-93 

transport oxygen through aerenchyma (Perata and Alpi 1993) and can persist in anaerobic conditions 

that would exclude other sedge species over time (Gomm 1979). Baltic rush (Juncus balticus) has a 

greater range of drought tolerance than many other rushes, and may not be as negatively impacted by 

long-term drying trends that would exclude other rush species. 

Unfortunately, with a few noted exceptions such as those found above, there is a considerable 

knowledge gap regarding a majority of individual species’ tolerance to water-table depth and 

associated anaerobic conditions. It is also difficult to categorize level of water tolerance by genus or 

other human-made classifications because of significant differences between species (e.g., aquatic 

versus Nebraska sedges). Many species have broad ecological amplitudes and do quite well in typical 

wetland settings as well as more “terrestrial” habitats (Tiner 1991). 

There is, however, enough existing data to begin addressing Refuge management strategies from a 

scientific basis. It has been observed that timing and duration of soil saturation during the growing 

season can determine the distribution and abundance of Nebraska sedge (Carex nebraskensis) and 

Kentucky bluegrass (Poa pratensis) in riparian meadows (Kluse and Allen-Diaz 2005; Martin and 

Chambers 2001). There is also a positive correlation between soil aeration and species abundance, 

and anaerobic conditions can negatively influence total plant cover and species diversity (Dwire et al. 

2006). Stem density of some wetland obligates may decrease without adequate soil aeration during 

the growing season (e.g., beaked sedge in Mornsjo 1969). Flooding depth and duration may 

negatively impact sedges and grasses, while allowing rush populations to expand (Gomm 1979; 

Rumburg and Sawyer 1965). Henszey et al. (1991) found that 7 to 10 cm (2-4 inches) of standing 

water during spring flooding, with a maximum water-table depth of −30 to −90 cm (−11 to −35 

inches), was enough to create a shift to a wetter meadow plant community and a decrease in the 

presence of tufted hairgrass (Deschampsia caespitosa). 

Water-table–driven thresholds are particularly difficult to determine, partially due to a general lack of 

species-specific data and the large degree of overlap that can occur among species (Dwire et al. 

2006). Summarizing existing data and knowledge about the physiology and response of specific plant 

species (i.e., presence or absence of aerenchyma) may assist in the creation of general water 

management guidelines. This could serve as a foundation for managing water-table depths at the 

peak of growing season according to requirements of dominant species within particular guilds. 

Because water table and topography play such a decisive role in determining the composition and 

dynamics of meadow and wetland habitats on the Refuge, the Ecology Work Group has already 

begun constructing the STM using hydrology as its foundation. Depending on the availability of 

water, one soil type may host either a hemi-marsh or a mesic meadow. The key to understanding the 

roles and impacts of haying and grazing during the life of the CCP is remaining mindful that these 

treatments interact strongly with site-specific hydrological regimes. 

How the Use of Grazing During the Growing Season can be Valuable in Meeting or Maintaining 

Wildlife Habitat Objectives: The concept of scale is critical in discussing the role livestock play in 

managing biodiversity within the Refuge’s wet meadow habitats. Taken as a whole, these meadows 

encompass a diverse assemblage of plant community types consisting primarily of novel 

communities.11 Within specific areas, however, a lack of species diversity is often problematic, 

 

11 Novel plant communities consist of species assemblages that did not naturally occur prior to the introduction of 

desirable and undesirable exotics. Many novel communities are able to function in a similar manner to native 

communities (e.g., promotion of soil stability, watershed function, distribution of nutrients and energy) and provide 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-94 Appendix B. Compatibility Determinations 

especially for wildlife such as the bobolink, which depends on a wide assortment of plant species to 

carry out their annual reproductive cycles (Wittenberger 1978, 1980). As discussed earlier, 

topography plays a significant role in determining depth to water table and provides a foundational 

template in guiding the potential expression of multiple grass, sedge, rush, and forb species. Within 

the wet meadow complex we discover the highest potential for diversity within mesic areas that are 

subirrigated for a majority of the growing season. Lower-lying areas are negatively predisposed to 

diversity due to extended anaerobic conditions and the limited number of species that are able to 

cope with an oxygen-limited environment. The following discussion is primarily mindful of mesic 

sites within this habitat type, although some points are relevant to sedge- and rush-dominated 

communities where introduced forage species such as reed canarygrass overtake desirable natives. 

When let loose to graze on actively growing vegetation, livestock are capable of inducing a series of 

biological and physiological modifications that can drive changes in function at the individual plant 

scale. Grazing can also alter the expression of plant populations, leading either to an increase or 

decrease of biomass production at the community or ecosystem scale (Dyer et al. 1993) or in the 

number of plant species that are expressed (Leege et al. 1981). Cattle effects on vegetation should 

always be examined at various scales, including (1) the effect upon continuous changes in resource 

allocation and the phenological/morphological/physiological12 responses and adaptations of 

individual plants; and (2) the effect upon plant community attributes such as plant species abundance, 

distribution, diversity, and overall habitat structure. These considerations should take place in a 

context that recognizes the influence of local hydrological dynamics and prevailing soil properties 

(e.g., depth to restrictive layer, pH, texture). Such an approach will allow Refuge staff and partners 

such as the Ecology Work Group to establish management strategies that are likely to succeed in 

attaining or maintaining desired conditions. 

It is important to remain mindful that overarching conclusions are difficult to apply across the 

landscape because herbivory affects the same species differently across various sites and any 

generalizations would require an attempt to replicate responses in different areas (Belsky 1992). 

Kauffman et al. (1983) stressed the importance of recognizing and differentiating between plant 

community types: “Because of the great community diversity and differing ecological tolerances of 

riparian plant communities, a management practice that may be beneficial for one community may 

not be beneficial to another community in the same area.” 

Physiological Responses of Vegetation to Grazing During the Growing Season: Research 

conducted on numerous forage grasses has demonstrated that herbivory has an immediate effect on 

the functionality of individual plants during the growing season. A temporary cessation of root 

elongation (Crider 1955) and decreases in root respiration and nutrient acquisition (Davidson and 

Milthorpe 1966) can occur within 24 hours. Crider (1955) noted that there was a relationship 

between the percentage of foliage removed and the percentage of roots that ceased growing for a 

time. Richards (1984) concluded that a “reduction of root growth following defoliation appears to be 

an effective mechanism to aid reestablishment of the photosynthetic canopy and the root:shoot 

balance.” Briske and Richards (1995) believed that such alterations and reductions are an important 

adaptation to chronic defoliation and associated reduced entire-plant photosynthetic rates. The 

findings of Kauffman et al. (2004) illustrate this overall concept well. They examined the overall 

 

satisfactory habitat for wildlife. Others become monotypic over time and become less diverse than site potential 

would otherwise merit. 

12 Physiology refers to how a plant functions at various levels (e.g., growth rate, hormone production). Phenology 

examines the relationship between a plant’s growth and reproductive cycle in response to environmental conditions. 

Morphology considers the various forms and structural components of plants. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-95 

impact of belowground root biomass in response to herbivory and found that although there was no 

difference between plots in the distribution of root biomass by depth, root biomass was consistently 

higher in volume in non-grazed sites. Similar research conducted on aquatic sedge in a tundra setting 

yielded different results, finding that two or more defoliation events were required before root growth 

was reduced. Respiration and nutrient absorption rates were either maintained or increased for this 

species in relatively infertile conditions (Chapin and Slack 1979). 

The complex relationship between physiological responses to defoliation and the overlying influence 

of temporal and spatial scales give testimony to the nonlinear nature of these interactions. In 

addressing the nonlinearity of these responses, Dyer et al. (1993) noted that metabolic activity and 

growth and development rates initially increase directly following a defoliation event until a 

maximum level of all three characteristics is attained. Once this level is reached, production potential 

decreases with sustained or increased levels of grazing (see also De Angelis 1992; Dyer et al. 1986; 

Dyer et al. 1991). Competitive interactions between species could be influenced by the level at which 

individual species would plateau in this way. These findings suggest that the desirable timing, 

duration, and location of prescribed grazing will differ dramatically based on the treatment’s effect 

on the competitive abilities of desirable and undesirable plant species. 

Considering Plant Morphology: Belsky (1992) confirmed the importance of plant morphological 

expression in determining the influence of grazing upon plant competition in a diversity of Tanzania 

grasslands. She noted that tall perennial species increased and short perennial species decreased 

when grazing was removed from her plots. Across all plots, cessation of grazing led to an increase in 

species dominance and a decrease in species diversity. She concluded that short, sexually 

reproducing species were overtopped and crowded out by tall, vegetatively reproducing species. 

When grazing effects were examined, she found that the reverse was true. 

This research is consistent with the general understanding that has been developed regarding plant 

morphological relationships with defoliation as related to tillering rates, shoot length (and associated 

meristematic tissues),13 and the presence or absence of asexual reproduction (rhizomes and stolons). 

Considering such holistic relationships, Belsky concluded that herbivory response is different when 

one plant is affected versus multiple plants and that intraspecific and interspecific competition are 

critical components of the outcome of these interactions. 

Responses of Plant Communities to Grazing: Research has demonstrated that grazing may 

encourage competition by reducing enough biomass (cover and density of prevailing vegetation) to 

release available resources (Briske 1991; Damhoureyeh and Hartnett 1997; Kluse and Allen-Diaz 

2005) or may be able to maintain current levels of competition by favoring the growth of 

disturbance-adapted species (Chesson and Huntly 1997). Shifting the intensity and duration of 

grazing has also been demonstrated to alter species composition, distribution, and productivity 

(Crawley 1987). 

Plants compete for resources both spatially and temporally. The phenology of some species, such as 

Nevada bluegrass, will allow them to compete more readily early in the growing season while other 

species have not yet emerged from dormancy. Others, such as smooth brome, have the ability to 

readily respond to autumn moisture when neighboring species have already entered quiescence. In 

this same manner, plant species have been observed to respond differently physiologically to 

 

13 Meristematic tissue simply refers to groups of cells that are densely packed and able to divide, thus providing the 

growth and elongation of plant parts (e.g., leaves). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-96 Appendix B. Compatibility Determinations 

herbivory. Those species that are able to reallocate resources quickly, have developed mechanisms to 

protect meristematic tissue, or have reduced the overall likelihood of being defoliated will have a 

competitive advantage over their neighbors. Differences in the response to herbivory not only occur 

among various plant species, but among various genotypes of the same species as well. 

In addition, cattle and other livestock are not indiscriminate in their grazing behaviors. Therefore 

their presence can influence plant community composition by providing a competitive edge to 

untargeted plants. The individual plants cattle will likely prefer include those lowest in structural 

carbohydrates and providing the highest, most available amount of nutrients such as nitrogen for the 

production of protein via rumen microorganisms. 

Leege et al. (1981) addressed the impact of grazing versus rest on mountain meadow sites that had 

either experienced or were protected from heavy grazing for over 10 years. They observed that 

redtop, rushes, timothy, dandelion, and clover increased and sedges and aster decreased in grazed 

moist meadow communities. In wet meadows they discovered that redtop, tufted hairgrass, bulrush, 

timothy, and clover increased while sedges were more common in protected areas. Jackson and 

Allen-Diaz (2006) conducted a study on spring-fed wetlands in northern California (which more 

closely resemble conditions found on Refuge meadows), and found that herbaceous cover and 

diversity were maintained under light to moderate grazing regimes. Kauffman et al. (1983) 

discovered that lineleaf Indian lettuce (Montia linearis), various willowweeds (Epilobium spp.), and 

sedges were favored while meadow timothy, leafy-bract aster (Aster foliacens), and northwest 

cinquefoil decreased with a 3-year rest from grazing in eastern Oregon. These studies do not 

necessarily conflict with one another, but point out that species’ responses to grazing not only differ 

between type of use (heavy versus moderate being an extremely coarse description of use) and 

composition of plant species, but also across individual populations within a species. 

Prescriptions are easiest to meet when target vegetation is also the most preferred by livestock (e.g., 

reed canarygrass during spring green-up). Flexibility and continuous monitoring is required, 

however, to ensure that non-target vegetation is not impacted enough to compromise specific grazing 

objectives. This is important because the vegetation most preferred by livestock would likely shift 

during designated treatment windows. 

When considering the use of grazing in a specific area, first-hand knowledge of local cattle behavior 

and an awareness of studies conducted on comparable sites are very helpful. Most grazing research 

does not provide enough information to fully understand the overall role that livestock played in 

study results and how their impact may be replicated or avoided in other situations. 

The studies discussed above are helpful in understanding how grazing behavior and competitive 

interspecific relationships within different plant communities have influenced plant community 

characteristics over time. They also provide things to look out for or to be particularly cognizant of 

when creating treatment strategies in similar communities. They do not, however, provide a reliable 

mechanism for predicting vegetation response across the landscape. Use of the best science available, 

continuous inventory and monitoring associated with adaptive management, and management 

flexibility will provide the best results over time as methods and approaches are refined through sitespecific experience. 

Responses of Plant Communities to Dormant Season HO/RBG: Haying may be used in the pursuit 

of directional change (replacement of one community by another) when conducted within the 

growing season (e.g., cattail abatement in encroached wet meadows), but such a use is more 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-97 

appropriately placed alongside growing season treatments as discussed above. The overall concept of 

haying and RBG treatment is to provide non-directional management14 on wet meadow habitat. The 

purpose of this section is to evaluate the scientific literature to determine what impacts haying and 

RBG may have on plant communities as structural objectives (e.g., for migratory and shorebird 

habitat) are met. 

Traditionally, the haying of native meadows within the Harney Basin begins in early July when 

plants have reached maturity and before a decline in forage quality takes place. Over the last 20 

years, the Refuge adjusted its haying practices by delaying cutting until August 10 because collected 

data revealed that a much higher mortality rate of nesting and fledged birds takes place before then 

(Rule et al. 1990). Although a later haying date does decrease the value of forage harvested by 

cooperating permittees, this practice is consistent with meeting wildlife production objectives across 

the Refuge’s wet meadow areas. Because wildlife depend on specific habitat attributes in order to 

successfully propagate, it is important to consider vegetative impacts alongside reproductive 

chronologies. 

A review of available research generally supports the practice of delayed mowing as valuable in 

maintaining meadow diversity.15 Martin and Chambers (2001, 2002) concluded that biomass was not 

affected by clippings conducted in late July and that late season herbage removal had few effects on 

the vegetation because it had already begun to senesce. This is consistent with other studies such as 

Critchley et al. (2009), who noted that late cutting (associated with senescence) was most likely to 

aid in the reestablishment of target species–rich communities. 

Discussion of HO versus RBG: Both RBG and HO treatments can provide benefits to wildlife. HO 

can provide a higher level of control by working with permittees to treat only target areas, thus 

ensuring that non-target plant communities remain unimpacted. RBG targets mowed vegetation that 

offers nearly twice the level of crude protein for livestock than that which is left standing (Turner 

1987),16 thus ensuring that livestock will focus on treated acres as well. However, it is possible for 

fall rains to provide green-up that may attract livestock to non-mowed areas within the overall 

treatment boundary, thus causing unintentional grazing outside of the designated treatment area. 

Shifts in management from RBG to HO have already taken place across the Refuge in areas where 

this has commonly occurred to prevent the future occurrence of this. 

Even though RBG and HO are both used to meet the same meadow prescriptions, there are several 

reasons why the Refuge anticipates continuing to use RBG as a habitat management tool. First, the 

presence of noxious weeds on Refuge meadows is a considerable problem. HO involves the transport 

of hay and associated weed seeds from the Refuge to private lands. The more HO is used, the greater 

the spread of weeds such as perennial pepperweed will be across the county and beyond. Because all 

Refuge meadows host pepperweed and other problem plants at various levels of infestation, current 

weed control efforts primarily target existing HO fields in order to retard the spread of invasive 

plants onto other lands. (Priorities are necessary as it will cost over $1.5 million for initial treatment 

 

14 Non-directional management strives to maintain the long-term equilibrium of a site where changes in plant 

composition is temporary and reversible. 

15 Cited research does not, however, directly address the Refuge’s practice of coinciding prolonged irrigation with 

delayed mowing. 

16 Turner (1987) found that the average crude protein content of rake-bunch versus standing crop was 7.5 percent 

and 4.3 percent, respectively, over a 3-year period within the Harney Basin. Because pregnant, mature cows require 

approximately 8 percent crude protein to maintain condition, they will seek available forage that is highest in 

nutritional value. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-98 Appendix B. Compatibility Determinations 

of all impacted areas on the Refuge). Herbicides in current use are restricted from use along 

waterways, which prevents full resolution of the problem. In addition, the soil seed bank will likely 

require this level of treatment to continue indefinitely. The spread of weeds to private lands is less of 

a concern when livestock are grazed directly on the Refuge using RBG, because livestock can be 

quarantined when leaving the Refuge, thus preventing additional expansion of noxious weeds across 

land management boundaries. 

Second, many fields require the mowing of vegetation such as cattail and common reed to prevent or 

halt the encroachment of emergent marsh vegetation into the wet meadows. Emergent vegetation is 

generally not palatable to livestock. Nonetheless, HO permittees are required to pay for the tonnage 

that is hauled off the Refuge, and they are required to bale what is cut in order to achieve litter 

management objectives for wildlife species the following season. When mowing is conducted in 

association with RBG, piles are spread out by livestock as they seek nutritious, digestible feed. Any 

remaining emergent plant litter then becomes disseminated by cattle, which assists in its breakdown 

prior to the following spring growing season, ultimately promoting the vigor of desirable meadow 

species.17 

If piled RBG-treated vegetation remains on the field at the start of the next growing season, it is 

possible for sandhill cranes and other birds to contract a potentially lethal fungal infection called 

Aspergillosis. This can occur either under natural conditions or when piled vegetation becomes wet 

and moldy. Adequate use of vegetation by livestock in RBG-treated meadows has been successful at 

preventing avian mortality. 

Effects to Soils 

Soils play a critical role in the management of wildlife habitat because they provide the substrate by 

which plant communities express themselves. Consideration of soil resources is not only important 

for the production of vegetation, but also to meet water quality and geomorphic objectives as well. 

Concerns related to soil resources relative to the use of grazing and haying include the potential for 

increased erosion, compaction, and/or changes in fertility. 

Within the Refuge’s wet meadows, two soils dominate the areas targeted for haying or RBG. The 

Skidoosprings series consists of sandy loam within 11 inches of the soil surface, while the Fury series 

consists of silty-clay loam within the top 10 inches. More attention is merited for the Fury series 

because of its finer texture class. Typical of mollisols, however, this soil type is high in organic 

matter content and also hosts plant species that are high in root length density (RLD) (see discussion 

below) and biomass. Finer textured soils such as this across the Refuge where haying or grazing 

treatments are occurring will be prioritized in annual monitoring efforts. 

Erosion: The Refuge’s wet meadows are located on relatively flat topography within the Blitzen and 

Double-O valleys and are able to rapidly dissipate the energy of potentially destructive flood waters. 

Because they do not host stream channels and are not found on slopes, erosion caused by water is not 

a large concern. Impacts caused by wind erosion are also negated by the extensive fibrous root 

systems of vegetation found just below the surface of the soil within this habitat type. The potential 

for soil erosion is greatest along dikes, but most of these areas fall outside designated rake-bunch 

 

17 A third reason that may be argued is the impact repeated use of HO may have on meadow systems via nutrient 

mining. How long can a site remain productive if nutrients aren’t returned to the system from which they came? 

There is no research to back up this hypothesis, however, although soil testing may be conducted comparing HO and 

RBG fields to determine if this concern is merited. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-99 

areas and the exclusion of cattle from all canal systems is expected to be completed in the next few 

years. 

Livestock management and associated inventory and monitoring activities will seek to prevent the 

creation of bare soil in wet meadows by not impacting isolated areas to the point where vegetation is 

removed and large areas of bare soil are exposed (e.g., regular movement of mineral tubs, adequate 

graveling of the immediate area of stock tanks, routing tank overflows to nearby emergent stands). 

Compaction: The dominant concern regarding the relationship between soils and haying/grazing 

treatments is compaction. The way soils respond to the presence of machinery or livestock depends 

on the following prevailing factors: soil texture, on-site soil conditions (wet versus dry, frozen versus 

thawed), and plant community type (e.g., sedges versus bunchgrasses). 

Influence of Soil Texture: Fine-textured soils (clay, clay-loam, etc.) have high plasticity and 

cohesion properties. When they are disturbed under moist conditions, their aggregates are easily 

broken down. When this occurs, macropores within the soil profile can be greatly diminished. If the 

impact (i.e., compaction) is extensive enough the soil can become puddled.18 Because of this, issues 

regarding compaction and infiltration cannot be separated. Fortunately, there are mitigating factors 

that influence whether and to what extent such “restructuring” takes place under moist conditions. 

Soils high in organic matter in the O and A horizons are much more stable than those that are not. 

Soil organic matter can consist either of detritus/humus or living vegetative root masses. In riparian 

studies, RLD has been found to greatly influence site stability. RLDs were found to be especially 

high in communities dominated by Nebraska sedge, Douglas sedge, and Baltic rush (Manning et al. 

1989). Although Manning et al. (1989) associated RLD with the control of erosion in riparian 

systems, a link can be made between community type and likely compaction issues within wet 

meadows. Warren et al. (1986) observed that degree of compaction was at least partially influenced 

by relative sparseness of vegetation in upland sites.

Research conducted on moderately fine soils (silt loam/loam) subjected to season-long and deferred 

(rotating early/late summer use) grazing treatments found that bulk density (a measure of 

compaction) was significantly lower and infiltration rates were consistently higher in exclosed plots 

within both dry and wet meadow sites (Kauffman et al. 2004). Results from a Kentucky bluegrass 

community study stated that the amount of compaction varied according to soil texture and only 

impacted the upper 4 inches of the profile. Sites highest in silt and clay had significantly reduced 

pore space and higher bulk density on grazed areas (treated annually June 1 through October 31) than 

within exclosures. Where soil texture was more coarse (slightly less clay and more sand), only the 

first 2 inches displayed these properties (Orr 1960). 

Comparable observations were made by other studies examining the relationship of treatment 

duration/timing and various soils along a texture gradient. The conclusion of a study conducted on 

fine-textured soil hosting newly seeded alfalfa (Medicago sativa) and bromegrass (Bromus 

biebersteinii) revealed that increases in cattle stocking rates during the winter significantly increased 

soil bulk density (Stephensen and Veigel 1987). Plots within a blue grama (Bouteloua gracilis) and 

buffalograss (Buchloe dactyloides) site consisting of rough-textured soil revealed no significant 

differences between treatments,19 while bulk density significantly increased in fine-textured soils 

 

18 Puddling is a term used to express a state of relative impermeability of the soil to air and water. 

19 The grazing treatment took place from May 1 to October 31 for a period of 30 years. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-100 Appendix B. Compatibility Determinations 

(Van Haveren 1983). No compaction was found to occur on gravelly/sandy loam soils in a riparian 

area in northeastern Oregon (Bohn and Buckhouse 1985). 

Of particular interest is a study conducted by Wheeler et al. (2002) in a plant community that 

consisted primarily of Kentucky bluegrass, water sedge, beaked sedge, tufted hairgrass, and 

dandelion, similar in nature to the hydrologically driven plant community gradient found within the 

Refuge’s wet meadows. The study found that although bulk density increased at a depth of 5 to 15 

cm (2-6 inches) in grazed treatments occurring in early spring and late summer, the highly organic 

surface area (0-5 cm [0-2 inches]) did not experience compaction. Of additional interest in this study 

was the discovery that the bulk density and infiltration rate impacts observed at lower soil depth 

recovered within 1 year after grazing ceased, which was mainly attributed to frequent freeze–thaw 

events and high soil organic matter. Similarly, Stephensen and Veigel (1987) observed that recovery 

of impacted soils on their plots was nearing completion after two growing seasons following their 

full range of stocking intensities. 

Effects to Surface and Groundwater Resources

Under the CCP, cattle grazing will not be permitted in riparian or riverine habitats without sitespecific management prescriptions created with input provided by the Ecology Work Group. Such 

prescriptions will clearly state the rationale for livestock use as well as timing, stocking rate, and 

other thresholds used in meeting specific plant community attributes. A minimum buffer of 20 meters 

(65 feet) will protect river and creek channels from haying and grazing treatments. Water delivery 

canals will not fall under this buffer requirement with the exception of East Canal, which is managed 

as a fishery for redband trout. 

Surface Water: A study assessing the water quality impacts associated with Refuge water and habitat 

management (irrigation of hay and rake-bunch meadows, grazing, surface and subsurface return from 

wetlands and agricultural fields) was conducted in the mid-2000s (Mayer et al. 2007). The study 

investigated a variety of water quality parameters, including water temperature, conductivity, pH, 

dissolved oxygen, turbidity, nutrients, E. coli, and total coliform between April and September. 

Grazing has the potential to influence bacteria and nutrients in surface water. 

Bacteria: E. coli and total coliform samples were collected at numerous stations from Page Springs 

(southern boundary of the Refuge) to below Sodhouse Dam (near Malheur Lake). The state standard 

for E. coli is that the geometric mean of five samples collected over a 1-month period cannot exceed 

126 organisms per 100 mL and no single sample can exceed 406 organisms per 100 mL. 

Samples from Station 1 (Blitzen River below Page Springs Dam) were very low (geometric mean of 

1 organism/100 mL). Numbers increased slightly downstream at Station 10 (Blitzen River near Grain 

Camp Dam) and Station 12 (Blitzen River below Sodhouse Dam), but they were still quite low 

(geometric means of 10 organisms/100 mL or less). The highest numbers of E. coli were found at the 

confluence of McCoy Creek and the Blitzen River, but the numbers were still well below the 

standard (<50 organisms/100 mL). 

Nutrients: The study also examined nutrient loading for irrigated wet meadow areas. Based on the 

Westside P Ranch area examined in the study, the authors concluded that return flows from 

seasonally flooded wet meadow habitat contribute to phosphorus concentrations in the river, and 

possibly to nitrogen. However, the study authors did not identify cattle to be the source of this 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-101 

nutrient loading. It could be the wetting/drying cycle and/or the prevalence of thousands of 

defecating waterbirds and waterfowl associated with these wetlands. 

Groundwater: Stock tanks are used to supply livestock with water sufficient to meet their needs 

while on the Refuge. Water for the stock tanks comes from wells. Because stock tanks use a minimal 

amount of water drawn from wells with 2 hp pumps, groundwater levels will not be likely to be 

significantly impacted. 

Other Effects 

Loss of Habitat from Facility Construction: Under the CCP, no new facilities will be constructed 

for haying and grazing activities. 

Impacts to Priority Public Uses: Haying and grazing operations may occasionally conflict with the 

experiences of some Refuge visitors. However, such impact will be expected to be moderate to minor 

at the Refuge due to the seasonal differences in uses. Refuge visitation peaks during spring, when 

little grazing or haying will likely occur. Growing season mowing and grazing will not occur at a 

scale that will disrupt or significantly impact wildlife viewing opportunities enjoyed by Refuge 

visitors. During the fall when haying and RBG operations are active, wildlife observation and 

photography visitation falls off. Hunting use increases during this season but is concentrated in the 

Buena Vista Unit and around Malheur Lake, where little or no haying or grazing occurs. 

Impacts from Horses and ATVs: Livestock trailing will continue to occur on the Refuge. ATVs and 

horses are permissible for use in trailing activities and ATVs may be used in providing supplement 

tubs in RBG areas. The impacts of horses are considered in the Wildlife Observation, Photography, 

and Interpretation Compatibility Determination. 

Negative impacts will be avoided or minimized by considering specific routes, timing, and other 

factors on a case-by-case basis. 

Infrastructure: Regular, semiannual road maintenance activities cover the minimal disturbance that 

livestock trailing and equipment/hay hauling activities may cause. Livestock activities have not 

harmed, nor are they predicted to harm, public use trails on the Refuge. 

Use of Diamond and Nine Mile corrals impacts less than 2 acres of Refuge land. Therefore, impacts 

from this use are negligible. 

Public Review and Comment

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

 Stipulations Necessary to Ensure Compatibility 

General 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-102 Appendix B. Compatibility Determinations 

 Use shall be administered as described in the Description of Use above. 

 Neighboring habitat boundaries and large mosaics of upland areas (e.g., dry meadow, 

sagebrush lowland) found within wet meadow treatments will either be excluded by means of 

fencing or monitored annually to ensure that these areas are not negatively impacted by 

grazing treatments. Parameters for monitoring will include desirable attributes associated 

with pertinent habitat types. 

 Class 1 ATVs with Oregon permits will be allowed at Malheur Refuge in association with 

grazing and haying. Class 1 includes ATVs and three-wheelers, are vehicles 50 inches wide 

or less, have a dry weight of 800 pounds or less, have a saddle or seat, and travel on three or 

four tires (OPRD 2011). ATVs may only be used in trailing livestock along designated routes 

to prescribed treatment areas and when necessary to maintain herd health (e.g., feed 

supplementation) and maintain fence lines (e.g., stringing wire). ATV use is restricted to the 

fields subject to the use or the designated routes for trailing. ATVs must be weed-free upon 

entering the Refuge. 

 A pre-treatment inventory of local wildlife populations within the propsed warm season 

treatment area(s) will take place prior to the initiation of treatments. 

Grazing 

 Permittee has the responsibility to ensure that all fences are intact and gates closed before 

turning out livestock. 

Haying 

 All haying operations must be conducted from dawn to dusk only. 

 Hay cannot be fed out on the Refuge unless authorized by the Refuge Manager for the 

purpose of weed prevention. Quarantines will last no longer than 5 days. 

Justification 

The haying and grazing cooperative land management program contributes to achieving Refuge 

purposes and goals as identified in the CCP and the Refuge System mission by providing valuable 

foraging, resting, pairing, nesting, and brood-rearing areas and conditions for the sandhill crane, 

bobolink, cinnamon teal, and other meadow-dependent species. It also contributes by economically 

providing weed control and other habitat maintenance functions that are not feasible for limited 

Refuge staff to accomplish. Grazing and haying are desirable means of maintaining this type of 

habitat because its area is too large for annual prescribed burning and repeated mowing of the 

meadows is beyond the capability of the Refuge staff. Haying and Grazing could have adverse 

impacts including potential disturbance to wildlife, trampling of nests, water quality impacts and 

introduction of invasive species. In addition auxiliary components of the grazing program such as 

introduction of fence lines and use of ATVs can also have adverse impacts on wildlife. Although 

allowing haying and cattle grazing on the Refuge can result in the above described disturbances to 

wildlife, disturbance will be intermittent and short term, particularly since wildlife disturbance 

concerns are primarily associated with warm season treatments, which are experimental in nature 

when initiated. The efficacy of this strategy will be rigorously reviewed on an annual basis by the 

ecology working group to ensure that in fact ecological targets are being achieved, adverse impacts 

are being minimized, and that the most effective overall strategies are being employed. Because a 

majority of haying and grazing treatments that will take place occur late in the season when most 

birds are capable of avoiding disturbance (i.e., dormant season), the relatively limited number of 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-103 

individuals expected to be adversely affected will not cause wildlife populations to materially 

decline, the physiological condition and production of species will not be impaired, their behavior 

and normal activity patterns will not be altered dramatically, and their overall welfare will not be 

negatively impacted. The goal of both dormant and growing season treatments is to improve habitat 

for wildlife and rigorous annual review and revision by the ecology working group will help ensure 

that short-term tradeoffs are good investments for the birds. Thus Malheur National Wildlife Refuge 

CCP Appendix B Compatibility Determinations B-103 allowing haying and cattle grazing on the 

Refuge in conjunction with rigorous annual review and revision (as necessary) is found to be in 

support of and compatible with the purposes for establishment of the Refuge and the mission of the 

Refuge System. 

Mandatory Reevaluation Date 

 09/2022 Mandatory 10-year Reevaluation Date (for all uses other than priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Allen-Diaz, B.H. 1991. Water table and plant species relationships in Sierra Nevada meadows. 

American Midland Naturalist 126:30-43. 

Altman, B. and A.L. Holmes. 2000. Conservation strategy for landbirds in the Columbia Plateau of 

eastern Oregon and Washington. Prepared for Oregon and Washington Partners in Flight. 

American Bird Conservancy and Point Reyes Bird Observatory. Petaluma, CA. 

Austin, J.E., W.H. Pyle, J.R. Keough, and D.H. Johnson. 2002. Evaluation of management practices 

in wetland meadows at Grays Lake National Wildlife Refuge, Idaho, 1997-2000. U.S. 

Geological Survey, Northern Prairie Wildlife Research Center. Jamestown, ND. 

Belsky, A.J. 1992. Effects of grazing, competition, disturbance and fire on species composition and 

diversity in grassland communities. Journal of Vegetation Science 3:187-200. 

Bohn, C.C. and J.C. Buckhouse. 1985. Some responses of riparian soils to grazing management in 

northeastern Oregon. Journal of Range Management 38(4):378-381. 

Bollinger, E.K., and T.A. Gavin. 1992. Eastern bobolink populations: ecology and conservation in an 

agricultural landscape. Pages 497-506 in: J.M. Hagan, III, and D.W. Johnston, eds. Ecology 

and conservation of Neotropical migrant landbirds. Washington, D.C.: Smithsonian Institute 

Press. 

Briske, D.D. 1991. Developmental morphology and physiology of grasses. Pages 85-108 in: R.K. 

Heitshmidt, and J.W. Stuth, eds. Grazing management: an ecological perspective. Portland, 

OR: Timber Press. 

Briske, D.D. and J.H. Richards. 1995. Plant responses to defoliation: a physiological, morphological, 

and demographic evaluation. Pages 635-710 in: Wildland plants: physiological ecology and 

developmental morphology. D.J. Bedunah and R.E. Sosebee, eds. Denver, CO: Society for 

Range Management. 

Brooks, M.D.J. and M. Lusk. 2008. Fire management and invasive plants: a handbook. United States 

Fish and Wildlife Service. Arlington, VA. 27 pp. 

Chapin III, S.F. and M. Slack. 1979. Effect of defoliation upon root growth, phosphate absorption 

and respiration in nutrient-limited tundra graminoids. Oecologia 42:67-79. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-104 Appendix B. Compatibility Determinations 

Chesson, P. and N. Huntley. 1997. The roles of harsh and fluctuating conditions in the dynamics of 

ecological communities. American Naturalist 150:519-553. 

Christianson T. 2009. Fence marking to reduce greater sage-gouse (Centrocercus urophasianus) 

collisions and mortality near Farson, Wyoming – summary of interim results. Wyoming 

Game and Fish Department. 

Crawley, M.J. 1987. What makes a community invasible? Pages 429-453 in: A.J. Gray, M.J. 

Crawley, and P.J. Edwards, eds. Colonization, succession and stability. Oxford, UK: 

Blackwell Scientific. 

Crider, F.J. 1955. Root growth stoppage resulting from defoliation of grass. U.S. Department of 

Agriculture Technical Bulletin 1102:23. 

Critchley, C.N.R., J.A. Fowbert, and B. Wright. 2009. Dynamics of species-rich upland hay 

meadows over 15 years and their relation with agricultural management practices. Applied 

Vegetation Science 10(3):307-314.

Dale, B.C., P.A. Martin, and P.S. Taylor. 1997. Effects of hay management on grassland songbirds in 

Saskatchewan. Wildlife Society Bulletin 25:616-626. 

Damhoureyeh, C.M. and D.C. Hartnett. 1997. Effects of bison and cattle on the growth, reproduction, 

and abundances of five tallgrass prairie forbs. American Journal of Botany 84:1719-1728. 

David, J. and G. Ivey. 1995. Double-O habitat management plan, Malheur National Wildlife Refuge. 

U.S. Fish and Wildlife Service. Princeton, OR. 88 pp. 

Davidson, J.L. and F.L. Milthorpe. 1966. Leaf growth in Dacylis glomerata following defoliation. 

Annals of Botany 30(118):173-184. 

Davidson, N.C. and P.R. Evans. 1988. Prebreeding accumulation of fat and muscle protein by arcticbreeding shorebirds. Proceedings of the Nineteenth International Ornithological Congress, 

Ottawa 342-352. 

DeAngeles, D.L. 1992. Dynamics of nutrient cycling and food webs. London: Chapman and Hall. 

Dechant, J.A., M.L. Sondreal, D.H. Johnson, L.D. Igl, C.M. Goldade, A.L. Zimmerman, and B.R. 

Euliss. 1999 (Revised 2001). Effects of management practices on grassland birds: bobolink. 

Northern Prairie Research Center, Jamestown, ND. 24 pp. 

Dechant, J.A., M.L. Sondreal, D.H. Johnson, L.D. Igl, C.M. Goldade, M.P. Nenneman, and B.R. 

Euliss. 2003. Effects of management practices on grassland birds: short-eared owl. Northern 

Prairie Wildlife Research Center, Jamestown, ND. Available at: 

http://www.npwrc.usgs.gov/resource/literatr/grasbird/seow/seow.htm (Version 12 Dec 2003). 

Ducks Unlimited. 1994. Continental conservation plan: an analysis of North American waterfowl 

populations and a plan to guide conservation programs of Ducks Unlimited. Ducks 

Unlimited, Inc., Washington, D.C. 

Dwire, K.A., J.B. Kauffman, and J.E. Baham. 2006. Plant species distribution in relation to watertable depth and soil redox potential in montane riparian meadows. Wetlands 26(1):131-146. 

Dyer, M.I., C.L. Turner, and T.R. Seastedt. 1993. Herbivory and its consequences. Ecological 

Applications 3(1):10-16 

Dyer, M.I., M.A. Acra, G.M. Wang, D.C. Coleman, D.W. Freckman, S.J. McNaughton, and B.R. 

Strain. 1991. Source-sink relations in two Panicum coloratum ecotypes in response to 

herbivory. Ecology 72:1472-1483. 

Dyer, M.I., D.L. De Angelis, and W.M. Post. 1986. A model of herbivore feedback on plant 

productivity. Mathematical Biosciences 79:171-184. 

Eldridge, J. 1992. Management of habitat for breeding and migrating shorebirds in the Midwest. Fish 

and Wildlife Leaflet 13.2.14. 6 pp. 

Eldridge, J.L. and G.L. Krapu. 1988. The influence of diet quality on clutch size and laying pattern in 

mallards. The Auk 105:102-110. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-105 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

Epperson, W.L., J.M. Eadie, D.B. Marcum, E.L. Fitzhugh, and R.E. Delmas. 1999. Late season hay 

harvest provides habitat for marshland birds. California Agriculture 53:12-17. 

Farmer, A.H. and A.H Parent. 1996. Effects of the landscape on shorebird movements at spring 

migration stopovers. Condor 99:698-707. 

Foster, C.L. 1985. Habitat definition of nesting birds in the Double-O Unit, Malheur National 

Wildlife Refuge, OR. M.S. thesis. Humboldt State University, Arcata, CA. 111 pp. 

Foster, B.L. and K.L. Gross. 1998. Species richness in a successional grassland: effects of nitrogen 

enrichment and plant litter. Ecology 79(8):2593-2602. 

Gomm, F.B. 1979. Management alternatives for native meadows. Special Report 532, December. 

Agricultural Experiment Station, Oregon State University. Corvallis, OR. 

Harrington, J.L. and M. R. Conover. 2010. Characteristics of ungulate behavior and mortality 

associated with wire fences. Wildlife Society Bulletin 34:1295-1305. 

Helmers, D.L. 1992. Shorebird management manual. Western Hemisphere Shorebird Reserve 

Network. Manomet, MA. 58 pp. 

Henszey, R.J., Q.D. Skinner, and T.A. Wesche. 1991. Response of montane meadow vegetation after 

two years of streamflow augmentation. Regulated Rivers: Research and Management 6:29-

38. 

Herkert, J.R. 1991. An ecological study of the breeding birds of grassland habitats within Illinois. 

Ph.D. dissertation. University of Illinois, Urbana. 115 pp. 

Herkert, J.R. 1994. Breeding bird communities of midwestern prairie fragments: the effects of 

prescribed burning and habitat-area. Natural Areas Journal 14:128-135. 

Horton, S.K., C.D. Littlefield, D.G. Paullin, and R.E. Vorderstrasse. 1983. Migratory bird 

populations and habitat relationships in Malheur-Harney lakes basin, Oregon. Unpublished 

Report. U.S. Fish and Wildlife Service. Portland, OR. 

Houghton, J.T., G.J. Jenkins, J.J. Ephraums, eds. 1990. 1990 Intergovernmental panel on climate 

change. Cambridge, UK: Cambridge University Press. 

Ivey, Gary. 2011. Personal communication between Gary Ivey, Wildlife and Wetlands Consultant, 

and Refuge staff, U.S. Fish and Wildlife Service, August 2011. 

Ivey, G.L, C.F. Foster, and D.G. Paullin. in prep. Abundance and migration patterns of migrant 

shorebirds in the Harney Basin, Oregon. Unpublished report. 

Ivey, G.L. and B.E. Dugger. 2008. Factors influencing nest success of greater sandhill cranes at 

Malheur National Wildlife Refuge, Oregon. Waterbirds 31:52-61. 

Ivey, G.L. and C.P. Herziger. 2000. Distribution of greater sandhill crane pairs in Oregon, 

1999/2000. Oregon Department of Fish and Wildlife Nongame Technical Report #03-01-00. 

Salem, OR. 

Ivey, G.L. and C.P. Herziger. 2006. Intermountain west waterbird conservation plan, version 1.2. A 

plan associated with the Waterbird Conservation for the Americas Initiative. U.S. Fish and 

Wildlife Service Pacific Region, Portland, OR. Available at: 

http://www.fws.gov/birds/waterbirds/intermountainwest/MainTextV12nocover.pdf

Jackson, R.D. and B. Allen-Diaz. 2006. Spring-fed wetland and riparian plant communities respond 

differently to altered grazing intensity. Journal of Applied Ecology 43(3):485-498. 

Johnson, D.H. 1997. Effects of fire on bird populations in mixed-grass prairie. Pages 181-206 in: 

F.L. Knopf and F.B. Samson, eds. Ecology and conservation of Great Plains vertebrates. New 

York: Springer. Bozeman, MT: Mountain Prairie Information Node. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-106 Appendix B. Compatibility Determinations 

Kauffman, J.B., W.C. Krueger, and M. Vavra. 1983. Effects of late season cattle grazing on riparian 

plant communities. Journal of Range Management 36(6):685-691. 

Kauffman, J.B., A.S. Thorpe, and E.N.J. Brookshire. 2004. Livestock exclusion and belowground 

ecosystem responses in riparian meadows of Eastern Oregon. Ecological Applications 

14(6):1671-1679. 

Kluse, J.S. and B.H. Allen-Diaz. 2005. Importance of soil moisture and its interaction with 

competition and clipping for two montane meadow grasses. Plant Ecology 176:87-99. 

Leege, T.A., D.J. Herman, and B. Zamora. 1981. Effects of cattle grazing on mountain meadows in 

Idaho. Journal of Range Management 34(4):324-327. 

Littlefield, C.D. 1975. Greater sandhill crane management plan for Malheur National Wildlife 

Refuge, Harney County, Oregon. Station Library, Malheur National Wildlife Refuge. 42 pp. 

Littlefield, C.D. 1985. Radio-telemetry studies of juvenile greater sandhill cranes on Malheur 

National Wildlife Refuge, Oregon. Final Rep. Contract No. 10181-4594. U.S. Fish Wildlife 

Service, Malheur National Wildlife Refuge. Princeton, OR. 31 pp. 

Littlefield, C.D. 1989. Status of greater sandhill crane breeding populations in California, 1988. 

California Department of Fish and Game, Nongame Bird and Mammal Section Report. 

Sacramento, CA. 

Littlefield, C.D. 2010. Personal communication between Jess Wenick, Ecologist, Malheur Refuge, 

and Carroll D. Littlefield, the Bioresearch Ranch. 

Littlefield, C.D. and R.A. Ryder. 1968. Breeding biology of the greater sandhill crane on Malheur 

National Wildlife Refuge. Colorado State University. Fort Collins, CO. 19 pp. 

Madden, E.M. 1996. Passerine communities and bird-habitat relationships on prescribe-burned, 

mixed-grass prairie in North Dakota. M.S. thesis. Montana State University, Bozeman, MT. 

153 pp. 

Madden, E.M., A.J. Hansen, and R.K. Murphy. 1999. Influence of prescribed fire history on habitat 

and abundance of passerine birds in northern mixed-grass prairie. Canadian Field-Naturalist 

113:627-640. 

Manning, M.E., S.R. Swanson, T. Svejar, and J. Trent. 1989. Rooting characteristics of four 

intermountain meadow community types. Journal of Range Management 42(4):309-312. 

Martin, D.W. and J.C. Chambers. 2001. Effects of water table, clipping, and species interactions on 

Carex nebrascensis and Poa pratensis in riparian areas. Wetlands 21(3):422-430. 

Martin, D.W. and J.C. Chambers. 2002. Restoration of riparian meadows degraded by livestock 

grazing: above- and belowground responses. Plant Ecology 163:77-91. 

Mayer, T., R. Roy, T. Hallock, and K. Janssen. 2007. Hydrology and water quality at Malheur 

National Wildlife Refuge. U.S. Fish and Wildlife Service. Unpublished report on file at the 

Refuge office. 

Mornsjo T. 1969. Studies on vegetation and development of a peatland in Scania, south Sweden. 

Opera Botanica 24:187. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

ODFW. 2006. Oregon Conservation Strategy. Salem, OR. 

OPRD (Oregon Parks and Recreation Department). 2011. ATV permits. Available at: 

http://www.oregon.gov/OPRD/ATV/Permits.shtml. 

Oring, L.W, L. Neel, and K.E. Oring. 2000. Intermountain west regional shorebird plan. Available at: 

http://www.fws.gov/shorebirdplan/regionalshorebird/downloads/IMWEST4.pdf. 

Orr, H.W. 1960. Soil porosity and bulk density on grazed and protected Kentucky bluegrass range in 

the Black Hills. Society for Range Management 13(2):80-86. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-107 

Pacific Flyway Council. 1997. Pacific Flyway management plan for the central valley population of 

greater sandhill cranes. Pacific Flyway Study Committee. Portland, OR. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: a survey of historical localities, 2009. U.S. Geological 

Survey Open-File Report 2010-1235. LaGrande, OR. 96 pp. 

Perata, P. and A. Alpi. 1993. Plant responses to anaerobiosis. Plant Science 93:1-17. 

Poiani, K.A. and Johnson, W.C. 1991. Global warming and prairie wetlands: potential consequences 

for waterfowl habitat. BioScience 41:611-618. 

Renfrew, R.B. and C.A. Ribic. 2001. Grassland birds associated with agricultural riparian practices 

in southwestern Wisconsin. Journal of Range Management 54:566-552. 

Richards, J.H. 1984. Root growth response to defoliation in two Agropyron bunchgrasses: field 

observations with an improved periscope. Oecologia 64:21-25. 

Ricklefs, R.E. 1974. Energetics of reproduction in birds. Pages 152-297 in: R.A. Paynter, Jr., ed., 

Avian energetics. Cambridge, MA: Nuttall Ornithology Club No. 15. 

Rule, M., G. Ivey, D. Johnson, and D. Paullin. 1990. Blitzen Valley management plan. Malheur 

National Wildlife Refuge. Princeton, OR. 169 pp. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

Rumburg, C.B. and W.A. Sawyer. 1965. Response of wet-meadow vegetation to length and depth of 

surface water from wild-flood irrigation. Agronomy Journal 57:245-247. 

Stephenson, G.R. and A. Veigel. 1987. Recovery of compacted soil on pastures used for winter cattle 

feeding. Journal of Range Management 40(1):46-48. 

Stringham, T.S., W.C. Krueger, and D.R. Thomas. 2001. Application of non-equilibrium ecology to 

rangeland riparian zones. Journal of Range Management 54(3):210-217. 

Tiner, R.W. 1991. The concept of a hydrophyte for wetland identification. BioScience 41(4):236-

247. 

Turner, H.A. 1987. Utilizing rake-bunched hay for wintering mature cows. Oregon Agricultural 

Experiment Station Special Report 801:1-7. Corvallis, OR. 

U.S. Department of the Interior. 1994. The impact of Federal programs on wetlands, Vol. II. A 

report to the Congress by the Secretary of the Interior. U.S. Department of the Interior. 

Washington, D.C. 

Van Haveren, B.P. 1983. Soil bulk density as influenced by grazing intensity and soil type on a 

shortgrass prairie site. Journal of Range Management 36(5):586-588. 

Warren, S.D., T.L. Thurow, W.H. Blackburn, and N.E. Garza. 1986. The influence of livestock 

trampling under intensive rotation grazing on soil hydrologic characteristics. Journal of 

Range Management 39(6):491-495. 

Wheeler, M.A., M.J. Trlica, G.W. Frasier, and J.D. Reeder. 2002. Seasonal grazing affects soil 

physical properties of a montane riparian community. Journal of Range Management 

55(1):49-56. 

Wittenberger, J.F. 1978. The breeding biology of an isolated bobolink population in Oregon. Condor 

80:355-371. 

Wittenberger, J.F. 1980. Vegetation structure, food supply, and polygyny in bobolinks. Ecology 

61(1):140-150. 

Xiong, S., M.E. Johansson, F.M.R. Hughes, A. Hayes, K.S. Richards, and C. Nilsson. 2003. 

Interactive effects of soil moisture, vegetation canopy, plant litter, and seed addition on plant 

diversity in a wetland community. Journal of Ecology 91(6):976-986.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-108 Appendix B. Compatibility Determinations 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-109 

B.8 Plant Gathering of Culturally Important Plants Compatibility 

Determination 

RMIS Database Use: Plant Gathering 

Refuge Name: Malheur National Wildlife Refuge 

City/County and State: Princeton, Harney County, Oregon 

Establishing and Acquisition Authorities and Refuge Purposes: 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the [National Wildlife Refuge] System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C. 668dd-668ee]). 

Description of Use 

Malheur Refuge is the ancestral home of the Burns Paiute Tribe. Culturally important plants that 

grow in the wetlands, marshes, and riparian areas have been collected by members of the Tribe for 

generations. Culturally important plant collection involves taking hand cuttings from live plants (e.g., 

willow whips) or plants that have reached senescence (cattails and bulrush). Plant materials are 

collected in small amounts and plant mortality does not occur as a result of these activities. 

Collection typically occurs in areas closed to all public access. 

Culturally important plants collected on the Refuge are used by Tribal members in a non-commercial 

way to obtain materials used to perpetuate traditional weaving techniques, and as an educational 

opportunity used to introduce Tribal youth to an important aspect of their heritage. Tribal elders have 

been involved in the development of a native plant list that is consulted by Refuge staff when habitat 

restoration projects are being planned on the Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-110 Appendix B. Compatibility Determinations 

The occurrence of this activity is infrequent and is not expected to grow significantly in the near 

future. Tribal members prefer to collect plant materials on the Refuge because of their abundance, 

ease of access, and the absence of herbicide use. Selection of collection areas occurs in coordination 

with Refuge staff and typically occurs where access for elders is easy, where plants are abundant, 

where collection has occurred in the past and plants have responded positively (e.g., willow growth is 

enhanced by cutting), and where conflicts with wildlife will be minimal or absent. Collection 

typically occurs from late summer through the winter when plants are dormant and when fields and 

ponds are dry. 

The opportunity for Tribal members to collect culturally important plants on the Refuge has resulted 

in the development of a positive and collaborative relationship between the Burns Paiute Tribe and 

Malheur Refuge. Continuation of this culturally important opportunity will ensure that the 

relationship continues and matures in the future. 

Plant Materials: Plants typically collected include cattails (Typha spp.), bulrush (Scirpus spp.), 

sedges (Carex spp.), redosier dogwood (Cornus sericea), various willows (Salix spp.), milkweed 

(Asclepias spp.), and seepweed (Suaeda spp.). 

Availability of Resources 

Adequate Refuge personnel and base operational funds are available to manage this activity at 

existing and projected levels. Staff time (less than 1 day per year) primarily involves phone 

conversations, email correspondence, and preparation of SUPs. 

Anticipated Impacts of the Use 

Non-commercial collection of culturally important plants at current levels is not expected to incur 

more than negligible short-term or long-term impacts to natural resources. These will involve 

localized and temporary vegetation trampling and localized and temporary wildlife disturbance. Sites 

will be monitored by Refuge staff to ensure that plant gathering does not result in depletion of the 

harvested resource. Under these conditions, no long-term impacts will be expected. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). But it is unclear at this time if the 

Refuge population is part of the Great Basin distinct population, which is the Federal candidate 

species, or if they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

plant collecting will be negligible and will not be expected to increase disturbance to candidate 

species any more than non-commercial uses. Persons engaging in plant collecting will be required to 

apply for an SUP, and stipulations for reducing impacts to candidate species will be further covered 

by the permit. If uses result in unacceptable adverse effects to candidate species or habitats, the 

Refuge will impose restrictions to mitigate disturbance. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-111 

Impacts to Other Priority Public Uses: Persons collecting plants may occasionally flush wildlife 

from areas used by hunters, wildlife observers, photographers, anglers, or EE groups, but this conflict 

will be expected to be minimal. 

Public Review and Comment

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

 An SUP will be issued for the collection of culturally important plants by Burns Paiute Tribe 

members. The SUP will indicate the plant collection locations, dates of access, and quantity 

of materials that may be harvested. 

 Collection sites shall be monitored by Refuge staff to ensure that plant gathering does not 

result in depletion of the harvested resource. 

Justification 

Although collection of plants can result in vegetation modification and disturbance to wildlife, this 

activity will occur on a small percentage of Refuge acres. There is sufficient undisturbed habitat 

available to Refuge wildlife for escape and cover, and wildlife populations will find sufficient food 

resources and resting places. The relatively limited number of individual plants and animals expected 

to be adversely affected will not cause wildlife populations to materially decline, the physiological 

condition and production of Refuge species will not be impaired, their behavior and normal activity 

patterns will not be altered dramatically, and their overall welfare will not be negatively impacted. 

Thus, allowing this use to occur under the stipulations described above will not materially detract or 

interfere with the purposes for which the Refuge was established or the Refuge System’s mission. 

Issuance of an SUP eliminates the potential for overcollection of culturally important plants, 

guarantees that collectors have authorization to be in areas closed to public access, and ensures that 

Refuge staff are aware of collection activities. 

Mandatory Reevaluation Date 

 09/2022 Mandatory 10-year Reevaluation Date (for all uses other than priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-112 Appendix B. Compatibility Determinations 

References 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

Pacific Flyway Council. 1997. Pacific Flyway management plan for the Central Valley Population of 

Greater Sandhill Cranes, Pacific Flyway Study Committee. Unpublished report. Portland, OR 

44 pp. + appendices. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-113 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-114 Appendix B. Compatibility Determinations 

B.9 Research, Scientific Collecting, and Surveys Compatibility 

Determination 

RMIS Database Use: Research; Scientific Collecting; Surveys

Refuge Name: Malheur National Wildlife Refuge 

City/County and State: Princeton/Harney, Oregon 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act) 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of fish, wildlife, 

and plant resources and their habitats within the Unites States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 USC 668dd-668ee]). 

Description of Use 

Program: The Refuge allows research on a variety of biological, physical, archeological, and social 

issues and concerns to address Refuge management information needs or other issues not related to 

Refuge management. This CD refers to research, collecting, or surveys conducted by non-USFWS 

entities. This may include other Federal, state, tribal, and private entities, or their contractors. 

Location of Use: Research, scientific collecting, and surveys may occur at any location on the 

Refuge. Location will depend on the research objectives. 

The Refuge has numerous archaeological and paleontological sites. All research conducted on the 

Refuge must take this into consideration. All laws and Refuge policy associated with artifacts must 

be followed when gaining access to closed sites on the Refuge for research. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-115 

Associated Facilities and Access: Although no facilities at the Refuge will be maintained expressly 

for this use, the use may involve temporary use of some facilities. Research study sites, sampling 

locations, and transects shall be temporarily marked by highly visible wooden or metal posts, and/or 

flagging that must be removed when research ceases. 

Access to study sites shall be by foot, truck, all-terrain vehicle, boat, airboat, canoe, other approved 

watercraft, and aircraft. Vehicle use is allowed on Refuge roads normally open to the public. 

Researchers may not enter closed areas, unless specifically authorized access in the SUP. 

Administration of the Use: The use will be conducted on an as-needed basis, subject to SUP 

approval. Prior to initiating the project, research applicants must submit a proposal outlining: 1) 

objectives of the study; 2) justification for the study; 3) detailed methodology and schedule; 4) 

potential impacts on Refuge wildlife and/or habitat, including disturbance (short and long term), 

injury, or mortality; 5) potential impacts to wilderness natural areas; 6) personnel required; 7) costs 

to Refuge, if any; and 8) end products (i.e., reports, publications). 

Proposals will be reviewed by Refuge staff, the Regional Office Branch of Refuge Biology, and 

others as appropriate. Evaluation criteria will include, but not be limited to, the following: 1) research 

that will contribute to management will have higher priority than other requests; 2) research that will 

conflict with higher priority research, monitoring, or management programs may not be granted; 3) 

research projects that can be reasonably conducted off-Refuge are less likely to be approved; 4) 

research that causes undue disturbance or is intrusive will likely not be granted. Level and type of 

disturbance will be carefully weighed when evaluating a request. All requests will be carefully 

considered because some species are very sensitive to disturbance; 5) research evaluation will 

determine if any effort has been made to minimize disturbance through study design, including 

considering adjusting location, timing, scope, number of permittees, study methods, number of study 

sites, etc.; 6) if staffing or logistics make it impossible for the Refuge to monitor researcher activity 

in a sensitive area, this may be reason to deny the request; 7) the length of the project will be 

considered and agreed upon before approval. Projects will not be open-ended and will be reviewed 

annually at a minimum. 

If no conflicts to the Refuge’s mission are determined and an SUP is written, then the study will be 

conducted. At any time if the research is in violation of the terms and agreement of the SUP, the 

Refuge can terminate access. 

Number of Projects and Seasonal Patterns: The number of projects is expected to vary but based 

upon current experience, may range from 2 to 12 projects per year. Chapter 4 in the CCP describes 

the kinds of research projects that have occurred in the past. 

The season of use may be at any time of the year. This use will only be permitted when conflicts did 

not occur with natural resources. This will be detailed in the permit’s Special Conditions section. For 

example, Malheur Lake access with an airboat will not be granted to researchers if a disruption of 

breeding and nesting birds occurs. 

Availability of Resources 

Resources Involved in the Administration and Management of Use: Time will be required by office 

staff to prepare and issue SUPs. Designated research areas will need to be monitored by staff within 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-116 Appendix B. Compatibility Determinations 

the Biology, Visitor Services, or Archaeological programs and Refuge law enforcement to ensure 

permit conditions are met. 

Special Equipment, Facilities, or Improvements Necessary to Support the Use: The demand for 

Refuge equipment and facilities will be considered on a case-by-case basis depending on research 

study objectives. Arrangements will have to be made between the Refuge and researchers to 

determine if support is needed. If so, the researcher will have to provide grant money to cover costs 

or the Refuge will donate in-kind to the project. 

Maintenance Costs: Maintenance costs will be considered on a case-by-case basis depending on the 

research study objectives. The specific use will have to provide grant money to cover costs or the 

Refuge will donate in-kind to the project. 

Monitoring Costs: No monitoring costs will occur. The researchers will be responsible for 

monitoring. 

Offsetting Revenues: Because this usage aids the Refuge in understanding specific objectives and 

projects in addition to staff activities, research results provide the potential for overall cost savings 

for Refuge management activities. Since research represents a cost saving to the Refuge, there will be 

no fee for the issuance of permits. 

Anticipated Impact of the Use(s) 

Given the stipulations listed below, some short-term impacts can be expected, but no long-term or 

cumulative effects are anticipated because of the specifications in the SUP. 

Short-term Impacts: Research activities may disturb fish and wildlife and their aquatic and terrestrial 

habitats in the short term. For example, the presence of researchers can cause waterfowl to flush from 

resting and feeding areas, or cause disruption of birds in nests or breeding territories. Efforts to 

capture animals can cause disturbance or injury. To wildlife, the energy cost of disturbance may be 

appreciable in terms of disruption of feeding, displacement from preferred habitat, and the added 

energy expended to avoid disturbance. 

Sampling activities can cause compaction of soils and the trampling of vegetation, the establishment 

of temporary foot trails and boat trails through vegetation beds, disruption of aquatic sediments, and 

minor tree damage when tree climbers access bird nests. This may lead to avenues of predation and 

predator habituation. The removal of vegetation or sediments by core sampling methods can cause 

increased localized turbidity and disrupt non-target plants and animals. Installation of posts, 

equipment platforms, collection devices and other research equipment in open water may present a 

hazard to boaters if said items are not adequately marked and/or removed at appropriate times or 

upon completion of the project. Research efforts may also discover methods that result in a reduction 

in impacts described above. 

Adverse impacts of research will be minimized through stipulations described below. Vehicular 

access will be allowed only on roads and mowed dike tops, thus resulting in no net increase in 

vehicular impact. Access into any closed areas will only be permitted under terms specifically 

described in the SUP, thus avoiding and minimizing human disturbance to feeding and resting 

waterfowl. Researchers will also be required to observe public use regulations to avoid disturbance of 

fish and wildlife and provide areas of quiet and solitude sought by many users of the Refuge. Any 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-117 

research equipment that remains in the field for the duration of the project will be clearly marked to 

avoid potential hazards presented to other Refuge users.

Long-term Impacts: The long-term impacts of research may include injury or death to groups of 

wildlife or to individuals during efforts to capture samples. Continual disruption could cause 

expenditure of energy, decreased immunity to pathogens, nest abandonment, displacement in less 

than optimal habitat, and nest swamping from wave action. However, given the stipulations listed 

below, no or very minimal impacts will be expected in the long term. Research efforts may also 

discover methods that result in a reduction in impacts described above. 

Cumulative and Indirect/Secondary Impacts: Because continuous, long-term research will rarely be 

allowed at one site, long-term cumulative impacts such as poor water quality, benthic disturbances, 

wildlife disturbance, and/or vegetation trampling will be negligible. SUP conditions will include 

special conditions to ensure that impacts to wildlife and habitats are kept to a minimum and are short 

term. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). But it is unclear at this time if the 

Refuge population is part of the Great Basin distinct population, which is the Federal candidate 

species, or if they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

research will be negligible and will not be expected to increase disturbance to candidate species any 

more than non-commercial uses. Persons engaging in research will be required to apply for an SUP, 

and stipulations for reducing impacts to candidate species will be further covered by the permit. If 

uses result in unacceptable adverse effects to candidate species or habitats, the Refuge will impose 

restrictions to mitigate disturbance. 

Impacts to Priority Public Uses: Researchers may occasionally flush wildlife from areas used by 

hunters, wildlife observers, photographers, anglers, or EE groups, but this conflict will be expected to 

be minimal. 

Public Review and Comment 

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-118 Appendix B. Compatibility Determinations 

Stipulations Necessary to Ensure Compatibility 

This activity will only be allowed in designated areas and specific terms will be established in 

associated SUPs regarding designated research areas, permissible dates, conditions of research, offroad use of vehicles, and acceptable research procedures. Permit conditions are likely to change from 

project to project depending on study objectives. These conditions may include, but are not limited 

to, the following: 

 If the proposed research methods will impact or potentially impact Refuge resources (habitat 

or wildlife), it must be demonstrated that the research is essential (i.e., critical to survival of a 

species; critical habitat for a species; or assessment and/or restoration after cataclysmic 

events) and the researcher must identify the issues in advance of the impact. Highly intrusive 

or manipulative research is generally not permitted in order to protect our natural resource.

 Prior to conducting investigations, researchers will submit a written study proposal with their 

request to obtain an SUP from the Refuge that makes specific stipulations related to when, 

where, and how the research will be conducted (see Description Of Use section). Managers 

retain the option to prohibit research on the Refuge that does not contribute to the purposes of 

the Refuge or the mission of the Refuge System, or that causes undue resource disturbance or 

harm. 

 Approved research projects will be conducted under a Refuge-issued SUP, which will have 

additional project-specific stipulations. 

 Researchers must possess all applicable state and Federal permits for the capture and 

possession of protected species for conducting regulated activities in wetlands and for other 

regulated activities. 

 Research must adhere to current species protocols for data collection. 

 Researchers must clearly mark posts, equipment platforms, fencing material, and other 

equipment left unattended in open water so as to not pose a navigation hazard to boaters. 

Such items shall be removed from the river as soon as practicable upon completion of the 

research. 

 SUPs will be valid for 1 year only. Renewals will be subject to the Refuge Manager’s review 

of research data, status reports, compliance with the CD and permit stipulations, and permits. 

 Off-road access is only allowed when soils are frozen or dry in areas where native vegetation 

will not be impacted, within specific boundaries. 

 Research must be during hours when appropriate staff are available to monitor conduct and 

permit compliance. 

 Inspection and washing of research equipment to decrease the spread of invasive species is 

required. 

 Activities are allowed only where minimal impacts to wildlife may occur. 

 Periodic evaluation of research projects will be held to assess if objectives are being met and 

ensure that resources are not being degraded. 

 Regulations to ensure the safety of all participants must be followed. 

 Law enforcement patrols are conducted to ensure compliance with state and Refuge 

regulations. 

 The Refuge Manager can suspend/modify conditions/terminate on-Refuge research that is 

already permitted and in progress, should unacceptable impacts or issues arise or be noted. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-119 

Justification 

Research by third parties plays an integral role in Refuge management by providing information 

needed to manage the Refuge on a sound scientific basis. Investigations into the biological, physical, 

archeological, and social components of the Refuge provide a means to analyze management actions, 

impacts from internal and outside forces, and ongoing natural processes on the Refuge environment. 

Research provides scientific evidence as to whether the Refuge is functioning as intended when 

established by Congress. 

Although these activities can result in disturbance to wildlife, these activities will occur on a small 

percentage of Refuge acres. There is sufficient undisturbed habitat available to Refuge wildlife for 

escape and cover, and wildlife populations will find sufficient food resources and resting places. The 

relatively limited number of individual plants and animals expected to be adversely affected will not 

cause wildlife populations to materially decline, the physiological condition and production of 

Refuge species will not be impaired, their behavior and normal activity patterns will not be altered 

dramatically, and their overall welfare will not be negatively impacted. Thus, allowing research, 

scientific collecting, and survey activities to occur under the stipulations described above will not 

materially detract or interfere with the purposes for which the Refuge was established or the Refuge 

System’s mission. 

Mandatory Reevaluation Date 

 09/2022 Mandatory 10-year Reevaluation Date (for all uses other than priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-120 Appendix B. Compatibility Determinations 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-121 

B.10 Farming Compatibility Determination 

RMIS Database Use: Farming 

Refuge Name: Malheur National Wildlife Refuge 

City/County and State: Princeton/Harney, Oregon 

Establishing and Acquisition Authorities and Refuge Purposes 

 “ ... a Refuge and breeding ground for migratory birds and other wild life ... ” Executive 

Order 7106, dated July 19, 1935, as modified by Public Land Order 1511, dated September 

24, 1957 

 “ ... for use as an inviolate sanctuary, or for any other management purpose, for migratory 

birds.” 16 U.S.C. 715d (Migratory Bird Conservation Act) 

 “ ... for the development, advancement, management, conservation, and protection of fish 

and wildlife resources ... ” 16 U.S.C. 742f(a)(4) 

 “ ... for the benefit of the United States Fish and Wildlife Service, in performing its activities 

and services. Such acceptance may be subject to the terms of any restrictive or affirmative 

covenant, or condition of servitude ... ” 16 U.S.C. 742f(b)(1) (Fish and Wildlife Act of 1956) 

 “ ... conservation, management, and ... restoration of the fish, wildlife, and plant resources 

and their habitats ... for the benefit of present and future generations of Americans ... ” 16 

U.S.C. 668dd(a)(2) (National Wildlife Refuge System Administration Act)

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network of lands 

and waters for the conservation, management and, where appropriate, restoration of fish, wildlife, 

and plant resources and their habitats within the Unites States for the benefit of present and future 

generations of Americans” (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 USC 668dd-668ee]). 

Description of Use(s) 

Acres and Crops Grown: The cooperative program will include between 80 to 1,000 acres to support 

objectives described in the CCP using appropriate farming practices. Crops will include wheat, 

barley, rye, oats, or similar crops known to have wildlife forage value. Crops will generally be grown 

under non-irrigated or sub-irrigated conditions; however, in some years spring runoff and rainfall 

during the growing season are insufficient to produce a successful crop. 

Location of Use: The use will take place in areas deemed advantageous to target wildlife species per 

the goals and objectives listed in various Refuge plans. Initially, the farming program will focus on 

areas in the vicinity of Center Patrol Road near Refuge Headquarters north of Rattlesnake Butte. 

Timing of Use: Depending on the target crop, seed bed preparation and seeding will take place in 

late winter/early spring with associated soil amendments and herbicide being applied in spring and 

summer, respectively. Mowing will occur in the summer or early fall, depending on the crop. 

Harvesting of the crop will occur as soon as the crop has matured and ripened and before the fall 

hunting season. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-122 Appendix B. Compatibility Determinations 

Equipment, Facilities and Improvements: To support this use, standard crop farming equipment will 

be used such as tractors, plows, disks, seeders, trucks, wagons, spray rigs, and combines. The 

cooperator will not use any on-Refuge facilities for seed or harvested grain storage. Minimal access 

road improvements and maintenance will be needed for farming equipment ingress/egress. 

Administration of the Use: Cropland management will be carried out by private parties on Refuge 

lands under the terms of cooperative agreement. The agreement could take the form of either a 

Cooperative Farming Agreement (CFA) or a Cooperative Land Management Agreement (CLMA). 

Under either scenario, the farmer will receive an 80 percent share of the crop and the remaining 20 

percent is left in the field for wildlife. Under this scenario, approximately 950 acres of grain will be 

needed. The two types of cooperative agreements are described below: 

 CFA: Within such agreements, the cooperator will provide labor, equipment, and materials 

and the government will provide the land base unless other arrangements are made between 

the Refuge Manager and cooperator(s). The resulting crop will be shared by the cooperator 

and the government. 

 CLMA: The CLMA is an in-kind program, which means that both parties receive benefits 

from the land. In this case, the cooperator and Refuge both receive a portion of the crop, and 

the Service receives management actions that enhance habitat condition through activities 

such as weed control and prevention strategies incorporated into the program. 

The CLMA will be an annual agreement composed of: 1) objectives of the program; 2) 

commitment and responsibilities of each partner under the contract; 3) description and map 

of the area affected by the agreement; 4) details on the techniques, schedules, strategies, and 

methods to be used in the cooperative agreement; 5) crop or other products produced under 

the agreement; and 6) delineation of shares. The CLMA will be reviewed and updated 

annually. The CLMA will not express or describe any permanent or long-term agreement 

between the cooperator and the Refuge. 

The cooperator (farmer) will be selected based on his or her ability to: 1) adapt and meet the 

changing conditions of the program; 2) apply best land management practices to selected land tracts; 

3) use best management practices of an integrated pest management (IPM) plan; 4) meet the special 

conditions outline in the CLMA; 5) sustain an operation under potential impacts of wildlife 

depredation and changing habitat conditions; and 6) be economically capable of operating under the 

conditions of the program. 

Rationale for the Use: The purpose of developing a cooperative farming program is to manage highcarbohydrate autumn foraging habitat for sandhill cranes, waterfowl, and other migratory and 

resident wildlife species. The Refuge (together with cereal grains then grown on the Refuge) was 

identified as one of four autumn staging and migration stopover sites in the Greater Sandhill Crane 

(Central Valley Population) Pacific Flyway Plan (Pacific Flyway Council 1997). The plan noted that 

the Malheur fields had been used for several decades. Grain farming will support greater sandhill 

crane use during the fall staging period, when a large percentage of the Central Valley population 

uses the Refuge. The Pacific Flyway Management Plan (Pacific Flyway Council 1997) recommended 

up to 400 acres of cereal grain production at Malheur Refuge to provide for staging cranes. The plan 

also noted that autumn roosting habitat (large isolated wetlands, secure from human disturbance) 

should be maintained at Malheur Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-123 

This level was established with the assumption that grain farming will continue on the Refuge. 

Canada geese, dabbling ducks, and migratory grassland birds also benefit from grain farming since 

they use grain to build their fat reserves. Grain production also increases the Refuge’s carrying 

capacity for wintering Canada geese. 

An additional purpose of the program is to limit the presence of invasive species by providing a 

mechanical tool to set back infestations and develop a stage for the restoration of native plant 

communities. Farming cultivation practices such as mowing, haying, and chemical application have 

been recognized as viable means to control invasive plant species and discourage the proliferation of 

non-beneficial plants. 

Over the next several years the cropland farming program will be the main instrument for 

implementing Objective 4j in the CCP for Malheur Refuge. This action will support the goals and 

objectives outlined in the CCP for Malheur Refuge and the Pacific Flyway Council Management 

Plan for Sandhill Cranes (Pacific Flyway Council 1997). 

Availability of Resources 

Special equipment, facilities, or improvements necessary to support the use and maintenance costs 

are the responsibility of the cooperator with no associated expenses to the Refuge. 

Offsetting Revenues: Because this use aids the Refuge in specific wildlife and habitat objectives and 

frees up maintenance staff equipment, materials, and personnel for other projects, there is the 

potential for overall cost savings for Refuge management activities. Since cooperative farming could 

represent a cost saving to the Refuge, there will be no fee associated with the agreement. The costs of 

administering and managing this use under the CCP are detailed in Table B-18. 

Table B-18. Cost to Implement the Use 

Category and Itemization One-time 

 Cost 

Annual 

($/yr) 

Administration and management $2,000 $2,000 

Maintenance $0 $0 

Monitoring $1,000 $1,000 

Special equipment, facilities, or improvements $0 $0 

Offsetting revenues $0 $0 

Anticipated Impact of the Use 

Short-term Impacts: Farming activities in proposed areas are currently taking place by force account 

(conducted by Refuge staff), so the nature of the disturbance will not be significantly different. The 

activity may cause some degree of disturbance to wildlife, including negative impacts on fauna that 

are not able to emigrate off-site during soil-disturbing activities. Any hydrologic impacts will be 

minimal (water needs of the actual crops will be served primarily through sub-irrigation). Wind 

erosion will be marginalized by instituting best management practices such as crop residue 

management, eliminating or reducing fall cultivation practices. The sites already host significant 

invasive plant species and are currently being treated in cooperation with force account farming 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-124 Appendix B. Compatibility Determinations 

activities; thus, cultivation practices will have minimal impacts to native plant communities. With the 

size of the fields 50 acres or less, farming activities will have negligible effects to invertebrate, 

reptile, and amphibian populations and their movements. Disturbance to ground nesting birds should 

be minimal by delaying any mowing operations to after the nesting season. 

Sandhill cranes, Canada geese, dabbling ducks, and grassland passerines benefit from grain farming 

since they use grain to build their fat reserves. Grain production also increases the Refuge’s carrying 

capacity for wintering Canada geese. This activity provides for the early detection and treatment of 

invasive species, thereby creating a healthier environment for native plant communities. This is 

particularly important in areas targeted for native plant restoration. 

Long-term Impacts: Farming activities may deplete the soil seed bank of native species over time, 

but due to the fact that these areas currently contain high percentages of noxious weeds in existing 

seed banks, the negative impact is offset by an increased level of control of non-desirable vegetation 

over time. 

Cultivating annual crops may alter soil structure and wind erosion may occur. Whenever possible, 

cooperators will seek strategies to minimize this occurrence, such as timing and manner of tilling. 

The acreage being converted to farming is currently being farmed by force account and consists of 

0.01 percent of Refuge lands. Therefore, the impacts noted above are expected to be negligible. 

Because farming is already taking place on these acres, this practice will likely have a neutral impact 

within the structure of the program. 

Positive long-term benefits result in providing food/habitat for birds during critical migration period 

and minimizing crop depredation on neighboring lands. 

Cumulative Impacts: Farming will only be practiced on lands that have been previously farmed. The 

management direction is not expected to incrementally add to any other actions that are planned or 

currently occurring in the area. The proposal benefits numerous wildlife species. This activity will 

not significantly impact other Refuge activities or actions and will not affect Refuge-wide or 

nationwide wildlife populations. 

Impacts to Listed Species: There are no listed or endangered species on the Refuge. Greater sagegrouse (Centrocercus urophasianus) and the Great Basin Columbia spotted frog (Rana luteiventris) 

are designated as Federal candidate species for listing under the Endangered Species Act. Incidental 

post-breeding observations of sage-grouse have been made in recent years in the southeast portion of 

the Blitzen Valley. Spotted frogs have been documented in limited areas on the Refuge (Engle 2001; 

Pearl et al. 2010; Rombough and Engler 2010; ODFW 2011). But it is unclear at this time if the 

Refuge population is part of the Great Basin distinct population, which is the Federal candidate 

species, or if they belong to the Oregon population. 

Although the Refuge has occurrences of these candidate species, it is anticipated that impacts from 

farming will be negligible and will not be expected to increase disturbance to candidate species any 

more than non-commercial uses. If uses result in unacceptable adverse effects to candidate species or 

habitats, the Refuge will impose restrictions to mitigate disturbance. 

Impacts to Priority Public Uses: During operations, farming cooperators may occasionally flush 

wildlife from areas used by hunters, wildlife observers, photographers, anglers, or EE groups, but this 

conflict will be expected to be minimal. The presence of the crops, which may attract a variety of 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-125 

species, may support hunting, wildlife observation, wildlife photography, environmental education, 

and interpretation 

Public Review and Comment 

Various opportunities were provided for the public to engage in the CCP planning process. Appendix 

J details public involvement undertaken during the development of the CCP. 

Determination 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility 

 This activity will be conducted under an annual CLMA or CFA specifying roles and 

responsibilities of the Service and each cooperator. 

 Cooperators will only apply herbicides and fertilizers with prior Refuge approval. 

 All weed control strategies and associated herbicides must be approved by the FWS and 

Pesticide Use Proposal procedures. 

 Seeds must be certified weed free. 

 Equipment must be thoroughly cleansed before entering the Refuge to prevent the 

introduction of new weed species or populations to the Refuge. 

Justification 

Crop production has been shown to provide a cost-effective means of providing high-quality food 

source for target wildlife species at the Refuge. Specifically, crop production provides high-energy 

grain and forage crops, as well as green forage crops that are highly digestible and easily accessible. 

Wintering and migrating waterfowl and cranes readily use agricultural crop fields to help meet their 

energy needs. The use of a cooperator to produce grain crops may facilitate the management of 

croplands by increasing the reliability of a successful crop. 

In addition, the food support crop production provides for target wildlife species and indirectly 

supports several wildlife-dependent recreational activities such as wildlife observation and 

photography. 

By conducting the crop production program under the practices and stipulations described above, it is 

anticipated that wildlife species that could be adversely affected will find sufficient food resources 

and resting places so their abundance and use will not be measurably lessened on the Refuge. 

Additionally, it is anticipated that monitoring, as needed, will prevent unacceptable or irreversible 

impacts to fish, wildlife, plants, and their habitats. 

The cooperative farming program will contribute to achieving Refuge purposes and goals as 

identified in the 1990 Blitzen Valley Management Plan (Rule et al. 1990) and the Refuge System 

mission by providing valuable foraging areas and conditions for sandhill cranes, waterfowl, and other 

wildlife. It also benefits other Refuge management actions by providing weed control and other 

habitat-maintenance functions. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-126 Appendix B. Compatibility Determinations 

The combination of management practices and stipulations identified above will ensure that crop 

production contributes to the enhancement, protection, conservation, and management of native 

wildlife populations and their habitats on the Refuge. As a result, crop production contributes to 

achieving Refuge purposes; contributes to the mission of the National Wildlife Refuge System; and 

helps maintain the biological integrity, diversity, and environmental health of the Refuge. 

Mandatory Reevaluation Date 

 09/2022 Mandatory 10-year Reevaluation Date (for all uses other than priority public uses) 

NEPA Compliance for Refuge Use Decision 

 X Environmental Impact Statement and Record of Decision 

References 

Engle, J.C. 2001. Population biology and natural history of Columbia spotted frogs (Rana 

luteiventris) in the Owyhee Uplands of southwest Idaho: implications for monitoring and 

management. M.S. thesis. Boise State University, Boise, ID. 66 pages. Available at: 

http://www.fws.gov/oregonfwo/Species/Data/ColumbiaSpottedFrog/. 

ODFW. 2011. Greater sage-grouse backgrounder. Available at: 

http://www.dfw.state.or.us/wildlife/sagegrouse/docs/Greater_Sage_Grouse_Candiadate_speci

es_Backgrounder.pdf [sic]. 

Pacific Flyway Council. 1997. Pacific Flyway management plan for the Central Valley Population of 

Greater Sandhill Cranes, Pacific Flyway Study Committee. Unpublished report. Portland, OR 

44 pp. + appendices. 

Pearl, C.A., S.K. Galvan, M.J. Adams, and B. McCreary. 2010. Columbia spotted frog (Rana 

luteiventris) in southeastern Oregon: A survey of historical localities, 2009. U.S. Geological 

Survey Open File Report 2010-1235. 96 pp. 

Rombough, C. and J. Engler. 2010. Surveys for Columbia spotted frog (Rana luteiventris) at ARRA 

project sites, Malheur NWR. Report to USFWS from Rombough Biological. Princeton, OR. 

13 pp. 

Rule, M., G. Ivey, D. Johnson, and D. Paullin. 1990. Blitzen Valley management plan. Malheur 

National Wildlife Refuge. Princeton, OR. 169 pp. 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix B. Compatibility Determinations B-127 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

B-128 Appendix B. Compatibility Determinations 

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Full moon over East Canal

©Barbara Wheeler

Appendix C

Implementation Appendix C

Implementation

Appendix D

Wilderness Review

Appendix E

BIDEH

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-1 

Appendix C. Implementation 

C.1 Overview 

Implementation of the management direction of the Comprehensive Conservation Plan (CCP) will 

require increased staffing and funding levels to successfully accomplish the planned actions, which 

will depend upon additional Congressional allocations, partnerships, and grants. There are no 

guarantees that additional federal funds will be made available to implement any of these projects. 

We will seek to develop innovative and committed partnerships with a variety of public and private 

entities. The identified activities and projects will be implemented as funds become available. 

This Refuge has one of the largest infrastructures in the National Wildlife Refuge System, with 

approximately 200 miles of public roads; 2,000 miles of waterways/dikes; 5 dams; 1,000 water 

control structures; 6 automated fish screens; 27 administrative, 7 quarters, and 25 visitor services 

facilities; 4 historic building sites; and a large fleet of heavy/light vehicles and equipment. This 

extensive infrastructure requires a high degree of routine maintenance/repair to efficiently and 

effectively support the various Refuge programs and maintain tens of thousands of acres of wetlands, 

30 miles of rivers/creeks, and 16,000 acres of irrigated meadow. At the current staffing level, a vast 

majority of routine maintenance/repair needs are addressed reactively. Additional staff and/or 

funding are needed to proactively address the maintenance/repair backlog and move this Refuge 

forward to its full ecological potential and ensure biological integrity. 

The CCP describes activities and projects to be implemented over the next 15 years. Many of these 

projects are included in the Refuge Operational Needs System (RONS-new staff), or Service Asset 

Maintenance and Management System (SAMMS-deferred maintenance projects), which are used to 

request funding from Congress. Currently, a very large backlog of maintenance needs exists for the 

Refuge. In 2011, the deferred maintenance backlog for the Refuge was approximately $48 million, 

with more projects needing to be added annually. An attempt to reduce this backlog needs to be 

addressed and is included here in the analysis of staffing and funding needs. Prioritized staffing 

needs identified in the RONS will be necessary to implement the CCP to meet Refuge goals, 

objectives, and legal mandates. 

Annual revenue-sharing payments, associated with the Refuge in Harney County, may continue. 

Total payments made in 2011 were $75,842.00 to Harney County. 

Inventory and monitoring activities will be conducted on new and existing projects and activities to 

document changes across time, habitat conditions, and responses to management practices. The 

adaptive management process will be employed to address new information that may show the need 

for management adjustments, confirm existing strategies, or identify additional information needs. 

Based on the best information available at the time, the Refuge with feedback from partners and 

interested parties will make decisions for future management actions. 

As with the sharing/learning aspects of adaptive management, the Refuge recognizes the importance 

for transparency of decision making. The Refuge is committed to bringing together interested parties 

to assist with evaluation of available information and consultation about management options and 

their implications prior to course-changing decisions being made. This process does not diminish the 

Refuge’s legal authority to make decisions but, rather, serves to enhance the decision-making process 

by enabling the Refuge to approach issues from multiple perspectives, thereby finding creative 

solutions to complex challenges. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-2 Appendix C. Implementation 

C.2 Costs to Implement the CCP 

The following sections detail both one-time and recurring costs for needed projects. One-time costs 

reflect the initial costs associated with a project, whether it is purchase of equipment, contracting 

services, construction, a research project, etc. Recurring costs reflect the future operational and 

maintenance costs associated with the project. The following tables primarily document projects with 

a physically visible, track-able, “on-the-ground” component, such as structures, habitat restoration, 

research, and monitoring and surveys. The scope and costs for “administrative” activities such as 

memoranda of understanding (MOUs), reporting, and establishment of partnerships are difficult to 

estimate in advance and thus are not accounted for in the tables below. 

C.2.1 One-time Costs 

One-time costs are project costs that have a start-up cost associated with them, such as purchasing a 

new vehicle for wildlife and habitat monitoring, or designing and installing an interpretive sign. 

Some are full project costs for projects that can be completed in 3 years or less. One-time costs can 

include the cost of temporary or term salary associated with a short-term project. Salary for existing 

and new positions, and operational costs, are reflected in operational (or recurring) costs. 

Funds for one-time costs will be sought through increases in Refuge base funding, special project 

funds, and grants. Projects listed in Table C-2 show one-time costs, such as those associated with 

building and facility needs including offices, public use facilities, road improvements, and new signs. 

One-time costs are also associated with projects such as habitat restoration, invasive plant and animal 

control, and research. New research projects, because of their short-term nature, are considered onetime projects and include costs of contracting services or hiring temporary staff for the short-term 

project. Some project costs are taken from RONS or SAMMS proposals; others are not yet in any 

project database and their costs have been estimated, particularly if the scope of the project is 

unknown at this time due to lack of baseline data. 

C.2.2 Annual Operational (Recurring) Costs 

Operational costs reflect Refuge spending of base funds allocated each year. These are also known as 

recurring costs and are usually associated with day-to-day operations and projects that last longer 

than 3 years. Operational costs use base funding in Service fund code 1260. 

Table C-1 highlights the current and future staff needed to accomplish the activities forecast in the 

CCP. 

Table C-2 highlights projected one-time and recurring costs for new or expanded visitor service 

opportunities and facilities, aquatic and terrestrial habitat restoration, conservation activities, and 

inventory and monitoring needs. This table includes such things as implementation and operational 

expenditures such as supplies, materials, utilities, and maintenance costs. 

Maintenance Costs: The maintenance need over the next 15 years is defined as funds needed to 

repair or replace buildings, equipment, and facilities. Maintenance includes preventative 

maintenance; cyclic maintenance; repairs; replacement of parts, components, or items of equipment; 

adjustments, lubrication, and cleaning (non-janitorial) of equipment; painting; resurfacing; 

rehabilitation; special safety inspections; and other actions that ensure continuing service and prevent 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-3 

breakdown. Maintenance costs include the maintenance “backlog”—maintenance needs that have 

come due but are as yet unfunded, as well as the increased maintenance need associated with new 

facilities, infrastructure needing updating or rehabilitation, moving to a carbon negative status, and 

employing facility greening measures. 

The facilities associated with the Refuge that require maintenance include trails, interpretive panels, 

regulatory signs, roads, water delivery system, and structures. Major equipment includes airboats, 

vehicles, heavy equipment, firefighting equipment, all-terrain vehicles (ATVs), and utility terrain 

vehicle UTVs. 

Staffing: Table C-1 illustrates the staffing costs. One column shows the current estimated 

expenditure on the Refuge, in FY 2011 dollars. The next column reflects costs associated with 

increased staffing needs under the CCP. 

Table C-1. Current and Future Staffing 

Current Staff Positions Series and 

Grade1 

Annual Salary 

Cost 

Expenditure 

Under Current 

Management 

Expenditure 

Under Future 

Management 

Wildlife Refuge Manager GS-0485-14 138,330 138,330 138,330 

Wildlife Refuge Manager GS-0485-13 132,270 132,270 132,270 

Wildlife Biologist GS-0486-12 97,660 97,660 97,660 

Fish Biologist GS-0482-11 93,000 93,000 93,000 

Archaeologist GS-0193-11 96,410 96,410 96,410 

Ecologist GS-0408-11 87,240 87,240 87,240 

Park Ranger GS-0025-11 93,150 93,150 93,150 

Fire Management Officer GS-0401-11 94,290 94,290 94,290 

Park Ranger (LEO) GL-0025-9 88,660 88,660 88,660 

Prescribed Fire Specialist GS-0455-9 40,000 40,000 40,000 

Administrative Officer GS-0341-9 71,680 71,680 71,680 

Supervisory Range Technician GS-0462-8 71,740 71,740 71,740 

Office Assistant GS-0303-6 49,340 49,340 49,340 

Forestry Technician GS-0462-5 50,270 50,270 50,270 

Range Technician GS-0455-5 14,930 14,930 14,930 

Biological Technician (fisheries) GS-0404-4 27,000 27,000 27,000 

Forestry Aide Fire GS-0462-3 13,910 13,910 13,910 

Range Technician GS-0455-3 15,410 15,410 15,410 

Supervisory Engineering Equipment 

Operator WS-5716-9 97,480 97,480 97,480 

Engineering Equipment Operator WG-5716-10 77,860 77,860 77,860 

Engineering Equipment Operator WG-5716-10 78,640 78,640 78,640 

Engineering Equipment Operator WG-5716-10 78,680 78,680 78,680 

Maintenance Mechanic WG-4749-9 70,600 70,600 70,600 

Engineering Equipment Operator WG-5716-8 61,910 61,910 61,910 

Total Annual Cost for Current Staff 1,740,460 1,740,460 1,740,460 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-4 Appendix C. Implementation 

Future Staff Positions in the Refuge 

Operational Needs System (RONS) + 

Project # and 2008 Ultimate 

Organizational Chart 

Series and 

Grade 

Annual Salary 

Cost 

Current 

Management 

Future 

Management 

Geographic Information System Specialist, 

FY08-5019 GS-0150-11 104,480 104,480 

Natural Resource Specialist, FY08-5005 GS-0401-11 104,480 104,480 

Private Lands Biologist, FY08-5016 GS-0401-11 104,480 104,480 

Refuge Operations Specialist, FY08-5013 GS-0485-9 86,360 86,360 

Park Ranger (Volunteer Coordinator), 

FY08-5008 GS-0025-9 86,360 86,360 

Park Ranger (Interpretive), FY10-1303 GS-0025-7 70,600 70,600 

Range Technician, FY08-5004 GS-0455-7 70,600 70,600 

Hydrological Technician, FY08-5007 GS-1317-7 70,600 70,600 

Biological Technician (Habitat), FY08-5018 GS-0404-6 63,530 63,530 

Biological Technician (Facilities), FY08-

5015 GS-0404-6 63,530 63,530 

Maintenance Mechanic, FY08-5009 WS-4749-10 121,970 121,970 

Engineering Equipment Operator, FY08-

5017 WG-5716-8 82,190 82,190 

Engineering Equipment Operator, FY08-

5003 WG-5716-8 82,190 82,190 

Maintenance Mechanic, FY08-5006 WG-4749-8 82,190 82,190 

Maintenance Worker, FY08-5011 WG-4749-6 70,490 70,490 

Park Ranger (Law Enforcement), FY10-

2173 GL-0025-11 80,370 80,370 

Park Ranger (Law Enforcement), FY10-

2174 GL-0025-9 68,640 

Total Annual Cost for Future Staff 1,344,420 

Grand Totals 3,084,880 1

GS/GL: General Schedule, Federal Employee, WG/WS: Wage Grade Scale, Federal Employee 

Costs are based on FY 2011 Full-Time Equivalent (FTE) utilization plan for the Refuge and the 

Office of Personnel Management (OPM) General Schedule FY 2011 plus 40 percent benefits. For the 

proposed positions, the cost is the grade level at step one plus 40 percent for benefits. 

Table C-1 illustrates an increase of 16.0 FTE staff positions over the current staffing level for the 

management direction. At the current staffing level, action items that need immediate attention can 

be addressed, but the Refuge does not have the capacity to be proactive in addressing items before 

they reach the critical threshold. To have the Refuge reach its full potential, it needs additional staff 

to move its operational level from reactive to proactive. 

The Geographic Information System (GIS) Specialist position is needed to improve and build the 

capacity of the aquatic health and habitat management programs by coordinating the development of 

needed resource geospatial databases, including design, data collection, data storage, and resource 

data implementation. The GIS information will enable the Refuge to effectively track climate change, 

improve inventory and monitoring data, communicate geospatial information, and enhance decision 

making. Geospatial information is critical to effectively implementing the actions outlined in this 

plan. RONS Project No. FY08-5019 

The Natural Resources Specialist position is needed to develop and implement CCP step-down 

management plans, compatibility determinations, habitat management plans, environmental 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-5 

assessments, environmental management system protocols, and other strategic habitat conservation 

plans. RONS Project No. FY08-5005 

The Private Lands Biologist position is needed to develop the necessary private landowner 

relationships to address the variety of natural resources issues impacting Harney County, such as 

watershed connectivity, aquatic health, fish passage/screening, and migratory bird habitat 

conservation. RONS Project No. FY08-5016 

The Refuge Operations Specialist is needed to conduct environmental compliance, safety programs, 

permitting, infrastructure “greening” activities, sustainable practices, RONS input, SAMMS input, 

database management, and facility maintenance/repair planning activities. RONS Project No. FY08-

5013 

Park Rangers (4) are needed for the following: 

1. The Park Ranger will serve as the much-needed volunteer coordinator. He/she will 

recruit, coordinate, orient, train, and support volunteers for a variety of Refuge programs 

such as visitor services, maintenance, administration, and fish/wildlife management. This 

position is critical for the Refuge to continue moving forward with citizen science 

opportunities for inventory/monitoring, visitor contact/bookstore operations, special events 

assistance, and visitor services programming. RONS Project No. FY08-5008 

2. The Park Ranger will assist the visitor services manager in providing high-quality 

wildlife-dependent recreational programming for the visiting public, schools, special events, 

and organized groups. The position will also assist with visitor services program assessment, 

social media development, docent training, and event planning. RONS Project No. FY10-

1303 

3. The Park Ranger, Law Enforcement Officer will assist in protecting wildlife, lands, 

facilities, employees, and the general public. This position will serve as the liaison for 

canoe/kayak tours of Malheur Lake. RONS Project No. FY10-2173 

4. The Park Ranger, Law Enforcement Officer will assist in protecting wildlife, lands, 

facilities, employees, and the general public. RONS Project No. FY10-2174 

The Range Technician will assist with livestock-related issues, field and geospatial data collection, 

plant community monitoring and enhancement, the development of cooperative land management 

agreements, invasive species control, boundary fence inspection and repair, and coordinating with the 

haying/grazing program permittees. RONS Project No. FY08-5004 

Biological Technicians (2) are needed for the following:

1. The Biological Technician will be responsible for mowing the hundreds of miles of dike 

tops and road ways and removing beaver/muskrat debris from water control structures and 

dams. RONS Project No. FY08-5015 

2. The Biological Technician will assist with aquatic health and fisheries programs, 

biological inventory and monitoring programs, and other habitat-management activities. 

RONS Project No. FY08-5018 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-6 Appendix C. Implementation 

The Hydrological Technician will collect the necessary water flow data to protect Refuge water 

rights, enabling the Refuge to accurately meet legal requirements critical to protecting water rights. 

RONS Project No. FY08-5007 

Engineering Equipment Operators (2) will be responsible for:

1. The Engineering Equipment Operator will meet the needs of an increased maintenance 

program by assisting with the maintenance/repair of the water delivery system, roads, dikes, 

and habitat enhancement projects. RONS Project No. FY08-5017 

2. The Engineering Equipment Operator will meet the needs of an increased maintenance 

program by assisting with the maintenance/repair of the water delivery system, roads, dikes, 

and habitat enhancement projects. RONS Project No. FY08-5003 

Maintenance Mechanics (2) will be responsible for:

1. The Maintenance Mechanic, Work Leader will supervise facility maintenance to ensure 

the necessary level of coordination, administration, and workforce planning is in place for an 

efficient and effective maintenance program. RONS Project No. FY08-5009 

2. The Maintenance Mechanic will maintain/repair facilities’ infrastructure. RONS Project 

No. FY08-5004 

The Maintenance Worker will assist with the maintenance of facilities and infrastructure, health 

and safety program, grounds keeping, and trail and sign maintenance. RONS Project No. FY08-5011 

C.2.3 Partnership Opportunities 

Partnerships are critically important to the implementation of this plan, which is reflected in Chapter 

2’s goals, objectives, and strategies. The Refuge’s ecological significance, reputation for being a 

leader in field research, and location facilitate many opportunities for partnerships. Current and past 

partners include federal and state agencies, tribes, non-governmental organizations, volunteers, and 

individuals. 

Coordinated partnership efforts will focus on habitat restoration, land protection, environmental 

education, fish and wildlife monitoring, outreach, and quality wildlife-dependent recreation. Refuge 

staff will work to strengthen existing partnerships and will actively look for new partnerships to 

assist in achieving the goals, objectives, and strategies in this CCP/WSP. 

This is a general list of partners we have established working relationships with through past efforts 

or in the formulation of this collaborative CCP. These partners support this plan’s vision and have 

committed to working with the Refuge to implement the plan’s prescribed actions and activities to 

ensure programmatic integrity for biological, visitor services, sustainable practices, and cultural 

resource programs. For a complete list of CCP collaborators and partners, see Appendix I. 

 Burns Paiute Tribe 

 Audubon Society of Portland and other Audubon chapters 

 Malheur Wildlife Associates 

 Bureau of Land Management 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix C. Implementation C-7 

 Ducks Unlimited 

 Eastern Oregon Agriculture Research Station 

 Harney County Chamber of Commerce 

 Harney County Historical Society 

 Harney County Soil and Water Conservation District 

 Harney County Watershed Council 

 High Desert Partnership 

 Intermountain Joint Venture 

 The Nature Conservancy 

 Natural Resources Conservation Service 

 Oregon Defenders of Wildlife 

 Oregon Department of Fish and Wildlife 

 Oregon Joint Venture 

 Oregon Natural Desert Association 

 Private landowners 

 U.S. Geological Survey 

 U.S. Forest Service 

 U.S. Army Corps of Engineers 

 Universities (University of Wisconsin-River Falls, University of Minnesota, Oregon State 

University, and Iowa State University) 

 Wetlands Conservancy 

 Private citizens 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-8 Appendix C. Implementation Table C-2. Budget Summary for Implementation and Inventory and Monitoring (I&M) Activities (Wildlife and Habitat, Sustainable Practices Programs) 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Goal 1. Lacustrine 

1a 

Aquatic: I&M 

Conduct baseline inventories of aquatic vertebrates/invertebrates to guide future management actions 

Fish assemblage and Tui Chub production (includes riverine) (each 3 years) 

3 3,000 VH 500 x 

Macroinvertebrate assemblage 16,000 VH 200 x Native mussel distribution 1 500 M 300 x Immigration, emigration, mortality, spawning, and juvenile rearing (see RONS) 

3 500,000 VH 500 x 

Aquatic: Research 

Surveys, inventories, and assessments pre- and post-carp control aquatic habitats 

Water quality monitoring (turbidity, etc.) 1 3,000 1,000 VH 1,500 x Carp population dynamics (age and growth) 125,000 VH 10,000 x 

Research carp population dynamics and movements 

Carp mark and recapture 50,000 VH x 

Carp telemetry Initial 5 48,000 54,000 VH 24,000 78,000 

Aquatic: Management Action 

Conduct research to investigate and implement aggressive control strategies 

Statistical analysis and model construction 206,000 VH - x Rotenone 200,000 M Attractants, repellents 47,000 H 12,000 35,000 Barriers, traps, and screens 300,000 VH - x Harvesting 900,000 H - x 

Aquatic: Habit Enhance emergent Wind breaks and carp exclosures 1 21,400 5,000 VH - x 
Appendix C. Implementation C-9 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Management vegetation within the 

lake system 

to promote colonization/expansion of emergent/submergent vegetation 

Understand relationships among water chemistry, lake levels, and habitat/migratory bird responses in lakes 

Development of lacustrine section of State-and-Transition Model 

1 3,200 VH - x 

Develop a model to predict habitat response to carp control 

Establishment of an Aquatic Health Assessment and Implementation Plan for the Malheur Wetlands; collaboration with Oregon State University (OSU), Harney County Soil and Water Conservation District (HCSWCD), Ducks Unlimited (DU) 

422,000 VH - x 

Habitat: I&M 

Lacustrine emergent trend (cost covered in telemetry) 1 - - H - x 

Lacustrine submergent trend 1 800 H - x 

Habitat: Management 

Use Integrated Pest Management (IPM) strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

1 25,000 M - x 

Wildlife: I&M 

Conduct baseline/ongoing inventories of wildlife to guide future management actions 

Waterfowl production survey (also includes 4a, 4b, 4c, and 4d) 1 900 3,000 H x x Colonial waterbird production survey 

1 300 600 H x x 

Muskrat lodge count 1 1,000 L x 

Goal 2. Riverine

2a Aquatic: Screens, barriers, fish wheel, weirs, passage, and traps each 10,000 800,000 VH - x 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-10 Appendix C. Implementation 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Management Initiate small in-stream strategic pilot projects in tributaries 

or reaches of the Blitzen River in response to assessment results 

each 500,000 

L in 

2, H 

in 3 

x 

Dikes, water control structures, and roads 1 500,000 500,000 VH x x 

Habitat: I&M 

Wetland/riverine strategic plan and associated studies and National Environmental Policy Act (NEPA) 

Assorted studies, inventories, pilot projects, and studies identified by Utah State Report 

3,000,000 

L in 

2, H 

in 3 

x 

Floodplain topography (Lidar, other methods) 1,000,000 

L in 

2, H 

in 3 

- x 

Cultural resources inventory and mitigation 2,000,000 

L in 

2, H 

in 3 

x 

Administration 

Adjudicate riverine water rights, continued gauging of flows (water supply, potential climate change, channel and 

floodplain change) 

1 5,000 VH x x 

2b 

Aquatic: I&M Conduct baseline inventories of fish, wildlife, and vegetation to guide future management actions. 5 30,000 VH x x 

Conduct surveys, inventories, and assessments of pre- and post-carp control effects on aquatic habitats. 

each 

study 30,000 VH x x 

Aquatic: Research 

Conduct research to understand carp population dynamics and seasonal movements. 1 30,000 VH x x Conduct research to understand relationships among water 

chemistry, water levels, and habitat/migratory bird responses in this habitat type. 

2 800 1,000 VH x x 

Goal 3. Woody Riparian

 Habitat: I&M Woody riparian trend (validation monitoring of objective) 5 500 M x 
Appendix C. Implementation C-11 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

3a 

Habitat: Management 

Active planting or seeding appropriate native species 

Propagating and planting shrub species each 2,000 30,000 M x 

Exclude livestock from riparian habitats 

Construct/ maintain 4-strand fence 1 5,000 40,000 VH x x 

Promote riparian shrub health 

Use of disturbance (fire) (~5% of habitat total) 22,000 H x 

Permanently exclude grazing from streamside corridors 

Construct fence 1 1,500 60,000 VH x x 

Manipulate soil moisture in riparian areas outside of the naturally occurring floodplain 

Maintain irrigation infrastructure (folded into costs in 4a) H 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) (200 acre/year @ $80.00/acre) 

1 16,000 H x x 

Wildlife: I&M Woodland bird survey (equipment costs covered in other survey costs) 1 400 M x 

Goal 4. Wet Meadow

4a 

Aquatic: I&M 

Conduct baseline inventories of fish, wildlife, and vegetation to guide future management actions. 5 30,000 VH x x 

Conduct surveys, inventories, and assessments of pre- and post-carp control effects on aquatic habitats. 

each 

study 30,000 VH x x 

Aquatic: Research 

Conduct research to understand carp population dynamics and seasonal movements. 1 30,000 VH x x 

Conduct research to understand relationships among water chemistry, water levels, and habitat/migratory bird responses 2 800 1,000 VH x x 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-12 Appendix C. Implementation 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

in this habitat type. 

Aquatic Habitat: Management 

Develop a model to predict habitat response based upon changes in biotic and abiotic factors in the habitat type. 1 50,000 VH x x 

Habitat: I&M Wet meadow trend (validation monitoring of objective) 1 36,000 H x Habitat: Research 

Plant community–specific research and associated wildlife response 1 36,000 H x 

Habitat: Management 

Water delivery and management through maintenance or enhancement of infrastructure (e.g., delivery ditches, water control structures) 

1 350,000 H x x 

Modify dikes, ditches, and other infrastructure as needed to reclaim acres lost to cattail encroachment (e.g., Northwest big sagebrush field). 

250,000 M x x 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants 

1 350,000 H x x 

Prescribed fire, discing, herbicides, and mowing to reduce extensive emergent cover 1 10,000 H x 

Wildlife: I&M 

Migratory bird survey (includes 4b–j as well) 1 10,000 H x x 

Passerine bird survey (includes 4b, 4d–i as well) 1 10,000 H x x Waterfowl/waterbird production survey (includes 4b–c as well) 1 10,000 H x x 

Goal 4. Emergent Marsh

4b Aquatic: I&M 

Conduct baseline inventories of fish, wildlife, and vegetation to guide future management actions. 5 30,000 VH x x 

Conduct surveys, inventories, and assessments of pre- and post-carp control effects on aquatic habitats. 

each 

study 30,000 VH x x 
Appendix C. Implementation C-13 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Aquatic: Research 

Conduct research to understand carp population dynamics and seasonal movements. 1 30,000 VH x x 

Conduct research to understand relationships among water chemistry, water levels, and habitat/migratory bird responses in this habitat type. 

2 800 1,000 VH x x 

Aquatic Habitat: Management 

Develop a model to predict habitat response based upon changes in biotic and abiotic factors in the habitat type. 1 50,000 VH x x 

Habitat: I&M Emergent marsh trend 1 2,000 H x Habitat: Research 

Experiment with grazing as a tool in monotypic stands of emergent cover to set back succession 

Covered in 

4a research H x 

Habitat: Management 

Prescribed fire to remove extensive emergent cover 2 192,000 M x x 

Discing to remove extensive emergent cover 1 400 M x Mowing to remove extensive emergent cover 1 400 M x Herbicide applications to control emergent plants 5 45,000 M x x Flood up and drawdowns (water level management) 

Covered in 

4a 

Management 

H 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

4 20,000 M x x 

Goal 4. Palustrine Open Water/Emergent

4c 

Aquatic: I&M 

Conduct baseline inventories of fish, wildlife, and vegetation to guide future management actions. 5 30,000 VH x x 

Conduct surveys, inventories, and assessments of pre- and post-carp control effects on aquatic habitats. 

each 

study 30,000 VH x x 

Aquatic: Conduct research to understand carp population dynamics 1 30,000 VH x x 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-14 Appendix C. Implementation 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Research and seasonal movements. 

Conduct research to understand relationships among water chemistry, water levels, and habitat/migratory bird responses in this habitat type. 

2 800 1,000 VH x x 

Aquatic Habitat: Management 

Develop a model to predict habitat response based upon changes in biotic and abiotic factors in the habitat type. 1 50,000 VH x x 

Habitat: I&M Palustrine Open Water/Emergent Trend 1 400 H x Habitat: Management 

Water delivery and management through maintenance or enhancement of infrastructure (e.g., delivery ditches, water control structures). Needs associated with spotted frog refugia will be addressed in identified areas (e.g., East Canal, Five Mile Spring within West Canal, etc.) 

Covered in 

4a 

Management 

H x x 

Prescribed fire to remove extensive emergent cover 5 3,600 M x x Discing to remove extensive emergent cover 1 400 M x x Mowing to remove extensive emergent cover 1 400 M x x Flood up and drawdowns (water level management) 

Covered in 

4a 

Management 

H 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

M 

Goal 4. Dry Meadow

4d 

Habitat: I&M Dry meadow trend 1 400 M x x Habitat: Management 

Use agricultural practices (e.g., haying, grazing, etc.) to maintain/enhance fields 

Covered in 

4a 

Management 

M 
Appendix C. Implementation C-15 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

Use burning regimes where feasible 3 12,000 M x x Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

M 

Wildlife: I&M Grassland breeding bird survey 1 600 H x 

Goal 4. Salt Desert Scrub

4e 

Habitat: I&M Salt desert scrub trend 1 400 L x Habitat: Management 

Protect existing sensitive sites with microbiotic crusts 1 10,000 M x x 

Use of prescribed fire depending on site-specific factors 5 20,000 L x Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

L 

Wildlife: I&M Passerine breeding bird survey (includes 4f–h) 1 700 M x 

Goal 4. Sagebrush Lowlands

4f 

Habitat: I&M Sagebrush lowland trend 1 400 M x Habitat: Management 

Prescribed fire 15,000 M x 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

M 

Goal 4. Sagebrush Steppe

4g 

Habitat: I&M Sagebrush steppe trend 1 400 M x Habitat: Management 

Add diversity to crested wheatgrass monocultures using best 

science practices (i.e., Krumbo Unit research from Eastern Oregon Agricultural Research Station) 

? ? ? M x x 

Use IPM strategies including chemical, mechanical, Covered in L 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-16 Appendix C. Implementation 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

4a 

Management 

Goal 4. Dune

4h 

Habitat: I&M Dune trend 1 400 L x Habitat: Management 

Protect dune areas from disturbance 

Covered in 

4e 

Management 

M 

Use IPM strategies (chemical, mechanical, horticultural, and/or biological control) for invasive plants (Appendix G) 

Covered in 

4a 

Management 

L 

Goal 4. Playa

4i 

Habitat: I&M Playa trend 1 200 L x Habitat: Management 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

L 

Wildlife: I&M Shorebird breeding survey 1 400 H x x 

Goal 4. Crop Land

4j 

Habitat: I&M Crop land trend 1 200 L x Habitat: Management 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive plants (see Appendix G) 

Covered in 

4a 

Management 

L 

Goal 5. Cold and Hot Springs

5a Aquatic: I&M Spotted frog population Covered in 1a VH x x 

Aquatic: Research Carp control Covered in Goals 1 and VH x 
Appendix C. Implementation C-17 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

2 

Aquatic: Management Aquatic assemblages 5 30,000 H x Habitat: I&M Cold and hot spring trends 1 400 M x Habitat: Management 

Use IPM strategies including chemical, mechanical, horticultural, and biological control agents to control/eradicate invasive species (see Appendix G) 

1 1,000 VH x x 

Administration Adjudicate ground water rights 1 5,000 VH x 

Goal 5. Cliff, Rimrock, and Lava Flows

5b 

Habitat: Management 

Continued use of existing Refuge gravel/rock pits. Upon closure of gravel rock pits remediation will occur L x x 

Administration Continue to restrict access to rimrock areas for the benefit of wildlife 1 100 L x x Wildlife: I&M Raptor wintering and nesting surveys 1 400 M x x 

Goal 13. Assessments of Hydrological Features

13b 

Water allocation (water budget, habitat use, and availability 

surveys) 1 5,000 130,000 VH x 

Goal 13. Scientific Assessments

13e 

Assess avian predation on carp 200,000 VH x 

Assess carp control study areas pre- and post-treatment each study 30,000 VH x x 

Goal 14. Sustainability

14a 

 Establish Refuge program benchmarks for sustainabilitybased practices 25,000 H x 

Provide staff training for the implementation of 1 1,000 H x 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-18 Appendix C. Implementation 

Objective Program Strategy Project/Methodology 

Recurrence 

interval 

Recurring 

Cost One-time Cost 

Priority1 Current Manage ment Future Management 

sustainability-based principles and practices Complete energy audits, carbon footprint audits, and biomass-based carbon sequestration assessments 5 25,000 250,000 H x Use GIS technologies for benchmarking and tracking Environmental Management Plan parameters and climate change across program areas 

1 5,000 50,000 H x 

Integrate sustainability-based initiatives into all partnerships and other external stakeholder activities 1 1,000 H x  Integrate training for social justice/equity, community development, and cultural resource and partnership performance standards with all sustainability-based initiatives 

1 1,000 H x 

Refit and right-size facilities and infrastructure for energy efficiency and production 1 35,000 2,000,000 H x 

1Priority Rankings: 

Very High (VH): these actions are very critical and must be completed in the first 5 years of the plan in order to move other elements of the plan forward. Funding will be directed to complete VH 

priority actions first and foremost. High (H): these actions are critical and must be completed in the first 5 years of the plan in order to move other elements of the plan forward. Funding will be directed to complete H priority actions as funding levels allow. Medium (M): these actions will be accomplished as time and funds allow. Low (L): these actions will be accomplished as time and funds allow. Columns: x = project is included in the management direction or current management. -- = project is not included in the management direction or current management (thus, cost = 0). Note: An empty space in the recurring cost column means that there will be no recurring costs. A number in this column means that the cost will recur at the amount specified at the interval identified. 

An empty space in the one-time cost column means that there will be no one-time costs. A number in this column means that a one-time cost at the amount specified will need to occur at some point 

over the lifetime of the CCP (15 years). If there is numeric information in the column for current management and only an x in the future management column, the number in the column for current management refers to the one-time cost that has already been spent. The one-time cost will be 0 for future management, but the recurring costs and recurrence interval will be the same. If there is 

numeric information in each column, this is the one-time cost that will vary (again, some money has already been spent). The recurring costs and intervals will be the same for current management and 

future management. 
Appendix C. Implementation C-19 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Table C-3. Budget Summary for Implementation and Inventory and Monitoring Activities (Visitor Services and Cultural Resources Programs) 

Activity or Project Cost/Unit 

# of Units 

(Current 

Management) 

# of Units 

(Future 

Management)

One-time 

Expense 

(Current 

Management) 

($) 

One-time 

Expense 

(Future 

Management) 

($) 

Recurring 

Expense 

(Current 

Management) 

($/year) 

Recurring 

Expense 

(Future 

Management) 

($/year) 

Goal 6. Welcome and Orient Visitors

Objective 6a. Provide welcome and orientation to visitorsUpdate existing panels and develop new panels at new locations $15,000 4 8 $60,000 $120,000 $500 $500 Maintain existing and develop new vault toilets $25,000 0 1 $0 $25,000 $3,500 $5,000 Maintain existing and develop accessible picnic tables, trash cans, and shelters 

ADA – 

$4,500, nonADA – 

$1,500 

0 1 ADA, 2 non $0 $7,500 $5,000 $5,000 

Build enlarged visitor contact station and gift shop $250,000 -- 1 $0 $250,000 $0 $10,000 Rehabilitate museum facility (temperature and humidity control, accessibility) (see interpretation for interpretive panels) 

$25,000-

$75,000 -- 1 $0 $50,000 $0 $0 

Establish seasonal contact station at P Ranch $10,000- $100,000 0 1 $0 $45,000 $0 $3,000 Develop modern media welcome and outreach materials, maintain website, etc. $10,000 $0 $0 $1,000 $1,000 Objective 6b. Address transportation issues Raise and surface Center Patrol Road (CPR) $1,200,000 1 1 0 $1,500,000 $100,000 Develop additional vehicle pull-offs $10,000- $25,000 0 3 $0 $52,500 $0 $0 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-20 Appendix C. Implementation Activity or Project Cost/Unit # of Units (Current Management) # of Units (Future Management) One-time Expense (Current Management) ($) One-time Expense (Future Management) ($) Recurring Expense (Current Management) ($/year) Recurring Expense (Future Management) ($/year) Improve East Canal for vehicle access $30,000 0 3 $0 $90,000 $0 $0 Improve public vehicle access at Boat Landing Road, including vehicle pull-offs $30,000 0 1.5 $0 $45,000 $0 $0 Maintain Krumbo Lane $10,000 Develop parking areas to assist with public use programs $50,000 3 $0 $150,000 $0 $0 Overall road maintenance (public roads, vehicle pull-offs, parking areas) $0 $20,000 Goal 7. Wildlife Observation, Photography, Interpretations Objective 7a. Provide wildlife observation and photography opportunities Docent tours on lake $100,000 $0 1 $0 $100,000 $0 $15,000 Other land-based docent-led tours monthly plus special events (advertise, train, provide) $50,000 0 1 $0 $50,000 $0 $5,000 Provide new non-ADA trails (also see fishing compatibility determination [CD] for fishing trails - not included here), and develop new trail signage (spur trail) $6,000 9 12 0 $72,000 $0 $2,000 Provide new ADA trails at Sodhouse, Benson Pond, P Ranch, (also see fishing CD - not included here) $75,000 0 3 $0 $225,000 $0 $2,000 Construct viewing overlook at Krumbo Reservoir $40,000 0 1 $0 $40,000 $0 $1,000 Construct elevated viewing platforms $55,000 0 4 $0 $220,000 $0 $4,000 Provide photography blinds $10,000 0 3 $0 $30,000 $0 $1,000 Administration and management $0 $0 $20,000 $20,000 Objective 7b. Provide birding opportunities Maintenance (habitats) 0 6 $1,000 $1,000 
Appendix C. Implementation C-21 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Activity or Project Cost/Unit 

# of Units 

(Current 

Management) 

# of Units 

(Future 

Management)

One-time 

Expense 

(Current 

Management) 

($) 

One-time 

Expense 

(Future 

Management) 

($) 

Recurring 

Expense 

(Current 

Management) 

($/year) 

Recurring 

Expense 

(Future 

Management) 

($/year) 

Objective 7c. Provide interpretive opportunitiesDevelop new interpretive panels $10,000 0 3--6 $0 $45,000 $1,000 $1,000 Administration and management (local events, public presentations, media) $0 $0 $35,000 $35,000 Objective 7d. Provide environmental education programsBuild outdoor shelter at Refuge headquarters (HQ) (sun and wind protection) $80,000 1 $0 $80,000 $1,000 $1,000 Provide outdoor learning area at Refuge HQ $25,000 1 $0 $25,000 $1,000 $1,000 Administration and management (curriculum development, initiatives, special events, coordination) 

$5,000 $0 $0 $7,000 $14,000 

Equipment and materials $10,000 $0 $0 $1,500 $2,000 

Goal 8. Provide Hunting and Fishing Opportunities 

Objective 8a. Provide upland game hunting opportunitiesAdministration and management (programmatic, law enforcement, information) 

$0 $0 $2,000 $2,000 

Maintenance (covered under waterfowl hunting CD) $0 $0 $0 $0 Objective 8b. Provide waterfowl hunting opportunitiesImprove Saddle Butte access road (covers upland game use too) $130,000 0 1 $0 $130,000 $0 $0 Open new ADA boat launch and parking area on Malheur Lake (end of Boat Landing Road) 

$150,000 0 1 $0 $150,000 $0 $0 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-22 Appendix C. Implementation Activity or Project Cost/Unit # of Units (Current Management) # of Units (Future Management) One-time Expense (Current Management) ($) One-time Expense (Future Management) ($) Recurring Expense (Current Management) ($/year) Recurring Expense (Future Management) ($/year) Develop new publications and signage for hunt program $2,000 0 1 $0 $2,000 $1,000 $1,000 Staff administration and management (programmatic, law enforcement, information) $0 $0 $5,000 $5,000 Facility maintenance $0 $0 $2,000 $2,000 Objective 8c. Provide stream fishing opportunities Develop fishing brochure $5,000 $1,500 $1,500 $2,000 $2,000 South Fishing Loop: Build 2-3 new pedestrian crossings and complete development of loop trail $275,000 0 1 $0 $275,000 $0 $0 Lower Blitzen: Open new seasonal bank fishing (trail with 2 bridges and parking) (portion will be ADA-accessible) $275,000 0 1 $0 $275,000 $0 $0 Develop outdoor fishing information kiosks $10,000 0 6 $0 $60,000 $0 $0 Replace Krumbo floating platform/other maintenance of Krumbo facilities $35,000 1 1 0 $35,000 $2,000 $2,000 Fishing program administration and management (programmatic, law enforcement, information) $6,000 $6,000 Goal 11. Identify and Protect Prehistoric and Historic Resources that are Eligible or Listed on the National Register of Historic Places Objective 11a. Increase management efforts for eligible historic sites Stabilization and restoration of historic structures at Sodhouse Ranch 8 8 $300,000 $300,000 $5,000 $5,000 Stabilization and restoration of the historic structures at P Ranch 3 3 $0 $150,000 $2,000 $2,000 
Appendix C. Implementation C-23 

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Activity or Project Cost/Unit 

# of Units 

(Current 

Management) 

# of Units 

(Future 

Management)

One-time 

Expense 

(Current 

Management) 

($) 

One-time 

Expense 

(Future 

Management) 

($) 

Recurring 

Expense 

(Current 

Management) 

($/year) 

Recurring 

Expense 

(Future 

Management) 

($/year) 

Stabilization and restoration of the sod structure at Barnes Springs 1 1 $0 $35,000 $500 $500 Stabilization and restoration of the historic structures at Double-O Ranch 3 3 $0 $100,000 $2,000 $2,000 Maintain Civilian Conservation Corps buildings at Refuge HQ and Buena Vista Station and Benson Pond 

8 8 $0 $60,000 $5,000 $5,000 

Goal 12. Manage the Refuge’s Paleontological Resources for their Educational and Scientific Values 

Objective 12b. Provide interpretation of paleontological resources Develop interpretive and educational materials for paleontological resources $15,000 2 2 $30,000 $30,000 $0 $0 

$675,000 $675,000 $14,500 $14,500 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

C-24 Appendix C. Implementation This page left blank intentionally. 
Appendix D

Wilderness Review

Inventory Phase

Landscape from north of CPR

©Barbara Wheeler

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix E

BIDEH

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-1 

Appendix D. Wilderness Review Inventory Phase 

D.1 Introduction 

D.1.1 Refuge Overview 

The 187,757 acre Malheur National Wildlife Refuge (NWR) is situated within the Harney Basin in 

southeastern Oregon. Located in the Northern Great Basin, this portion of the state is lightly 

populated, generally arid with cold winters, and characterized by wide open spaces. Although the 

Refuge constitutes a small percentage of the Northern Great Basin it is disproportionately important 

as a stop along the Pacific Flyway and as a resting, breeding, and nesting area for migratory birds and 

other wildlife. Many species migrating through or breeding here are highlighted as priority species in 

national bird conservation plans. 

Malheur NWR is composed of three very distinct environments, each including a diversity of native 

habitats and landscapes. The core of the Refuge is dominated by a shallow lake basin and 

encompasses the Harney, Mud, and Malheur Lakes. This 103,799-acre area covers 56 percent of 

Refuge lands with the majority of acres being highly impacted by invasive common carp. The 

Blitzen Valley, a broad corridor (64,215 acres) to the south of the lake basin, is divided down its 

entire length by the Blitzen River and its associated linear riparian habitat. The Blitzen Valley covers 

34 percent of the Refuge and provides most of the water flowing to the lake basins. The Double-O is 

a broad valley basin that covers 10 percent of Refuge lands. Intermittent water from the Silver Creek 

watershed flows through this management area and drains into Harney Lake. Together, these three 

environments result in a diversity of habitats and support more than 415 species of birds, mammals, 

fish, reptiles, and amphibians. 

Historical bird counts show that the Refuge and the Silvies River floodplain just north of the Refuge 

may support anywhere between 5 to 66 percent of the Pacific Flyway migrating populations for 

various priority waterfowl. On the Refuge, breeding habitat is significant for waterbirds, with the 

Refuge currently supporting over 20 percent of the Oregon population of breeding greater sandhill 

cranes. Most colonial waterbird numbers have easily exceeded 10 percent of the regional population 

at peak, even reaching up to 77 percent of the Great Basin population for certain species. Numbers of 

migrating shorebirds have been documented at levels high enough to qualify the Refuge as a 

Regional Western Hemispheric Shorebird Reserve. The Refuge also supports high densities of 

certain nesting riparian passerines and meadow-dependent species such as the largest nesting 

population of bobolinks in the western United States. 

Currently the majority of productive habitat is within the Blitzen Valley and the Double-O Units. 

Both of these units are comprised of highly altered habitats consisting of open water ponds, marshes, 

meadows, uplands, and riparian areas. Pond, marsh, and meadow habitats are intensively managed 

through an extensive series of roads, dikes, canals, water control structures, and other man-made 

features. 

The lake units of the Refuge (Malheur, Mud, and Harney) have experienced a lesser degree of active 

management than the other units. However, during the first half of the twentieth century, invasive 

common carp were introduced into the Harney Basin. Introduction of carp has caused the ecological 

collapse of one of the largest natural freshwater marshes (Malheur Lake) in the lower 48 states. 

This has resulted in a change from the 1970s when the lake’s bulrush/cattail marsh spanned tens of 

thousands of acres, supporting hundreds of thousands of waterfowl, shorebirds, and waterbirds. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-2 Appendix D. Wilderness Review Inventory Phase 

This Wilderness Review only includes the 

inventory phase (phase 1 of the whole 

wilderness review process). A subsequent 

study phase would occur following the 

publication of the CCP/EIS. 

Today the lake is a large body of muddy water absent of aquatic vegetation, with very limited bird 

use. The carp-induced conditions in Malheur Lake are compromising the biological integrity, 

diversity, and environmental health of the lake. These factors are ultimately preventing Malheur Lake 

from fulfilling the refuge purpose that President Theodore Roosevelt established by Executive Order 

No. 929, “as a preserve and breeding ground for native birds.” 

D.1.2 The Wilderness Review Process 

U.S. Fish and Wildlife Service (USFWS) policy (602 FW 3.4 C.(1) (c)) requires that wilderness 

reviews be completed as part of the Comprehensive Conservation Planning process. 

The National Wildlife Refuge Service’s (NWRS’s) Policy on Wilderness Stewardship includes 

guidance for conducting wilderness reviews (610 FW 4). 

A wilderness review is the process of determining whether the FWS should recommend NWRS lands 

and waters to Congress for wilderness designation. The wilderness review process consists of three 

phases: wilderness inventory, wilderness study, and wilderness recommendation. 

Wilderness Inventory (Phase I) 

The wilderness inventory is a broad look at a refuge to identify lands and waters that meet the 

minimum criteria for wilderness: size, naturalness, 

and outstanding opportunities for solitude or 

primitive and unconfined type of recreation. All 

areas meeting the criteria are classified as 

preliminary Wilderness Study Areas (WSAs). If 

preliminary WSAs are identified, those areas then 

proceed to the study phase. 

Wilderness Study (Phase II) 

During the study phase, WSAs are further analyzed: 

 for all values of ecological, recreational, cultural, economic, symbolic importance. 

 for all resources, including wildlife, vegetation, water, minerals, soils. 

 for existing and proposed public uses. 

 for existing and proposed refuge management activities within the area. 

 to assess the refuge’s ability to manage and maintain the wilderness character in perpetuity, 

given the current and proposed management activities. Factors for evaluation may include, 

but are not limited to, staffing and funding capabilities, increasing development and 

urbanization, public uses, and safety. 

Wilderness Recommendation (Phase III) 

If the wilderness study demonstrates that a WSA meets the requirements for inclusion in the National 

Wilderness Preservation System, a wilderness study report would be written that presents the results 

of the wilderness review, accompanied by a Legislative Environmental Impact Statement (LEIS). 

The wilderness study report and LEIS that support wilderness designation are then transmitted from 

the Director of the USFWS through the Secretary of Interior to the President of the United States, 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-3 

and ultimately to the United States Congress for action. Refuge lands recommended for wilderness 

consideration by the wilderness study report will retain their WSA status and be managed as 

wilderness and in accordance with the management direction established in the refuge’s CCP until 

Congress makes a decision on the area. According to FWS (610 FW 3.13), when a WSA is revised or 

eliminated, or when there is a revision in “wilderness stewardship direction, we include appropriate 

interagency and tribal coordination, public involvement, and documentation of compliance with 

NEPA.” 

D.1.3 Criteria for Evaluating Lands for Possible Inclusion in the National 

Wilderness Preservation System 

The Wilderness Act of 1964, as amended (16 U.S.C. 1131-1136) provides the following description 

of wilderness: 

A wilderness, in contrast with those areas where man and his own works dominate 

the landscape, is hereby recognized as an area where the earth and its community 

of life are untrammeled by man, where man himself is a visitor who does not 

remain. An area of wilderness is further defined to mean in this Act as an area of 

undeveloped Federal land retaining its primeval character and influence, without 

permanent improvements or human habitation, which is protected and managed 

so as to preserve its natural conditions .... 

The following criteria for identifying areas as wilderness are outlined in Section 2(c) of the Act and 

are further expanded upon in NWRS policy (610 FW 4). The first three criteria are evaluated during 

the inventory phase; the fourth criterion is listed during the inventory but is then evaluated during the 

study phase. 

 generally appears to have been affected primarily by the forces of nature, with the imprint of 

man’s work substantially unnoticeable; 

 has outstanding opportunities for solitude or a primitive and unconfined type of recreation; 

 has at least 5,000 acres of land or is of a sufficient size as to make practicable its preservation 

and use in an unimpaired condition; and 

 may also contain ecological, geological, or other features of scientific, educational, scenic, or 

historic value. 

D.1.4 Relationship to Previous Wilderness Reviews 

The Wilderness Act of 1964 (Public Law 88-577) provided the authority for evaluating existing 

NWRs, or parts thereof, for inclusion into the National Wilderness Preservation System. This Law 

directed the review of every roadless area of 5,000 contiguous acres or more, and every roadless 

island within the NWRS. 

A wilderness review and subsequent WSA document was prepared in March 1967 (U.S. Department 

of the Interior [USDI] 1967); this document identified Malheur Lake (48,317 acres) and Harney Lake 

(30,000 acres) as potential wilderness areas. As a part of this procedure, the Secretary of the Interior 

directed the USGS to conduct mineral surveys on these sites. The USGS completed the mineral 

appraisal in March 1967. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-4 Appendix D. Wilderness Review Inventory Phase 

A public Wilderness Hearing was conducted in Burns, Oregon, on May 2, 1967, to gather public 

input, and written comments continued to be accepted through August 1967. In a letter dated 

September 5, 1967, the USDI Bureau of Outdoor Recreation indicated that the Malheur Lake unit 

would be reduced to 20,600 acres; this decision was based on public comments. The Harney Lake 

unit remained at 30,000 acres. 

The revised proposal, totaling 50,600 acres in the Malheur Lake and Harney Lake units, was first 

introduced in a Wilderness Omnibus Bill (S.3014) in October 1969. The Senate Committee on 

Interior and Insular Affairs held hearings on November 6, 1969. Due to opposition from Congress 

regarding the Malheur Lake unit, the Malheur proposal was deleted from the bill (S.3014) and sent 

back for revision. 

According to a FWS Wilderness Fact Sheet, in 1973 the FWS once again reviewed the proposal as 

directed by Congress and revised the proposal to encompass only the 30,000-acre Harney Lake area. 

Memos also indicate that this revision was forwarded as a recommendation to the Secretary of the 

Interior. This recommendation was formally adopted, according to Refuge memos, by the Secretary 

on May 16, 1973. The 1979 Wilderness Fact Sheet and memos from the associate director of the 

Bureau of Sport Fisheries and Wildlife (BSF&W) to the Legislative Council (dated July 31, 1973, 

and signed August 4, 1973) and from the Secretary of the Interior to the Chairman of the House 

Committee on Interior and Insular Affairs outlines the issues and revised recommendation. A draft 

Environmental Statement (as they were known at that time) was prepared later in 1973 (USDI 1973), 

but was never finalized. This draft Environmental Statement included only the 30,000-acre Harney 

Lake unit. 

In 1975, H.R. 5893 (dated April 10, 1975) and H.R. 3507 (dated February 20, 1975) were introduced 

during the 1st session of the 94th Congress. Both of these bills included the original 50,600 acres 

from the original 1967 proposal. The inclusion of Malheur Lake in these bills appears to be a 

mistaken carryover from the original 1969 bill, as none of the requested revisions (from the 1969 

hearings) were forwarded to Congress, and there is no indication in the records that Congress 

discussed the Malheur proposal. No action was taken regarding the Malheur proposal during the 

1976 Omnibus Wilderness Hearings. 

Between 1976 and 1987, there are no Malheur NWR wilderness-related correspondences in the files. 

From 1988 to the present, all correspondences indicate that only the 30,000-acre Harney Lake unit 

was still being considered for wilderness designation. The Harney Lake unit has continued to be 

managed as a Wilderness Study Area since the original 1969 proposal was introduced. 

D.2 Inventory Phase of Wilderness Review 

The following constitutes the inventory (Phase I) of the wilderness review for Malheur NWR. Based 

on inventory outcomes, the next phase (wilderness study) will be conducted as a step-down process 

to the CCP. 

D.2.1 Lands and Waters Considered Under This Wilderness Review 

All FWS-owned lands and waters (in fee title) within the Malheur NWR–acquired boundary were 

considered during this wilderness review. This review includes the re-evaluation of Refuge lands 

first evaluated during the 1960s and 1970s as described above. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-5 

D.2.2 Inventory Units 

The first step of a wilderness assessment is to divide the refuge or other management entity into 

preliminary wilderness evaluation units. The boundaries of these artificial units can follow the refuge 

boundary, but may not cross permanent roadways, private or other non-Federal lands, or non-Service 

owned waterways. These roads, non-Federal lands, or waterways can form the boundary for an 

individual evaluation unit. Other obvious incompatible wilderness uses or structures (such as refuge 

headquarters, residential areas, rights-of-way, and non-jurisdictional waters) may also be eliminated 

from any evaluation units at this time. Once boundaries have been established for each individual 

evaluation unit, the criteria in Sections D.2.3 and D.2.4 are applied to determine each unit’s 

suitability as potential wilderness and the need for further evaluation under the Wilderness Study. 

In determining units to be evaluated for wilderness character per this inventory, the Refuge was 

mapped using geographic information system (GIS) software. Using the major constraints set by the 

Wilderness Act, specifically land ownership/refuge boundary and permanent road systems, initial 

large evaluation units were developed by including all contiguous lands within those intractable 

confines. Through this process, ten units were defined for evaluation and are described below. 

D.2.3 Evaluation of Unit Size 

Criteria for Evaluation 

Roadless areas are defined in Section 3(c) of the Wilderness Act as: 1) a roadless area of 5,000 

contiguous acres or more, or 2) a roadless island. “Roadless” is defined as the absence of improved 

roads suitable and maintained for public travel by means of 4-wheeled, motorized vehicles that are 

intended for highway use. 

According to Service policy (610 FW 4), roadless areas meet the size criteria if any one of the 

following standards applies: 

 The area is over 5,000 contiguous acres solely in FWS ownership. 

 It is a roadless island of any size. A roadless island is defined as “an area surrounded by 

permanent waters or an area that is markedly distinguished from the surrounding lands by 

topographical or ecological features.” 

 It is an area of less than 5,000 contiguous Federal acres that is of sufficient size as to make 

practicable its preservation and use in an unimpaired condition, and of a size suitable for 

wilderness management. 

 It is an area of less than 5,000 contiguous Federal acres that is contiguous with a designated 

wilderness, recommended wilderness, or area under wilderness review by another Federal 

wilderness managing agency such as the Forest Service, National Park Service, or Bureau of 

Land Management (BLM). 

Results of Evaluation 

The 59,664-acre Malheur Lake Unit meets the minimum size requirements for a wilderness area. 

This acreage encompasses the lake bed and associated wetland habitats. Because of the continuity of 

this area, it was not deemed reasonable to split the lake bed into smaller parcels. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-6 Appendix D. Wilderness Review Inventory Phase 

The 31,157-acre Harney Lake Unit meets the minimum size requirements for a wilderness area. 

This is 1,157 acres more than in the 1969 Harney Lake Wilderness Proposal. 

The 5,818-acre Double-O–Stinking Lake Unit meets the minimum size requirement for a 

wilderness area. This area includes the northwestern section of the Double-O Unit, including the 

Stinking Lake Research Natural Area (RNA). 

The 5,660-acre Double-O–Chappo Unit meets the minimum size requirement; this unit is comprised 

of the northeastern section of the Double-O Unit. 

The 7,973-acre Sodhouse-West Unit meets the minimum size requirement. It includes lands west of 

the Center Patrol Road. 

The 6,497-acre Sodhouse-East Unit meets the minimum size requirement. It includes lands east of 

the Center Patrol Road, including the waters of the Blitzen River. 

The 1,206-acre Upper Bridge Creek–Knox Springs Unit does not meet the minimum size 

requirement, but is located adjacent to a BLM Wilderness Study Area and therefore will be further 

evaluated. 

The 426-acre Barnes Springs Unit does not meet the minimum size requirement, but is located 

adjacent to a BLM Wilderness Study Area and therefore will be further evaluated. 

The 4,520-acre Buena Vista–Unit 8 Unit does not meet the minimum size requirement, but is 

sufficiently close to minimum size to continue evaluation. 

The 3,336-acre P Ranch–East Block Unit includes lands east of the Center Patrol Road to the 

Refuge boundary. This unit does not meet the minimum size requirement and will not be evaluated 

further. 

Six of the ten units identified for wilderness evaluation are of sufficient size to evaluate further in the 

inventory process. Two additional units do not meet the size requirement, but are adjacent to existing 

BLM wilderness study areas, and therefore will be considered further for inventory evaluation. One 

unit is only slightly less than the minimum size requirement, so it will be evaluated further. The 

remaining unit is sufficiently below the minimum size requirement and therefore will not be further 

evaluated. 

D.2.4 Naturalness Evaluation 

Criteria for Evaluation 

Section 2(c) defines wilderness as an area that “... generally appears to have been affected primarily 

by the forces of nature with the imprint of man’s work substantially unnoticeable.” 

According to Service Policy (610 FW 4), an area meets the naturalness criterion under the following 

considerations: 

 We make a distinction between an area’s “apparent naturalness” and “historic conditions” in 

the context of biological integrity, diversity, and environmental health. The term “historic 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-7 

conditions” refers to the condition of the landscape in a particular area before the onset of 

significant, human-caused change. The term “apparent naturalness” refers to whether or not 

an area looks natural to the average visitor who is not familiar with historic conditions versus 

human-affected ecosystems in a given area. We address the question of the presence or 

absence of apparent naturalness (i.e., are the works of humans substantially unnoticeable to 

the average visitor?) in the inventory phase of the wilderness review. In the study phase of 

the wilderness review, we make an assessment of an area’s existing levels of biological 

integrity, diversity, and environmental health. 

 We avoid an approach to assessing naturalness that limits wilderness designation only to 

those areas judged pristine. Land that was once logged, used for agriculture, or otherwise 

significantly altered by humans may be eligible for wilderness designation if it has been 

restored or is in the process of being restored to a substantially natural appearance. 

 We use caution in assessing the effects on naturalness that relatively minor human impacts 

create. An area being evaluated may include some human impacts provided they are 

substantially unnoticeable in the unit as a whole. Examples of manmade features that would 

not disqualify an area for consideration as a WSA include: trails, trail signs, bridges, fire 

towers, fire breaks, fire presuppression facilities, pit toilets, fisheries enhancement facilities 

(such as fish traps and stream barriers), fire rings, hitching posts, snow gauges, water quantity 

and quality measuring devices, research monitoring markers and devices, wildlife 

enhancement facilities, radio repeater sites, air quality monitoring devices, fencing, spring 

developments, and small reservoirs. Even with these features, an area may express wilderness 

character and values. 

 We may disqualify portions of an area from consideration where significant human-caused 

hazards make that area unsafe for public use, such as contaminated sites or the existence of 

unexploded ordnance from military activity. Once these conditions are corrected, we may 

then consider that portion of the area. 

 We do not disqualify areas from further wilderness study solely on the basis of the “sights 

and sounds” of civilization located outside the areas. Where human impacts are outside the 

area being inventoried, we do not normally consider them in assessing naturalness. However, 

if an outside impact of major significance exists, we should note it and evaluate it in the 

inventory conclusions. Human impacts outside the area should not automatically lead us to 

conclude that an area lacks wilderness characteristics. 

 We do not disqualify areas from further wilderness study solely on the basis of established or 

proposed refuge management activities or refuge uses that require the use of temporary roads, 

motor vehicles, motorized equipment, motorboats, mechanical transport, landing of aircraft, 

structures, and installations generally prohibited in designated wilderness (see definition of 

“generally prohibited use” in 610 FW 1.5). The physical impacts of these practices should be 

the focus of the naturalness evaluation. We evaluate existing and proposed refuge 

management activities and refuge uses in the study phase of the wilderness review. 

Today few areas exist that do not exhibit some impact from anthropogenic influences, be it noise, 

light, or air pollution; water quality or hydrological manipulations; past and current land management 

practices; roads; suppression of wildfires; invasions by non-native species of plants and animals; or 

public uses. While allowing for the near-complete pervasiveness of modern society on the landscape, 

the spirit of the Wilderness Act is to protect lands that still retain the wilderness qualities of being: 1) 

natural, 2) untrammeled, and 3) undeveloped. These three qualities are the cornerstones of wilderness 

character. For areas proposed or designated as wilderness, wilderness character must be monitored to 

determine baseline conditions and thereafter be periodically monitored to assess the condition of 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-8 Appendix D. Wilderness Review Inventory Phase 

these wilderness qualities. Proposed and designated wilderness areas by law and policy are required 

to maintain wilderness character through management and/or restoration in perpetuity. 

Defining the first two qualities (natural and untrammeled) requires a knowledge and understanding of 

the ecological systems that are being evaluated as potential wilderness. Ecological systems are 

comprised of three primary attributes: composition, structure, and function. Composition refers to the 

components that make up an ecosystem, such as the habitat types, native species of plants and 

animals, and abiotic (physical and chemical) features. These contribute to the diversity of the area. 

Structure is the spatial arrangement of the components that contribute to the complexity of the area. 

Composition and structure are evaluated to determine the naturalness of the area. Function refers to 

the processes that result from the interaction of the various components, both temporally and 

spatially, and the disturbance processes that shape the landscape. These processes include, but are not 

limited to, predator–prey relationships, insect and disease outbreaks, nutrient and water cycles, 

decomposition, fire, windstorms, flooding, and both general and cyclic weather patterns. Ecological 

functions are evaluated to determine the wildness or untrammeled quality of the area. 

The third quality assessment is whether an area is undeveloped. Undeveloped refers to the absence of 

permanent structures such as roads, buildings, dams, fences, and other man-made alterations to the 

landscape. Exceptions can be made for historical structures or structures required for safety or health 

considerations, provided they are made of natural materials and relatively unobtrusive on the 

landscape. 

Results of Naturalness Assessment 

Malheur Lake Unit: The Malheur Lake Unit contains approximately 8 miles of levee system, 1.6 

miles of access roads, and 68 miles of boundary fence. Roads access hunt areas and a boat launch. 

An artificial osprey nesting platform also exists within the lake bed. In the 1970s, Malheur Lake was 

an extensive bulrush/cattail/sago pondweed marsh that supported hundreds of thousands of migrating 

and nesting birds. The lake today is a body of muddy water devoid of most bird use. Although 

Malheur Lake has retained most hydrological inputs, the lake basin itself has lost much of its natural 

function due to the introduction of invasive species. Invasive species, aquatic and terrestrial, have 

altered this ecological system in a manner that has changed all natural attributes except hydrology. 

The hydrology of the lake is still driven by annual climate conditions that cause the lake to fluctuate 

from an average low of 24,000 acres to an average high of 47,000 acres. Lake surface acres have 

ranged from a low of 400 in 1992 to a high of 170,000 in 1984 (well outside of the Refuge 

boundary). 

Due to the impacts of invasive common carp, Malheur Lake is now devoid of nearly all aquatic 

vegetation. Upland areas that are not submerged contain significant amounts of invasive species such 

as perennial pepperweed and Russian olive. Aquatic and terrestrial invasives are also present in all 

tributaries. This has created a situation where issues on the Refuge impact the watershed and the 

watershed impacts the Refuge. Although Malheur Lake is nearly devoid of aquatic vegetation, and it 

has lost much of its natural biological function, the works of man are substantially unnoticeable to 

the casual visitor. Malheur Lake would appear natural to the average visitor who is not familiar with 

historical conditions versus the human-affected ecosystem. Even though Malheur Lake is a highly 

altered ecological system that no longer functions properly, it does meet the wilderness criteria of 

“apparent naturalness.” Naturalness in combination with properly functioning ecosystems is a valued 

attribute. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-9 

Although Malheur Lake meets the “apparent naturalness” criteria, current ecological conditions do 

not meet the requirements of the NWR System mission, nor does the Lake possess biological 

integrity, diversity, or good environmental health. In addition to these criteria, Malheur Lake’s 

suitability for management and preservation as wilderness is evaluated based on the area’s primary 

purpose. The purpose for Malheur Lake is “... a refuge and breeding ground for migratory birds and 

other wild life ...” as defined by Executive Order 7106, dated July 19, 1935. 

Through the Comprehensive Conservation Planning process, the Refuge is developing strategies to 

restore the ecological function of Malheur Lake, thereby enabling the fulfillment of Refuge purpose 

and other mandates. As strategies are developed, they will be based on the best available science, 

including site-specific science that is being currently being compiled through extensive research, 

inventory, and monitoring. The Refuge’s goal is to develop and implement a comprehensive 

restoration strategy for Malheur Lake while striving to retain the area’s natural appearance. 

Malheur Lake does meet “apparent naturalness” from a wilderness standard; however, the purpose 

and other required mandates for Malheur Lake are not being fulfilled under current deteriorated 

biological conditions. For this reason USFWS will delay further wilderness evaluation until 

ecological integrity is restored. 

Harney Lake Unit: The Harney Lake Unit is primarily an alkali playa with a desert scrub vegetation 

component around the periphery. Minimal water flows reach the Harney Lake basin and originate 

primarily from spring systems and Silver Creek. Silver Creek inflows rarely reach the basin due to 

upstream diversions on the adjacent Double-O unit and private lands. Independent of these diversions 

and impoundments, water flows from springs and Silver Creek are insufficient to fill the basin 

annually, and the basin fills completely only during extreme flood events. This alkali playa creates a 

unique and somewhat harsh environment suited for specific flora and fauna. This unit also contains 

the Harney Lake RNA. 

The Harney Lake Unit does not contain alterations by man-made features or biological agents. 

This unit retains much of its natural characteristics and will be further evaluated in Section D.2.5. 

Double-O-Stinking Lake Unit: The Double-O–Stinking Lake Unit is comprised of arid shrubland 

habitat and natural spring systems. This area includes the Stinking Lake RNA. This unit has a welldeveloped wetland system, and the springs have been significantly altered for water management. 

The unit has three water troughs or other watering developments and eight man-made wetland units. 

Water flows in these wetland units are manipulated by 35 water control structures and over 7 miles of 

levees/roads, one borrow ditch, and 19 miles of water delivery ditches. Improved roadways for 

administrative use total almost 10 miles, and public access is allowed along the southern boundary of 

the unit. There are two historic homesteads in the unit. Other developments include an osprey nesting 

platform, two wells, one fish screen, and two bridges. Power lines bisect the unit to service both 

Refuge and private facilities. 

The unit contains approximately 17 miles of fencing with 75 percent of this as interior fence. 

Invasive plants are problematic, especially perennial pepperweed, reed canarygrass, and Canada 

thistle. Non-native common carp are present and represent a serious threat to the native biodiversity; 

this species requires continual and intensive control measures. 

Within the unit is the Stinking Lake RNA. This portion of the unit retains its natural character and 

function; however, this 1,555-acre area does not meet the minimum wilderness size requirements. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-10 Appendix D. Wilderness Review Inventory Phase 

Thus the Double-O–Stinking Lake Unit requires considerable management and contains developed 

features that compromise the natural qualities of the unit and will not be considered further for 

evaluation. 

Double-O–Chappo Unit: The Double-O–Chappo Unit lies adjacent to the Double-O–Stinking Lake 

Unit within the northeastern section of the Double-O Unit. The unit is comprised of arid shrubland 

habitat and outflows from the natural spring systems. This unit has a developed wetland system and 

has one water trough and seven man-made wetland units. Water flows in these wetland units are 

manipulated by 24 water control structures and over 6 miles of levees, 2.5 miles of water delivery 

ditches, and one borrow ditch. There are 4.3 miles of improved roadways for administrative use and 

public access is allowed along portions of these roads. Other developments include public use 

signage and two small bridges. 

In the unit there is approximately 22 miles of fencing, half of which is interior fencing. The unit 

contains a mechanically leveled field used in the past for farming. Invasive plants are problematic, 

especially perennial pepperweed, reed canarygrass, and Canada thistle. Non-native common carp are 

present and represent a serious threat to the native biodiversity; this species requires continual and 

intensive control measures. The unit is intensively manipulated; all water flows are managed with 

numerous man-made structures. Past farming practices have altered the natural plant communities. 

Due to these factors, the unit does not contain the natural qualities to be further considered for 

evaluation. 

Sodhouse-West Unit: The Sodhouse-West Unit consists of lands west of the Center Patrol Road, in 

the northern portion of the Blitzen Valley. The unit has seven man-made wetlands that are 

manipulated by 25 water control structures, 3 miles of dikes, and 32 miles of canals and ditches. The 

unit contains about 20 miles of administrative roads, with an additional 15 miles of public roads 

along the unit boundary, including State Highway 205. Other developments include two historic 

lookout towers and 13 miles of interior fencing; portions of the unit are farmed and hayed. The unit 

contains large acres of invasive weeds, such as perennial pepperweed, reed canarygrass, thistles, and 

cheatgrass; carp are also a significant issue within the waterways and negatively impact the native 

flora and fauna of the site. Due to the presence of non-native species, the highly managed nature of 

the unit, and the man-made developments, this unit does not retain sufficient naturalness to be 

included for further wilderness evaluation. 

Sodhouse-East Unit: The Sodhouse-East Unit is comprised of a section of long linear lands east of 

the Center Patrol Road, including the waters of the Blitzen River. The unit contains one dam and five 

man-made wetlands that are manipulated by 23 water control structures, 8 miles of dikes, and 9 miles 

of canals and ditches. Portions of the unit are farmed for grain crops. The unit contains about 9 miles 

of administrative roads, with an additional 11 miles of public roads. Other developments include four 

bridges, a dam/fish ladder, a gravel pit, and 11 miles of interior fencing. The unit contains large acres 

of invasive weeds, such as perennial pepperweed, reed canarygrass, thistles, and cheatgrass; carp are 

also a significant issue within the waterways and negatively impact the native flora and fauna of the 

site. Due to the presence of non-native species and the highly managed nature of the unit with manmade developments, this unit does not retain sufficient naturalness to be included for further 

evaluation. 

Buena Vista–Unit 8: The Buena Vista–Unit 8 Unit is a linear unit of the Refuge containing one 

water trough, six man-made wetlands that are manipulated by 24 water control structures, 9 miles of 

dikes/levees, and many miles of canals and ditches. Portions of the unit are farmed for grain crops. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-11 

The unit contains about 12 miles of administrative roads, with an additional 5.5 miles of public roads 

and is bordered by State Highway 205. Other developments include four bridges, a dam, a fish 

ladder, two fish screens, a gravel pit, and 11 miles of interior fencing. The unit also contains large 

acres of invasive weeds, such as perennial pepperweed, reed canarygrass, thistles, and cheatgrass; 

carp are also a significant issue within the waterways and negatively impact the native flora and 

fauna of the unit. Due to the presence of non-native species requiring active control, man-made 

developments, and its highly managed nature, this unit does not retain sufficient naturalness nor is of 

sufficient size (4,520 acres) to be included for further evaluation. 

Upper Bridge Creek/Knox Springs Unit: The 1,206-acre Upper Bridge Creek/Knox Springs Unit is 

located adjacent to a BLM Wilderness Study Area. The unit contains one developed spring area and 

one culvert. A managed ditch delivers water from the spring to Refuge wetlands. The unit has 2 miles 

of exterior and 4 miles of interior fence. The unit also has six man-made rock weirs in Bridge Creek. 

Ongoing restoration activities include the use of mechanized equipment for reconnecting creeks to 

floodplains, rehabilitation of waterway embankments, and tree/shrub plantings. Fencing enclosures 

are required for plant establishment during restoration activities. The upland vegetation of the site is 

dominated by non-native crested wheatgrass plantings with almost no remaining native plants. 

Invasive cheatgrass is also prevalent in the unit. Due to the unit’s highly altered ecosystem there is a 

long-term need for non-native grass eradication, revegetation with native forbs and grasses, and an 

ongoing riparian restoration program. Under current conditions, this unit cannot fulfill the Refuge 

purpose, or be considered to have biological integrity, diversity, and environmental health. Because 

of the lack of natural qualities, the Upper Bridge Creek/Knox Springs Unit will not be considered for 

further wilderness evaluation at this time. 

Barnes Springs Unit: The 426-acre Barnes Springs Unit is located adjacent to a BLM Wilderness 

Study Area. The unit contains one developed spring and an adjacent homestead site. Other 

developments include 3.8 miles of boundary fencing and 0.4 miles of roads/trails. This unit also 

contains large acres of invasive weeds, especially medusahead and cheatgrass. The former originates 

and re-infests the Refuge from large infestations on adjacent BLM lands. Medusahead is a 

particularly difficult species to eradicate/control, requiring mechanized spraying and manipulation. 

Juniper encroachment onto this unit requires mechanical thinning and prescribed burning regimes. 

Under current conditions, this unit cannot fulfill the Refuge purpose, or be considered to have 

biological integrity, diversity, and environmental health. Because of the lack of natural qualities, the 

Barnes Springs Unit will not be considered for further wilderness evaluation at this time. 

D.2.5 Evaluation of Opportunities for Outstanding Solitude or 

Primitive/Unconfined Recreation 

Criteria for Evaluation 

In addition to size and naturalness, wilderness areas must provide outstanding opportunities for 

solitude or a primitive and unconfined type of recreation. The area does not need to have outstanding 

opportunities for both elements and does not need to have outstanding opportunities on every acre. 

An area also does not have to be open to public use and access to qualify under these criteria. Each 

area is assessed on its own merits and is not compared to other areas. 

Opportunities for solitude refer to the ability of a visitor to be alone and secluded from other visitors 

in the area. Primitive and unconfined recreation means non-motorized, dispersed outdoor recreation 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-12 Appendix D. Wilderness Review Inventory Phase 

activities that are compatible and do not require developed facilities or mechanical transport. 

Primitive recreation activities may provide opportunities to experience challenge and risk, selfreliance, and adventure. 

Results of Outstanding Solitude or Primitive/Unconfined Recreation Assessment 

The Harney Lake Unit is not open to public use to protect the unit’s unique micro-habitats and the 

importance of the site to wildlife species, such as nesting western snowy plovers. Public use and 

interpretive facilities are planned adjacent to, but not within, the unit. If the unit were open to public 

use, the size of the unit would provide outstanding opportunities for solitude and/or primitive 

recreation. 

D.2.6 Inventory Summary and Conclusion 

Table D-1 summarizes the above evaluation factors for each of the units that were delineated and 

evaluated as described in Section D.2.2. 

The majority of Malheur NWR is a highly altered wetland and upland system. The lands and waters 

were significantly altered both prior to and during Service ownership. The Refuge has actively 

managed these lands to meet the needs of wildlife species at both Refuge and Pacific Flyway levels 

to enable the Refuge to meet its establishing purposes. The effects of management have included 

changes to the soils, flora, and fauna. Man-made developments abound in the form of an extensive 

road system, hundreds of miles of primary dikes, ditches, and fences, altered creeks and river, and 

thousands of water-management structures. 

In this inventory (Phase I) the Harney Lake Unit was found to meet the minimum wilderness criteria 

for size, naturalness, and outstanding opportunities for solitude and primitive/unconfined recreation. 

A total of 31,157 acres were found to have wilderness characteristics, which is 1,157 acres greater 

than the existing WSA proposed in 1969. Based on the findings in this inventory, Harney Lake will 

be further evaluated in the Wilderness Study Phase as a step-down process to the CCP. 

Table D-1. Results of Wilderness Inventory (Phase I) for Malheur NWR 

Refuge Unit Size Naturalness 

Outstanding 

opportunities for solitude 

or primitive/unconfined 

recreation 

Summary: Area will 

move forward for 

Phase II Wilderness 

Study 

Malheur Lake Yes Yes NE No* 

Harney Lake Yes Yes Yes Yes 

Double-O–Stinking 

Lake 

Yes No NE No 

Double-O–Chappo Yes No NE No 

Sodhouse-West Yes No NE No 

Sodhouse-East Yes No NE No 

Upper Bridge 

Creek/Knox Springs 

No* No NE No 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix D. Wilderness Review Inventory Phase D-13 

Refuge Unit Size Naturalness 

Outstanding 

opportunities for solitude 

or primitive/unconfined 

recreation 

Summary: Area will 

move forward for 

Phase II Wilderness 

Study 

Barnes Spring No** No NE No 

Buena Vista–Unit 8 No No NE No 

P Ranch–East No NE NE No 

Notes: 

NE – Not evaluated (once any wilderness criteria was not met, further evaluation was not conducted.) 

* USFWS will delay further wilderness evaluation until ecological integrity is restored. 

**Located adjacent to existing wilderness area or wilderness study area; size requirement does not apply. 

D.3 References 

U.S. Department of the Interior (USDI). 1967. Wilderness Study Areas: Malheur National Wildlife 

Refuge. Fish and Wildlife Service. Bureau of Sport Fisheries and Wildlife. Unpublished 

report on file at Refuge office. 

USDI. 1973. Draft Environmental Statement. Proposed Malheur Wilderness Area, Harney County, 

Oregon. Bureau of Sport Fisheries and Wildlife. Unpublished report on file at Refuge office. 

24 pp. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

D-14 Appendix D. Wilderness Review Inventory Phase 

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White pelican

©Dan Dzurisin

Appendix E

Biological Integrity, Diversity,

and Environmental Health

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix F

Statement of Compliance

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Integrity, Diversity, and Environmental Health E-1 

Appendix E. Biological Integrity, Diversity, and Environmental Health 

The Refuge System Administration Act directs managers to maintain the biological integrity, 

diversity, and environmental health (BIDEH) on refuges for the benefit of present and future 

Americans. Accordingly, the following assessment of BIDEH has been prepared for each of the 

major habitats at Malheur National Wildlife Refuge. 

Table E-1. Biological Integrity, Diversity, and Environmental Health for Malheur National 

Wildlife Refuge 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

Lacustrine (Lakes) 

Malheur Lake fluctuates greatly in 

size, from a typical minimum pool of 

500 acres to approximately 90,000 

acres in the mid-1980s. It has also been 

completely dry (1934) and has 

extended up to 170,000 acres (mid1980s). 

Historically, a chemical and physical 

gradient could be observed from west 

(Mud Lake and directly east of Hwy 

205) to east. The far west side 

consisted of a complex network of 

ponds, islands, and peninsulas. The 

center of the lake was dominated by 

emergent (e.g., hardstem bulrush) 

marshes and interspersed open water 

areas. The eastern side has been highly 

alkaline and contains large areas of 

open water. 

Common emergent species included 

hardstem bulrush, cattail, bur-reed, 

Baltic rush, and various sedges. Open 

water areas included submergent plants 

such as watermilfoil, sago pondweed, 

horned pondweed, coontail, small and 

leafy pondweed, white water buttercup, 

bladderwort, and widgeongrass. 

Soil surveys indicate that emergent 

vegetation responded to existing water 

levels and did not persist in specific 

areas with the exception of river inlets 

and significant spring sources. 

Inflow sources include the 

Blitzen and Silvies rivers and 

Sodhouse Spring. River flows 

are predominantly influenced 

by snowpacks on Steens 

Mountain and Malheur Forest. 

Shallow water levels, annual 

and seasonal fluctuations in 

water depth, and a mosaic of 

permanent and cyclical water 

levels. 

The prevailing chemical 

gradient and variable water 

depths determined the 

composition of plant 

communities throughout the 

lake. 

Ice movement/scouring 

following flood events impact 

topography and reduce the 

presence and cover of 

emergent vegetation. 

Common carp (introduced to 

the system in the early 1900s) 

has decimated the 

productivity of this 

marsh/lake system. They root 

up submergent vegetation and 

dramatically increase 

turbidity. 

Hydrological inputs to the 

lake, particularly from the 

Silvies River, have been 

altered. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

E-2 Appendix E. Biological Integrity, Diversity, and Environmental Health 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

Riverine 

Waterways support riparian 

communities that are appropriate to 

stream channel type. The hydrologic 

floodplains are intact with balanced 

pool/riffle/glide ratios depending on 

slope and substrate. Water turbidity is 

typically low with an appropriate level 

of sediment storage, which buffers 

against the sediment loading of critical 

rearing pools and spawning gravels for 

native fish. 

Boulders, undercut banks, logs, and 

vegetation provide ample hiding cover 

for native fish and other aquatic 

species. Eddies and other slow current 

areas contain abundant populations of 

various aquatic invertebrates. 

Low turbidity also allows a variety of 

native aquatic vegetation to establish 

and propagate in suitable micro niches. 

Streams such as Bridge and 

Mud had 1%-4% gradients and 

were dominated by boulders, 

cobbles, and gravel. The 

Blitzen River had a low 

gradient (<1%) and was 

dominated by gravel and silt 

substrates. Sediment discharge 

and particle size as well as 

streamflow and slope were in 

balance. 

Balance between sinuosity and 

percent slope maintained the 

physiological integrity of the 

channel by reducing velocity 

while intact floodplains 

disperse energy. 

Common carp 

There has been a loss of 

riparian plant diversity due to 

past management and 

competition with invasive 

plant species. 

Channelization of the Blitzen 

River has compromised instream habitat and the 

system’s ability to disperse 

energy during high flow 

events. 

Incised channel. 

Most floodplains are no 

longer functionally active as a 

result of altered hydrology 

from ditching, diversions, and 

dams along the river. 

Woody Riparian 

The Refuge hosts a variety of 

riparian/riverine systems, ranging from 

the Blitzen River itself to various 

tributaries that flow into it from 

neighboring valleys and canyons on the 

northern side of Steens Mountain. 

Although many plant associations are 

found within this broader community, 

the principal woody species include 

various species of willow, redosier 

dogwood, Woods’ rose, golden currant, 

common snowberry, Lewis’ mock 

orange, water birch, and alder. 

Herbaceous groundcover characterized 

by Nebraska sedge, yellow monkeyflower, Northwest cinquefoil, 

American speedwell, woolly sedge, 

slenderbeak sedge, meadow barley, 

Stream bank soils consist of 

gravel and cobble due to 

common flooding disturbance, 

alluvial bars, and very little 

soil development. 

Within the active floodplain, 

the soils are deep and consist 

of pluvial deposits on 

alluvium. 

Reed canarygrass, hemlock, 

perennial pepperweed, and 

other invasives are able to 

out-compete native vegetation 

following most disturbances. 

River channelization 

Historical livestock grazing 

Lowered groundwater table 

Infrastructure (ditches, dams, 

roads) 

Water quality impairments 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Integrity, Diversity, and Environmental Health E-3 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

tufted hairgrass, western yarrow, and 

Baltic rush. Altered hydrology and 

minimum flows 

Broad-scale loss of functional 

connectivity between rivers 

and streams, and their 

floodplains 

Palustrine Emergent (Seasonally Flooded Wet Meadows) 

Wet meadows typically occupy the 

transition zone between marsh and 

moist meadow plant communities. 

Native vegetation includes Baltic rush, 

woolly sedge, Nebraska sedge, 

slenderbeak sedge, arrowgrass, 

meadow barley, tufted hairgrass, 

Nevada bluegrass, western yarrow, 

slender cinquefoil, largeleaf avens, 

Oregon checker mallow, and fringed 

willowherb. 

Surface water is generally 

present during the growing 

season (at least 2 months). 

Only isolated depressions or 

sloughs hold water into the 

early fall. 

Soils are derived from 

alluvium and are very deep 

and poorly drained (pH of 6.6-

7.0). 

Introduced species such as 

Kentucky bluegrass and 

common timothy have 

become “naturalized” within 

these communities, but offer 

habitat structure similar to 

that of many native species. 

Invasive species such as reed 

canarygrass (an introduced 

cultivar), phragmites, and 

perennial pepperweed 

displaced native species. 

Cattails appear to encroach on 

areas that are inundated for 

longer than two months. 

Altered hydrology through 

river channelization and 

ditching as well as 

agricultural practices 

including livestock grazing. 

Palustrine Emergent (Seasonally Flooded Marsh associated with Wet Meadows) 

This habitat type commonly exists 

within mosaics of wet meadow and 

open water. Stand density varies 

greatly and has a maximum height of 

approximately 3 meters (9.8 feet). 

Common emergent plant species 

include bur-reeds, bulrushes, cattails, 

sedges, rushes, and spikerushes. 

Emergent vegetation can 

typically tolerate fluctuations 

in water availability, ranging 

from approximately 1 meter 

above to 10-12 cm (4-5 

inches) below the soil surface. 

Extended periods of standing 

water aid in preventing the 

transition to mesophytic plant 

communities. 

The maintenance of existing 

emergent communities is 

artificial, requiring extensive 

infrastructure and active 

water diversion from the 

Blitzen River, its tributaries, 

and springs. All water 

delivery in the Double-O 

Unit, including Silver Creek 

flows, is highly manipulated. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

E-4 Appendix E. Biological Integrity, Diversity, and Environmental Health 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

Submergent plants such as pondweeds, 

bladderworts, waterweeds, and 

duckweeds occur in nearby open water. 

Willow species can occur along 

elevated ecotones along marsh 

perimeters. 

Emergent marshes existed 

throughout the lower Blitzen 

Valley and became less 

extensive north of Buena 

Vista. 

Associated with very deep, 

very poorly drained soils that 

formed in alluvium, alluvium 

over lacustrine deposits 

derived from igneous rock, or 

organic matter. These soils are 

located on low stream terraces 

and their depressions as well 

as lake basins. 

The natural hydroperiod for 

most marsh communities 

likely existed from spring 

through mid-summer. 

Increased densities of 

emergent vegetation reduce 

boundary habitat for wildlife 

and decrease the diversity of 

this community type. 

Historical livestock grazing 

and haying practices favored 

the establishment of 

meadows. Altered hydrology 

via river channelization and 

the creation of irrigation 

ditches. 

Palustrine Emergent (Semipermanent Flooded Wetland Impoundments) 

These open water habitats are 

semipermanently flooded at depths that 

preclude the development of extensive 

stands of emergent vegetation. 

Submerged and floating plants such as 

common and greater duckweed; 

Canadian waterweed; coontail; 

watermilfoil; common bladderwort; 

white water crowfoot; and sago, 

longleaf, and small pondweed regularly 

occur in open water. Emergent plants 

(e.g., bulrushes, cattails, sedges, 

rushes, spikerushes) occupy shallow 

areas within and alongside open water 

communities. 

With the exception of small 

natural depressions next to 

springs (i.e., Double-O 

Spring), this community type 

has been maintained through 

active and intensive 

management. 

Occasional drawdowns 

(drought) oxidize and 

consolidate substrates to 

facilitate the germination of 

submergent vegetation such as 

sago pondweed. When pond 

and lake bottoms are exposed, 

production of smartweed and 

other desirable native 

colonizers also is often quite 

high, especially on mudflats in 

shallow benches. 

Aging infrastructure and 

management of vegetation 

within water delivery systems 

pose challenges in ensuring 

ready and consistent water 

availability. 

Invasive species such as carp 

and reed canarygrass. 

Historical ditches and canals 

and the removal of beaver 

have altered hydrology. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Integrity, Diversity, and Environmental Health E-5 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

Dry Meadow 

Moist meadows typically occupy the 

transition zone between wet meadow 

and upland plant communities. 

Dominant native grass species include 

creeping wildrye, bluejoint, and 

Nevada bluegrass. Native forbs include 

slender cinquefoil, western yarrow, and 

lanceleaf goldenweed. 

Soils are similar to those of 

wet meadow communities, but 

are generally located in 

slightly elevated areas with 

increased aerobic conditions 

during the growing season. 

Depth to water table typically 

ranges from 0 to -12 inches 

during the growing season. 

Native forb understory has 

been greatly decreased 

through competition with 

invasive species and noxious 

weed treatment. 

These communities are highly 

susceptible to invasion by 

perennial pepperweed. 

Due to the introduction of 

irrigation infrastructure and 

the leveling of some 

meadows in the early 

twentieth century, the extent 

of this community has likely 

been reduced. 

Salt Desert Scrub 

This plant community resides in barren 

alkali flats or alkaline valley 

bottomlands. It consists of widely 

spaced shrubs with dense patches of 

rhizomatous grasses with low densities 

of other annual and perennial grasses 

and succulent forbs. 

Plant species include black 

greasewood, inland saltgrass, alkali 

sacaton, alkali cordgrass, and alkali 

bluegrass. Mat muhly and Sandberg 

bluegrass may be present in mosaics, 

which exhibit more moderate 

conditions (lower pH). 

Infrequent inundation of outer 

playa areas or wind erosion 

from these playas distributes 

salts to nearby low-lying areas, 

causing elevations in alkalinity 

and pH, which favor this 

community association. 

Heavy livestock grazing may 

compromise plant species 

diversity in more moderate 

areas within this plant 

community type. 

Sagebrush Lowland 

Commonly found in swales, toeslopes, 

the base of alluvial fans, and adjacent 

to moist meadow communities within 

the Blitzen Valley. 

Native plant species include native 

Sites are moist or wet in the 

spring and dry by midsummer. 

Associated species are fairly 

tolerant of high soil sodium 

Susceptible to invasive plants 

such as cheatgrass and 

perennial pepperweed 

invasion. 

Historical livestock grazing 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

E-6 Appendix E. Biological Integrity, Diversity, and Environmental Health 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

shrubs (e.g., Wyoming big sagebrush, 

basin big sagebrush, rabbitbrush, 

bitterbrush, and horsebrush) 

interspersed with bunchgrasses such as 

basin wildrye, Sandberg bluegrass, 

crested wheatgrass, needle and thread, 

and Indian ricegrass. 

These sites are typically forb-poor. 

content and alkalinity. 

Soils are generally deep and 

have moderate water-holding 

capacity (sandy loams). 

decreased plant species 

diversity in many of these 

areas. 

Sagebrush Steppe 

This community is dominated by 

shrubs with an understory of various 

bunchgrass and forb species found 

within interspaces. It can be found 

above greasewood/basin big sagebrush 

communities on various aspects, 

slopes, and soil types. 

Plant species include Wyoming big 

sagebrush, low sagebrush, bluebunch 

wheatgrass, Sandberg bluegrass, 

bottlebrush squirreltail, Idaho fescue, 

needle and thread, Thurber’s 

needlegrass, western yarrow, arrowleaf 

balsamroot, and various locoweed and 

phlox species. 

A gradient in soil depth 

determines whether Wyoming 

big sagebrush or low 

sagebrush dominates a site. 

Low sagebrush sites typically 

host higher densities of forbs 

due to higher concentrations of 

available soil moisture due to 

shallow, rocky conditions. 

These communities depend on 

natural fire cycles or 

equivalent disturbances to 

maintain a balance between 

shrub, grass, and forb 

components. A lack of 

disturbance lends itself to high 

shrub densities with sparse 

vegetation in the interspaces. 

Invasive plants (especially 

cheatgrass) have 

compromised many sites 

from recovering naturally 

from wildfire. 

Livestock grazing 

Juniper encroachment from 

historical fire suppression 

greatly reduced native shrub 

densities and increased soil 

erosion. 

Medusahead infests clay sites 

and is capable of outcompeting native grasses and 

forbs in the understory. 

Much of this habitat has been 

replaced on the Refuge with 

crested wheatgrass 

monocultures after wildfires. 

Dune 

Open sand dunes hosting with widely 

spaced shrubs, grasses, and forbs 

located adjacent to playa basins. 

Shrubs include shortspine horsebrush, 

fourwing saltbush, bud sagebrush, 

green and gray rabbitbrush, and basin 

big sagebrush. Grasses include Indian 

These plant communities are 

created by wind erosion off 

nearby dry playa bottoms (i.e., 

Stinking Lake and Harney 

Lake). 

As sites deteriorate (loss of 

vegetative cover and increased 

Susceptible to invasion by 

halogeton, povertyweed, and 

Russian thistle 

Agricultural practices have 

altered plant community 

composition and succession 

in many dune areas. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix E. Biological Integrity, Diversity, and Environmental Health E-7 

Characteristics of the Community 

(Structure, Seral Stage, Species 

Composition, Age Class) 

Natural Processes 

Responsible for these 

Conditions 

Limiting Factors 

ricegrass, needle and thread, 

bottlebrush squirreltail, and alkali 

sacaton. Forbs include tufted evening 

primrose, Paiute suncup, Geyer’s 

milkvetch, sharpleaf penstemon, and 

various lupines. 

wind erosion), a shift toward 

black greasewood and inland 

saltgrass is possible. 

Soils are formed by lacustrine 

sands and are neutral to 

moderately alkaline (pH 8.2). 

They are moist in the winter 

and spring and are usually dry 

June through October. 

Low available water capacity 

on or near the soil surface 

limits the survival of 

seedlings. 

Drought-prone 

Playa 

Virtually no vascular plants reside 

within Harney and Stinking lakes, with 

the exception of spring areas where 

steady freshwater inflows modify 

water chemistry. 

High water events provide temporary 

opportunities for aquatic plants and 

animals (i.e., sago pondweed and tui 

chub) to increase. 

These systems are rich in invertebrates 

such as brine flies and brine shrimp. 

Evaporation of closed basin 

water results in high levels of 

alkalinity and associated pH. 

Dilution during high water 

events stimulates temporary 

production of aquatic species. 

Soils are typically very deep 

and poorly drained and were 

formed in volcanic lacustrine 

deposits. Texture commonly 

consists of silty clay loam and 

is strongly alkaline (10.5), 

with pH dropping to 8.0 at 

approximately 50 inches 

depth. 

Altered irrigation/water 

movement patterns may have 

disrupted natural water level 

cycles (particularly in 

Stinking Lake). 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

E-8 Appendix E. Biological Integrity, Diversity, and Environmental Health 

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Mule deer buck

©Barbara Wheeler

Appendix F

Statement of Compliance

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix G

Integrated Pest Management

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Statement of Compliance F-1 

Appendix F. Statement of Compliance 

The following executive orders and legislative acts have been reviewed as they apply to the 

implementation of the Comprehensive Conservation Plan (CCP) for Malheur National Wildlife 

Refuge, located in Oregon. 

 

National Environmental Policy Act (1969) (42 U.S.C. 4321 et seq.). The planning process has 

been conducted in accordance with National Environmental Policy Act (NEPA) Implementing 

Procedures, with Department of Interior and Fish and Wildlife Service procedures, and in 

coordination with the affected public. The requirements of NEPA (42 U.S.C. 4321 et seq.) and its 

implementing regulations in 40 C.F.R. 1500-1508 have been satisfied in the procedures used to reach 

this decision. These procedures included the development of a range of alternatives for the Malheur 

Refuge CCP; analysis of the likely effects of each alternative; and public involvement throughout the 

planning process. The affected public was notified of the availability of documents through Federal 

Register notices, news releases to local newspapers, the Service’s refuge planning website, and 

planning updates. Copies of the final CCP have been distributed to an extensive mailing list. In 

addition, the Service hosted a variety of public scoping events in 2009 (see Appendix J). 

National Historic Preservation Act (1966) (16 U.S.C. 470 et seq.). The management of the 

archaeological and cultural resources of Malheur Refuge will comply with the regulations of Section 

106 of the National Historic Preservation Act (NHPA). No historic properties are known to be 

affected by the proposed action based on the criteria of an effect or adverse effect as an undertaking 

defined in 36 C.F.R. 800.9 and Service Manual 614 FW 2; however, determining whether a 

particular action has the potential to affect cultural resources is an ongoing process that occurs as 

step-down and site-specific project plans are developed. Should historic properties be identified or 

acquired in the future, the Service will comply with the NHPA if any management actions have the 

potential to affect any of these properties. 

 

Endangered Species Act (16 U.S.C. 1531-1544). This Act provides for the conservation of 

threatened and endangered species of fish, wildlife, and plants by Federal action and by encouraging 

the establishment of state programs. Documentation is required under Section 7 of the Act. Refuge 

policy requires the Refuge Manager to document issues that affect or may affect endangered species 

before initiating projects. At this time there are no species listed as endangered or threatened 

inhabiting the Refuge. Effects to candidate species have been considered and are described in 

Chapter 6 of the CCP/EIS and in the Compatibility Determinations (Appendix B). Consultation on 

specific projects will be conducted prior to implementation to avoid any adverse impacts to these 

species and their habitat. 

 

Executive Order 12372, Intergovernmental Review. Coordination and consultation with affected 

tribal, local, and state governments, other Federal agencies, and local interested persons has been 

completed through personal contact by Refuge staff and Refuge supervisors. 

 

Executive Order 11988, Floodplain Management. Under this order, Federal agencies “shall take 

action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and 

welfare, and to restore and preserve the natural and beneficial values served by floodplains.” The 

CCP is consistent with Executive Order 11988 because CCP implementation would maintain a 

number of dams and diversions on the Blitzen River system, which would minimize impacts to 

human safety, health, and welfare, from floods. The proposed action may restore floodplain 

connectivity along the Blitzen River system when and where feasible. In the interim, managed 

wetlands, marshes, and meadows located in the historical floodplain will continue to contribute to the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

F-2 Appendix F. Statement of Compliance 

natural and beneficial fish and wildlife resource values unique to the area. 

Wilderness Act of 1964. The Service has evaluated the suitability of the Refuge for wilderness 

designation (Appendix D) through the “Inventory” phase according to the guidelines of the 

Wilderness Review process as described in 610 FW 4. In this inventory (Phase I), the Harney Lake 

Unit was found to meet the minimum wilderness criteria for size, naturalness, and outstanding 

opportunities for solitude and primitive/unconfined recreation. A total of 31,157 acres were found to 

have wilderness characteristics. Based on the findings in this inventory, Harney Lake will be further 

evaluated in the “Study” phase as a step-down process to the CCP. 

Executive Order 11990, Protection of Wetlands. The CCP is consistent with Executive Order 

11990 because CCP implementation would potentially enhance and restore wetland resources on the 

Refuge. 

National Wildlife Administration Act of 1966, as amended by the National Wildlife Refuge 

System Improvement Act of 1997 (16 U.S.C. 668dd-668ee). The National Wildlife Refuge System

Improvement Act (Public Law 105-57, Improvement Act) requires the Service to develop and

implement a CCP for each refuge. The CCP identifies and describes Refuge purposes; Refuge vision 

and goals; fish, wildlife, and plant populations and related habitats in the Refuge; archaeological and 

cultural values of the Refuge; issues that may affect populations and habitats of fish, wildlife, and 

plants; actions necessary to restore and improve biological diversity on the Refuge; and opportunities 

for wildlife-dependent recreation, as required by the Act. During our planning process, the Refuge 

Manager evaluated all the Refuge’s existing and proposed uses for appropriateness. The Refuge’s 

priority wildlife-dependent uses—wildlife observation, interpretation, photography, environmental 

education, waterfowl hunting, upland game hunting, and fishing—are automatically deemed 

appropriate under Service policy. Other uses were found to be appropriate, including commercial 

tours and photography, grazing and haying, gathering culturally important plants, conducting 

research, and farming. We completed compatibility determinations for all of the appropriate uses. 

Executive Order 12898. Federal Actions to Address Environmental Justice in Minority and 

Low-Income Populations. All Federal actions must address and identify, as appropriate,

disproportionately high and adverse human health or environmental effects of its programs, policies,

and activities on minority populations, low-income populations, and Indian tribes in the United

States. The CCP was evaluated, and no adverse human health or environmental effects were

identified for minority or low-income populations, Indian tribes, or anyone else. 

Executive Order 13186, Responsibilities of Federal Agencies to Protect Migratory Birds. This 

Order directs agencies to take certain actions to further implement the Migratory Bird Treaty Act. A 

provision of the Order directs Federal agencies to consider the impacts of their activities, especially 

in reference to birds on the Fish and Wildlife Service’s list of Birds of Conservation Concern. It also 

directs agencies to incorporate conservation recommendations and objectives in the North American 

Waterbird Conservation Plan and bird conservation plans developed by Partners in Flight into agency 

planning as described in Chapter 1. The effects of all alternatives to Refuge habitats used by 

migratory birds were assessed within the CCP/EIS. 

Executive Order 13175, Consultation and Coordination with Indian Tribal Governments. As 

required under the Secretary of the Interior’s Secretarial Order 3206—American Indian Tribal 

Rights, Federal-Tribal Trust Responsibilities, and the Endangered Species Act—the Project Leader 

notified and consulted interested tribes. The Service consulted with the Burns Paiute Tribe 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix F. Statement of Compliance F-3 

throughout the Service’s planning process.

Architectural Barriers Act of 1968. This Act requires facilities designed, built, altered, or leased 

with Federal funds to be accessible for persons with mobility impairments. Accessibility planning 

was integrated into our CCP process, and specific actions are identified in Chapter 2 of the CCP. 

Integrated Pest Management. This plan conforms to Department of the Interior Pesticide Use 

Policy as described in 517 DM 1.1 and the Service’s Integrated Pest Management (569 FW 1) policy.

An integrated pest management approach has been adopted to eradicate, control, or contain pest and 

invasive species on the Refuge. In accordance with 517 DM 1, only pesticides registered with the 

Environmental Protection Agency (EPA) in full compliance with the Federal Insecticide, Fungicide, 

and Rodenticide Act and as provided in regulations, orders, or permits issued by EPA may be applied 

on lands and waters under Refuge jurisdiction. 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

F-4 Appendix F. Statement of Compliance 

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Carp

USFWS

Appendix G

Integrated Pest

Management Plan

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix H

Glossary & Acronyms

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-1 

Appendix G. Integrated Pest Management Plan 

G.1 Background 

Integrated Pest Management (IPM) is an interdisciplinary approach using methods to prevent, 

eliminate, contain, and/or control pest species in concert with other management activities on refuge 

lands and waters to achieve wildlife and habitat management goals and objectives. IPM is also a 

scientific, adaptive management process where available scientific information and best professional 

judgment of the refuge staff as well as other resource experts are used to identify and implement 

appropriate management strategies that can be modified and/or changed over time to ensure 

effective, site-specific management of pest species to achieve desired outcomes. In accordance with 

43 CFR 46.145, adaptive management is particularly relevant where long-term impacts may be 

uncertain, and future monitoring will be needed to make adjustments in subsequent implementation 

decisions. After a tolerable pest population (threshold) is determined considering the achievement of 

refuge resource objectives and the ecology of pest species, one or more methods, or combinations 

thereof, will be selected that are feasible, efficacious, and most protective of non-target resources, 

including native species (fish, wildlife, and plants), and Service personnel, Service-authorized agents, 

volunteers, and the public. Staff time and available funding will be considered when determining 

feasibility/practicality of various treatments. 

IPM techniques to address pests are presented as CCP strategies (see Chapter 2 of this CCP) in an 

adaptive management context to achieve refuge resource objectives. In order to satisfy requirements 

for IPM planning as identified in the Director’s Memo (dated September 9, 2004) entitled Integrated 

Pest Management Plans and Pesticide Use Proposals: Updates, Guidance, and an Online Database, 

the following elements of an IPM program have been incorporated into this CCP: 

 Habitat and/or wildlife objectives that identify pest species and appropriate thresholds to 

indicate the need for and successful implementation of IPM techniques; and 

 Monitoring before and/or after treatment to assess progress toward achieving objectives 

including pest thresholds. 

Where pesticides would be necessary to address pests, this appendix provides a structured procedure 

to evaluate the potential effects of proposed uses involving ground-based applications to refuge 

biological resources, and environmental quality in accordance with effects analyses which were 

presented in Chapter 6, Environmental Effects, of the Final Malheur Refuge CCP/EIS. Only pesticide 

uses that would likely cause minor, temporary, or localized effects to refuge biological resources and 

environmental quality with appropriate best management practices (BMPs), where necessary, would 

be allowed for use on the refuge. 

This appendix does not describe the more detailed process to evaluate potential effects associated 

with aerial applications of pesticides. Moreover, it does not address the effects of mosquito control 

with pesticides (larvicides, pupacides, or adulticides) based upon identified human health threats and 

presence of disease-carrying mosquitoes in sufficient numbers from monitoring conducted on a 

refuge. However, the basic framework to assess potential effects to refuge biological resources and 

environmental quality from aerial application of pesticides or use of insecticides for mosquito 

management would be similar to the process described in this appendix for ground-based treatments 

of other pesticides. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-2 Appendix G. Integrated Pest Management Plan 

G.2 Pest Management Laws and Policies 

In accordance with Service policy 569 FW 1 (Integrated Pest Management), plant, invertebrate, and 

vertebrate pests on units of the National Wildlife Refuge System can be controlled to ensure balanced 

wildlife and fish populations in support of refuge-specific wildlife and habitat management 

objectives. Pest control on federal (refuge) lands and waters also is authorized under the following 

legal mandates: 

 National Wildlife Refuge System Administration Act of 1966, as amended (16 USC 668dd668ee); 

 Plant Protection Act of 2000 (7 USC 7701 et seq); 

 Noxious Weed Control and Eradication Act of 2004 (7 USC 7781-7786, Subtitle E); 

 Federal Insecticide, Fungicide, and Rodenticide Act of 1996 (7 USC 136-136y); 

 National Invasive Species Act of 1996 (16 USC 4701); 

 Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 USC 4701); 

 Food Quality Protection Act of 1996 (7 USC 136); 

 Executive Order 13148, Section 601(a); 

 Executive Order 13112; and 

 Animal Damage Control Act of 1931 (7 USC 426-426c, 46 Stat. 1468). 

Pests are defined as “...living organisms that may interfere with the site-specific purposes, 

operations, or management objectives or that jeopardize human health or safety” by Department 

policy 517 DM 1 (Integrated Pest Management Policy). Similarly, 569 FW 1 defines pests as 

“...invasive plants and introduced or native organisms that may interfere with achieving our 

management goals and objectives on or off our lands, or that jeopardize human health or safety.” 517 

DM 1 also defines an invasive species as “a species that is non-native to the ecosystem under 

consideration and whose introduction causes or is likely to cause economic or environmental harm or 

harm to human health.” Throughout the remainder of this CCP, the terms pest and invasive species

are used interchangeably because both can prevent/impede achievement of refuge wildlife and 

habitat objectives and/or degrade environmental quality. 

In general, control of pests (vertebrate or invertebrate) on a refuge would conserve and protect the 

nation’s fish, wildlife, and plant resources as well as maintain environmental quality. Per 569 FW 1, 

animal or plant species that are considered pests may be managed if the following criteria are met: 

 Threat to human health and well-being or private property, the acceptable level of damage by 

the pest has been exceeded, or state or local government has designated the pest as noxious; 

 Detrimental to resource objectives as specified in a refuge resource management plan (e.g., 

comprehensive conservation plan, habitat management plan), if available; and 

 Control would not conflict with attainment of resource objectives or the purposes for which 

the refuge was established. 

The specific justifications for pest management activities on the refuge are the following: 

 Protect human health and well-being; 

 Prevent substantial damage to important refuge resources; 

 Protect newly introduced native species or re-establish them; 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-3 

 Control non-native (exotic) species in order to support existence for populations of native 

species; 

 Prevent damage to private property; and 

 Provide the public with quality, compatible wildlife-dependent recreational opportunities. 

In accordance with Service policy 620 FW 1 (Habitat Management Plans), there are additional 

management directives regarding invasive species found on refuges: 

 “We are prohibited by Executive Order, law, and policy from authorizing, funding, or 

carrying out actions that are likely to cause or promote the introduction or spread of invasive 

species in the United States or elsewhere.” 

 “Manage invasive species to improve or stabilize biotic communities to minimize 

unacceptable change to ecosystem structure and function and prevent new and expanded 

infestations of invasive species. Conduct refuge habitat management activities to prevent, 

control, or eradicate invasive species...” 

Animal species damaging/destroying federal property and/or detrimental to the management program 

of a refuge may be controlled as described in 50 CFR 31.14 (Official Animal Control Operations).

For example, the incidental removal of beavers damaging refuge infrastructure (e.g., clogging, with 

subsequent damage of water control structures) and/or negatively affecting habitats (e.g., removing 

woody species from existing or restored riparian zones) managed on refuge lands may be conducted 

without a pest control proposal. We recognize beavers are native species and most of their activities 

on refuge lands represent a natural process beneficial for maintaining wetland habitats. Though 

currently not found on the refuge, exotic nutria can also be controlled using the most effective 

techniques considering site-specific factors without a pest control proposal. Along with the loss of 

quality wetland habitats associated with breaching of impoundments, the safety of refuge staff and 

the public (e.g., auto tour routes) can be under threat when they drive on structurally compromised 

levees and dikes that may result in sudden and unexpected cave-ins. 

Trespass and feral animals also may be controlled on refuge lands. Based upon 50 CFR 28.43 

(Destruction of Dogs and Cats), dogs and cats running at large on a national wildlife refuge and 

observed in the act of killing, injuring, harassing, or molesting humans or wildlife may be disposed 

of in the interest of public safety and protection of the wildlife. Feral animals should be disposed by 

the most humane method(s) available and in accordance with relevant Service directives (including 

Executive Order 11643). Disposed wildlife specimens may be donated or loaned to public 

institutions. Donation or loans of resident wildlife species will only be made after securing state 

approval (50 CFR 30.11 [Donation and Loan of Wildlife Specimens]). Surplus wildlife specimens 

may be sold alive or butchered, dressed, and processed subject to federal and state laws and 

regulations (50 CFR 30.12 [Sale of Wildlife Specimens]). 

G.3 Strategies 

To fully embrace IPM as identified in 569 FW 1, the following strategies, where applicable, would 

be carefully considered on the refuge for each pest species: 

 Prevention. This would be the most effective and least expensive long-term management 

option for pests. It encompasses methods to prevent new introductions or the spread of 

established pests to un-infested areas. It requires identifying potential routes of invasion to 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-4 Appendix G. Integrated Pest Management Plan 

reduce the likelihood of infestation. Hazard Analysis and Critical Control Points (HACCP) 

planning can be used to determine if current management activities on a refuge may 

introduce and/or spread invasive species in order to identify appropriate BMPs for 

prevention. See http://www.haccp-nrm.org/ for more information about HACCP planning. 

Prevention may include source reduction, using pathogen-free or weed-free seeds or fill, 

exclusion methods (e.g., barriers), and/or sanitation methods (e.g., wash stations) to prevent 

re-introductions by various mechanisms including vehicles, personnel, livestock, and horses. 

Because invasive species are frequently the first to establish newly disturbed sites, prevention 

would require a reporting mechanism for early detection of new pest occurrences with quick 

response to eliminate any new satellite pest populations. Prevention would also require 

consideration of the scale and scope of land management activities that may promote pest 

establishment within un-infested areas or promote reproduction and spread of existing 

populations. Along with preventing initial introduction, prevention would involve halting the 

spread of existing infestations to new sites (Mullin et al. 2000). The primary reason for 

prevention would be to keep pest-free lands or waters from becoming infested. Executive 

Order 11312 emphasizes the priority for prevention with respect to managing pests. 

The following would be methods to prevent the introduction and/or spread of pests on refuge 

lands: 

o Before beginning ground-disturbing activities (e.g., disking, scraping), inventory and 

prioritize pest infestations in project operating areas and along access routes. Refuge staff 

would identify pest species on-site or within reasonably expected potential invasion 

vicinity. Where possible, the refuge staff would begin project activities in un-infested 

areas before working in pest-infested areas. 

o The refuge staff would locate and use pest-free project staging areas. They would avoid 

or minimize travel through pest-infested areas or restrict it to those periods when spread 

of seed or propagules of invasive plants would be least likely. 

o The refuge staff would determine the need for and, when appropriate, identify sanitation 

sites where equipment can be cleaned of pests. Where possible, the refuge staff would 

clean equipment at on-refuge approved cleaning site(s) before entering project lands. This 

practice does not pertain to vehicles traveling frequently in and out of the project area 

that will remain on roadways. Seeds and plant parts of pest plants would need to be 

collected, where practical. The refuge staff would remove mud, dirt, and plant parts from 

project equipment before moving it into a project area. 

o The refuge staff would clean all equipment before leaving the project site, if operating in 

areas infested with pests. The refuge staff would determine the need for, and when 

appropriate, identify sanitation sites where equipment can be cleaned.

o Refuge staff, their authorized agents, and refuge volunteers would, where possible, 

inspect, remove, and properly dispose of seed and parts of invasive plants found on their 

clothing and equipment. Proper disposal means bagging the seeds and plant parts and 

then properly discarding of them (e.g., incinerating).

o The refuge staff would evaluate options, including closure, to restrict the traffic on sites 

with ongoing restoration of desired vegetation. The refuge staff would revegetate 

disturbed soil (except travel ways on surfaced projects) to optimize plant establishment 

for each specific site. Revegetation may include topsoil replacement, planting, seeding, 

fertilization, liming, and weed-free mulching as necessary. The refuge staff would use 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-5 

native material, where appropriate and feasible. They would also use certified weed-free 

or weed- and seed-free hay or straw where certified materials are reasonably available. 

o The refuge staff would provide information, training, and appropriate pest identification 

materials to permit holders and recreational visitors. The refuge staff would educate them 

about pest identification, biology, impacts, and effective prevention measures.

o The refuge staff would require grazing permittees to use preventative measures for their 

livestock while on refuge lands. 

o The refuge staff would inspect borrow material for invasive plants prior to use and 

transport onto and/or within refuge lands. 

o The refuge staff would consider invasive plants when planning for road maintenance 

activities. 

o The refuge staff would restrict off-road travel to designated routes. 

The following are methods to prevent the introduction and/or spread of pests into refuge 

waters: 

o The refuge staff would inspect boats (including air boats), trailers, and other boating 

equipment. Where possible, the refuge staff would remove any visible plants, animals, or 

mud before leaving any waters or boat launching facilities. Where possible, the refuge 

staff would drain water from motor, live well, bilge, and transom wells while on land 

before leaving the site. If possible, the refuge staff would wash and dry boats, 

downriggers, anchors, nets, floors of boats, propellers, axles, trailers, and other boating 

equipment to kill pests not visible at the boat launch. 

o Where feasible, the refuge staff would maintain a l00-foot buffer of aquatic pest-free 

clearance around boat launches and docks or quarantine areas when cleaning around 

culverts, canals, or irrigation sites. Where possible, the refuge staff would inspect and 

clean equipment before moving to new sites or one project area to another. 

These prevention methods to minimize/eliminate the introduction and/or spread of pests were taken 

verbatim or slightly modified from Appendix E of the Pacific Northwest Region Invasive Plant 

Program Final Environmental Impact Statement (U.S. Forest Service 2005). 

 Mechanical/Physical Methods. These methods would remove and destroy, disrupt the 

growth of, or interfere with the reproduction of pest species. For plant species, these 

treatments can be accomplished by hand, hand tools (manual), or power tools (mechanical) 

and include pulling, grubbing, digging, tilling/disking, cutting, swathing, grinding, sheering, 

girdling, mowing, and mulching of the pest plants. 

For animal species, Service employees or their authorized agents could use 

mechanical/physical methods (including trapping) to control pests as a refuge management 

activity. Based upon 50 CFR 31.2, trapping can be used on a refuge to reduce surplus wildlife 

populations for a “balanced conservation program” in accordance with federal or state laws 

and regulations. In some cases, non-lethally trapped animals would be relocated to off-refuge 

sites with prior approval from the state. 

Each of these tools would be efficacious to some degree and applicable to specific situations. 

In general, mechanical methods can effectively control annual and biennial pest plants. 

However, to control perennial plants, the root system has to be destroyed or it would resprout and continue to grow and develop. Mechanical controls are typically not capable of 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-6 Appendix G. Integrated Pest Management Plan 

destroying a perennial plant’s root system. Although some mechanical tools (e.g., disking, 

plowing) may damage root systems, they may stimulate regrowth, producing a denser plant 

population that may aid in the spread of the plant, depending upon the target species (e.g., 

Canada thistle). In addition, steep terrain and soil conditions would be major factors that can 

limit the use of many mechanical control methods. 

Some mechanical control methods (e.g., mowing), which would be used in combination with 

herbicides, can be very effective techniques to control perennial species. For example, 

mowing perennial plants followed sequentially by treating the plant regrowth with a systemic 

herbicide would often improve the efficacy of the herbicide compared to herbicide treatment 

alone. 

 Horticultural Methods. These methods involve manipulating habitat to increase pest 

mortality by reducing its suitability to the pest. Horticultural methods would include waterlevel manipulation, mulching, planting winter cover crops, changing planting dates to 

minimize pest impact, prescribed burning (which facilitates revegetation, increases herbicide 

efficacy, and removes litter to assist in emergence of desirable species), flaming with propane 

torches, planting trap crops, introducing crop rotations that include non-susceptible crops, 

moisture management, addition of beneficial insect habitat, reducing clutter, proper trash 

disposal, planting or seeding desirable species to shade or outcompete invasive plants, 

applying fertilizer to enhance desirable vegetation, prescriptive grazing, and other habitat 

alterations. 

 Biological Control Agents. Classical biological control would involve the deliberate 

introduction and management of natural enemies (parasites, predators, or pathogens) to 

reduce pest populations. Many of the most ecologically or economically damaging pest 

species in the United States originated in foreign countries. These newly introduced pests, 

which are free from natural enemies found in their country or region of origin, may have a 

competitive advantage over cultivated and native species. This competitive advantage often 

allows introduced species to flourish, and they may cause widespread economic damage to 

crops or outcompete and displace native vegetation. Once the introduced pest species’ 

population reaches a certain level, traditional methods of pest management may be cost 

prohibitive or impractical. Biological controls typically are used when these pest populations 

have become so widespread that eradication or effective control would be difficult or no 

longer practical. 

Biological control has advantages as well as disadvantages. Benefits include reducing 

pesticide usage, host specificity for target pests, long-term self-perpetuating control, low cost 

per acre, capacity for searching and locating hosts, synchronizing biological control agents to 

hosts’ life cycles, and the unlikelihood that hosts will develop resistance to agents. 

Disadvantages would include the following: limited availability of agents from their native 

lands, the dependence of control on target species density, slow rate at which control occurs, 

biotype matching, the difficulty and expense of conflicts over control of the target pest, and 

host specificity when host populations are low. 

A reduction in target species’ populations from biological controls is typically a slow 

process, and efficacy can be highly variable. It may not work well in a particular area even 

though it works in another area. Biological control agents require specific environmental 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-7 

conditions to survive over time. Some of these conditions are understood, whereas others are 

only partially understood or not at all. 

Biological control agents do not eradicate a target pest. When using biological control agents, 

residual levels of the target pest typically are expected; the agent population level or survival 

would be dependent upon the density of its host. After the pest population decreases, the 

population of the biological control agent would decrease correspondingly. This is a natural 

cycle. Some pest populations (e.g., invasive plants) tend to persist for several years after a 

biological control agent becomes established due to seed reserves in the soil, inefficiencies in 

the agent’s search behavior, and the natural lag in population buildup of the agent. 

The full range of pest groups potentially found on refuge lands and waters include 

microorganisms, invertebrates (insects, mollusks), vertebrates, and invasive plants (the most 

common group). Often it is assumed that biological control would address many, if not most, 

of these pest problems. There are several well-documented success stories of biological 

control of invasive weed species in the Pacific Northwest including Mediterranean sage, St. 

John’s wort (Klamath weed), and tansy ragwort. Emerging success stories include Dalmatian 

toadflax, diffuse knapweed, leafy spurge, purple loosestrife, and yellow star thistle. However, 

historically, each new introduction of a biological control agent in the United States has only 

about a 30 percent success rate (Coombs et al. 2004). Refer to Coombs et al. (2004) for the 

status of biological control agents for invasive plants in the Pacific Northwest. 

Introduced species without desirable close relatives in the United States would generally be 

selected as biological controls. Natural enemies that are restricted to one or a few closely 

related plants in their country of origin are targeted as biological controls (Center et al. 1997; 

Hasan and Ayres 1990). 

The refuge staff would ensure introduced agents are approved by the applicable authorities. 

Except for a small number of formulated biological control products registered by U.S. 

Environmental Protection Agency (USEPA) under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA), most biological control agents are regulated by the U.S. 

Department of Agriculture’s (USDA’s) Animal Plant Health Inspection Service - Plant 

Protection and Quarantine (APHIS-PPQ). State departments of agriculture and, in some 

cases, county agricultural commissioners or weed districts have additional approval authority.

Federal permits (USDA-APHIS-PPQ Form 526) are required to import biocontrol agents 

from another state. Form 526 may be obtained by writing to: 

 USDA-APHIS-PPQ 

 Biological Assessment and Taxonomic Support 

 4700 River Road, Unit 113 

 Riverdale, MD 20737 

or 

through the Internet at: 

http://www.aphis.usda.gov/ppq/permits/bioligical/weedbio.html. 

The Service strongly supports the development and legal and responsible use of appropriate, 

safe, and effective biological control agents for nuisance and non-indigenous or pest species. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-8 Appendix G. Integrated Pest Management Plan 

State and county agriculture departments may also be sources for biological control agents or 

they may have information about where biological control agents may be obtained. 

Commercial sources should have an Application and Permit to Move Live Plant Pests and 

Noxious Weeds (USDA-PPQ Form 226 USDA-APHIS-PPQ, Biological Assessment and 

Taxonomic Support, 4700 River Road, Unit 113, Riverdale, MD 20737) to release specific 

biological control agents in a state and/or county. Furthermore, certification regarding the 

biological control agent’s identity (genus, specific epithet, subspecies, and variety) and purity 

(e.g., parasite free, pathogen free, and biotic and abiotic contaminants) should be specified in 

purchase orders. 

Biological control agents are subject to 7 RM 8 (Exotic Species Introduction and 

Management). In addition, the refuge staff would follow the International Code of Best 

Practice for Classical Biological Control of Weeds as ratified by delegates to the 

International Symposium on Biological Control of Weeds (Balciunas 2000). This code 

identifies the following: 

o Release only approved biological control agents, 

o Use the most effective agents, 

o Document releases, and 

o Monitor for impact to the target pest, non-target species, and the environment. 

Biological control agents formulated as pesticide products and registered by the USEPA 

(e.g., Bti) are also subject to pesticide use proposals (PUP) review and approval (see below). 

A record of all releases would be maintained with date(s), location(s), and environmental 

conditions of the release site(s); the identity, quantity, and condition of the biological control 

agents released; and other relevant data and comments such as weather conditions. 

Systematic monitoring to determine the establishment and effectiveness of the release is also 

recommended. 

National Environmental Policy Act (NEPA) documents regarding biological and other 

environmental effects of biological control agents prepared by another federal agency, where 

the scope is relevant to evaluation of releases on refuge lands, would be reviewed. Possible 

source agencies for such NEPA documents include the Bureau of Land Management (BLM), 

the U.S. Forest Service, the National Park Service, the USDA-APHIS, and the military 

services. It might be appropriate to incorporate, by reference, parts or all of existing 

document(s) from the review. Incorporating by reference (43 CFR 46.135) is a technique 

used to avoid redundancies in analysis. It also can reduce the bulk of a Service NEPA 

document, which must only identify the documents that are incorporated by reference. In 

addition, relevant portions must be summarized in the Service NEPA document to the extent 

necessary to provide the decision maker and public with an understanding of the relevance of 

the referenced material to the current analysis. 

 Pesticides. The selective use of pesticides would be based upon pest ecology (including 

mode of reproduction), the size and distribution of pest populations, site-specific conditions 

(e.g., soils, topography), known efficacy under similar site conditions, and the capability to 

use BMPs to reduce/eliminate potential effects to non-target species and sensitive habitats, 

and the potential to contaminate surface and groundwater. All pesticide usage (pesticide, 

target species, application rate, and method of application) would comply with the applicable 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-9 

federal (FIFRA) and state regulations pertaining to pesticide use, safety, storage, disposal, 

and reporting. Before pesticides can be used to eradicate, control, or contain pests on refuge 

lands and waters, PUPs would be prepared and approved in accordance with 569 FW 1. PUP 

records would provide a detailed time-, site-, and target-specific description of the proposed 

use of pesticides on the refuge. All PUPs would be created, approved, or disapproved, and 

stored in the pesticide use proposal system (PUPS), which is a centralized database only 

accessible on the Service’s intranet (https://systems.fws.gov/pups). Only Service employees 

would be authorized to access PUP records for a refuge in this database. 

Application equipment would be selected to provide site-specific delivery to target pests 

while minimizing/eliminating direct or indirect (e.g., drift) exposure to non-target areas and 

degradation of surface and groundwater quality. Where possible, target-specific equipment 

(e.g., backpack sprayer, wiper) would be used to treat target pests. Other target-specific 

equipment to apply pesticides would include soaked wicks or paint brushes for wiping 

vegetation and lances, hatchets, or syringes for direct injection into stems. Granular 

pesticides may be applied using seeders or other specialized dispensers. In contrast, aerial 

spraying (e.g., fixed wing or helicopter) would only be used where access is difficult 

(remoteness) and/or the size/distribution of infestations precludes practical use of groundbased methods.

Because repeated use of one pesticide may allow resistant organisms to survive and 

reproduce, multiple pesticides with variable modes of action would be considered for 

treatments on refuge lands and waters. This is especially important if multiple applications 

within years and/or over a growing season would likely be necessary for habitat maintenance 

and restoration activities to achieve resource objectives. Integrated chemical and nonchemical controls also are highly effective, where practical, because pesticide-resistant 

organisms can be removed from the site.

Cost may not be the primary factor in selecting a pesticide for use on a refuge. If the least 

expensive pesticide would potentially harm natural resources or people, then a different 

product would be selected, if available. The most efficacious pesticide available with the 

least potential to degrade environment quality (soils, surface water, and groundwater) as well 

as the least potential to impact native species and communities of fish, wildlife, plants, and 

their habitats would be acceptable for use on refuge lands in the context of an IPM approach. 

 Habitat Restoration/Maintenance. Restoration and/or proper maintenance of refuge 

habitats associated with achieving wildlife and habitat objectives would be essential for longterm prevention, eradication, or control (at or below threshold levels) of pests. Promoting 

desirable plant communities through the manipulation of species composition, plant density, 

and growth rate is an essential component of invasive plant management (Brooks et al. 2004; 

Masters and Sheley 2001; Masters et al. 1996). The following three components of 

succession could be manipulated through habitat maintenance and restoration: site 

availability, species availability, and species performance (Cox and Anderson 2004). 

Although a single method (e.g., herbicide treatment) may eliminate or suppress pest species 

in the short term, the resulting gaps and bare soil create niches that are conducive to further 

invasion by the species and/or other invasive plants. On degraded sites where desirable 

species are absent or in low abundance, revegetation with native/desirable grasses, forbs, and 

legumes may be necessary to direct and accelerate plant community recovery and achieve 

site-specific objectives in a reasonable time frame. The selection of appropriate species for 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-10 Appendix G. Integrated Pest Management Plan 

revegetation would be dependent on a number of factors including resource objectives and 

site-specific abiotic factors (e.g., soil texture, precipitation/temperature regimes, and shade 

conditions). Seed availability and cost, ease of establishment, seed production, and 

competitive ability would also be important considerations. 

G.4 Priorities for Treatments 

For many refuges, the magnitude (number, distribution, and sizes of infestations) of pest problems is 

too extensive and beyond the available capital resources to effectively address during any single field 

season. To manage pests in the refuge, it would be essential to prioritize treatment of infestations. 

Highest priority treatments would be focused on early detection and rapid response to eliminate 

infestations of new pests, if possible. This would be especially important for aggressive pests 

potentially impacting species, species groups, communities, and/or habitats associated with refuge 

purpose(s), NWR System (NWRS) resources of concern (federally listed species, migratory birds, 

selected marine mammals, and interjurisdictional fish), and native species used for 

maintaining/restoring biological integrity, diversity, and environmental health. 

The next priority would be treating established pests that appear in one or more previously uninfested areas. Moody and Mack (1988) demonstrated through modeling that small, new outbreaks of 

invasive plants eventually infest an area larger than the established source population. They also 

found that control efforts focusing on the large, main infestation rather than the new, small satellites 

reduced the chances of overall success. The lowest priority would be treating large infestations 

(sometimes monotypic stands) of well-established pests. In this case, initial efforts would focus upon 

containment of the perimeter followed by work to control/eradicate the established infested area. If 

containment and/or control of a large infestation is not effective, then efforts would focus on halting 

pest reproduction or managing source populations. Maxwell et al. (2009) found that treating fewer 

populations that are sources represents an effective long-term strategy to reduce total number of 

invasive populations and decreasing meta-population growth rates. 

Although state-listed noxious weeds would always be of high priority for management, other pest 

species known to cause substantial ecological impact would also be considered. For example, 

cheatgrass may not be listed by a state as noxious, but it can greatly alter fire regimes in shrub steppe 

habitats resulting in large monotypic stands that displace native bunch grasses, forbs, and shrubs. 

Pest control would likely require a multi-year commitment from the refuge staff. Essential to the 

long-term success of pest management would be pre- and post-treatment monitoring, assessment of 

the successes and failures of treatments, and development of new approaches when proposed 

methods do not achieve desired outcomes. 

G.5 Best Management Practices 

BMPs can minimize or eliminate the possible effects associated with pesticide usage to non-target 

species and/or sensitive habitats as well as the degradation of water quality from drift, surface runoff, 

or leaching. Based upon the Department of Interior Pesticide Use Policy (517 DM 1) and the Service 

Pest Management Policy and Responsibilities (30 AM 12), the use of applicable BMPs (where 

feasible) also would likely ensure that pesticide uses may not adversely affect federally listed species 

and/or their critical habitats through determinations made using the process described in 50 CFR 402. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-11 

The following are BMPs pertaining to mixing/handling and applying pesticides for all ground-based 

treatments of pesticides, which would be considered and used, where feasible, based upon target- and 

site-specific factors and time-specific environmental conditions. Although not listed below, the most 

important BMP to eliminate/reduce potential impacts to non-target resources would be an IPM 

approach to prevent, control, eradicate, and contain pests. 

G.5.1 Pesticide Handling and Mixing 

 As a precaution against spilling, spray tanks would not be left unattended during filling. 

 All pesticide containers would be triple rinsed and the rinsate would be used as water in the 

sprayer tank and applied to treatment areas. 

 All pesticide spray equipment would be properly cleaned. Where possible, rinsate would be 

used as part of the make-up water in the sprayer tank and applied to treatment areas. 

 The refuge staff would triple rinse and recycle (where feasible) pesticide containers. 

 All unused pesticides would be properly discarded at a local “safe send” collection. 

 Pesticides and pesticide containers would be lawfully stored, handled, and disposed of in 

accordance with the label and in a manner safeguarding human health, fish, and wildlife, and 

preventing soil and water contamination. 

 The refuge staff would consider water quality parameters (e.g., pH, hardness) that are 

important to ensure greatest efficacy where specified on the pesticide label. 

 All pesticide spills would be addressed immediately using procedures identified in the refuge 

spill response plan. 

G.5.2 Applying Pesticides 

 Pesticide treatments would only be conducted by or under the supervision of Service 

personnel and non-Service applicators with the appropriate state certification to safely and 

effectively conduct these activities on refuge lands and waters. 

 The refuge staff would comply with all federal, state, and local pesticide use laws and 

regulations as well as departmental, Service, and NWRS pesticide-related policies. For 

example, the refuge staff would use application equipment and apply rates for the specific 

pest(s) identified on the pesticide label as required under FIFRA. 

 Before each treatment season and prior to mixing or applying any product for the first time 

each season, all applicators would review the labels, material safety data sheets (MSDSs), 

and PUPs for each pesticide, determining the target pest, appropriate mix rate(s), personal 

protective equipment (PPE), and other requirements listed on the pesticide label. 

 A 1-foot no-spray buffer from the water’s edge would be used, where applicable and where it 

does not detrimentally influence effective control of pest species. 

 Low-impact herbicide application techniques (e.g., spot treatment, cut stump, oil basal, 

Thinvert system applications) would be used rather than broadcast foliar applications (e.g., 

boom sprayer other larger tank wand applications), where practical. 

 Low-volume rather than high-volume foliar applications would be used where low-impact 

methods listed above are not feasible or practical, to maximize herbicide effectiveness and 

ensure correct and uniform application rates. 

 Applicators would use and adjust spray equipment to apply the coarsest droplet size spectrum 

with optimal coverage of the target species while reducing drift. 

 Applicators would use the largest droplet size that results in uniform coverage. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-12 Appendix G. Integrated Pest Management Plan 

 Applicators would use drift reduction technologies such as low-drift nozzles, where possible. 

 Where possible, spraying would occur during low (average <7 mph and preferably 3 to 5 

mph) and consistent direction wind conditions with moderate temperatures (typically <85°F). 

 Where possible, applicators would avoid spraying during inversion conditions (often 

associated with calm and very low wind conditions) that can cause large-scale herbicide drift 

to non-target areas. 

 Equipment would be calibrated regularly to ensure that the proper rate of pesticide is applied 

to the target area or species. 

 Spray applications would be made at the lowest height for uniform coverage of target pests to 

minimize/eliminate potential drift. 

 If windy conditions frequently occur during afternoons, spraying (especially boom 

treatments) would typically be conducted during early morning hours. 

 Spray applications would not be conducted on days with >30 percent forecast for rain within 

6 hours, except for pesticides that are rapidly rain fast (e.g., glyphosate in 1 hour) to 

minimize/eliminate potential runoff. 

 Where possible, applicators would use drift retardant adjuvants during spray applications, 

especially adjacent to sensitive areas. 

 Where possible, applicators would use a non-toxic dye to aid in identifying target area treated 

as well as potential overspray or drift. A dye can also aid in detecting equipment leaks. If a 

leak is discovered, the application would be stopped until repairs can be made to the sprayer. 

 For pesticide uses associated with cropland and facilities management, buffers, as 

appropriate, would be used to protect sensitive habitats, especially wetlands and other aquatic 

habitats. 

 When drift cannot be sufficiently reduced through altering equipment set up and application 

techniques, buffer zones may be identified to protect sensitive areas downwind of 

applications. The refuge staff would only spray adjacent to sensitive areas when the wind is 

blowing in the opposite direction. 

 Applicators would utilize scouting for early detection of pests to eliminate unnecessary 

pesticide applications. 

 The refuge staff would consider the timing of the application such that native plants are 

protected (e.g., senescence) while effectively treating invasive plants. 

 Rinsate from cleaning spray equipment after application would be recaptured and reused or 

applied to an appropriate pest plant infestation. 

 Application equipment (e.g., sprayer, ATV, tractor) would be thoroughly cleaned and PPE 

would be removed/disposed off on-site by applicators after treatments to eliminate the 

potential spread of pests to un-infested areas. 

G.6 Safety 

G.6.1 Personal Protective Equipment 

All applicators would wear the specific PPE identified on the pesticide label. The appropriate PPE 

will be worn at all times during handling, mixing, and applying. PPE can include the following: 

disposable (e.g., Tyvek) or laundered coveralls; gloves (latex, rubber, or nitrile); rubber boots; and/or 

a National Institute for Occupational Safety and Health (NIOSH)–approved respirator. Because 

exposure to concentrated product is usually greatest during mixing, extra care should be taken while 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-13 

preparing pesticide solutions. Persons mixing these solutions can be best protected if they wear long 

gloves, an apron, footwear, and a face shield. 

Coveralls and other protective clothing used during an application would be laundered separately 

from other laundry items. Transporting, storing, handling, mixing, and disposing of pesticide 

containers will be consistent with label requirements, USEPA and Occupational Safety and Health 

Administration (OSHA) requirements, and Service policy. 

If a respirator is necessary for pesticide use, then the following requirements would be met in 

accordance with Service safety policy: a written Respirator Program, fit testing, physical examination 

(including pulmonary function and blood work for contaminants), and proper storage of the 

respirator. 

G.6.2 Notification 

The restricted entry interval (REI) is the time period required after the application before someone 

may safely enter a treated area without PPE. Refuge staff, authorized management agents of the 

Service, volunteers, and members of the public who could be in or near a pesticide-treated area 

within the stated re-entry time period on the label would be notified about treatment areas. Posting 

would occur at any site where individuals might inadvertently become exposed to a pesticide during 

other activities on the refuge. Where required by the label and/or state-specific regulations, signs 

would also be posted on its perimeter and at other likely locations of entry. The refuge staff would 

also notify appropriate private property owners of an intended application, including any private 

individuals who have requested notification. Special efforts would be made to contact nearby 

individuals who are beekeepers or who have expressed chemical sensitivities. 

G.6.3 Medical Surveillance 

Medical surveillance may be required for Service personnel and approved volunteers who mix, 

apply, and/or monitor use of pesticides (see 242 FW 7 [Pesticide Users] and 242 FW 4 [Medical 

Surveillance]). In accordance with 242 FW 7.12A, Service personnel would be medically monitored 

if one or more of the following criteria are met: exposed or may be exposed to concentrations at or 

above the published permissible exposure limits or threshold limit values (see 242 FW 4); use 

pesticides in a manner considered “frequent pesticide use”; or use pesticides in a manner that requires 

a respirator (see 242 FW 14 for respirator use requirements). In 242 FW 7.7A, frequent pesticide use

means “when a person applying pesticide handles, mixes, or applies pesticides, with a Health Hazard 

rating of 3 or higher, for 8 or more hours in any week or 16 or more hours in any 30-day period.” 

Under some circumstances, individuals may be medically monitored even if they use pesticides 

infrequently, experience an acute exposure (sudden, short term), or use pesticides with a health 

hazard ranking of 1 or 2. This decision would consider the individual’s health and fitness level, the 

pesticide’s specific health risks, and the potential risks from other pesticide-related activities. Refuge 

cooperators (e.g., cooperative farmers) and other authorized agents (e.g., state and county employees) 

would be responsible for their own medical monitoring needs and costs. 

Standard examinations (at refuge expense) of appropriate refuge staff would be provided by the 

nearest certified occupational health and safety physician as determined by Federal Occupational 

Health. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-14 Appendix G. Integrated Pest Management Plan 

G.6.4 Certification and Supervision of Pesticide Applicators 

Appropriate refuge staff or approved volunteers handling, mixing, and/or applying or directly 

supervising others engaged in pesticide use activities would be trained and state or federally (BLM) 

licensed to apply pesticides to refuge lands or waters. In accordance with 242 FW 7.18A and 569 FW 

1.10B, certification is required to apply restricted use pesticides based upon USEPA regulations. For 

safety reasons, all individuals participating in pest management activities with general use pesticides 

also are encouraged to attend appropriate training or acquire pesticide applicator certification. The 

certification requirement would be for a commercial or private applicator depending upon the state. 

New staff unfamiliar with proper procedures for storing, mixing, handling, applying, and disposing 

of herbicides and containers would receive orientation and training before handling or using any 

products. Documentation of training would be kept in the files at the refuge office. 

G.6.5 Record Keeping 

G.6.5.1 Labels and material safety data sheets 

Pesticide labels and MSDSs would be maintained at the refuge shop and laminated copies kept in the 

mixing area. These documents also would be carried by field applicators, where possible. A written 

reference (e.g., note pad, chalk board, dry erase board) for each tank to be mixed would be kept in 

the mixing area for quick reference while mixing is in progress. In addition, approved PUPs stored in 

the PUPS database typically contain website links (URLs) to pesticide labels and MSDSs. 

G.6.5.2 Pesticide use proposals 

A PUP would be prepared for each proposed pesticide use associated with annual pest management 

on refuge lands and waters. A PUP would include specific information about the proposed pesticide 

use including the common and chemical names of the pesticide(s), target pest species, size and 

location of treatment site(s), application rate(s) and method(s), and federally listed species 

determinations, where applicable. 

In accordance with Service guidelines (Director’s memo [December 12, 2007]), refuge staff may 

receive up to 5-year approvals for Washington Office– and field–reviewed proposed pesticide uses 

based upon meeting identified criteria including an approved IPM plan, where necessary (see 

http://www.fws.gov/contaminants/Issues/IPM.cfm). For a refuge, an IPM plan (requirements 

described herein) can be completed independently or in association with a CCP or a habitat 

management plant (HMP) if IPM strategies and potential environmental effects are adequately 

addressed within appropriate NEPA documentation. 

PUPs would be created, approved or disapproved, and stored as records in the PUPS, a centralized 

database on the Service’s intranet (https://systems.fws.gov/pups). Only Service employees can access 

PUP records in this database. 

G.6.5.3 Pesticide usage 

In accordance with 569 FW 1, the refuge Project Leader would be required to maintain records of all 

pesticides annually applied on lands or waters under refuge jurisdiction. This would encompass 

pesticides applied by other federal agencies, state and county governments, and nongovernment 

applicators including cooperators and their pest management service providers with Service 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-15 

permission. For clarification, “pesticide” refers to all insecticides, insect and plant growth regulators, 

dessicants, herbicides, fungicides, rodenticides, acaricides, nematicides, fumigants, avicides, and 

piscicides. 

The following usage information can be reported for approved PUPs in the PUPS database: 

 Pesticide trade name(s) 

 Active ingredient(s) 

 Total acres treated 

 Total amount of pesticides used (lbs or gallons) 

 Total amount of active ingredient(s) used (lbs) 

 Target pest(s) 

 Efficacy (percentage control) 

To determine whether treatments are efficacious (eradicating, controlling, or containing the target 

pest) and achieving resource objectives, habitat and/or wildlife response would be monitored both 

pre- and post-treatment, where possible. Information regarding available annual funding and staffing, 

characteristics (attributes) of pest infestations (e.g., area, perimeter, degree of infestation, percentage 

cover, density), and habitat and/or wildlife response to treatments may be collected and stored in a 

relational database (e.g., Refuge Habitat Management Database), preferably a geo-referenced data 

management system (e.g., Refuge Lands geographic information system [GIS]) to facilitate data 

analyses and subsequent reporting. In accordance with adaptive management, data analysis and 

interpretation would allow treatments to be modified or changed over time, as necessary, to achieve 

resource objectives considering site-specific conditions in conjunction with habitat and/or wildlife 

responses. Monitoring could also identify short- and long-term impacts to natural resources and 

environmental quality associated with IPM treatments in accordance with adaptive management 

principles identified in 43 CFR 46.145. 

G.7 Evaluating Pesticide Use Proposals 

Pesticides would only be used on refuge lands for habitat management and croplands/facilities 

maintenance after approval of a PUP. In general, proposed pesticide uses on refuge lands would only 

be approved where there would likely be minor, temporary, or localized effects to fish and wildlife 

species as well as minimal potential to degrade environmental quality. Potential effects to listed and 

nonlisted species would be evaluated with quantitative ecological risk assessments and other 

screening measures. Potential effects to environmental quality would be based upon pesticide 

characteristics of environmental fate (water solubility, soil mobility, soil persistence, and 

volatilization) and other quantitative screening tools. Ecological risk assessments as well as 

characteristics of environmental fate and potential to degrade environmental quality for pesticides 

would be documented in Chemical Profiles (see Section G.7.6 of this appendix). These profiles 

would include threshold values for quantitative measures of ecological risk assessments and 

screening tools for environmental fate that represent minimal potential effects to species and 

environmental quality. In general, only pesticide uses with appropriate BMPs (see Section G.5 of this 

appendix) for habitat management and cropland/facilities maintenance on refuge lands that would 

potentially have minor, temporary, or localized effects on refuge biological and environmental 

quality (threshold values not exceeded) would be approved. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-16 Appendix G. Integrated Pest Management Plan 

G.7.1 Overview of Ecological Risk Assessment 

An ecological risk assessment process would be used to evaluate potential adverse effects to 

biological resources as a result of a pesticide(s) proposed for use on refuge lands. It is an established 

quantitative and qualitative methodology for comparing and prioritizing risks of pesticides and 

conveying an estimate of the potential risk for an adverse effect. This quantitative methodology 

provides an efficient mechanism to integrate best available scientific information regarding hazard, 

patterns of use (exposure), and dose-response relationships in a manner that is useful for ecological 

risk decision making. It provides an effective way to evaluate potential effects where there is missing 

or unavailable scientific information (data gaps) to address reasonable, foreseeable adverse effects in 

the field as required under 40 CFR 1502.22. Protocols for ecological risk assessment of pesticide 

uses on the refuge were developed through research and established by the U.S. Environmental 

Protection Agency (2004). Assumptions for these risk assessments are presented in Section G.7.2.3 

of this appendix. 

The toxicological data used in ecological risk assessments are typically the results of standardized 

laboratory studies provided by pesticide registrants to the USEPA to meet regulatory requirements 

under FIFRA. These studies assess the acute (lethality) and chronic (reproductive) effects associated 

with short- and long-term exposure to pesticides on representative species of birds, mammals, 

freshwater fish, aquatic invertebrates, and terrestrial and aquatic plants. Other effects data publicly 

available would also be used for risk assessment protocols described herein. Toxicity endpoint and 

environmental fate data are available from a variety of resources. 

Table G-1. Ecotoxicity Tests Used to Evaluate Potential Effects to Birds, Fish, and Mammals to 

Establish Toxicity Endpoints for Risk Quotient Calculations 

Species Group Exposure Measurement endpoint 

Bird 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)1 

Fish 

Acute Median Lethal Concentration (LC50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)2

Mammal 

Acute Oral Lethal Dose (LD50) 

Chronic No Observed Effect Concentration (NOEC) or 

No Observed Adverse Effect Concentration (NOAEC)3

1

Measurement endpoints typically include a variety of reproductive parameters (e.g., number of eggs, number of offspring, 

eggshell thickness, and number of cracked eggs). 2

Measurement endpoints for early life stage/life cycle typically include embryo hatch rates, time to hatch, growth, and time to 

swim-up. 

3

Measurement endpoints include maternal toxicity, teratogenic effects or developmental anomalies, evidence of mutagenicity or 

genotoxicity, and interference with cellular mechanisms such as DNA synthesis and DNA repair. 

G.7.2 Determining Ecological Risk to Fish and Wildlife 

The potential for pesticides used on the refuge to cause direct adverse effects to fish and wildlife 

would be evaluated using USEPA’s Ecological Risk Assessment Process (USEPA 2004). This 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-17 

deterministic approach, which is based upon a two-phase process involving estimation of 

environmental concentrations and then characterization of risk, would be used for ecological risk 

assessments. This method integrates exposure estimates (estimated environmental concentration 

[EEC] and toxicological endpoints [e.g., LC50 and oral LD50]) to evaluate the potential for adverse 

effects to species groups (birds, mammals, and fish) representative of legal mandates for managing 

units of the NWRS. This integration is achieved through risk quotients (RQs) calculated by dividing 

the EEC by acute and chronic toxicity values selected from standardized toxicological endpoints or 

published effect (Table G-1). 

RQ = EEC/Toxicological Endpoint 

The level of risk associated with direct effects of pesticide use would be characterized by comparing 

calculated RQs to the appropriate Level of Concern (LOC) established by USEPA (1998 [Table G2]). The LOC represents a quantitative threshold value for screening potential adverse effects to fish 

and wildlife resources associated with pesticide use. The following are four exposure-species group 

scenarios that would be used to characterize ecological risk to fish and wildlife on the refuge: acutelisted species, acute-nonlisted species, chronic-listed species, and chronic-nonlisted species. 

Acute risk would indicate the potential for mortality associated with short-term dietary exposure to 

pesticides immediately after an application. For characterization of acute risks, median values from 

LC50 and LD50 tests would be used as toxicological endpoints for RQ calculations. In contrast, 

chronic risks would indicate the potential for adverse effects associated with long-term dietary 

exposure to pesticides from a single application or multiple applications over time (within a season 

and over years). For characterization of chronic risks, the No Observed Concentration (NOAEC) or 

No Observed Effect Concentration (NOEC) for reproduction would be used as toxicological 

endpoints for RQ calculations. Where available, the NOAEC would be preferred over a NOEC value. 

Listed species are those federally designated as threatened, endangered, or proposed in accordance 

with the Endangered Species Act of 1973 (16 USC 1531-1544, 87 Stat. 884, as amended-Public Law 

93-205). For listed species, potential adverse effects would be assessed at the individual level 

because loss of individuals from a population could detrimentally impact a species. In contrast, risks 

to nonlisted species would consider effects at the population level. An RQ<LOC would indicate the 

proposed pesticide use “may affect, not likely to adversely affect” individuals (listed species) and it 

would not pose an unacceptable risk for adverse effects to populations (nonlisted species) for each 

taxonomic group (Table G-2). In contrast, an RQ>LOC would indicate a “may affect, likely to 

adversely affect” for listed species and it would also pose unacceptable ecological risk for adverse 

effects to nonlisted species. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-18 Appendix G. Integrated Pest Management Plan 

Table G-2. Presumption of Unacceptable Risk for Birds, Fish, and Mammals 

Risk Presumption Level of Concern 

Listed Species Nonlisted Species 

Acute Birds 0.1 0.5 

Fish 0.05 0.5 

Mammals 0.1 0.5 

Chronic Birds 1.0 1.0 

Fish 1.0 1.0 

Mammals 1.0 1.0 

Source: U.S. Environmental Protection Agency 1998.

G.7.2.1 Environmental exposure 

Following release into the environment through application, pesticides experience several different 

routes of environmental fate. Pesticides that are sprayed can move through the air (e.g., particle or 

vapor drift) and may eventually end up in other parts of the environment such as non-target 

vegetation, soil, or water. Pesticides applied directly to the soil may be washed off the soil into 

nearby bodies of surface water (e.g., surface runoff) or may percolate through the soil to lower soil 

layers and groundwater (e.g., leaching) (Baker and Miller 1999; Butler et al. 1998; EXTOXNET 

1993; Pope et al. 1999; Ramsay et al. 1995). Pesticides injected into the soil may also be subject to 

the latter two fates. The aforementioned possibilities are by no means exhaustive, but they do 

indicate the movement of pesticides in the environment is very complex, with transfers occurring 

continually among different environmental compartments. In some cases, these exchanges occur not 

only between areas that are close together, but may also involve transportation of pesticides over 

long distances (Barry 2004; Woods 2004). 

G.7.2.1.1 Terrestrial exposure 

The EEC for exposure to terrestrial wildlife would be quantified using an USEPA screening-level 

approach (USEPA 2004). This screening-level approach is not affected by product formulation 

because it evaluates pesticide active ingredient(s). This approach would vary depending upon the 

proposed pesticide application method: spray or granular. 

G.7.2.1.1.1 Terrestrial: spray application 

For spray applications, exposure would be determined using the Kanaga nomogram method (Pfleeger 

et al. 1996; USEPA 2004, 2005a) through the USEPA’s Terrestrial Residue Exposure model (TREX) version 1.2.3 (USEPA 2005b). To estimate the maximum (initial) pesticide residue on short 

grass (<20 cm tall) as a general food item category for terrestrial vertebrate species, T-REX input 

variables would include the following from the pesticide label: maximum pesticide application rate 

(pounds of active ingredient [acid equivalent] per acre) and pesticide half-life (days) in soil. 

Although there are other food item categories (tall grasses; broadleaf plants and small insects; and 

fruits, pods, seeds and large insects), short grass was selected because it would yield maximum EECs 

(240 ppm per lb active ingredient [a.i.]/acre) for worst-case risk assessments. Short grass is not 

representative of forage for carnivorous species (e.g., raptors), but it would characterize the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-19 

maximum potential exposure through the diet of avian and mammalian prey items. Consequently, 

this approach would provide a conservative screening tool for pesticides that do not biomagnify. 

For RQ calculations in T-REX, the model would require the weight of surrogate species and Mineau 

scaling factors (Mineau et al. 1996). Body weights of bobwhite quail and mallard are included in TREX by default, but body weights of other organisms (Table G-3) would be entered manually. The 

Mineau scaling factor accounts for small-bodied bird species that may be more sensitive to pesticide 

exposure than would be predicted only by body weight. Mineau scaling factors would be entered 

manually with values ranging from 1 to 1.55 that are unique to a particular pesticide or group of 

pesticides. If specific information to select a scaling factor is not available, then a value of 1.15 

would be used as a default. Alternatively, zero would be entered if it is known that body weight does 

not influence toxicity of pesticide(s) being assessed. The upper bound estimate output from the TREX Kanaga nomogram would be used as an EEC for calculation of RQs. This approach would yield 

a conservative estimate of ecological risk. 

Table G-3. Average Body Weight of Selected Terrestrial Wildlife Species Frequently Used in 

Research to Establish Toxicological Endpoints 

Species Body Weight (kg) 

Mammal (15 g) 0.015 

House sparrow 0.0277 

Mammal (35 g) 0.035 

Starling 0.0823 

Red-winged blackbird 0.0526 

Common grackle 0.114 

Japanese quail 0.178 

Bobwhite quail 0.178 

Rat 0.200 

Rock dove (aka pigeon) 0.542 

Mammal (1,000 g) 1.000 

Mallard 1.082 

Ring-necked pheasant 1.135 

Source: Dunning 1984. 

G.7.2.1.1.2 Terrestrial: granular application 

Granular pesticide formulations and pesticide-treated seed would pose a unique route of exposure for 

avian and mammalian species. The pesticide is applied in discrete units, which birds or mammals 

might ingest accidentally with food items or intentionally as in the case of some bird species that 

actively seek and pick up gravel or grit to aid digestion or eat seed as a food source. Granules may 

also be consumed by wildlife foraging on earthworms, slugs, or other soft-bodied soil organisms to 

which the granules may adhere. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-20 Appendix G. Integrated Pest Management Plan 

Terrestrial wildlife RQs for granular formulations or seed treatments would be calculated by dividing 

the maximum milligrams of a.i. exposed (e.g., EEC) on the surface of an area equal to 1 square foot 

by the appropriate LD50 value multiplied by the surrogate’s body weight (Table G-3). An adjustment 

to surface area calculations would be made for broadcast, banded, and in-furrow applications. An 

adjustment also would be made for applications with and without incorporation of the granules. 

Without incorporation, it would be assumed that 100 percent of the granules remain on the soil 

surface available to foraging birds and mammals. Press wheels push granules flat with the soil 

surface, but they are not incorporated into the soil. If granules are incorporated into the soil during 

band or T-band applications or after broadcast applications, it would be assumed only 15 percent of 

the applied granules remain available to wildlife. It would be assumed that only 1 percent of the 

granules are available on the soil surface following in-furrow applications. 

EECs for pesticides applied in granular form and as seed treatments would be determined 

considering potential ingestion rates of avian or mammalian species (e.g., 10%–30% body 

weight/day). This would provide an estimate of maximum exposure that may occur as a result of 

granule or seed treatment spills such as those that commonly occur at end rows during application 

and planting. The availability of granules and seed treatments to terrestrial vertebrates would also be 

considered by calculating the loading per unit area (LD50/ft2

)for comparison to USEPA LOCs 

(USEPA). T-REX version 1.2.3 (USEPA 2005b) contains a submodel that automates Kanaga 

exposure calculations for granular pesticides and treated seed. 

The following formulas will be used to calculate EECs depending upon the type of granular pesticide 

application: 

 In-furrow applications assume a typical value of 1 percent granules, bait, or seed remaining 

unincorporated. 

mg a.i./ft.

2

= [(lbs. product/acre)(% a.i.)(453,580 mg/lbs)(1% exposed))] / {[(43,560 ft.

2

/acre)/(row 

spacing (ft.))] / (row spacing (ft.)} 

or 

mg a.i./ft

2 

= [(lbs product/1,000 ft. row)(% a.i.)(1,000 ft row)(453,580 mg/lb)(1% exposed) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Incorporated banded treatments assume a typical value of 15 percent of granules, bait, and 

seeds remaining unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/1,000 row ft.)(% a.i.)(453,580 mg/lb)(1−% incorporated)] / (1,000 

ft.)(band width (ft.)) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

 Broadcast treatment without incorporation assumes 100 percent of granules, bait, seeds are 

unincorporated. 

mg a.i./ft.

2 

= [(lbs. product/acre)(% a.i.)(453,590 mg/lb)] / (43,560 ft.

2

/acre) 

EEC = [(mg a.i./ft.

2

)(% of pesticide biologically available)] 

Where: 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-21 

o Percentage of pesticide biologically available = 100 percent without species-specific 

ingestion rates 

o Conversion for calculating mg a.i./ft.

2 

using ounces is 453,580 mg/lb/16 = 28,349 mg/oz. 

The following equation would be used to calculate an RQ based on the EEC calculated by one of the 

above equations. The EEC would be divided by the surrogate LD50 toxicological endpoint multiplied 

by the body weight (Table G-3) of the surrogate. 

RQ = EEC / [LD50 (mg/kg) * body weight (kg)] 

As with other risk assessments, an RQ>LOC would be a presumption of unacceptable ecological 

risk. An RQ<LOC would be a presumption of acceptable risk with only minor, temporary, or 

localized effects to species. 

G.7.2.1.2 Aquatic exposure 

Exposures to aquatic habitats (e.g., wetlands, meadows, ephemeral pools, water delivery ditches) 

would be evaluated separately for ground-based pesticide treatments of habitats managed for fish and 

wildlife compared with cropland/facilities maintenance. The primary exposure pathway for aquatic 

organisms from any ground-based treatments likely would be particle drift during the pesticide 

application. However, different exposure scenarios would be necessary due to contrasting application 

equipment and techniques as well as pesticides used to control pests on agricultural lands (especially 

those cultivated by cooperative farmers for economic return from crop yields) and facilities 

maintenance (e.g., roadsides, parking lots, trails) compared with other managed habitats on the 

refuge. In addition, pesticide applications may be done at <25 feet of the high water mark of aquatic 

habitats for habitat management treatments, whereas, no-spray buffers (≥25 feet) would be used for 

croplands/facilities maintenance treatments. 

G.7.2.1.2.1 Habitat treatments 

For the worst-case exposure scenario to non-target aquatic habitats, EECs (Table G-4) would be 

derived from Urban and Cook (1986), which assumes an intentional overspray to an entire, nontarget water body (1 foot depth) from a treatment <25 feet from the high water mark using the max 

application rate (acid basis [see above]). However, use of BMPs for applying pesticides (see Section 

G.5.2) would likely minimize/eliminate potential drift to non-target aquatic habitats during actual 

treatments. If there would be unacceptable (acute or chronic) risk to fish and wildlife with the 

simulated 100 percent overspray (RQ>LOC), then the proposed pesticide use may be disapproved, or 

the PUP would be approved at a lower application rate to minimize/eliminate unacceptable risk to 

aquatic organisms (RQ = LOC). 

Table G-4. Estimated Environmental Concentrations (ppb) of Pesticides in Aquatic Habitats (1 

foot depth) Immediately after Direct Application 

Lbs/acre EEC (ppb) 

0.10 36.7 

0.20 73.5 

0.25 91.9 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-22 Appendix G. Integrated Pest Management Plan 

Lbs/acre EEC (ppb) 

0.30 110.2 

0.40 147.0 

0.50 183.7 

0.75 275.6 

1.00 367.5 

1.25 459.7 

1.50 551.6 

1.75 643.5 

2.00 735.7 

2.25 827.6 

2.50 919.4 

3.00 1,103.5 

4.00 1,471.4 

5.00 1,839 

6.00 2,207 

7.00 2,575 

8.00 2,943 

9.00 3,311 

10.00 3,678 

Source: Urban and Cook 1986. 

G.7.2.1.2.2 Cropland/facilities maintenance treatments 

Field drift studies conducted by the Spray Drift Task Force, which is a joint project of several 

agricultural chemical businesses, were used to develop a generic spray drift database. From this 

database, the AgDRIFT computer model was created to satisfy USEPA pesticide registration spray 

drift data requirements and to provide a scientific basis to evaluate off-target movement of pesticides 

from particle drift and assess potential effects of exposure to wildlife. Several versions of the 

computer model have been developed (i.e., versions 2.01 through 2.10). The Spray Drift Task Force 

AgDRIFT model version 2.01 (Spray Drift Task Force 2003; Teske et al. 2002) would be used to 

derive EECs resulting from drift of pesticides to refuge aquatic resources from ground-based 

pesticide applications >25 feet from the high water mark. The Spray Drift Task Force AgDRIFT 

model is publicly available at http://www.agdrift.com. At this website, click “AgDRIFT 2.0” 

followed by “Download Now,” and follow the instructions to obtain the computer model. 

The AgDRIFT model is composed of submodels called tiers. Tier I ground submodel would be used 

to assess ground-based applications of pesticides. Tier outputs (EECs) would be calculated with 

AgDRIFT using the following input variables: maximum application rate (acid basis [see above]), 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-23 

low boom (20 inches), fine to medium droplet size, EPA-defined wetland, and a ≥25-foot distance 

(buffer) from treated area to water. 

G.7.2.2 Use of information on effects of biological control agents, pesticides, degradates, 

and adjuvants 

In accordance with the requirements set forth in 43 CFR 46.135, the Service would specifically 

incorporate through reference ecological risk assessments prepared by the U.S. Forest Service and 

BLM. These risk assessments and associated documentation are also available with the 

administrative record for the Final Environmental Impact Statement entitled Pacific Northwest 

Region Invasive Plant Program – Preventing and Managing Invasive Plants (U.S. Forest Service 

2005) and Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 

Western States Programmatic EIS (PEIS) (BLM 2007). In accordance with 43 CRF 46.120(d), use of 

existing NEPA documents by supplementing, tiering to, incorporating by reference, or adopting 

previous NEPA environmental analyses would avoid redundancy and unnecessary paperwork. 

As a basis for completing “Chemical Profiles” for approving or disapproving refuge PUPs, 

ecological risk assessments for the following herbicide and adjuvant uses prepared by the U.S. Forest 

Service would be incorporated by reference: 

 2,4-D 

 Chlorsulfuron 

 Clopyralid 

 Dicamba 

 Glyphosate 

 Imazapic 

 Imazapyr 

 Metsulfuron methyl 

 Picloram 

 Sethoxydim 

 Sulfometuron methyl 

 Triclopyr 

 Nonylphenol polyethylate (NPE)–based surfactants 

As a basis for completing Chemical Profiles for approving or disapproving refuge PUPs, ecological 

risk assessments for the following herbicide uses as well as evaluation of risks associated with 

pesticide degradates and adjuvants prepared by the BLM would be incorporated by reference: 

 Bromacil 

 Chlorsulfuron 

 Diflufenzopyr 

 Diquat 

 Diuron 

 Fluridone 

 Imazapic 

 Overdrive (diflufenzopyr and dicamba) 

 Sulfometuron methyl 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-24 Appendix G. Integrated Pest Management Plan 

 Tebuthiuron 

 Pesticide degradates and adjuvants (Appendix D – Evaluation of risks from degradates, 

polyoxyethylene-amine (POEA) and R-11, and endocrine disrupting chemicals) 

G.7.2.3 Assumptions for ecological risk assessments 

There are a number of assumptions involved with the ecological risk assessment process for 

terrestrial and aquatic organisms associated with using the USEPA’s (2004) process. These 

assumptions may be risk neutral or may lead to an over- or under-estimation of risk from pesticide 

exposure depending upon site-specific conditions. This section describes these assumptions, their 

application to the conditions typically encountered, and whether they may lead to recommendations 

that are risk neutral, or that underestimate or overestimate ecological risk from potential pesticide 

exposure. 

 Indirect effects would not be evaluated by ecological risk assessments. These effects include 

the mechanisms of indirect exposure to pesticides: consuming prey items (fish, birds, or 

small mammals), reductions in the availability of prey items, and disturbance associated with 

pesticide application activities. 

 Exposure to a pesticide product can be assessed based upon the active ingredient. However, 

exposure to a chemical mixture (pesticide formulation) may result in effects that are similar 

or substantially different from exposure to only the active ingredient. Non-target organisms 

may be exposed directly to the pesticide formulation or only various constituents of the 

formulation as they dissipate and partition in the environment. If toxicological information 

for both the active ingredient and the formulated product are available, then data representing 

the greatest potential toxicity would be selected for use in the risk assessment process 

(USEPA 2004). As a result, this conservative approach may lead to an overestimation of risk 

characterization from pesticide exposure. 

 Because toxicity tests with listed or candidate species or closely related species are not 

available, data for surrogate species would be most often used for risk assessments. 

Specifically, bobwhite quail and mallard duck are the most frequently used surrogates for 

evaluating potential toxicity to federally listed avian species. Bluegill sunfish, rainbow trout, 

and fathead minnow are the most common surrogates for evaluating toxicity for freshwater 

fish. Sheep’s head minnow can be an appropriate surrogate marine species for coastal 

environments. Rats and mice are the most common surrogates for evaluating toxicity for 

mammals. Interspecies sensitivity is a major source of uncertainty in pesticide assessments. 

As a result of this uncertainty, data is selected for the most sensitive species tested within a 

taxonomic group (birds, fish, and mammals), given the quality of the data is acceptable. If 

additional toxicity data for more species of organisms in a particular group are available, the 

selected data will not be limited to the species previously listed as common surrogates. 

 The Kanaga nomogram outputs maximum EEC values that may be used to calculate an 

average daily concentration over a specified interval of time, which is referred to as a timeweighted average (TWA). The maximum EEC would be selected as the exposure input for 

both acute and chronic risk assessments in the screening-level evaluations. The initial or 

maximum EEC derived from the Kanaga nomogram represents the maximum expected 

instantaneous or acute exposure to a pesticide. Acute toxicity endpoints are determined using 

a single exposure to a known pesticide concentration typically for 48 to 96 hours. This value 

is assumed to represent ecological risk from acute exposure to a pesticide. On the other hand, 

chronic risk from pesticide exposure is a function of pesticide concentration and duration of 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-25 

exposure to the pesticide. An organism’s response to chronic pesticide exposure may result 

from the concentration of the pesticide, the length of exposure, or some combination of both 

factors. Standardized tests for chronic toxicity typically involve exposing an organism to 

several different pesticide concentrations for a specified length of time (days, weeks, months, 

years, or generations). For example, avian reproduction tests include a 10-week exposure 

phase. Because a single length of time is used in the test, time-response data is usually not 

available for inclusion in risk assessments. Without time-response data it is difficult to 

determine the concentration that elicits a toxicological response. 

 Using maximum EECs for chronic risk estimates may result in an overestimate of risk, 

particularly for compounds that dissipate rapidly. Conversely, using TWAs for chronic risk 

estimates may underestimate risk if it is the concentration rather than the duration of 

exposure that is primarily responsible for the observed adverse effect. The maximum EEC 

would be used for chronic risk assessments although it may result in an overestimate of risk. 

TWAs may be used for chronic risk assessments, but they would be applied judiciously 

considering the potential for an underestimation or overestimation of risk. For example, the 

number of days exposure exceeds a LOC may influence the suitability of a pesticide’s use. 

The greater the number of days the EEC exceeds the LOC, the greater the ecological risk. 

This is a qualitative assessment and is subject to reviewers’ expertise in ecological risk 

assessment and tolerance for risk. 

 The length of time used to calculate the TWA can have a substantial effect on the exposure 

estimates and there is no standard method for determining the appropriate duration for this 

estimate. The T-REX model assumes a 21-week exposure period, which is equivalent to 

avian reproductive studies designed to establish a steady-state concentration for 

bioaccumulative compounds. However, this does not necessarily define the true exposure 

duration needed to elicit a toxicological response. Pesticides that do not bioaccumulate may 

achieve a steady-state concentration earlier than 21 weeks. The duration of time for 

calculating TWAs would require justification and would not exceed the duration of exposure 

in the chronic toxicity test (approximately 70 days for the standard avian reproduction study). 

An alternative to using the duration of the chronic toxicity study is to base the TWA on the 

application interval. In this case, increasing the application interval would suppress both the 

estimated peak pesticide concentration and the TWA. Another alternative to using TWAs 

would be to consider the number of days that a chemical is predicted to exceed the LOC. 

 Pesticide dissipation is assumed to be first-order in the absence of data suggesting alternative 

dissipation patterns such as bi-phasic. Field dissipation data would generally be the most 

pertinent for assessing exposure in terrestrial species that forage on vegetation. However, 

these data are often not available and can be misleading, particularly if the compound is 

prone to “wash-off.” Soil half-life is the most common degradation data available. 

Dissipation or degradation data that reflect the environmental conditions typical of refuge 

lands would be used, if available. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. 

 Actual habitat requirements of any particular terrestrial species are not considered, and it is 

assumed that species exclusively and permanently occupy the treated area or adjacent areas 

receiving pesticide at rates commensurate with the treatment rate. This assumption would 

produce a maximum estimate of exposure for risk characterization. This assumption would 

likely lead to an overestimation of exposure for species that do not permanently and 

exclusively occupy the treated area (USEPA 2004). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-26 Appendix G. Integrated Pest Management Plan 

 Exposure through incidental ingestion of pesticide-contaminated soil is not considered in the 

USEPA risk assessment protocols. Research suggests <15 percent of the diet can consist of 

incidentally ingested soil depending upon species and feeding strategy (Beyer et al. 1994). 

An assessment of pesticide concentrations in soil compared to food item categories in the 

Kanaga nomogram indicates incidental soil ingestion will not likely increase dietary exposure 

to pesticides. Inclusion of soil into the diet would effectively reduce the overall dietary 

concentration compared to the present assumption that the entire diet consists of a 

contaminated food source (Fletcher et al. 1994). An exception to this may be soil-applied 

pesticides in which exposure from incidental ingestion of soil may increase. Potential for 

pesticide exposure under this assumption may be underestimated for soil-applied pesticides 

and overestimated for foliar-applied pesticides. The concentration of a pesticide in soil would 

likely be less than predicted on food items. 

 Exposure through inhalation of pesticides is not considered in the USEPA risk assessment 

protocols. Such exposure may occur through three potential sources: spray material in droplet 

form at time of application, vapor phase with the pesticide volatilizing from treated surfaces, 

and airborne particulates (soil, vegetative matter, and pesticide dusts). The USEPA (1990) 

reported that exposure from inhaling spray droplets at the time of application is not an 

appreciable route of exposure for birds. According to research on mallards and bobwhite 

quail, respirable particle size (particles reaching the lung) in birds is limited to maximum 

diameter of 2 to 5 microns. The spray droplet spectra covering the majority of pesticide 

application scenarios indicate that less than 1 percent of the applied material is within the 

respirable particle size. This route of exposure is further limited because the permissible 

spray drop size distribution for ground pesticide applications is restricted to American 

Society of Agricultural Engineering medium or coarser drop size distribution. 

 Inhalation of a pesticide in the vapor phase may be another source of exposure for some 

pesticides under certain conditions. This mechanism of exposure to pesticides occurs post 

application, and it would pertain to those pesticides with a high vapor pressure. The USEPA 

is currently evaluating protocols for modeling inhalation exposure from pesticides including 

near-field and near-ground air concentrations based upon equilibrium and kinetics-based 

models. Risk characterization for exposure with this mechanism is unavailable. 

 The effect from exposure to dusts contaminated with the pesticide cannot be assessed 

generically as partitioning issues related to application site soils and chemical properties of 

the applied pesticides render the exposure potential from this route highly situation specific. 

 Dermal exposure may occur through three potential sources: direct application of spray to 

terrestrial wildlife in the treated area or within the drift footprint, incidental contact with 

contaminated vegetation, or contact with contaminated water or soil. Interception of spray 

and incidental contact with treated substrates may pose a risk to avian wildlife (Driver et al. 

1991). However, available research related to wildlife dermal contact with pesticides is 

extremely limited, except dermal toxicity values, which are common for some mammals used 

as human surrogates (rats and mice). The USEPA is currently evaluating protocols for 

modeling dermal exposure. Risk characterization may be underestimated for this route of 

exposure, particularly with high-risk pesticides such as some organophosphates or carbamate 

insecticides. If protocols are established by the USEPA for assessing dermal exposure to 

pesticides, they would be considered for incorporation into pesticide assessment protocols. 

 Exposure to a pesticide may occur from consuming surface water, dew, or other water on 

treated surfaces. Water-soluble pesticides have the potential to dissolve in surface runoff, and 

puddles in a treated area may contain pesticide residues. Similarly, pesticides with lower 

organic carbon partitioning characteristics and higher solubility in water have a greater 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-27 

potential to dissolve in dew and other water associated with plant surfaces. Estimating the 

extent to which such pesticide loadings to drinking water occurs is complex and would 

depend upon the partitioning characteristics of the active ingredient, soils types in the 

treatment area, and the meteorology of the treatment area. In addition, the use of various 

water sources by wildlife is highly species-specific. Currently, risk characterization for this 

exposure mechanism is not available. The USEPA is actively developing protocols to 

quantify drinking water exposures from puddles and dew. If and when protocols are formally 

established by the USEPA for assessing exposure to pesticides through drinking water, these 

protocols would be incorporated into pesticide risk assessment protocols. 

 Risk assessments are based upon the assumption that the entire treatment area would be 

subject to pesticide application at the rates specified on the label. In most cases, there is 

potential for uneven application of pesticides through such plausible incidents as changes in 

calibration of application equipment, spillage, and localized releases at specific areas in or 

near the treated field that are associated with mixing, handling, and application equipment as 

well as applicator skill. Inappropriate use of pesticides and the occurrence of spills represent 

a potential underestimate of risk. It is likely not an important factor for risk characterization. 

All pesticide applicators are required to be certified by the state in which they apply 

pesticides. Certification training includes the safe storage, transport, handling, and mixing of 

pesticides; equipment calibration; and proper application, with annual continuing education. 

 The USEPA relies on Fletcher (1994) for setting the assumed pesticide residues in wildlife 

dietary items. The USEPA (2004) “believes that these residue assumptions reflect a realistic 

upper-bound residue estimate, although the degree to which this assumption reflects a 

specific percentile estimate is difficult to quantify.” Fletcher’s (1994) research suggests that 

the pesticide active ingredient residue assumptions used by the USEPA represent a 95th

percentile estimate. However, research conducted by Pfleeger et al. (1996) indicates that 

USEPA residue assumptions for short grass were not exceeded. Baehr and Habig (2000) 

compared USEPA residue assumptions with distributions of measured pesticide residues for 

the USEPA’s UTAB database. Overall residue selection level will tend to overestimate risk 

characterization. This is particularly evident when wildlife individuals are likely to have 

selected a variety of food items acquired from multiple locations. Some food items may be 

contaminated with pesticide residues, whereas others are not contaminated. However, it is 

important to recognize differences in species feeding behavior. Some species may consume 

whole aboveground plant material, but others will preferentially select different plant 

structures. Also, species may preferentially select a food item although multiple food items 

may be present. Without species-specific knowledge regarding foraging behavior, 

characterizing ecological risk other than in general terms is not possible. 

 Acute and chronic risk assessments rely on comparisons of wildlife dietary residues with 

LC50 or NOEC values expressed as concentrations of pesticides in laboratory feed. These 

comparisons assume that ingestion of food items in the field occurs at rates commensurate 

with those in the laboratory. Although the screening assessment process adjusts dry-weight 

estimates of food intake to reflect the increased mass in fresh-weight wildlife food, it does 

not allow for gross energy and assimilative efficiency differences between wildlife food 

items and laboratory feed. Differences in assimilative efficiency between laboratory and wild 

diets suggest that current screening assessment methods are not accounting for a potentially 

important aspect of food requirements. 

 There are several other assumptions that can affect non-target species not considered in the 

risk assessment process. These include possible additive or synergistic effects from applying 

two or more pesticides or additives in a single application, co-location of pesticides in the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-28 Appendix G. Integrated Pest Management Plan 

environment, cumulative effects from pesticides with the same mode of action, and effects of 

multiple stressors (e.g., combination of pesticide exposure, adverse abiotic and biotic factors) 

and behavioral changes induced by exposure to a pesticide. These factors may exist at some 

level contributing to adverse effects to non-target species, but they are usually characterized 

in the published literature in only a general manner, limiting their value in the risk assessment 

process.

 It is assumed that aquatic species exclusively and permanently occupy the water body being 

assessed. Actual habitat requirements of aquatic species are not considered. With the possible 

exception of scenarios where pesticides are directly applied to water, it is assumed that no 

habitat use considerations specific for any species would place the organisms in closer 

proximity to pesticide use sites. This assumption produces a maximum estimate of exposure 

or risk characterization. It would likely be realistic for many aquatic species that may be 

found in aquatic habitats within or in close proximity to treated terrestrial habitats. However, 

the spatial distribution of wildlife is usually not random because wildlife distributions are 

often related to habitat requirements of species. Clumped distributions of wildlife may result 

in an under- or over-estimation of risk depending upon where the initial pesticide 

concentration occurs relative to the species or species habitat. 

 For species found in the water column, it would be assumed that the greatest bioavailable 

fraction of the pesticide active ingredient in surface waters is freely dissolved in the water 

column. Additional chemical exposure from materials associated with suspended solids or 

food items is not considered because partitioning onto sediments is likely minimal. 

Adsorption and bioconcentration occur at lower levels for many newer pesticides compared 

with older, more persistent bioaccumulative compounds. Pesticides with RQs close to the 

listed species LOC have the potential for additional exposure from these routes and may be a 

limitation of risk assessments, where potential pesticide exposure or risk may be 

underestimated. 

 Mass transport losses of pesticide from a water body (except for losses by volatilization, 

degradation, and sediment partitioning) would not be considered for ecological risk 

assessment. The water body would be assumed to capture all pesticide active ingredients 

entering as runoff and drift, and adsorbed to eroded soil particles. It would also be assumed 

that the pesticide active ingredient is not lost from the water body by overtopping or flowthrough, nor is concentration reduced by dilution. In total, these assumptions would lead to a 

near maximum possible water-borne concentration. However, this assumption would not 

account for the potential to concentrate pesticide through evaporative loss. This limitation 

may have the greatest impact on water bodies with high surface-to-volume ratios such as 

ephemeral wetlands, where evaporative losses are accentuated and applied pesticides have 

low rates of degradation and volatilization. 

 For acute risk assessments, there would be no averaging time for exposure. An instantaneous 

peak concentration would be assumed, where instantaneous exposure is sufficient in duration 

to elicit acute effects comparable to those observed over more protracted exposure periods 

(typically 48 to 96 hours) tested in the laboratory. In the absence of data regarding time-totoxic event and analyses and latent responses to instantaneous exposure, risk would likely be 

overestimated. 

 For chronic exposure risk assessments, the averaging times considered for exposure are 

commensurate with the duration of invertebrate life cycle or fish early life stage tests (e.g., 

21–28 days and 56–60 days, respectively). Response profiles (time to effect and latency of 

effect) to pesticides likely vary widely with mode of action and species and should be 

evaluated on a case-by-case basis as available data allow. Nevertheless, because the USEPA 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-29 

relies on chronic exposure toxicity endpoints based on a finding of no observed effect, the 

potential for any latent toxicity effects or averaging time assumptions to alter the results of an 

acceptable chronic risk assessment prediction is limited. The extent to which duration of 

exposure from water-borne concentrations overestimate or underestimate actual exposure 

depends on several factors. These include the following: localized meteorological conditions, 

runoff characteristics of the watershed (e.g., soils, topography), the hydrological 

characteristics of receiving waters, the environmental fate of the pesticide active ingredient, 

and the method of pesticide application. It should also be understood that chronic effects 

studies are performed using a method that holds water concentration in a steady state. This 

method is not likely to reflect conditions associated with pesticide runoff. Pesticide 

concentrations in the field increase and decrease in surface water in a cycle influenced by 

rainfall, pesticide use patterns, and degradation rates. As a result of the dependency of this 

assumption on several undefined variables, risk associated with chronic exposure may be 

underestimated in some situations and overestimated in others. 

 There are several other factors that can affect non-target species not considered in the risk 

assessment process. These would include the following: possible additive or synergistic 

effects from applying two or more pesticides or additives in a single application, co-location 

of pesticides in the environment, cumulative effects from pesticides with the same mode of 

action, effects of multiple stressors (e.g., combination of pesticide exposure, adverse abiotic 

[not pesticides] and biotic factors), and sub-lethal effects such as behavioral changes induced 

by exposure to a pesticide. These factors may exist at some level, contributing to adverse 

effects to non-target species, but they are not routinely assessed by regulatory agencies. 

Therefore, information on the factors is not extensive, limiting their value for the risk 

assessment process. As this type of information becomes available, it would be included, 

either quantitatively or qualitatively, in this risk assessment process. 

 USEPA is required by the Food Quality Protection Act to assess the cumulative risks of 

pesticides that share common mechanisms of toxicity, or act the same within an organism. 

Currently, USEPA has identified four groups of pesticides that have a common mechanism of 

toxicity requiring cumulative risk assessments. These four groups are: the organophosphate 

insecticides, N-methyl carbamate insecticides, triazine herbicides, and chloroacetanilide 

herbicides. 

G.7.3 Pesticide Mixtures and Degradates 

Pesticide products are usually a formulation of several components generally categorized as active 

ingredients and inert, or other, ingredients. The active ingredient is defined by the FIFRA as 

preventing, destroying, repelling, or mitigating the effects of a pest, or as a plant regulator, defoliant, 

desiccant, or nitrogen stabilizer. In accordance with FIFRA, the active ingredient(s) must be 

identified by name(s) on the pesticide label along with its relative composition expressed in 

percentage(s) by weight. In contrast, inert ingredients are not intended to affect a target pest. Their 

role in the pesticide formulation is to act as a solvent (keep the active ingredient in a liquid phase), an 

emulsifying or suspending agent (keep the active ingredient from separating out of solution), or a 

carrier (such as clay in which the active ingredient is impregnated on the clay particle in dry 

formulations). For example, if isopropyl alcohol would be used as a solvent in a pesticide 

formulation, then it would be considered an inert ingredient. FIFRA only requires that inert 

ingredients identified as hazardous, their associated percentage composition, and the total percentage 

of all inert ingredients be declared on a product label. Inert ingredients that are not classified as 

hazardous are not required to be identified. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-30 Appendix G. Integrated Pest Management Plan 

The USEPA (September 1997) issued Pesticide Regulation Notice 97-6, which encouraged 

manufacturers, formulators, producers, and registrants of pesticide products to voluntarily substitute 

the term “other ingredients” for “inert ingredients” in the ingredient statement. This change 

recognized that all components in a pesticide formulation potentially could elicit or contribute to an 

adverse effect on non-target organisms and, therefore, are not necessarily inert. Whether referred to 

as “inerts” or “other ingredients,” these constituents within a pesticide product have the potential to 

affect species or environmental quality. The USEPA categorizes regulated inert ingredients into the 

following four lists (http://www.epa.gov/opprd001/inerts/index.html): 

 List 1: Inert Ingredients of Toxicological Concern 

 List 2: Potentially Toxic Inert Ingredients 

 List 3: Inerts of Unknown Toxicity 

 List 4: Inerts of Minimal Toxicity 

Several of the List 4 compounds are naturally occurring earthen materials (e.g., clay materials, 

simple salts) that would not elicit toxicological response at applied concentrations. However, some of 

the inerts (particularly the List 3 compounds and unlisted compounds) may have moderate to high 

potential toxicity to aquatic species based on MSDSs or published data. 

Comprehensively assessing potential effects to non-target fish, wildlife, plants, and/or their habitats 

from pesticide use is a complex task. It would be preferable to assess the cumulative effects from 

exposure to the active ingredient, its degradates, inert ingredients, and other active ingredients in the 

spray mixture. However, it would only be feasible to conduct deterministic risk assessments for each 

component in the spray mixture singly. Limited scientific information is available regarding 

ecological effects (additive or synergistic) from chemical mixtures that typically rely upon broadly 

encompassing assumptions. For example, the U.S. Forest Service (2005) found that mixtures of 

pesticides used in land (forest) management likely would not cause additive or synergistic effects to 

non-target species based upon a review of scientific literature regarding toxicological effects and 

interactions of agricultural chemicals (ATSDR 2004). Moreover, information on inert ingredients, 

adjuvants, and degradates is often limited by the availability of and access to reliable toxicological 

data for these constituents. 

Toxicological information regarding “other ingredients” may be available from sources such as the 

following: 

 TOMES (a proprietary toxicological database including USEPA’s IRIS, the Hazardous 

Substance Data Bank, and the Registry of Toxic Effects of Chemical Substances [RTECS]). 

 USEPA’s ECOTOX database, which includes AQUIRE (a database containing scientific 

papers published on the toxic effects of chemicals to aquatic organisms). 

 TOXLINE (a literature-searching tool). 

 MSDSs from pesticide suppliers. 

 Other sources such as the Farm Chemicals Handbook. 

Because there is a lack of specific inert toxicological data, inerts in a pesticide may cause adverse 

ecological effects. However, inert ingredients typically represent only a small percentage of the 

pesticide spray mixture, and it would be assumed that negligible effects would be expected to result 

from inert ingredients. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-31 

Although the potential effects of degradates should be considered when selecting a pesticide, it is 

beyond the scope of this assessment process to consider all possible breakdown chemicals of the 

various product formulations containing an active ingredient. Degradates may be more or less mobile 

and more or less hazardous in the environment than their parent pesticides (Battaglin et al. 2003). 

Differences in environmental behavior (e.g., mobility) and toxicity between parent pesticides and 

degradates would make assessing potential degradate effects extremely difficult. For example, a less 

toxic and more mobile bioaccumulative or persistent degradate may have potentially greater effects 

on species and/or degrade environmental quality. The lack of data on the toxicity of degradates for 

many pesticides would represent a source of uncertainty for assessing risk.

A USEPA-approved label specifies whether a product can be mixed with one or more pesticides. 

Without product-specific toxicological data, it would not possible to quantify the potential effects of 

these mixtures. In addition, a quantitative analysis could only be conducted if reliable scientific 

information allowed a determination of whether the joint action of a mixture would be additive, 

synergistic, or antagonistic. Such information would not likely exist unless the mode of action is 

common among the chemicals and receptors. Moreover, the composition of and exposure to mixtures 

would be highly site- and/or time-specific and, therefore, it would be nearly impossible to assess 

potential effects to species and environmental quality. 

To minimize or eliminate potential negative effects associated with applying two or more pesticides 

as a mixture, the use would be conducted in accordance with the labeling requirements. Labels for 

two or more pesticides applied as a mixture should be completely reviewed, where products with the 

least potential for negative effects would be selected for use on the refuge. This is especially relevant 

when a mixture would be applied in a manner that may already have the potential for an effect(s) 

associated with an individual pesticide (e.g., runoff to ponds in sandy watersheds). Use of a tank mix 

under these conditions would increase the level of uncertainty in terms of risk to species or potential 

to degrade environmental quality. 

Adjuvants generally function to enhance or prolong the activity of pesticide. For terrestrial 

herbicides, adjuvants aid in the absorption into plant tissue. Adjuvant is a broad term that generally 

applies to surfactants, selected oils, anti-foaming agents, buffering compounds, drift control agents, 

compatibility agents, stickers, and spreaders. Adjuvants are not under the same registration 

requirements as pesticides, and the USEPA does not register or approve the labeling of spray 

adjuvants. Individual pesticide labels identify types of adjuvants approved for use with the pesticide. 

In general, adjuvants compose a relatively small portion of the volume of pesticides applied. 

Selection of adjuvants with limited toxicity and low volumes would be recommended to reduce the 

potential for the adjuvant to influence the toxicity of the pesticide. 

G.7.4 Determining Effects to Soil and Water Quality 

The approval process for pesticide uses would consider potential to degrade water quality on and off 

refuge lands. A pesticide can only affect water quality through movement away from the treatment 

site. After application, pesticide mobilization can be characterized by one or more of the following 

(Kerle et al. 1996): 

 Attach (sorb) to soil, vegetation, or other surfaces and remain at or near the treated area; 

 Attach to soil and move off-site through erosion from runoff or wind; 

 Dissolve in water that can be subjected to runoff or leaching. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-32 Appendix G. Integrated Pest Management Plan 

As an initial screening tool, selected chemical characteristics and rating criteria for a pesticide can be 

evaluated to assess potential to enter ground and/or surface waters. These would include the 

following: persistence, sorption coefficient (Koc), groundwater ubiquity score (GUS), and solubility. 

Persistence, which is expressed as half-life (t1⁄2), represents the length of time required for 50 percent 

of the deposited pesticide to degrade (completely or partially). Persistence in the soil can be 

categorized as the following: non-persistent is less than 30 days, moderately persistent is 30 to 100 

days, and persistent is over 100 days (Kerle et al. 1996). Half-life data is usually available for aquatic 

and terrestrial environments. 

Another measure of pesticide persistence is dissipation time (DT50). This represents the time required 

for 50 percent of the deposited pesticide to degrade and move from a treated site, whereas half-life 

describes the rate for degradation only. As for half-life, units of dissipation time are usually 

expressed in days. Field or foliar dissipation time is the preferred data for use to estimate pesticide 

concentrations in the environment. However, soil half-life is the most common persistence data cited 

in published literature. If field or foliar dissipation data is not available, soil half-life data may be 

used. The average or representative half-life value of the most important degradation mechanism will 

be selected for quantitative analysis for both terrestrial and aquatic environments. 

The mobility of a pesticide is a function of how strongly it is adsorbed to soil particles and organic 

matter, its solubility in water, and its persistence in the environment. Pesticides strongly adsorbed to 

soil particles, relatively insoluble in water, and not environmentally persistent would be less likely to 

move across the soil surface into surface waters or to leach through the soil profile and contaminate 

groundwater. Conversely, pesticides that are not strongly adsorbed to soil particles, are highly water 

soluble, and are persistent in the environment would have greater potential to move from the 

application site (off-site movement). 

The degree of pesticide adsorption to soil particles and organic matter (Kerle et al. 1996) is expressed 

as the soil adsorption coefficient (Koc). The Koc is measured as micrograms of pesticide per gram of 

soil (μg/g) and can range from near zero to the thousands. Pesticides with higher Koc values are 

strongly adsorbed to soil and, therefore, would be less subject to movement. 

Water solubility describes the amount of pesticide that will dissolve in a known quantity of water. 

The water solubility of a pesticide is expressed as milligrams of pesticide dissolved in a liter of water 

(mg/L or parts per million [ppm]). Pesticide with solubility <0.1 ppm are virtually insoluble in water; 

those with solubility from 100 to 1,000 ppm are moderately soluble and those with solubility 

over10,000 ppm are highly soluble (U.S. Geological Survey [USGS] 2000). As pesticide solubility 

increases, there would be greater potential for off-site movement. 

The GUS is a quantitative screening tool to estimate a pesticide’s potential to move in the 

environment. It uses soil persistence and adsorption coefficients in the following formula. 

GUS = log10 (t1⁄2) × [4 − log10(Koc)] 

The potential pesticide movement rating would be based upon its GUS value. Pesticides with a GUS 

less than 0.1 would be considered to have an extremely low potential to move toward groundwater. 

Values of 1.0 to 2.0 would be low, 2.0 to 3.0 would be moderate, 3.0 to 4.0 would be high, and over 

4.0 would have a very high potential to move toward groundwater. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-33 

Water solubility describes the amount of pesticide dissolving in a specific quantity of water, where it 

is usually measured as mg/L or ppm. Solubility is useful as a comparative measure because 

pesticides with higher values are more likely to move by runoff or leaching. GUS, water solubility, 

t1⁄2, and Koc values are available for selected pesticides from the Oregon State University (OSU) 

Extension Pesticide Properties Database at http://npic.orst.edu/ppdmove.htm. Many of the values in 

this database were derived from the SCS/ARS/CES Pesticide Properties Database for Environmental 

Decision Making (Wauchope et al. 1992). 

Soil properties influence the fate of pesticides in the environment. The following six properties are 

mostly likely to affect pesticide degradation and the potential for pesticides to move off-site by 

leaching (vertical movement through the soil) or runoff (lateral movement across the soil surface). 

 Permeability is the rate of water movement vertically through the soil. It is affected by soil 

texture and structure. Coarse-textured soils (e.g., high sand content) have a larger pore size 

and are generally more permeable than fine textured soils (i.e., high clay content). The more 

permeable soils would have a greater potential for pesticides to move vertically down 

through the soil profile. Soil permeability rates (inches/hour) are usually available in county 

soil survey reports. 

 Soil texture describes the relative percentage of sand, silt, and clay. In general, greater clay 

content with smaller pore size would lower the likelihood and rate at which water would 

move through the soil profile. Clay also serves to adsorb (bind) pesticides to soil particles. 

Soils with high clay content would adsorb more pesticide than soils with relatively low clay 

content. In contrast, sandy soils with coarser texture and lower water holding capacity would 

have a greater potential for water to leach through them. 

 Soil structure describes soil aggregation. Soils with a well-developed soil structure have 

looser, more aggregated structure that would be less likely to be compacted. Both 

characteristics would allow for less restricted flow of water through the soil profile, resulting 

in greater infiltration.

 Organic matter would be the single most important factor affecting pesticide adsorption in 

soils. Many pesticides are adsorbed to organic matter, which reduces their rate of downward 

movement through the soil profile. Also, soils high in organic matter tend to hold more water, 

which may make less water available for leaching. 

 Soil moisture affects how fast water moves through the soil. If soils are already wet or 

saturated before rainfall or irrigation, excess moisture would become runoff rather than 

infiltrate into the soil profile. Soil moisture also influences microbial and chemical activity in 

soil, which affects pesticide degradation. 

 Soil pH influences chemical reactions that occur in the soil, which in turn determines whether 

a pesticide will degrade, the rate of degradation, and, in some instances, which degradation 

products are produced. 

Based upon the aforementioned properties, soils most vulnerable to groundwater contamination 

would be sandy soils with low organic matter. In contrast, the least vulnerable soils would be welldrained clayey soils with high organic matter. Consequently, pesticides with the lowest potential for 

movement in conjunction with appropriate BMPs (see below) would be used in an IPM framework to 

treat pests while minimizing effects to non-target biota and protecting environmental quality. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-34 Appendix G. Integrated Pest Management Plan 

Along with soil properties, the potential for a pesticide to affect water quality through runoff and 

leaching would be affected by site-specific environmental and abiotic conditions including rainfall, 

water table conditions, and topography (Huddleston 1996). 

 Water is necessary to separate pesticides from soil. This can occur in two basic ways. 

Pesticides that are soluble move easily with runoff water. Pesticide-laden soil particles can be 

dislodged and transported from the application site in runoff. The concentration of pesticides 

in the surface runoff would be greatest for the first runoff event following treatment. The 

rainfall intensity and route of water infiltration into soil, to a large extent, determine pesticide 

concentrations and losses in surface runoff. The timing of the rainfall after application also 

would have an effect. Rainfall interacts with pesticides at a shallow soil depth (0.25 to 0.5 

inch), which is called the mixing zone (Baker and Miller 1999). The pesticide/water mixture 

in the mixing zone tends to leach down into the soil or runoff depending upon how quickly 

the soil surface becomes saturated and how rapidly water can infiltrate into the soil. Leaching 

would decrease the amount of pesticide available near the soil surface (mixing zone) to 

runoff during the initial rainfall event following application and subsequent rainfall events. 

 Terrain slope would affect the potential for surface runoff and the intensity of runoff. Steeper 

slopes would have greater potential for runoff following a rainfall event. In contrast, soils that 

are relatively flat would have little potential for runoff, except during intense rainfall events. 

In addition, soils in lower areas would be more susceptible to leaching as a result of receiving 

excessive water from surrounding higher elevations. 

 Depth to groundwater would be an important factor affecting the potential for pesticides to 

leach into groundwater. If the distance from the soil surface to the top of the water table is 

shallow, pesticides would have less distance to travel to reach groundwater. Shallower water 

tables that persist for longer periods would be more likely to experience groundwater 

contamination. Soil survey reports are available for individual counties. These reports 

provide data in tabular format regarding the water table depths and the months during which 

they persist. In some situations, a hard pan exists above the water table that would prevent 

pesticide contamination from leaching. 

G.7.5 Determining Effects to Air Quality 

Pesticides may volatilize from soil and plant surfaces and move from the treated area into the 

atmosphere. The potential for a pesticide to volatilize is determined by the pesticide’s vapor pressure, 

which is affected by temperature, sorption, soil moisture, and the pesticide’s water solubility. Vapor 

pressure is often expressed in mm Hg. To make these numbers easier to compare, vapor pressure 

may be expressed in exponent form (I × 10-7), where I represents vapor pressure index. In general, 

pesticides with I less than 10 would have a low potential to volatilize, whereas pesticides with I 

greater than 1,000 would have a high potential to volatilize (Oregon State University 1996). Vapor 

pressure values for pesticides are usually available in the pesticide product MSDS or the USDA 

Agricultural Research Service (ARS) pesticide database. 

G.7.6 Preparing a Chemical Profile 

The following instructions would be used by Service personnel to complete Chemical Profiles for 

pesticides. Specifically, profiles would be prepared for pesticide active ingredients (e.g., glyphosate, 

imazapic) that would be contained in one or more trade name products that are registered and labeled 

with USEPA. All information fields under each category (e.g., toxicological endpoints, 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-35 

environmental fate) would be completed for a Chemical Profile. If no information is available for a 

specific field, then “No data is available in references” would be recorded in the profile. Available 

scientific information would be used to complete Chemical Profiles. Each entry of scientific 

information would be shown with applicable references. 

Completed Chemical Profiles would provide a structured decision-making process using quantitative 

assessment/screening tools with threshold values (where appropriate) that would be used to evaluate 

potential biological and other environmental effects to refuge resources. For ecological risk 

assessments presented in these profiles, the “worst-case scenario” would be evaluated to determine 

whether a pesticide could be approved for use considering the maximum single application rate 

specified on pesticide labels for habitat management and croplands/facilities maintenance treatments 

pertaining to refuges. Where the worst-case scenario likely would only result in minor, temporary, 

and localized effects to listed and nonlisted species with appropriate BMPs (see Section G.5 of this 

appendix), the proposed pesticide’s use in a PUP would have a scientific basis for approval under any 

application rate specified on the label that is at or below rates evaluated in a Chemical Profile. In 

some cases, the Chemical Profile would include a lower application rate than the maximum labeled 

rate in order to protect refuge resources. As necessary, Chemical Profiles would be periodically 

updated with new scientific information or as pesticides with the same active ingredient are proposed 

for use on the refuge in PUPs. 

Throughout this section, threshold values (to prevent or minimize potential biological and 

environmental effects) would be clearly identified for specific information presented in a completed 

Chemical Profile. Comparison with these threshold values provides an explicit scientific basis to 

approve or disapprove PUPs for habitat management and cropland/facilities maintenance on refuge 

lands. In general, PUPs would be approved for pesticides with Chemical Profiles where threshold 

values would not be exceeded. However, BMPs are identified for some screening tools that would 

minimize/eliminate potential effects (exceeding the threshold value) as a basis for approving PUPs. 

Date: Service personnel would record the date when the Chemical Profile is completed or updated. 

Chemical Profiles (e.g., currently approved PUPs) would be periodically reviewed and updated, as 

necessary. The most recent review date would be recorded on a profile to document when it was last 

updated. 

Trade Name(s): Service personnel would accurately and completely record the trade name(s) from 

the pesticide label, which includes a suffix that describes the formulation (e.g., WP, DG, EC, L, SP, 

I, II, or 64). The suffix often distinguishes a specific product among several pesticides with the same 

active ingredient. Service personnel would record a trade name for each pesticide product with the 

same active ingredient. 

Common chemical name(s): Service personnel would record the common name(s) listed on the 

pesticide label or MSDS for an active ingredient. The common name of a pesticide is listed as the 

active ingredient on the title page of the product label immediately following the trade name, and in 

Section 2 of the MSDS (Composition/Information on Ingredients). A Chemical Profile is completed 

for each active ingredient. 

Pesticide Type: Service personnel would record the type of pesticide for an active ingredient as one 

of the following: herbicide, dessicant, fungicide, fumigant, growth regulator, insecticide, piscicide, or 

rodenticide. 
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G-36 Appendix G. Integrated Pest Management Plan 

EPA Registration Number(s): This number (EPA Registration Number) appears on the title page of 

the label and in Section 1 of the MSDS (Chemical Product and Company Description). It is not the 

EPA Establishment Number, which is usually located near it. Service personnel would record the 

EPA Reg. No. for each trade name product with an active ingredient based upon PUPs. 

Pesticide Class: Service personnel would list the general chemical class for the pesticide (active 

ingredient). For example, malathion is an organophosphate and carbaryl is a carbamate. 

CAS (Chemical Abstract Service) Number: This number is often located in the second section 

(Composition/Information on Ingredients) of the MSDS. The MSDS table listing components usually 

contains this number immediately prior to or following the percentage composition. 

Other Ingredients: Based on the most recent MSDS for the proposed pesticide product(s), Service 

personnel would include any chemicals in the pesticide formulation not listed as an active ingredient 

and described as toxic or hazardous or regulated under the Superfund Amendments and 

Reauthorization Act (SARA), Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), Toxic Substances Control Act (TSCA), OSHA, State Right-to-Know, or other listed 

authorities. These are usually found in MSDS sections titled “Hazardous Identifications”, “Exposure 

Control/Personal Protection,” and “Regulatory Information.” If concentrations of other ingredients 

are available for any compounds identified as toxic or hazardous, then Service personnel would

record this information in the Chemical Profile by trade name. MSDSs may be obtained from the 

manufacturer, manufacturer’s website, or an online database maintained by Crop Data Management 

Systems, Inc. (see list below). 

G.7.6.1 Toxicological Endpoints 

Toxicological endpoint data would be collected for acute and chronic tests with mammals, birds, and 

fish. Data would be recorded for species available in the scientific literature. If no data are found for 

a particular taxonomic group, then “No data available in references” would be recorded as the data 

entry. Throughout the Chemical Profile, references (including toxicological endpoint data) would be 

cited using parentheses (#) following the recorded data. 

Mammalian LD50: For test species in the scientific literature, Service personnel would record 

available data for oral lethal dose (LD50) in mg/kg-bw (body weight) or ppm-bw. The most common 

test species in scientific literature are the rat and mouse. The lowest LD50 value found for a rat would 

be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk to mammals 

(see Table G-1 in Section G.7.1). 

Mammalian LC50: For test species in the scientific literature, Service personnel would record 

available data for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). The 

most common test species in scientific literature are the rat and mouse. The lowest LC50 value found 

for a rat would be used as a toxicological endpoint for diet-based RQ calculations to assess acute risk 

(see Table G-1 in Section G.7.1). 

Mammalian Reproduction: For test species listed in the scientific literature, Service personnel 

would record the test results (e.g., Lowest Observed Effect Concentration [LOEC], Lowest Observed 

Effect Level [LOEL], No Observed Adverse Effect Level [NOAEL], NOAEC) in mg/kg-bw or 

mg/kg-diet for reproductive test procedure(s) (e.g., generational studies [preferred], fertility, newborn 

weight). The most common test species available in scientific literature are rats and mice. The lowest 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-37 

NOEC, NOAEC, NOEL, or NOAEL test results found for a rat would be used as a toxicological 

endpoint for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.1). 

Avian LD50: For test species available in the scientific literature, Service personnel would record 

values for oral lethal dose (LD50) in mg/kg-bw or ppm-bw. Most common test species available in 

scientific literature are the bobwhite quail and mallard. The lowest LD50 value found for an avian 

species would be used as a toxicological endpoint for dose-based RQ calculations to assess acute risk 

(see Table G-1 in Section G.7.1). 

Avian LC50: For test species available in the scientific literature, Service personnel would record 

values for dietary lethal concentration (LC50) as reported (e.g., mg/kg-diet or ppm-diet). The most 

common test species available in scientific literature are the bobwhite quail and mallard. The lowest 

LC50 value found for an avian species would be used as a toxicological endpoint for diet-based RQ 

calculations to assess acute risk (see Table G-1 in Section G.7.1). 

Avian Reproduction: For test species available in the scientific literature, Service personnel would

record test results (e.g., LOEC, LOEL, NOAEC, NOAEL) in mg/kg-bw or mg/kg-diet consumed for 

reproductive test procedure(s) (e.g., early life cycle, reproductive). The most common test species 

available in scientific literature are the bobwhite quail and mallard. The lowest NOEC, NOAEC, 

NOEL, or NOAEL test results found for an avian species would be used as a toxicological endpoint 

for RQ calculations to assess chronic risk (see Table G-1 in Section G.7.1). 

Fish LC50: For test freshwater or marine species listed in the scientific literature, Service personnel 

would record the LC50 in ppm or mg/L. The most common test species available in the scientific 

literature are the bluegill, rainbow trout, and fathead minnow (marine). Test results for many game 

species may also be available. The lowest LC50 value found for a freshwater fish species would be 

used as a toxicological endpoint for RQ calculations to assess acute risk (see Table G-1 in Section 

G.7.1). 

Fish Early Life Stage (ELS)/Life Cycle: For test freshwater or marine species available in the 

scientific literature, Service personnel would record test results (e.g., LOEC, NOAEL, NOAEC, 

LOAEC) in ppm for test procedure(s) (e.g., early life cycle, life cycle). The most common test 

species available in the scientific literature are bluegill, rainbow trout, and fathead minnow. Test 

results for other game species may also be available. The lowest test value found for a fish species 

(preferably freshwater) would be used as a toxicological endpoint for RQ calculations to assess 

chronic risk (see Table G-1 in Section G.7.1). 

Other: For test invertebrate as well as non-vascular and vascular plant species available in the 

scientific literature, Service personnel would record LC50, LD50, LOEC, LOEL, NOAEC, NOAEL, or 

EC50 (environmental concentration) values in ppm or mg/L. The most common test invertebrate 

species available in scientific literature are the honey bee and the water flea (Daphnia magna). Green 

algae (Selenastrum capricornutum) and pondweed (Lemna minor) are frequently available test 

species for aquatic non-vascular and vascular plants, respectively. 

Ecological Incident Reports: After a site has been treated with pesticide(s), wildlife may be 

exposed to these chemical(s). When exposure is high relative to the toxicity of the pesticides, wildlife 

may be killed or visibly harmed (incapacitated). Such events are called ecological incidents. The 

USEPA maintains a database (Ecological Incident Information System) of ecological incidents. This 

database stores information extracted from incident reports submitted by various federal and state 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-38 Appendix G. Integrated Pest Management Plan 

agencies and nongovernment organizations. Information included in an incident report is the date and 

location of the incident, the type and magnitude of effects observed in various species, the use(s) of 

pesticides known or suspected of contributing to the incident, and results of any chemical residue and 

cholinesterase activity analyses conducted during the investigation. 

Incident reports can play an important role in evaluating the effects of pesticides by supplementing 

quantitative risk assessments. All incident reports for pesticide(s) with the active ingredient and 

associated information would be recorded. 

G.7.6.2 Environmental Fate 

Water Solubility: Service personnel would record values for water solubility (Sw), which describes 

the amount of pesticide that dissolves in a known quantity of water. Sw is expressed as mg/L (ppm). 

Pesticide Sw values would be categorized as one of the following: insoluble <0.1 ppm, moderately 

soluble = 100 to 1,000 ppm, highly soluble >10,000 ppm (USGS 2000). As pesticide Sw increases, 

there would be greater potential to degrade water quality through runoff and leaching. 

Sw values would be used to evaluate the potential for bioaccumulation in aquatic species (see 

Octanol-Water Partition Coefficient [Kow] below). 

Soil Mobility: Service personnel would record available values for soil adsorption coefficient (Koc

[μg/g]). It provides a measure of a chemical’s mobility and leaching potential in soil. Koc values are 

directly proportional to organic content, clay content, and surface area of the soil. Koc data for a 

pesticide may be available for a variety of soil types (e.g., clay, loam, sand). 

Koc values would be used in evaluating the potential to degrade groundwater by leaching (see

Potential to Move to Groundwater below).

Soil Persistence: Service personnel would record values for soil half-life (t1⁄2), which represents the 

length of time (days) required for 50 percent of the deposited pesticide to degrade (completely or 

partially) in the soil. Based upon the t1⁄2 value, soil persistence would be categorized as one of the 

following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days 

(Kerle et al. 1996). 

Threshold for Approving PUPs: 

 If soil t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect water 

quality. 

 If soil t1⁄2 >100 days, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the 

“Specific Best Management Practices” section to minimize potential surface runoff and 

leaching that can degrade water quality: 

o Do not exceed one application per site per year. 

o Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

o Do not use on steep slopes if substantial rainfall is expected within 24 hours or the 

ground is saturated. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-39 

Along with Koc, soil t1⁄2 values would be used in evaluating the potential to degrade groundwater by 

leaching (see Potential to Move to Groundwater below). 

Soil Dissipation: Dissipation time (DT50) represents the time required for 50 percent of the deposited 

pesticide to degrade and move from a treated site, whereas soil t1⁄2 describes the rate for degradation 

only. As for t1⁄2, units of DT50 are usually expressed in days. Field dissipation time would be the 

preferred data for use to estimate pesticide concentrations in the environment because it is based 

upon field studies unlike soil t1⁄2, which is derived in a laboratory. However, soil t1⁄2 is the most 

common persistence data available in the published literature. If field DT50 is not available, soil t1⁄2

data would be used in a Chemical Profile. The average or representative t1⁄2 value of the most 

important degradation mechanisms would be selected for quantitative analysis for both terrestrial and 

aquatic environments. 

Based upon the DT50 value, environmental persistence in the soil also would be categorized as one of 

the following: non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 

days. 

Threshold for Approving PUPs: 

 If soil DT50 ≤100 days, then a PUP would be approved without additional BMPs to protect 

water quality. 

 If soil DT50 >100 days, then a PUP would only be approved with additional BMPs 

specifically to protect water quality. One or more BMPs such as the following would be 

included in the “Specific Best Management Practices” section to minimize potential surface 

runoff and leaching that can degrade water quality: 

o Do not exceed one application per site per year. 

o Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

o Do not use on steep slopes if substantial rainfall is expected within 24 hours or the 

ground is saturated. 

Along with Koc, soil DT50 values (preferred over soil t1⁄2) would be used in evaluating the potential to 

degrade groundwater by leaching (see Potential to Move to Groundwater below), if available. 

Aquatic Persistence: Service personnel would record values for aquatic t1⁄2, which represents the 

length of time required for 50 percent of the deposited pesticide to degrade (completely or partially) 

in water. Based upon the t1⁄2 value, aquatic persistence would be categorized as one of the following: 

non-persistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days (Kerle et 

al. 1996). 

Threshold for Approving PUPs: 

 If aquatic t1⁄2 ≤100 days, then a PUP would be approved without additional BMPs to protect 

water quality. 

 If aquatic t1⁄2 >100 days, then a PUP would only be approved with additional BMPs 

specifically to protect water quality. One or more BMPs such as the following would be 

included in the “Specific Best Management Practices” section to minimize potential surface 

runoff and leaching that can degrade water quality: 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-40 Appendix G. Integrated Pest Management Plan 

o Do not exceed one application per site per year. 

o Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

o Do not use on steep slopes if substantial rainfall is expected within 24 hours or the 

ground is saturated. 

Aquatic Dissipation: Dissipation time (DT50) represents the time required for 50 percent of the 

deposited pesticide to degrade or move (dissipate); whereas, aquatic t1⁄2 describes the rate for 

degradation only. As for t1⁄2, units of DT50 are usually expressed in days. Based upon the DT50 value, 

environmental persistence in aquatic habitats also would be categorized as one of the following: nonpersistent <30 days, moderately persistent = 30 to 100 days, and persistent >100 days. 

Threshold for Approving PUPs: 

 If aquatic DT50 ≤100 days, then a PUP would be approved without additional BMPs to 

protect water quality. 

 If aquatic DT50 >100 days, then a PUP would only be approved with additional BMPs 

specifically to protect water quality. One or more BMPs such as the following would be 

included in the “Specific Best Management Practices” section to minimize potential surface 

runoff and leaching that can degrade water quality: 

o Do not exceed one application per site per year. 

o Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

o Do not use on steep slopes if substantial rainfall is expected within 24 hours or the 

ground is saturated. 

Potential to Move to Groundwater: Groundwater Ubiquity Score (GUS) = log10(soil t 1⁄2) × [4 −

log10(Koc)]. If a DT50 value is available, it would be used rather than a t1⁄2 value to calculate a GUS. 

Based upon the GUS, the potential to move toward groundwater would be recorded as one of the 

following categories: extremely low potential<1.0, low = 1.0 to 2.0, moderate = 2.0 to 3.0, high = 3.0 

to 4.0, or very high >4.0. 

Threshold for Approving PUPs: 

 If GUS ≤4.0, then a PUP would be approved without additional BMPs to protect water 

quality. 

 If GUS >4.0, then a PUP would only be approved with additional BMPs specifically to 

protect water quality. One or more BMPs such as the following would be included in the 

“Specific Best Management Practices” section to minimize potential surface runoff and 

leaching that can degrade water quality: 

o Do not exceed one application per site per year. 

o Do not use on coarse-textured soils where the ground water table is <10 feet and average 

annual precipitation >12 inches. 

o Do not use on steep slopes if substantial rainfall is expected within 24 hours or the 

ground is saturated. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-41 

Volatilization: Pesticides may volatilize (evaporate) from soil and plant surfaces and move off-target 

into the atmosphere. 

Threshold for Approving PUPs: 

 If I ≤1,000, then a PUP would be approved without additional BMPs to minimize drift and 

protect air quality. 

 If I >1,000, then a PUP would only be approved with additional BMPs specifically to 

minimize drift and protect air quality. One or more BMPs such as the following would be 

included in the “Specific Best Management Practices” section to reduce volatilization and 

potential to drift and degrade air quality: 

o Do not treat when wind velocities are <2 or >10 mph with existing or potential inversion 

conditions. 

o Apply the largest diameter droplets possible for spray treatments. 

o Avoid spraying when air temperatures are >85°F. 

o Use the lowest spray height possible above target canopy. 

o Where identified on the pesticide label, soil-incorporate pesticide as soon as possible 

during or after application. 

Octanol-Water Partition Coefficient (Kow): The octanol-water partition coefficient (Kow) is the 

concentration of a pesticide in octanol and water at equilibrium at a specific temperature. Because 

octanol is an organic solvent, it is considered a surrogate for natural organic matter. Therefore, Kow

would be used to assess potential for a pesticide to bioaccumulate in tissues of aquatic species (e.g., 

fish). If Kow >1,000 or Sw<1 mg/L and soil t1⁄2 >30 days, then there would be high potential for a 

pesticide to bioaccumulate in aquatic species such as fish (USGS 2000). 

Threshold for Approving PUPs: 

 If potential for a pesticide to bioaccumulate in aquatic species is not high, then the PUP 

would be approved. 

 If there is a high potential to bioaccumulate in aquatic species (Kow >1,000 or Sw <1 mg/L and 

soil t1⁄2 >30 days), then the PUP would not be approved, except under unusual circumstances 

where approval would only be granted by the Washington Office. 

Bioaccumulation/Bioconcentration: This is the physiological process where pesticide 

concentrations in tissue increase in biota because they are taken and stored at a faster rate than they 

are metabolized or excreted. The potential for bioaccumulation would be evaluated through 

bioaccumulation factors (BAFs) or bioconcentration factors (BCFs). Based upon BAF or BCF 

values, the potential to bioaccumulate would be recorded as one of the following: low: 0 to 300, 

moderate: 300 to 1,000, or high: >1,000 (Calabrese and Baldwin 1993). 

Threshold for Approving PUPs: 

 If BAF or BCF ≤1,000, then a PUP would be approved without additional BMPs. 

 If BAF or BCF> 1,000, then a PUP would not approved, except under unusual circumstances 

where approval would only be granted by the Washington Office. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-42 Appendix G. Integrated Pest Management Plan 

G.7.6.3 Worst-Case Ecological Risk Assessment 

Max Application Rates (acid equivalent): Service personnel would record the highest application 

rate of an active ingredient (ae basis) for habitat management and cropland/facilities maintenance 

treatments in this data field of a Chemical Profile. These rates can be found in Table CP.1 under the 

column heading “Max Product Rate – Single Application (lbs/acre – active ingredient on acid equiv 

basis).” This table would be prepared for a Chemical Profile from information specified in labels for 

trade name products identified in PUPs. If these data are not available in pesticide labels, then 

Service personnel would write “NS” for “not specified on label” in this table. 

EECs: An ECC represents potential exposure to fish and wildlife (birds and mammals) from 

pesticide use. EECs would be derived by Service personnel using a USEPA screening-level approach 

(USEPA 2004). For each maximum application rate (see description under “Max Application Rates 

[acid equivalent]”), Service personnel would record two EEC values in a Chemical Profile; these 

would represent the worst-case terrestrial and aquatic exposures for habitat management and 

croplands/facilities maintenance treatments. For terrestrial and aquatic EEC calculations, see 

description for data entry under “Presumption of Unacceptable Risk/Risk Quotients,” which is the 

next field for a Chemical Profile. 

Presumption of Unacceptable Risk/Risk Quotients: Service personnel would calculate and record 

acute and chronic RQs for birds, mammals, and fish using the provided tabular formats for habitat 

management and/or cropland/facilities maintenance treatments. RQs recorded in a Chemical Profile 

would represent the worst-case assessment for ecological risk. See Section G.7.2 of this appendix for 

a discussion regarding the calculations of RQs. 

For aquatic assessments associated with habitat management treatments, RQ calculations would be 

based upon selected acute and chronic toxicological endpoints for fish, and the EEC would be 

derived from Urban and Cook (1986) assuming 100 percent overspray to an entire 1-foot-deep water 

body using the max application rate (ae basis [see above]). 

For aquatic assessments associated with cropland/facilities maintenance treatments, RQ calculations 

would be done by Service personnel based upon selected acute and chronic toxicological endpoints 

for fish, and an EEC would be derived from the aquatic assessment in AgDRIFT version 2.01 under 

Tier I ground-based application with the following input variables: max application rate (acid basis 

[see above]), low boom (20 inches), fine to medium/coarse droplet size, 20 swaths, EPA-defined 

wetland, and 25-foot distance (buffer) from treated area to water. 

See Section G.7.2.1.2 of this appendix for more details regarding the calculation of EECs for aquatic 

habitats for habitat management and cropland/facilities maintenance treatments. 

For terrestrial avian and mammalian assessments, RQ calculations would be done by Service 

personnel based upon dietary exposure, where the “short grass” food item category would represent 

the worst-case scenario. For terrestrial spray applications associated with habitat management and 

cropland/facilities maintenance treatments, exposure (EECs and RQs) would be determined using the 

Kanaga nomogram method through the USEPA’s T-REX version 1.2.3. T-REX input variables 

would include max application rate (acid basis [see above]) and pesticide half-life (days) in soil to 

estimate the initial, maximum pesticide residue concentration on general food items for terrestrial 

vertebrate species in short (<20 cm tall) grass. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-43 

For granular pesticide formulations and pesticide-treated seed with a unique route of exposure for 

terrestrial avian and mammalian wildlife, see discussion on terrestrial granular application in Section 

G.7.2.1.1 of this appendix for the procedure that would be used to calculate RQs. 

All calculated RQs in both tables would be compared with LOCs established by USEPA (see Table 

G-2 in Section G.7.2). If a calculated RQ exceeds an established LOC value (in parentheses inside 

the table), then there would be potential for an acute or chronic effect (unacceptable risk) to federally 

listed (T&E) species and nonlisted species. See Section G.7.2 of this appendix for detailed 

descriptions of acute and chronic RQ calculations and comparisons to LOCs to assess risk. 

Threshold for approving PUPs: 

 If RQs≤LOCs, then a PUP would be approved without additional BMPs. 

 If RQs>LOCs, then a PUP would only be approved with additional BMPs specifically to 

minimize exposure (ecological risk) to bird, mammal, and/or fish species. One or more BMPs 

such as the following would be included in the “Specific Best Management Practices” section

to reduce potential risk to nonlisted or listed species: 

o Lower application rate and/or fewer number of applications so RQs≤LOCs. 

o For aquatic assessments (fish) associated with cropland/facilities maintenance, increase 

the buffer distance beyond 25 feet so RQs≤LOCs. 

Justification for Use: Service personnel would describe the reasons for using pesticide-based 

control of specific pests or groups of pests. In most cases, the pesticide label will provide the 

appropriate information regarding control of pests to describe in the section. 

Specific Best Management Practices (BMPs): Service personnel would record specific BMPs 

necessary to minimize or eliminate potential effects to non-target species and/or degradation of 

environmental quality from drift, surface runoff, or leaching. These BMPs would be based upon 

scientific information documented in previous data fields of a Chemical Profile. Where necessary 

and feasible, these specific practices would be included in PUPs as a basis for approval. 

If there are no specific BMPs that are appropriate, then Service personnel would describe why the 

potential effects to refuge resources and/or degradation of environmental quality is outweighed by 

the overall resource benefit(s) from the proposed pesticide use in the BMP section of the PUP. See 

Section G.5 of this appendix for a complete list of BMPs associated with mixing and applying 

pesticides appropriate for all PUPs with ground-based treatments that would be additive to any 

necessary, chemical-specific BMPs. 

References: Service personnel would record scientific resources used to provide data/information for 

a Chemical Profile. Use the number sequence to uniquely reference data in a chemical profile. 

The following online data resources are readily available for toxicological endpoint and 

environmental fate data for pesticides: 

1. California Product/Label Database. Department of Pesticide Regulation, California Environmental 

Protection Agency. (http://www.cdpr.ca.gov/docs/label/labelque.htm#regprods) 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-44 Appendix G. Integrated Pest Management Plan 

2. ECOTOX database. Office of Pesticide Programs, U.S. Environmental Protection Agency, 

Washington, D.C. (http://cfpub.epa.gov/ecotox/) 

3. Extension Toxicology Network (EXTOXNET) Pesticide Information Profiles. Cooperative effort 

of University of California-Davis, Oregon State University, Michigan State University, Cornell 

University, and University of Idaho through Oregon State University, Corvallis, Oregon. 

(http://extoxnet.orst.edu/pips/ghindex.html) 

4. FAO specifications and evaluations for plant protection products. Pesticide Management Unit, 

Plant Protection Services, Food and Agriculture Organization, United Nations. 

(http://www.fao.org/WAICENT/FAOINFO/AGRICULT/AGP/AGPP/Pesticid/) 

5. Human health and ecological risk assessments. Pesticide Management and Coordination, Forest 

Health Protection, U.S. Department of Agriculture, U.S. Forest Service. 

(http://www.fs.fed.us/foresthealth/pesticide/risk.htm) 

6. Pesticide Chemical Fact Sheets. Clemson University Pesticide Information Center. 

(http://entweb.clemson.edu/pesticid/Document/Labels/factshee.htm) 

7. Pesticide Fact Sheets. Published by Information Ventures, Inc. for Bureau of Land Management, 

Department of Interior; Bonneville Power Administration, U.S. Department of Energy; and U.S. 

Forest Service, U.S. Department of Agriculture. (http://infoventures.com/e-hlth/pesticide/pestfac.html) 

8. Pesticide Fact Sheets. National Pesticide Information Center. (http://npic.orst.edu/npicfact.htm) 

9. Pesticide Fate Database. U.S. Environmental Protection Agency, Washington, D.C. 

(http://cfpub.epa.gov/pfate/home.cfm). 

10. Pesticide product labels and material safety data sheets. Crop Data Management Systems, Inc. 

(CDMS) (http://www.cdms.net/pfa/LUpdateMsg.asp) or multiple websites maintained by 

agrichemical companies. 

11. Registered Pesticide Products (Oregon database). Oregon Department of Agriculture. 

(http://www.oda.state.or.us/dbs/pest_products/search.lasso) 

12. Regulatory notes. Pest Management Regulatory Agency, Health Canada, Ontario, Canada. 

(http://www.hc-sc.gc.ca/pmra-arla/) 

13. Reptile and Amphibian Toxicology Literature. Canadian Wildlife Service, Environment Canada, 

Ontario, Canada. (http://www.cws-scf.ec.gc.ca/nwrc-cnrf/ratl/index_e.cfm) 

14. Specific Chemical Fact Sheet – New Active Ingredients, Biopesticide Fact Sheet and Registration 

Fact Sheet. U.S. Environmental Protection Agency, Washington, D.C. 

(http://www.epa.gov/pestidides/factsheets/chemical_fs.htm) 

15. Weed Control Methods Handbook: Tools and Techniques for Use in Natural Areas. The Invasive 

Species Initiative. The Nature Conservancy. (http://tnsweeds.ucdavis.edu/handbook.html) 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-45 

16. Wildlife Contaminants Online. U.S. Geological Survey, Department of Interior, Washington, 

D.C. (http://www.pwrc.usgs.gov/contaminants-online/) 

17. One-liner database. 2000. U.S. Environmental Protection Agency, Office of Pesticide Programs, 

Washington, D.C. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-46 Appendix G. Integrated Pest Management Plan 

Chemical Profile 

Date: 

Trade Name(s): Common Chemical Name(s): 

Pesticide Type: EPA Registration Number: 

Pesticide Class: CAS Number: 

Other Ingredients: 

Toxicological Endpoints

Mammalian LD50: 

Mammalian LC50: 

Mammalian Reproduction: 

Avian LD50: 

Avian LC50: 

Avian Reproduction: 

Fish LC50: 

Fish ELS/Life Cycle: 

Other: 

Ecological Incident Reports 

Environmental Fate 

Water solubility (Sw): 

Soil Mobility (Koc): 

Soil Persistence (t1⁄2): 

Soil Dissipation (DT50): 

Aquatic Persistence (t1⁄2): 

Aquatic Dissipation (DT50): 

Potential to Move to Groundwater 

(GUS score): 

Volatilization (mm Hg): 

Octanol-Water Partition Coefficient (Kow): 

Bioaccumulation/Bioconcentration: BAF:` 

BCF: 

Worst-Case Ecological Risk Assessment

Max Application Rate 

(ai lbs/acre – ae basis) 

Habitat Management: 

Croplands/Facilities Maintenance: 

EECs Terrestrial (Habitat Management): 

Terrestrial (Croplands/Facilities Maintenance): 

Aquatic (Habitat Management): 

Aquatic (Croplands/Facilities Maintenance): 

Habitat Management Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-47 

Cropland/Facilities Maintenance Treatments: 

Presumption of Unacceptable Risk Risk Quotient (RQ) 

Listed (T&E) Species Nonlisted Species 

Acute Birds [0.1] [0.5] 

Mammals [0.1] [0.5] 

Fish [0.05] [0.5] 

Chronic Birds [1] [1] 

Mammals [1] [1] 

Fish [1] [1] 

Justification for Use: 

Specific Best Management 

Practices (BMPs): 

References: 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-48 Appendix G. Integrated Pest Management Plan Table CP.1 Pesticide Name Trade Namea Treatment Typeb Max Product Rate - Single Application (lbs/acre or gal/acre) Max Product Rate - Single Application (lbs/acre - active ingredient on acid equiv basis) Max Number of Applications Per Season Max Product Rate Per Season (lbs/acre/season or gal/acre/season) Minimum Time Between Applications (Days) 

aFrom each label for a pesticide identified in PUPs, Service personnel would record application information associated with possible/known uses on Service lands. bTreatment type: H – habitat management or CF – cropland/facilities maintenance. If a pesticide is labeled for both types of treatments (uses), then record separate data for H and 

CF applications. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-49 

G.8 References 

AgDrift. 2001. A user’s guide for AgDrift 2.04: a tiered approach for the assessment of spray drift of 

pesticides. Spray Drift Task Force. Macon, MO. 

ATSDR (Agency for Toxic Substances and Disease Registry). 2004. Guidance manual for the 

assessment of joint toxic action of chemical mixtures. U.S. Department of Health and Human 

Services, Public Health Service, ATSDR, Division of Toxicology. 62 pp. + appendices. 

Baehr, C. and C. Habig. 2000. Statistical evaluation of the UTAB database for use in terrestrial 

nontarget organism risk assessment. 10th Symposium on Environmental Toxicology and 

Risk Assessment. American Society of Testing and Materials. West Conshohocken, PA. 358 

pp. 

Baker, J. and G. Miller. 1999. Understanding and reducing pesticide losses. Extension Publication 

PM 1495, Iowa State University Extension. Ames, IA. 6 pp. 

Balciunas, J.K. 2000. Proceedings of the X International Symposium on Biological Control of 

Weeds. Montana State University, Bozeman, MT. 435 pp. 

Barry, T. 2004. Characterization of propanil prune foliage residues as related to propanil use patterns 

in the Sacramento Valley, CA. Proceedings of the International Conference on Pesticide 

Application for Drift Management. Waikoloa, HI. 15 pp. 

Battaglin, W.A., E.M. Thurman, S.J. Kalkhoff, and S.D. Porter. 2003. Herbicides and transformation 

products in surface waters of the midwestern United States. Journal of the American Water 

Resources Association (JAWRA) 39(4):743-756. 

Beyer, W.N., E.E. Connor, and S. Gerould. 1994. Estimates of soil ingestion by wildlife. Journal of 

Wildlife Management 58:375-382. 

Brooks, M.L., C.M. D’Antonio, D.M. Richardson, J.B. Grace, J.E. Keeley, J.M. DiTomaso, R.J. 

Hobbs, M. Pellant, and D. Pyke. 2004. Effects of invasive alien plants on fire regimes. 

BioScience 54:677-688. 

BLM (Bureau of Land Management). 2007. Vegetation treatments using herbicides on Bureau of 

Land Management lands in 17 western states programmatic EIS (PEIS). Washington office, 

Bureau of Land Management. 

Butler, T., W. Martinkovic, and O.N. Nesheim. 1998. Factors influencing pesticide movement to 

ground water. Extension Publication PI-2, University of Florida Cooperative Extension 

Service. Gainesville, FL. 4 pp. 

Calabrese, E.J. and L.A. Baldwin. 1993. Performing ecological risk assessments. Chelsea, MI: Lewis 

Publishers. 

Center, T.D., J.H. Frank, and F.A., Dray Jr. 1997. Biological control. Pages 245-263 in: Strangers in 

paradise: impact and management of nonindigenous species in Florida. Washington D.C.: 

Island Press. 

Cox, R.D. and V.J. Anderson. 2004. Increasing native diversity of cheatgrass-dominated rangeland 

through assisted succession. Journal of Range Management 57:203-210. 

Coombs, E.M., J.K Clark, G.L. Piper, and A.F. Cofrancesco Jr. 2004. Biological control of invasive 

plants in the United States. Corvallis, OR: Oregon State University Press. 

Driver, C.J., M.W. Ligotke, P. Van Voris, B.D. McVeety, B.J. Greenspan, and D.B. Brown. 1991. 

Routes of uptake and their relative contribution to the toxicologic response of northern 

bobwhite (Colinus virginianus) to an organophosphate pesticide. Environmental Toxicology 

and Chemistry 10:21-33. 

Dunning, J.B. 1984. Body weights of 686 species of North American birds. Western Bird Banding 

Association. Monograph No. 1. West Lafayette, ID. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

G-50 Appendix G. Integrated Pest Management Plan 

EPA (U.S. Environmental Protection Agency). 1990. Laboratory test methods of exposure to 

microbial pest control agents by the respiratory route to nontarget avian species. EPA/600/3-

90/070. Environmental Research Laboratory, Corvallis, OR. 

EPA. 1998. A comparative analysis of ecological risks from pesticides and their uses: background, 

methodology and case study. U.S. EPA. Environmental Fate & Effects Division, Office of 

Pesticide Programs, Washington, D.C. 105 pp. 

EPA. 2004. Overview of the ecological risk assessment process in the Office of Pesticide Programs, 

U.S. EPA. Endangered and threatened species effects determinations. Office of Pesticide 

Programs, Washington, D.C. 101 pp. 

EPA. 2005a. Technical overview of ecological risk assessment. Analysis phase: exposure 

characterization. U.S. EPA, Office of Pesticide Programs, Washington, D.C. Available at: 

http://www.epa.gov/oppefed1/ecorisk_ders/toera_analysis_exp.htm. Accessed July 28,2011. 

EPA. 2005b. User’s guide TREX v1.2.3. U.S. EPA, Office of Pesticide Programs, Washington, D.C. 

22 pp. Available at: http://www.epa.gov/oppefed1/models/terrestrial/trex_usersguide.htm. 

Accessed July 28, 2011. 

EXTOXNET (The Extension Toxicology Network). 1993. Movement of pesticides in the 

environment. Pesticide Information Project of Cooperative Extension Offices of Cornell 

University, Oregon State University, University of Idaho, University of California – Davis, 

and the Institute for Environmental Toxicology, Michigan State University. 4 pp. 

Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA 

food-chain (Kenaga) nomogram, an instrument for estimating pesticide residue on plants. 

Environmental Toxicology and Chemistry 13:1381-1391. 

Hasan, S. and P.G. Ayres. 1990. The control of weeds through fungi: principles and prospects. 

Tansley Review 23:201-222. 

Huddleston, J.H. 1996. How soil properties affect groundwater vulnerability to pesticide 

contamination. EM 8559. Oregon State University Extension Service. 4 pp. 

International Symposium on Biological Control of Weeds. International Code of Best Practice for 

Classical Biological Control of Weeds. 1999. Available at: http://sric.ucdavis.edu/exotic 

/exotic.htm. 

Kerle, E.A., J.J. Jenkins, P.A. Vogue. 1996. Understanding pesticide persistence and mobility for 

groundwater and surface water protection. EM 8561. Oregon State University Extension 

Service. 8 pp. 

Masters, R.A and R.L. Sheley. 2001. Invited synthesis paper: principles and practices for managing 

rangeland invasive plants. Journal of Range Management 54:502-517. 

Masters, R.A., S.J. Nissen, R.E. Gaussoin, D.D. Beran, and R.N. Stougaard. 1996. Imidazolinone 

herbicides improve restoration of Great Plains grasslands. Weed Technology 10:392-403. 

Maxwell, B.D., E. Lehnhoff, and L.J. Rew. 2009. The rationale for monitoring invasive plant 

populations as a crucial step for management. Invasive Plant Science and Management 2:1-9. 

Mineau, P., B.T. Collins, and A. Baril. 1996. On the use of scaling factors to improve interspecies 

extrapolation of acute toxicity in birds. Regulatory Toxicology and Pharmacology 24:24-29. 

Moody, M.E. and R.N. Mack. 1988. Controlling the spread of plant invasions: the importance of 

nascent foci. Journal of Applied Ecology 25:1009-1021. 

Mullin, B.H., L.W. Anderson, J.M. DiTomaso, R.E. Eplee, and K.D. Getsinger. 2000. Invasive plant 

species. Issue Paper (13):1-18. 

Oregon State University. 1996. EXTOXNET (Extension Toxicology Network) Pesticide Information 

Profiles. Oregon State University, Corvallis, OR. 

Pfleeger, T.G., A. Fong, R. Hayes, H. Ratsch, C. Wickliff. 1996. Field evaluation of the EPA 

(Kanaga) nomogram, a method for estimating wildlife exposure to pesticide residues on 

plants. Environmental Toxicology and Chemistry 15:535-543. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix G. Integrated Pest Management Plan G-51 

Pope, R., J. DeWitt, and J. Ellerhoff. 1999. Pesticide movement: what farmers need to know. 

Extension Publication PAT 36, Iowa State University Extension, Ames, Iowa and Iowa 

Department of Agriculture and Land Stewardship, Des Moines, IA. 6 pp. 

Ramsay, C.A., G.C. Craig, and C.B. McConnell. 1995. Clean water for Washington—protecting 

groundwater from pesticide contamination. Extension Publication EB1644, Washington State 

University Extension, Pullman, WA. 12 pp. 

Spray Drift Task Force. 2003. A summary of chemigation application studies. Spray Drift Task 

Force, Macon, MO. 

Teske, M.E., S.L. Bird, D.M. Esterly, T.B. Curbishley, S.L. Ray, and S.G. Perry. 2002. AgDRIFT: a 

model for estimating near-field spray drift from aerial applications. Environmental 

Toxicology and Chemistry 21:659-671. 

Urban, D.J and N.J. Cook. 1986. Ecological risk assessment. EPA 540/9-85-001. U.S. Environmental 

Protection Agency, Office of Pesticide Programs, Washington D.C. 94 pp. 

USGS (U.S. Geological Survey). 2000. Pesticides in stream sediment and aquatic biota: current 

understanding of distribution and major influences. USGS Fact Sheet 092-00, U.S. 

Geological Survey, Sacramento, CA. 4 pp. 

U.S. Forest Service. 2005. Pacific Northwest Region invasive plant program: preventing and 

managing invasive plants. Final environmental impact statement. 359 pp. 

Wauchope, R.D., T.M. Buttler, A.G. Hornsby, P.M. Augustijn-Beckers, and J.P. Burt. 1992. The 

SCS/ARS/CES pesticide properties database for environmental decision making. 

Reviews of Environmental Contamination and Toxicology 123:1-155. 

Woods, N. 2004. Australian developments in spray drift management. Proceedings of the 

International Conference on Pesticide Application for Drift Management. Waikoloa, HI. 8 

pp. 

 
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Turkey vultures

©Dan Dzurisin

Appendix H

Glossary of Terms

and Acronyms

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix I

Contributors

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-1 

Appendix H. Glossary of Terms and Acronyms 

H.1 Glossary 

303(d) – A section of the Clean Water Act that required states, territories, and authorized tribes to 

develop lists of impaired waters. These are waters that are too polluted or otherwise degraded to meet 

the water quality standards set by states, territories, or authorized tribes. 

4th level HUC – The fourth level of classification is the cataloging unit, the smallest element in the 

hierarchy of hydrologic units. 

Adaptive Management – The rigorous application of management, research, and monitoring to gain 

the information and experience necessary to assess and modify management activities. It refers to a 

process that uses feedback from refuge research and monitoring, and evaluation of management 

actions to support or modify objectives and strategies at all planning levels (602 FW 1.4). 

Adjudicated water right – An adjudication is an administrative or judicial determination of all 

rights to use water in a particular stream system or watershed, to establish the priority, point of 

diversion, place and nature of use and the quantity of water used among the various claimants. These 

stream or watershed adjudications can be initiated by a water user (including the United States) or by 

the State. The United States may be joined in an adjudication if the requirements of the McCarran 

Amendment are met. 

Aerenchyma – Modified parenchymatous tissue having large intracellular air spaces that is found 

especially in aquatic plants where it facilitates gaseous exchange and maintains buoyancy. 

Alternative – Different sets of objectives and strategies or means of achieving refuge purposes and 

goals, helping fulfill the Refuge System mission, and resolving issues (602 FW 1.6). The “no action” 

alternative is current refuge management, while the “action” alternatives are all other alternatives. 

Alluvial – Made up of or found in the materials that are left by the waters of rivers, floods, etc. 

Appropriate Use – A proposed or existing use on a refuge that meets at least one of the following 

four conditions: 

(1) The use is a wildlife-dependent recreational use as identified in the Improvement Act. 

(2) The use contributes to fulfilling the refuge purpose(s), the Refuge System mission or 

goals, or objectives described in a refuge management plan approved after October 9, 1997, 

the date the Improvement Act was signed into law. 

(3) The use involves the take of fish and wildlife under State regulations. 

(4) The use has been found to be appropriate as specified in Section 1.11 of the U.S. Fish and 

Wildlife Service (USFWS) Appropriate Use Policy (603 FW 1). 

Approved Acquisition Boundary – National Wildlife Refuge boundary approved by the National or 

Regional Fish and Wildlife Service Director for potential acquisition of lands by the Service. 

Approved Refuge Boundary – A National Wildlife Refuge boundary approved by the National or 

Regional Fish and Wildlife Service Director. Within this boundary, the Service may negotiate with 

landowners to acquire lands not already owned by the Service. 

Benthic – The collection of organisms living on or in sea or lake bottoms. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-2 Appendix H. Glossary 

Big Six – Wildlife-dependent recreational uses under Refuge System Improvement Act. This 

includes hunting, fishing, wildlife observation, photography, environmental education, and 

interpretation. 

Biological Diversity (also Biodiversity) – The variety of life and its processes, including the variety 

of living organisms, the genetic differences among them, and communities and ecosystems in which 

they occur (601 FW 3). The Refuge System’s focus is on indigenous species, biotic communities, 

and ecological processes. 

Biological Integrity – Biotic composition, structure, and functioning at the genetic, organism, and 

community levels comparable with historical conditions, including the natural biological processes 

that shape genomes, organisms, and communities (601 FW 3). 

Colluvium – Soil and debris that accumulate at the base of a slope by mass wasting or sheet erosion. 

It generally includes angular fragments, not sorted according to size, and may contain slabs of 

bedrock that dip back toward the slope, indicating both their place of origin and that slumping was 

the process of transportation. At the edges of valleys, colluvium may be interfingered with and 

almost indistinguishable from alluvium. 

Compatibility Determination – A written determination signed and dated by the refuge manager 

and regional chief signifying that a proposed or existing use of a National Wildlife Refuge is or is not 

a compatible use. The director makes this delegation through the Regional Direction (603 FW 2). 

Compatible Use – A wildlife-dependent recreational use or any other use of a refuge that, in the 

sound professional judgment of the director, will not materially interfere with or detract from the 

fulfillment of the mission of the Refuge System or the purposes of the refuge (603 FW 3.6). A 

compatibility determination supports the selection of compatible uses and identifies stipulations or 

limits necessary to ensure compatibility. 

Conservation Targets (also see Resources of Concern; Priority Species; Species Groups; and

Communities) – This is the term used by land management agencies and conservation organizations 

to describe the resources (ecological systems, ecological communities, species, species groups, or 

other natural resources) selected as the focus of conservation actions. 

Consumptive Use – Recreational activities, such as hunting and fishing that involve harvest or 

removal of wildlife or fish, generally to be used as food by humans. 

Consumptive Use Rate – Consumptive use rate represents the difference between the amount of 

water diverted and the amount of the return flow to the system (e.g., surface stream or underground 

basin). It is that amount by which the total resource is depleted. 

Cover – The estimated percent of an area, projected onto a horizontal surface, that is occupied by a 

particular plant species. 

Decadent – Undergoing a process of decline or decay. 

Dissolved Oxygen – The concentration of oxygen dissolved in water, expressed in mg/L or as 

percent saturation, where saturation is the maximum amount of oxygen that can theoretically be 

dissolved in water at a given altitude and temperature. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-3 

Duripan – A horizon in mineral soil characterized by cementation by silica. 

Ecotourism – Tourism that is designed to contribute to the protection of the environment or at least 

minimize damage to it, often involving travel to areas of natural interest in developing countries or 

participation in environmental projects. 

Effect (impact) – A direct result of an action that occurs at the same time and place; or an indirect 

result of an action that occurs earlier in time or in a different place and is reasonably foreseeable; or 

the cumulative results from the incremental impact of the action when added to other past, present, 

and reasonably foreseeable future actions, regardless of what agency or person undertakes such other 

actions (40 Code of Federal Regulations (CFR) 1508.8).

Emergent – Erect plants rooted underwater that grow above (emerge from) the surface of the water 

(e.g., cattails). 

Emissions Scenarios – Climate change term that is group into four categories of cumulative CO2 

emissions (all sources) between 1990 and 2100: low, medium low, medium high, and high emissions. 

Each category contains situations with a range of different driving forces yet similar cumulative 

emissions. 

Eolian – Borne, deposited, produced, or eroded by the wind. 

Exotic – From another part of the world; foreign. 

Fecundity – The quality or power of producing abundantly; fruitfulness or fertility. 

Flood Irrigation – A method of irrigation using water released into a field and allowed to flood over 

its entire surface. 

Fluvial – Of or pertaining to a river. 

Focal Species (also Priority Resources of Concern or Focal Conservation Target) – A suite of 

conservation targets that, for the purposes of planning, are sorted and condensed to represent threats 

to biological integrity, diversity, and environmental health at the refuge level. 

Goal – Descriptive, open-ended, and often broad statement of desired future conditions that conveys 

a purpose but does not define measurable units (620 FW 1.6). 

Greenhouse effect – The greenhouse effect refers to circumstances where the short wavelengths of 

visible light from the sun pass through a transparent medium and are absorbed, but the longer 

wavelengths of the infrared re-radiation from the heated objects are unable to pass through that 

medium. The trapping of the long wavelength radiation leads to more heating and a higher resultant 

temperature. 

Habitat Management Plan – A plan that provides refuge managers a decision-making process; 

guidance for the management of refuge habitat; and long-term vision, continuity, and consistency for 

habitat management on refuge lands (620 FW 1.4). 

Habitat Restoration – Management emphasis designed to move ecosystems to desired conditions 

and processes, and/or to healthy ecosystems. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-4 Appendix H. Glossary 

Historical Conditions – Composition, structure, and functioning of ecosystems resulting from 

natural processes that are believed, based on sound professional judgment, to have been present prior 

to substantial human-related changes to the landscape (601 FW 3). 

Idle – Not working or active; in the context of the Malheur Refuge comprehensive conservation plan 

(CCP), fields that are not receiving grazing or haying treatment in the current year. 

Important Bird Areas – A site, designated by the National Audubon Society, that provides essential 

habitat for one or more species of birds and that is recognized as being important on a global, 

continental, or state level. 

Integrated Pest Management (IPM) – The use of pest and environmental information in 

conjunction with available pest control technologies to prevent unacceptable levels of pest damage 

by the most economical means and with the least possible hazard to persons, property, and the 

environment. 

Interpretation – A teaching technique that combines factual information with stimulating 

explanation. Frequently used to help people understand natural and cultural resources. 

Inundation – To cover with water, especially floodwaters. 

Invasive – Marked by the tendency to spread. As applied to plant or animal species, invasive

connotes a species (often but not always non-native) that rapidly takes over a habitat or area, often 

crowding out other species and reducing diversity and ecosystem health. 

Inviolate Sanctuary – The original intent of the term inviolate sanctuary is found in the Migratory 

Bird Conservation Act (first passed in 1918 as the Migratory Bird Treaty Act and amended in 1934 

and 1938). This Act originally required that all refuges be inviolate sanctuaries and deemed that 

refuges’ primary purposes were as breeding grounds and habitat for migratory birds. Migratory bird 

hunting was prohibited in migratory waterfowl areas by the Act, but most other human uses were not 

addressed. The 1938 amendment to the Act gave refuge managers authority to decide if, when, and 

how bird hunting would be allowed. After World War II, public demand for opening refuges to 

recreation increased. The 1949 Duck Stamp Act allowed waterfowl hunting on refuges, but restricted 

the percentage of each refuge open to hunting. Current policy states that portions of a refuge are 

considered “inviolate sanctuaries” if they were (a) acquired with the approval of the Migratory Bird 

Conservation Commission (MBCC) for the purpose of an inviolate sanctuary; (b) acquired with 

MBCC approval or Land and Water Conservation Funds to protect a threatened or endangered 

species; or (c) established by an instrument or document that states the intent to manage the area as 

an “inviolate sanctuary for migratory birds” or to fulfill the purpose of the Migratory Bird 

Conservation Act. Policy further allows migratory game bird hunting on no more than 40 percent of 

the area considered inviolate sanctuary if it is compatible with a refuge’s purposes and mission. 

Inviolate sanctuary classification imposes no limits on hunting non-migratory birds, fur bearers, or 

other game species. 

Lacustrine – Of or relating to a lake. 

Lithology – The study of the general physical characteristics of rocks. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-5 

Lunette dune – Accumulations of semiconsolidated fine sand, silt, and clay-pellet aggregates that 

form rounded, low (meters high) dunes on the downwind sides of playas. 

Macrophyte – A plant that is large enough to be visible to the naked eye. A macrophyte may be an 

emergent, submergent, or floating type of aquatic plant. Its ecological significance is providing cover 

for fish and acting as substrate for aquatic invertebrates, as well as producing oxygen and serving as 

food for some fish and other wildlife. 

Meristematic tissue – Embryonic tissue located at the tips of stems and roots and occasionally 

along their entire length; can divide to produce new cells; one of the four main tissue systems in 

plants. 

Mesic – Characterized by, relating to, or requiring a moderate amount of moisture. 

Migratory birds – Those species of birds listed under 50 CFR 10.13 (as defined by various treaties) 

(720 FW 1). 

Monotypic – The sole member of a group, such as a single species that constitutes a genus. 

National Register of Historic Places – The nation’s master inventory of known historic properties 

administered by the National Park Service. Includes buildings, structures, sites, objects, and districts 

that possess historic, architectural, engineering, archeological, or cultural significance at the national, 

state, and local levels. 

National Wildlife Refuge – A designated area of land, water, or an interest in land or water within 

the Refuge System, excluding coordination areas (601 FW 1.3). 

National Wildlife Refuge System – Various categories of areas administered by the Secretary of the 

Interior for the conservation of fish and wildlife, including species threatened with extinction; all 

lands, waters, and interests therein administered by the Secretary as wildlife refuges; areas for the 

protection and conservation of fish and wildlife that are threatened with extinction; wildlife ranges; 

game ranges; wildlife management areas; or waterfowl production areas. 

National Wildlife Refuge System Improvement Act of 1997 (Public Law 105-57) – A federal law 

that amended and updated the National Wildlife Refuge System Administration Act of 1966 (16 

U.S.C. 668). 

Native – With respect to a particular ecosystem, a species that historically occurred or currently 

occurs (other than as a result of an introduction) in that ecosystem (601 FW 3). 

Non-consumptive Recreation – Recreational activities that do not involve harvest, removal, or 

consumption of fish, wildlife, or other natural resources. 

Non-native species – A species that is present in the planning area but was not known to exist prior 

to Euro-American settlement of the Americas. 

Novel community – Made up of either native and non-native species or native species outside 

historical spatial distributions. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-6 Appendix H. Glossary 

Noxious Weed – A plant species designated by Federal or state law as generally possessing one or 

more of the following characteristics: aggressive or difficult to manage; parasitic; a carrier or host of 

serious insect or disease; or non-native, new, or not common to the United States. According to the 

Federal Noxious Weed Act (PL 93-639), a noxious weed is one that causes disease or has adverse 

effects on man or his environment and is therefore detrimental to the agriculture and commerce of 

the United States and to the public health. 

Objective – A concise statement of what we want to achieve, how much we want to achieve, when 

and where we want to achieve it, and who is responsible for the work. Objectives derive from goals 

and provide the basis for determining strategies, monitoring refuge accomplishments, and evaluating 

the success of strategies. Objectives should be attainable, time-specific, and measurable (620 FW 

1.6). 

Outcropping – A portion of bedrock or other stratum protruding through the soil level. 

Pacific Decadal Oscillation (PDO) – Described as a long-lived El Niño-like pattern of Pacific 

climate variability. As seen with the better-known El Niño/Southern Oscillation (ENSO), extremes in 

the PDO pattern are marked by widespread variations in the Pacific Basin and the North American 

climate. 

Pacific Flyway – One of several major north-south travel corridors for migratory birds. The Pacific 

Flyway is west of the Rocky Mountains. 

Paleontological – The study of the forms of life existing in prehistoric or geologic times, as 

represented by the fossils of plants, animals, and other organisms. 

Palustrine – Relating to a system of inland, nontidal wetlands characterized by the presence of trees, 

shrubs, and emergent vegetation (vegetation that is rooted below water but grows above the surface). 

Pedogenic – The formation and development of soil. 

Phreatophyte – A deep-rooted plant that obtains water from a permanent ground supply or from the 

water table. 

Physiographic Province – A region in which the landforms are similar in geologic structure and 

differ significantly from the landform patterns in adjacent regions. 

Phytoplankton – Photosynthetic or plant constituent of plankton; mainly unicellular algae. 

Piezometric – Of or relating to pressure. 

Plant Community – An assemblage of plant species unique in its composition, occurring in 

particular locations under particular influences; a reflection or integration of the environmental 

influences on the site such as soils, temperature, elevation, solar radiation, slope, aspect, and rainfall; 

denotes a general kind of climax plant community (e.g., Oregon white oak woodland). 

Playa – Enclosed shallow depressions in desert basins, tectonic lows, interdune flats, wadis, and 

abandoned channels that contain deposits and evaporate from the impoundment of episodic stream 

flow or near-surface groundwater. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-7 

Priority Public Uses – Hunting, fishing, wildlife observation and photography, and environmental 

education and interpretation, where compatible, are identified under the National Wildlife Refuge 

System Improvement Act of 1997 as the six priority public uses of the National Wildlife Refuge 

System. 

Priority Resources of Concern – See Resources of Concern and Focal Species definitions. 

Proving up (on water rights) – The state process of meeting all the conditions placed on water right 

permits. 

Rake-bunch grazing – A form of treatment where meadow hay is mowed and raked into windrows, 

but left in place to be consumed by livestock during the late fall and winter. 

Refuge Purpose(s) – The purposes specified in or derived from the law, proclamation, executive 

order, agreement, public land order, donation document, or administrative memorandum establishing, 

authorizing, or expanding a refuge, refuge unit, or refuge subunit. For refuges that encompass 

congressionally designated wilderness, the purposes of the Wilderness Act are additional purposes of 

the refuge (620 FW 1.6). 

Residuum – Something remaining after removal of a part; a residue. 

Resource of Concern (ROC) – This refers to all plant and/or animal species, species groups, or 

communities specifically identified in refuge purpose(s), the Refuge System mission, or 

international, national, regional, state, or ecosystem conservation plans or acts. For example, 

waterfowl and shorebirds are ROCs on a refuge whose purpose is to protect “migrating waterfowl 

and shorebirds.” Federal or state threatened and endangered species on that same refuge are also an 

ROC under terms of the respective endangered species acts (620 FW 1.4). 

Rested – Allowed to be inactive in order to regain strength, health, or energy. 

Riverine – Relating to or resembling a river. Located on or inhabiting the banks of a river; riparian. 

Scoping – Early in the planning process, this is the phase of notifying the public of the opportunity to 

participate in the planning process to help identify issues, concerns, and opportunities related to the 

project. 

Seasonal Moisture Deficit – The difference between the amount of water that is in a soil and the 

amount needed for crops to grow successfully. 

Seasonal Wetlands – Areas that are periodically inundated or have soils saturated to the surface at 

some time during the growing season (but not year-round). 

Senescent – Growing old; aging. As applied to plants, when they are in a dormant phase (often 

during winter). 

Sen-Theil-Kendall Line – A type of statistical analysis for water resources. 

Significant Effect – Use of this term in the National Environmental Policy Act (NEPA) requires 

consideration of both context and intensity (40 CFR 1508.27). The significance of an action must be 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-8 Appendix H. Glossary 

analyzed in its current and proposed short- and long-term effects on the whole of a given resource 

(e.g., affected region) (context). Intensity is the severity of the effect. 

SLR Line – A simple linear regression line. 

Snow Water Equivalents – A common snowpack measurement. It is the amount of water contained 

within the snowpack. It can be thought of as the depth of water that would theoretically result if the 

entire snowpack were melted instantaneously. 

Species of Concern (Federal) – Taxa whose conservation status is of concern to the USFWS (many 

previously known as Category 2 candidates), but for which further information is still needed. Such 

species receive no legal protection and use of the term does not necessarily imply that a species will 

eventually be proposed for listing. 

Steppe – Arid land with xerophilous vegetation, found usually in regions of extreme temperature 

range and loess soil. 

Strategy – A specific action, tool, technique, or combination of actions, tools, and techniques used to 

meet unit objectives (620 FW 1.6). 

Subirrigated – To irrigate (land) by means of an underground system of pipelines or by natural 

moisture in the subsoil. 

Submergent – A plant that is completely beneath the surface of water. 

Successional – The gradual and orderly process of ecosystem development brought about by changes 

in community composition and the production of a climax characteristic of a particular geographic 

region. 

Telemetry – The science and technology of automatic measurement and transmission of data by 

wire, radio, or other means from remote sources, such as from space vehicles, to receiving stations 

for recording and analysis. 

THEIL – A nonparametric statistical test that can be used instead of regression-based methods for 

discerning a monotonic trend. 

TMDL (total maximum daily load) – A calculation of the maximum amount of a pollutant that a 

waterbody can receive and still safely meet water quality standards. 

Tolerance thresholds – The maximum amount of disturbance a suite of plant species can tolerate 

before an irreparable shift in plant community composition takes place. 

Transpiration – The passage of water through a plant from the roots through the vascular system to 

the atmosphere. 

Tuff – A rock composed of the finer kinds of volcanic detritus usually fused together by heat. 

Wetlands – Wetlands are lands transitional between terrestrial and aquatic systems, where the water 

table is usually at or near the surface or the land is covered by shallow water at some time during the 

growing season of each year (660 FW 2). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-9 

Wildlife-dependent Recreational Use – A use of a refuge involving hunting, fishing, wildlife 

observation and photography, or environmental education and interpretation. These are the six 

priority public uses of the Refuge System as established in the National Wildlife Refuge System 

Administration Act, as amended. Wildlife-dependent recreational uses, other than the six priority 

public uses, are those that depend on the presence of wildlife. The Service will also consider these 

other uses in the preparation of refuge CCPs; however, the six priority public uses always will take 

precedence (620 FW 1.6).

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-10 Appendix H. Glossary 

H.2 Acronyms 

Act National Wildlife Refuge System Improvement Act of 1997 

(also Improvement Act or NWRSIA) 

ADA Americans with Disabilities Act 

AM Adaptive Management 

ARPA Archaeological Resources Protection Act 

AUD Appropriate Use Determination 

BCR Bird Conservation Region 

BIDEH Biological Integrity, Diversity, and Environmental Health 

BLM Bureau of Land Management 

BMP Best Management Practice 

CCC Civilian Conservation Corps 

CCP Comprehensive Conservation Plan 

CEQ Council on Environmental Quality 

C.F.R. Code of Federal Regulations 

cfs Cubic Feet per Second 

CIG Climate Information Group at the University of Washington 

COA Conservation Opportunity Area 

CPR Center Patrol Road 

DDT Dichlorodiphenyltrichloroethane 

DPS Distinct Population Segment 

EE Environmental Education 

EIS Environmental Impact Statement 

EMS Environmental Management System 

ENSO El Niño/Southern Oscillation 

EOLC Eastern Oregon Livestock Company 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

HACCP Hazard Analysis and Critical Control Points Planning 

HCHS Harney County Historical Society Museum 

HCWC Harney County Watershed Council 

HUC Hydrologic Unit Code 

I&M Inventory and Monitoring 

IBA Important Bird Area 

Improvement Act National Wildlife Refuge System Improvement Act (P.L. 105-57) 

IPM Integrated Pest Management 

IPCC Intergovernmental Panel on Climate Change 

LCC Landscape Conservation Cooperative 

LEIS Legislative Environmental Impact Statement 

MBCC Migratory Bird Conservation Commission 

MPH Miles Per Hour 

msl Mean Sea Level 

NAGPRA Native American Graves Protection and Repatriation Act 

NAS National Academy of Sciences 

NEPA National Environmental Policy Act 

NHPA National Historic Preservation Act 

NOAA National Oceanic and Atmospheric Administration 

NRCS Natural Resources Conservation Service 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix H. Glossary H-11 

NRHP National Register of Historic Places 

NWR National Wildlife Refuge 

NWRS National Wildlife Refuge System or the Refuge System 

NWS National Weather Service 

OCS Oregon Conservation Strategy 

ODEQ Oregon Department of Environmental Quality 

ODFW Oregon Department of Fish and Wildlife 

ODOT Oregon Department of Transportation 

O-M pcp October-March Precipitation 

OPDR Oregon Parks and Recreation Department 

OWRD Oregon Water Resources Department 

PCB Polychlorinated Biphenyl 

PDO Pacific Decadal Oscillation 

PIF Partners in Flight 

P.L. Public Law 

PLO Public Land Order 

PPM Parts Per Million 

PRISM Parameter-elevation Regressions on Independent Slopes Model 

PRPA Paleontological Resources Preservation Act 

PUP Pesticide Use Proposal 

RAPP Refuge Annual Performance Plan 

Refuge Administration Act National Wildlife Refuge System Administration Act of 1966 as 

amended (16 U.S.C. 668dd-668ee) 

Refuge System National Wildlife Refuge System or NWRS 

RNA Research Natural Areas 

ROC Resource of Concern 

SCORP Oregon Statewide Comprehensive Outdoor Recreation Plan 

Service United States Fish and Wildlife Service or USFWS 

SLR Sea Level Rise 

SNOTEL Snowpack Telemetry (designed to collect snowpack and related 

climatic data in the Western United States and Alaska) 

STM State and Transition Model 

SWE Snow Water Equivalent 

TLDEIS Transmission Line Project Draft Environmental Impact Statement 

TMDL Total Maximum Daily Load 

U.S.C. United States Code 

USEPA U.S. Environmental Protection Agency 

USFS U.S. Forest Service 

USFWS United States Fish and Wildlife Service or the Service 

USGS United States Geological Survey 

USHCN United States Historical Climatology Network 

WSA Wilderness Study Areas 

YCC Youth Conservation Corp 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

H-12 Appendix H. Glossary 

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Ross’ geese landing

at Malhuer NWR

©Dan Dzurisin Appendix I

Contributors

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix J

Public Involvement

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Contributors I-1 

Appendix I. Contributors 

Table I-1. Core Planning Team 

Name Title Organization 

Linda Beck Fish Biologist, Malheur Refuge U.S. Fish and Wildlife Service 

(USFWS) 

Tim Bodeen Refuge Manager, Malheur Refuge USFWS 

Carla Burnside Archaeologist, Malheur Refuge USFWS 

Jamie Damon Facilitator Oregon Consensus 

Jim Dastyck Wildlife Biologist, Malheur Refuge USFWS 

Carey Goss Visitor Services Manager, Malheur 

Refuge 

USFWS 

Chad Karges Deputy Project Leader, Malheur Refuge USFWS 

John Megan Law Enforcement Officer, Malheur 

Refuge 

USFWS 

Sharon Selvaggio Planner, Division of Planning and 

Visitor Services, Region 1 

USFWS 

Jess Wenick Ecologist, Malheur Refuge USFWS 

Table I-2. Collaborative Participants and Reviewers 

Name Title Organization 

Chad Abel Fisheries Program Manager Burns Paiute Tribe 

Eric Anderson Instructional System Specialist USFWS 

Matthew Anderson Fish Biologist Oregon State University 

(OSU) 

Przemyslaw Bajer Postdoctoral Associate University of Minnesota 

Roger Baker Subject Matter Expert Malheur Wildlife Associates 

(MWA) 

Bradley Bales Migratory Bird Program Coordinator Oregon Department of Fish 

and Wildlife (ODFW) 

Jenny Barnett Zone I&M Biologist USFWS 

Christine Bates Burns District Office, Fish & Wildlife 

Biologist 

Bureau of Land Management 

(BLM) 

Jessica Boone Former Director Harney County Chamber of 

Commerce 

Brad Bortner Chief, Division of Migratory Birds and 

Habitat Programs, Region 1 

USFWS 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

I-2 Appendix I. Contributors 

Name Title Organization 

Chad Boyd Ecologist Eastern Oregon Agricultural 

Research Station (ARS) 

Dr. Kelly Cain Sustainable Practices Consultant St. Croix Institute for 

Sustainability Community 

Development, University of 

Wisconsin-River Falls 

John Christy Ecologist OSU 

Tami Coe Administrative Officer, Malheur Refuge USFWS 

Aaron Collins Visitor Services Manager USFWS 

Mike Colvin Doctoral Student Iowa Cooperative Fish and 

Wildlife Research Unit 

Mary Coolidge Assistant Conservation Director Audubon Society of Portland 

Dan Craver Geographic Information Specialist USFWS 

Jan Cupernall MWA Board Member MWA 

Denise Dachner Outdoor Recreation Planner USFWS 

Adam Daniel Common Carp Researcher University of Waikato, New 

Zealand 

Stacy Davies Roaring Springs Ranch Manager Roaring Springs Ranch 

David Dobkin Executive Director High Desert Ecological 

Research Institute 

Tom and Sally Downs Subject Matter Expert Retired USFWS 

Meg Duhr-Schultz Student Career Exploration Program 

(SCEP) 

USFWS 

Jason Dunham Supervisory Research Aquatic Ecologist U.S. Geological Survey 

(USGS) 

Alice Elshoff MWA Board Member MWA 

Joe Engler Regional Refuge Biologist USFWS 

Duncan Evered Director Malheur Field Station (MFS) 

Bridgette FlandersWanner Assistant Regional Refuge Biologist USFWS 

Michelle Franulovich Supervisory Natural Resource Specialist - 

Recreation 

BLM 

Nancy Gilbert Field Supervisor USFWS 

Michael Green Division of Migratory Birds & State 

Programs 

USFWS 

Mike Gregg Land Management Research and 

Demonstration (LMRD) Biologist 

USFWS 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Contributors I-3 

Name Title Organization 

Ben Harrison Deputy Regional Chief National Wildlife 

Refuge System, Pacific Region 

USFWS 

Jean Harrison Graphic Artist Private/Retired USFWS 

Ivan Hartert Student Career Exploration Program 

(SCEP) 

USFWS 

Terri Hellbusch Administrative Assistant, Malheur Refuge USFWS 

Keegan Heron Volunteer USFWS 

Orritt Hoffman P Ranch Substation Manager, Malheur 

Refuge 

USFWS 

Jen Hoke Director Harney County Chamber of 

Commerce 

Jeff Holm Refuge Program Specialist USFWS 

Charles Houghton Division Chief of Planning and Visitor 

Services, Region 1 

USFWS 

Matt Howe Visual Information Specialist USFWS 

Mark Howell NRCS Wildlife Biologist USGS 

Shannon Hurn District Fish Biologist ODFW 

Gary Ivey President MWA, Subject Matter Expert MWA 

Dick Jenkins Neighboring Land Owner Jenkins Ranch, Round Barn 

VC 

Dustin Johnson Extension, Harney County OSU 

Jay Kerby Southeast Oregon Project Manager The Nature Conservancy 

Kevin Kilbride Regional Refuge Biologist USFWS 

Rodney Klus District Wildlife Biologist ODFW 

Esther Lev Director Wetlands Conservancy 

Matt Little Conservation Director Oregon Natural Desert 

Association (ONDA) 

Sam Lohr Fish Biologist USFWS 

Don Lyons Postdoctoral Research Associate Oregon Cooperative Fish & 

Wildlife Research Unit 

Erica Maltz Fisheries Program Manager Burns Paiute Tribe 

Gary Marshall Private Land Manager Broken Circle Ranch 

Tara Martinak Public Affairs Specialist BLM 

Mike Marxen Branch Chief, Division of Planning and 

Visitor Services, Region 1 

USFWS 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

I-4 Appendix I. Contributors 

Name Title Organization 

Alan Mauer Fish & Wildlife Biologist USFWS 

Tim Mayer Water Resource Division, Region 1 USFWS 

Scott McCarthy Branch Chief of Refuge Planning, Region 

1 

USFWS 

Lila Messnick Director MFS 

Bill Modey Double-O Substation Manager, Malheur 

Refuge 

USFWS 

Karen Moon Director Harney County Watershed 

Council 

Danny Morris Maintenance Supervisor USFWS 

Maren Murphy Recreation Planning Assistant Americorps/USFWS 

Dan Nichols Private Land Owner Harney County Court 

Matt Obradovich Biologist BLM 

Julia Olsen Former Director Harney County Chamber of 

Commerce 

Dan Otley Private Land Owner Rancher 

Virginia Parks Regional Refuge Archaeologist USFWS 

Clay Pierce Assistant Unit Leader, Fisheries Iowa Cooperative Fish and 

Wildlife Research Unit 

Anan Raymond Regional Cultural Resources Manager USFWS 

Andy Renc Buena Vista Substation Manager, 

Malheur Refuge 

USFWS 

Robert Renchler Realty Specialist BLM 

William Renwick MWA Board Member High Desert 

Partnership/MWA 

Shannon Richardson Fish Biologist USFWS 

Steve Robertson Education Director Audubon Society of Portland 

Dan Roby Associate Professor Fisheries & Wildlife OSU 

Chris Rombough Herpetologist Private Contractor 

Pete Runnels County Commissioner Harney County 

Court/Business Owner 

Zola Ryan District Conservationist Natural Resources 

Conservation Service 

Bob Sallinger Conservation Director Audubon Society of Portland 

Rudy Schuster Branch Chief of Policy Analysis and 

Science Assistant 

USGS 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix I. Contributors I-5 

Name Title Organization 

Mike Shannon Regional Biologist Ducks Unlimited 

Steve Shunk Naturalist Paradise Birding 

Angela Sitz Ecological Services Office Assistant USFWS 

Peter Sorensen Professor University of Minnesota 

Al Smith Mussel Biologist Retired - ODFW 

Erin Stockenberg Geographic Information Specialist USFWS 

Martin St. Louis Summer Lake Wildlife Area Manager ODFW 

Marty Suter District Manager Harney County Soil and Water 

Conservation District 

Tony Svejcar Research Leader ARS 

Bruce Taylor Oregon Biodiversity Program Director, 

Executive Director 

Oregon Defenders of Wildlife, 

Oregon Habitat Joint Venture 

Rick Thein Subject Matter Expert Private Citizen 

Rick Vetter Fish Biologist US Forest Service 

Lacey Wall Planning Assistant USFWS 

Tim Walters Former District Fish Biologist ODFW 

Julie Weikel Board Member ONDA 

Robin West Refuge Supervisor USFWS 

   
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

I-6 Appendix I. Contributors 

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Northern pintail

©Barbara Wheeler

Appendix J

Public Involvement

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix K

Wet Meadow Treatment

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Involvement J-1 

Appendix J. Public Involvement 

Public involvement was sought throughout the development of the comprehensive conservation plan 

(CCP). A collaborative process was defined as a goal early in the planning process and was an 

integral aspect of the planning process. Public involvement strategies included face-to-face meetings 

with community organizations, local, State, and Federal agencies, elected officials (or their aides), 

tribal governments, and Refuge users. The planning team also held open houses, conducted listening 

posts, provided newsletters, and gave presentations to inform the public, invite discussion, and solicit 

feedback. The Refuge maintained a website where CCP information could be found and where the 

public could print out comment forms or submit emails during the scoping phase. Below is a brief 

summary of the events, meetings, and outreach tools that were used in our scoping public 

involvement efforts. 

Meetings with Congressional Representatives and/or their Aides 

 July 2009. Met with U.S. Representative Greg Walden’s aide Colby Marshall, Burns, OR 

 October 2010. Met with U.S. Representative Greg Walden’s aide Nick Strader, Bend, OR 

 October 2010. Met with U.S. Senator Ron Wyden’s aide Wayne Kennedy, Bend, OR 

 October 2010. Met with U.S. Senator Jeff Merkley’s aide, Bend, OR 

 February 2011. Met with U.S. Senator Jeff Merkley’s aide Elizabeth Scheeler, Pendleton, OR 

 September 2011. Met with U.S. Representative Greg Walden’s aide Nick Strader, Bend, OR 

Meetings with Tribes 

 April 2009. Met with Burns Paiute staff, Burns, OR 

 November 2009. Open house at Burns Paiute Tribe Gathering Center, Burns, OR 

 June 2010. Meet with Burns Paiute Tribe at council meeting, Burns, OR 

 April 2012. Met with Burns Paiute Tribe at council meeting, Burns, OR 

Meetings with Elected Officials 

 February 2009. Met with Dan Nichols, Harney County Court (County Commissioners), 

Burns, OR 

 April 2009. Met with Harney County Court (County Commissioners), Burns, OR 

 July 2009. Met with Steve Grasty, Harney County Court (County Commissioners), Burns, 

OR 

 January 2010. Met with Harney County Court (County Commissioners), Burns, OR 

 August 2010. Met with Dan Nichols, Harney County Court (County Commissioners), Burns, 

OR 

 September 2010. Met with Harney County Court (County Commissioners), Burns, OR 

 January 2011. Met with Dan Nichols, Harney County Court (County Commissioners), Burns, 

OR 

 February 2011. Met with Dan Nichols, Harney County Court (County Commissioners), 

Burns, OR 

 March 2011. Met with Dan Nichols, Harney County Court (County Commissioners), Burns, 

OR 

 May 2011. Met with Steve Grasty, Harney County Court (County Commissioners), Burns, 

OR 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

J-2 Appendix J. Public Involvement 

 May 2011. Met with Dan Nichols, Harney County Court (County Commissioners), Burns, 

OR 

Meetings with Community/Business Organizations 

 April 2009. Met with the board of the High Desert Partnership, Burns, OR 

 August 2009. Met with Lions Club, Burns OR 

 October 2009. Met with Burns/Hines Kiwanis Club, Burns, OR 

 October 2009. Met with various merchants, Burns, OR 

 October 2009. Met with the board of Portland Audubon Society, Portland, OR 

 October 2009. Met with Harney County Chamber of Commerce. 

 October 2009. Met with Harney County Historical Society, Burns OR 

 November 2009. Met with Harney County Stockgrowers, Burns, OR 

 December 2009. Met with Harney County Farm Bureau, Burns, OR 

 January 2010. Met with Lions Club, Burns, OR 

 January 2010. Met with Ducks Unlimited, Burns, OR 

 April 2010. Met with the Oregon Natural Desert Association, Burns, OR 

 May 2010. Met with Malheur Wildlife Associates, Frenchglen, OR 

 June 2010. Met with Central Oregon Flyfishers, Princeton, OR 

 June 2010. Met with Oregon Natural Desert Association, Bend, OR 

 August 2010. Met with Oregon Natural Desert Association, Bend, OR 

 August 2010. Met with Bureau of Land Management (BLM) Steens Mountain Advisory 

Council, Burns, OR 

 September 2010. Met with East Cascades Audubon Chapter, Bend, OR 

 September 2010. Met with Ducks Unlimited and Defenders of Wildlife, Burns, OR 

 September 2010. Met with Oregon Natural Desert Association, Burns, OR 

 October 2010. Met with Oregon Natural Desert Association, Burns, OR 

 October 2010. Met with Portland Audubon Society, Burns, OR 

 January 2011. Met with Ducks Unlimited, Burns, OR 

 January 2011. Met with Oregon Natural Desert Association, Burns, OR 

 January 2011. Met with Defenders of Wildlife, Burns, OR 

 February 2011. Met with Lions Club, Ontario, OR 

 February 2011. Met with High Desert Partnership, Burns, OR 

 March 2011. Met with Harney County Soil and Water Conservation District (HCSWCD), 

Burns Oregon 

 May 2011. Met with Ducks Unlimited, Vancouver, WA 

 May 2011. Met with Ducks Unlimited, Princeton, OR 

 May 2011. Met with Oregon Natural Desert Association, Burns, OR 

 June 2011. Met with Ducks Unlimited, Burns, OR 

Meetings with Collaborators 

 May 2009. Met with collaborators, Prineville, OR 

 October 2009. Met with collaborators, Prineville, OR 

 May 2010. Met with collaborators, Harney County Chamber of Commerce, Burns, OR 

 June 2010. Met with collaborators, Harney County Chamber of Commerce, Burns, OR 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Involvement J-3 

 September 2010. Met with collaborators, Harney County Chamber of Commerce, Burns, OR 

 January 2011. Met with collaborators, Agriculture Research Station, Burns, OR 

 March 2011. Met with collaborators, Senior Citizen Center, Burns, OR 

 April 2011. Met with collaborators, High Desert Partnership, Burns, OR 

 May 2011. Met with collaborators, U.S. Forest Service (USFS) Office, Prineville, OR 

 September 2011. Met with collaborators and High Desert Partnership about Harney Basin 

Wetlands Initiative, Harney County Chamber of Commerce, Burns, OR 

 October 2011. Met with collaborators, Harney County Chamber of Commerce, Burns, OR 

Meetings with Agencies and Academia 

 January 2009. Met with Oregon Department of Fish and Wildlife (ODFW) staff, Burns, OR 

 February 2009. Met with Harney County Soil and Water Conservation District, Burns, OR 

 March 2009. Met with Oregon Natural Desert Association, Bend, OR 

 April 2009. Met with Agricultural Research Service staff, Burns OR. 

 October 2009. Met with various Oregon State University (OSU) professors and students from 

wildlife department (34), Corvallis, OR 

 October 2009. Met with Harney County school educators in Burns and Crane OR 

 October 2009. Met with U.S. Geological Survey (USGS) staff, Forest and Range Resources 

Center, Corvallis, OR 

 January 2010. Met with University of Minnesota Staff, St. Paul, MN 

 January 2010. Met with Iowa State University Staff, Ames, IA 

 February 2010. Conference call with USGS staff, Forest and Range Resources Center, and 

OSU Co-Op, Corvallis, OR 

 March 2010. Met with USFS Staff, Burns, OR 

 March 2010. Met with Harney County Soil and Water Conservation District, Burns, OR 

 April 2010. Conference call with USGS staff and Forest and Range Resources Center, 

Corvallis, OR 

 April 2010. Conference call with Aquatic Health Funding and Partnership Work Group 

 April 2010. Conference call with Aquatic Health Carp Control Work Group 

 April 2010. Presented at NWR-CRFPO 2010 Workshop, Vancouver, WA 

 April 2010. Met with Harney County Soil and Water Conservation District, Burns, OR 

 May 2010. Conference call with Fish Carcass Users Group 

 May 2010. Met with U.S. Army Corp of Engineers, Princeton, OR 

 June 2010. Conference call with Aquatic Health Assessment Work Group 

 June 2010. Met with Genie Monteblanc, Science Delivery Project Coordinator, Princeton, 

OR 

 July 2010. Met with David Dobkin and Lewis & Clark College students, Princeton, OR 

 September 2010. Met with ODFW, BLM, and Aquatic Health Group Chair, Burns, OR 

 September 2010. Conference call with Aquatic Health Funding and Partnership Work Group 

 October 2010. Met with University of Minnesota staff, Princeton, OR 

 October 2010. Met with Central Utah Water Conservancy District, Orem, UT 

 October 2010. Met with ODFW, Burns, OR 

 November 2010. Met with ODFW, Burns, OR 

 December 2010. Met with ODFW, Burns, OR 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

J-4 Appendix J. Public Involvement 

 January 2011. Met with ODFW Directorate, Tualatin National Wildlife Refuge (NWR), 

Tualatin, OR 

 January 2011. Met with DU, Burns, OR 

 January 2011. Met with ODFW, BLM, HCSWCD, HCWSC, FS, Oregon Natural Desert 

Association, DU, The Nature Conservancy, BPT, USGS, OSU, HDP, Defenders of Wildlife 

for NAWCA Funding, BLM District Office, Burns, OR 

 February 2011. Met with OSU and USGS scientists, Corvallis, OR 

 February 2011. Met with American Fisheries Society, Bend, OR 

 March 2011. Met with ODFW, BLM, HCSWCD, HCWSC, FS, Oregon Natural Desert 

Association, DU, The Nature Conservancy, BPT, USGS, HDP, Defenders of Wildlife for 

NAWCA Funding, BLM District Office, Burns, OR 

 April 2011. Met with ODFW, Burns Office. 

 May 2011. Met U.S. Fish and Wildlife Service Regional Office for Brown Bag carp 

presentation, Portland, OR 

 May 2011. Met with fisheries professionals, Vancouver, WA 

 June 2011. Met with HCSWD, Natural Resource Conservation Society (NRCS), and ODFW, 

Burns, OR 

 June 2011. Met with Bill Renwick, Burns, OR 

Ecology Work Group 

 January 2010. Teleconference with Tony Svejcar (Agricultural Research Service), Esther Lev 

(Wetlands Conservancy), John Christy (Oregon Natural Heritage Program), and Mike 

Shannon (Ducks Unlimited), Burns, OR 

 July 2010. Teleconference with Tony Svejcar, Esther Lev, John Christy, and Gary Ivey 

(independent wildlife biologist), Burns, OR 

 May 2011. Telephone discussions with core group (see January 2010 attendees) regarding 

May 2011 update 

 September 2011. Telephone discussions with core group (see January 2010 attendees) 

regarding September 2011 update 

 October 2011. Refuge field trip and inventory and monitoring planning by core group. 

Princeton, OR 

Public Open Houses/Scoping Sessions 

 February 2008. Presentation and public open houses for CCP scoping afternoon and evening 

sessions. Salem, OR 

 February 2008. Presentation and public open houses for CCP scoping afternoon and evening 

sessions. Corvallis, OR 

 September 2009. Presentation and public open house, Harney County Chamber of 

Commerce, Burns, OR 

 October 2009. Presentation and public open house, Central Oregon Environmental Center, 

Bend, OR 

 October 2009. Presentation and public open house, Doubletree Hotel-Lloyd Center, Portland, 

OR 

 October 2009. Presentation and public open house, Golden Eagle Audubon Society, Boise, 

ID 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Involvement J-5 

Listening Posts/Displays 

 September 2009. Held at Harney County Fair, Burns, OR 

 September 2009. Held at Harney County Library, Burns, OR 

 September 2009. Held at Harney County Senior Citizens Center, Burns, OR 

 September 2009. Held at Harney County Chapter of the Oregon Hunters Association, Burns, 

OR 

 September 2009. Held at The Narrows Restaurant, Princeton, OR 

 September 2009. Held at Round Barn Visitor Center, Diamond, OR 

 September 2009. Held at Lane County Audubon Society, Eugene, OR 

 September 2009. Held at Harney County Chamber of Commerce, Burns, OR 

 September 2009. Held at Frenchglen Hotel, Frenchglen, OR 

 September 2009. Held at Harney County Courthouse, Burns, OR 

 October 2009. Held at Thriftway Grocery Store, Hines, OR 

 October 2009. Held at Central Oregon Environmental Center, Bend, OR 

 October 2009. Held at Crane High School, Crane, OR 

 October 2009. Held at Portland Audubon Society, Portland, OR 

 October 2009. Held at Corvallis Audubon Society, Corvallis, OR 

 March 2010. Redmond Sports Show, Redmond, OR 

 August 2010. Harney County Library Foundation, Burns, OR 

 August 2010. Invasive Carp Awareness Day, Princeton, OR 

Meetings with Individuals 

 February 2009. Met with Gary Marshall, Refuge permit holder, Princeton, OR 

 March 2009. Met with Dick Jenkins, local rancher, Diamond, OR 

 July 2009. Met with John and Laurie O’Connor, former Refuge employees, Burns, OR 

 July 2009. Met with Dick Jenkins, owner of Round Barn Interpretive Center, longtime 

resident, current Refuge haying/grazing permit holder, Diamond, OR 

 July 2009. Met with John and Cindy Witzel, lifelong residents of Frenchglen, descendents of 

former Refuge haying/grazing permit holder, Frenchglen, OR 

 July 2009. Met with Malena Koenik, Frenchglen General Store owner, Frenchglen, OR 

 July 2009. Met with Steve, Dwight, and Susie Hammond, neighboring landowners and 

former permit holders, Frenchglen, OR 

 July 2009. Met with Guy Sheeter, retired school teacher and hunter, Burns, OR 

 July 2009. Met with Joe Hendry, retired BLM biologist, Burns, OR 

 September 2009. Met with Stacy Davies, local rancher, Catlow Valley, OR 

 September 2009. Met with Tom Downs, former Refuge employee, Fields, OR 

 October-November 2009. Met with several Refuge permit holders (G. Marshall, G. Miller, 

Tyler family, R. Dunbar, Buck Taylor, and Don Opie), rural Harney County, OR 

 November 2009. Met with Mark and Susan Doverspike, ranchers, rural Harney County, OR 

 March 2010. Met with Bill Renwick, community activist, Burns, OR 

 March 2010. Met with Gary Marshall, Refuge permit holder, Princeton, OR 

 August 2010. Met with Gary Marshall, Refuge permit holder, Princeton, OR 

 October 2010. Met with past Refuge managers, Princeton, OR 

 January 2011. Met with Tom Downs, former Refuge employee, Fields, OR 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

J-6 Appendix J. Public Involvement 

 February 2011. Met with past Refuge biologists, Princeton, OR 

 March 2011. Met with Bill Renwick, Burns, OR 

 March 2011. Met with Dan Otley, Diamond, OR 

 March 2011. Met with Dick Jenkins, Diamond, OR 

 May 2011. Met with Nancy Fine, Ruralite writer, Burns, OR 

 May 2011. Met with Gary Marshall, Refuge permit holder, Burns, OR 

 June 2011. Met with Wayne Baron, entrepreneur, Burns, OR 

Workshops/Field Reviews 

 June 2009. Conducted a Wildlife and Habitat Program Review with approximately 40 

participants, Princeton, OR 

 July 2009. Conducted a Visitor Services Program Review with approximately 40 participants, 

Princeton, OR 

 October 20, 2009. Conducted a Priority Resources of Concern workshop with approximately 

40 participants, Prineville, OR 

 March 2010. Conducted an Invasive Carp workshop with 64 participants, Burns, OR 

 January 2011. Presented Aquatic Health and Habitat CCP goals, objectives, and progress 

made to Science in the Service meeting, Stevenson, WA 

Press Coverage 

 Fall 2009. Various notices of CCP open houses and listening posts printed in the local BurnsTimes Herald, The Oregonian, and online (Oregon Birders’ online network, National Rifle 

Association online notice, online notice of CCP public open house in Salem’s Statesman 

Journal). 

 March 2012. Press releases printed in the Burns-Times Herald and the Bend Bulletin about 

the availability of the draft CCP for review and comments. 

Planning Updates 

 September 2009. Planning Update 1 mailed to approximately 400 persons, organizations, and 

officials. Copies of the planning update were also placed at key Refuge points, including the 

Visitor Center and brochure boxes, and copies were made available to people at listening 

posts and public meetings. Copies of the planning update were also placed at various 

locations in Burns, Oregon, and surrounding locations, including: Chamber of Commerce, 

BLM office, ODFW office, USFS office, HCSWCD office, NRCS office, Big R store, Rite 

Aid store, King’s store, B&B Sporting Goods store, District Hospital, High Desert Medical 

Center, Library, Burns Post Office, Hines Post Office, Narrows Restaurant, Round Barn 

Visitor Center, Malheur Field Station, Diamond Hotel, Steens Mountain Resort, Fields store, 

Frenchglen Hotel, and Crane store. 

 November 2009. Creation of Carp Coalition Listserve. Updates sent at least monthly to 

approximately 150 members from creation to present. 

 May 2010. Planning Update 2 mailed to approximately 400 persons, organizations, and 

officials. Copies of the planning update were also placed at key Refuge points, including the 

Visitor Center and brochure boxes, and copies were made available to people at listening 

posts and public meetings. Copies of the planning update were also placed at various 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix J. Public Involvement J-7 

locations in Burns, Oregon, and surrounding locations, including: Chamber of Commerce, 

BLM office, ODFW office, USFS office, HCSWCD office, NRCS office, Big R store, Rite 

Aid store, King’s store, B&B Sporting Goods store, District Hospital, High Desert Medical 

Center, Library, Burns Post Office, Hines Post Office, Narrows Restaurant, Round Barn 

Visitor Center, Malheur Field Station, Diamond Hotel, Steens Mountain Resort, Fields store, 

Frenchglen Hotel, and Crane store. 

 February 2012. Planning Update 3 mailed to approximately 400 persons, organizations, and 

officials. Copies of the planning update were also placed at key Refuge points, including the 

Visitor Center and brochure boxes, and copies were made available to people at listening 

posts and public meetings. Copies of the planning update were also placed at various 

locations in Burns, Oregon, and surrounding locations, including: Chamber of Commerce, 

BLM office, ODFW office, USFS office, HCSWCD office, NRCS office, Big R store, Rite 

Aid store, King’s store, B&B Sporting Goods store, District Hospital, High Desert Medical 

Center, Library, Burns Post Office, Hines Post Office, Narrows Restaurant, Round Barn 

Visitor Center, Malheur Field Station, Diamond Hotel, Steens Mountain Resort, Fields store, 

Frenchglen Hotel, and Crane store. 

 December 2012. Planning Update 4 mailed to approximately 400 persons, organizations, and 

officials. Copies of the planning update were also placed at key Refuge points, including the 

Visitor Center and brochure boxes, and copies were made available to people at listening 

posts and public meetings. Copies of the planning update were also placed at various 

locations in Burns, Oregon, and surrounding locations, including: Chamber of Commerce, 

BLM office, ODFW office, USFS office, HCSWCD office, NRCS office, Big R store, Rite 

Aid store, King’s store, B&B Sporting Goods store, District Hospital, High Desert Medical 

Center, Library, Burns Post Office, Hines Post Office, Narrows Restaurant, Round Barn 

Visitor Center, Malheur Field Station, Diamond Hotel, Steens Mountain Resort, Fields store, 

Frenchglen Hotel, and Crane store. 

Other Tools 

 June 2009. Updated Refuge website to include CCP information. 

 March 2011. Central Oregon Sportsman Show, Redmond, OR 

Federal Register Notices 

 June, 2009. Federal Register published Notice of Intent to prepare a CCP and environmental 

impact statement (EIS); request for comments. 

 March, 2012. Federal Register published Notice of Release of draft CCP and EIS; request for 

comments. 

 December, 2012. Federal Register published Notice of Availably of the final CCP and EIS. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

J-8 Appendix J. Public Involvement 

This page left blank intentionally. 
Hay at P Ranch

©Barbara Wheeler

Appendix K

Wet Meadow Treatment Ratios

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix L

Ecology Work Group

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Wet Meadow Treatment Ratios K-1 

Appendix K. Wet Meadow Treatment Ratios

K.1 Refuge Management Treatments 

K.1.1 Management Treatment Acres 

The following table (Table K-1) will be used to track acres treated by various management strategies 

throughout the life of the CCP. It will enable Refuge staff, collaborators, and interested public to 

understand if and how management may change over time in striving toward or maintaining met 

objectives in various habitat types. 

Table K-1. Management Treatment Acres per Treatment Year 

Treatment Acres per Treatment Year 

2013-2014 2014-2015 2015-2016 2016-2017 2018-2019 2019-2020 

Rakebunch (DS) 

True Graze (DS) 

True Graze (WS) 

Haying (DS) 

Seeding 

Grain Farming 

Shrub Planting 

Disking 

Chemical-Habitat 

Chemical-Fisheries 

Rx Fire 

Commercial Fishing 

Juniper Control 

Carp Objectives Met 

DS: Dormant Season; WS: Warm Season as described in Appendix B Haying and Grazing CD 

K.2 Dormant Season Haying and Grazing in Wet Meadows 

The initial ratio of wet meadows receiving haying and rake-bunch grazing treatments on an annual 

basis to those left idle will be 60:40 (±10 percent). This translates to 12,000 to 15,000 of 20,000 to 

25,000 acres being treated in a given year1

. This figure is based on the sound professional judgment 

of seven past and present Refuge wildlife biologists with 50 collective years of experience managing 

 

1

 Acreage ranges exist to provide needed flexibility to account for (1) acreage refinement as the Refuge’s GIS layers 

become more precise, (2) the possible need of reclassifying some acreages as inventory and monitoring data 

continues to be collected (e.g., existing emergent marsh that has resulted from cattail encroachment into wet 

meadow), and (3) climatic conditions or other unforeseen restraints that may hinder the Refuge’s ability to treat all 

targeted acres. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

K-2 Appendix K. Wet Meadow Treatment Ratios 

Refuge meadows. This ratio is relevant only when considering all wet meadows within the Refuge 

and differs across fields and area-specific management units. The needs of focal species, the suite of 

wildlife they represent, and the nature of habitats they depend on determines the use and extent of 

these tools in realizing or maintaining attributes identified under Objective 4a. The ratio itself is not 

prescriptive. It serves as an indicator of treatment changes over time. 

The purpose of this appendix is to provide an overarching rationale behind the initial 60:40 ratio by 

highlighting four major areas (southern, central, and northern Blitzen Valley and Double-O Unit) and 

identifying associated needs for treated and/or untreated acres for wet meadow focal species (i.e., 

bobolink, greater sandhill crane, and cinnamon teal). It is not intended to replace established Refuge 

management units, but is designed specifically to facilitate greater understanding of how 

management needs change as one moves across the Refuge landscape. 

K.2.1 South Blitzen Valley 

Total wet meadow area: Out of 20,300 total acres in this 

management area, 8,000 will be occupied by wet meadow habitat. 

Focal species as identified in the CCP for wet meadow 

habitats2

: 

 Bobolink: Concentrated populations are found in mesic 

wet meadows, totaling approximately 3,500 acres. 

Nesting/feeding habitat is dependent on short vegetation 

heights achieved via treatments (populations decrease 

substantially under non-treated status). The Blitzen Valley 

hosts the largest bobolink population west of the Great 

Plains and has over 90 percent of the bobolinks that breed 

in Oregon. They only occur at approximately six other 

sites supporting numbers of less than 20 individuals 

(Marshall et al. 2006). Approximately 85 percent of the 

Refuge bobolinks are found in this area (2,471 out of 

2,902, Refuge unpublished data). 

 Greater sandhill crane: A 1999 Refuge summary report found 99 out of 235 pairs (42 

percent) using this area. Nesting occurs in adjacent emergent marsh vegetation. Crane pairing 

and young-rearing takes place on approximately 6,000 acres of meadows with an overall 

treated vegetation height of <6 inches. Acreage overlaps bobolink use areas. 

 Cinnamon teal: Primarily dry meadow habitats and secondarily, upland habitats provide a 

majority of this species’ nesting habitat in this area. Mallards, which are represented by this 

focal species, do commonly nest in emergent marsh habitat. Mesic wet meadows less prone 

to flooding provide suitable nesting habitat (approximately 800 acres) for some waterfowl 

species. Areas susceptible to nest loss via water management are treated to provide waterfowl 

pairing/pre-nesting habitat (overlap above treated acreages). 

Treated:Untreated ratio for this area: 90:10 for wet meadow, 35:65 for total area 

 

2

 Basic habitat principles discussed in regard to the southern Blitzen Valley generally apply to all units. 

Wet meadow

Emergent marsh

Dry meadow

Other habitat types
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix K. Wet Meadow Treatment Ratios K-3 

K.2.2 Mid-Blitzen Valley 

Total wet meadow area: Out of 19,600 total acres, 6,400 will be 

occupied by wet meadow habitat. 

Focal species as identified in the CCP for wet meadow habitats: 

 Bobolink: Approximately 50 to 100 acres of suitable, 

used mesic wet meadow habitat are known to exist in this 

area. Less than 1 percent of Refuge bobolinks are found 

in this area (14 out of 2,902, Refuge unpublished data). 

 Greater sandhill crane: Concentrations of greater 

sandhill crane territories remain high, but are a little lower 

in this area compared to the south Blitzen Valley (62 out 

of 235 pairs, or 26 percent). Approximately 4,000 acres of 

wet meadow are treated to provide crane pairing/prenesting habitat. 

 Cinnamon teal: Approximately 2,300 acres of mesic wet 

meadow is left untreated to provide nesting habitat. 

An increase in reed canarygrass dominance in many meadows greatly minimizes their value in regard 

to waterfowl nesting habitat and overall wildlife use if left untreated. Currently approximately 4,000 

acres (out of approximately 6,000 total acres) of reed canarygrass is located in this area. 

Treated:Untreated ratio for this area: 64:36 for wet meadow, 21:79 for total area. 

K.2.3 North Blitzen Valley 

Total wet meadow area: Out of 24,000 total acres, 4,600 will be 

occupied by wet meadow habitat. 

Focal species as identified in the CCP for wet meadow habitats: 

 Bobolink: The use of this species is focused on expansive wet 

meadows on the north end of this area (approximately 600 

acres). Approximately 14 percent of the Refuge bobolinks are 

found in this area (417 out of 2,902, Refuge unpublished data). 

 Greater sandhill crane: Crane territories are less concentrated 

in this area (28 out of 235 pairs, or 12 percent) so approximately 

1,200 acres of treatment are targeted for pairing/pre-nesting 

habitat. 

 Cinnamon teal: Many wet meadow communities in this area 

are very small and less prone to extensive nest flooding because 

of the prevailing dichotomy of elevations found throughout its 

fields and the greater edge of surrounding dry meadow nesting 

habitats. Approximately 3,200 acres of the area’s wet meadows are 

left untreated to provide nesting habitat.

Treated:Untreated ratio for this area: 30:70 for wet meadow, 6:94 for total area. 

Wet meadow

Emergent marsh

Dry meadow

Other habitat types

Wet meadow

Emergent marsh

Dry meadow

Other habitat types
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

K-4 Appendix K. Wet Meadow Treatment Ratios 

K.2.4 Double-O 

Total wet meadow area: Out of 20,000 total acres, 4,600 will be 

occupied by wet meadow habitat. 

Focal species as identified in the CCP for wet meadow 

habitats: 

 Bobolink: 0 acres. 

 Greater sandhill crane: Crane territories concentrate in 

the southern fields where water is provided by DoubleO Spring as well as the northwestern meadows 

maintained by Silver Creek. Approximately 2,000 acres are treated for pairing and youngrearing. Twenty percent, or 46 out of 235 crane pairs use this area 

 Cinnamon teal: 300 acres of wet meadow areas north and east of the central ponded area 

(Martha, Warbler, and Derrick ponds) are managed primarily for waterfowl nesting.

Treated:Untreated ratio for this area: 40:60 for wet meadow, 10:90 for total area. 

Total Treated:Untreated ratio across all habitat types within the Refuge: 8:92 

K.3 References 

Marshall, D.B., M.G. Hunter, and A. Contreras. 2006. Birds of Oregon: a general reference. 

Corvallis, O: Oregon State University Press 752 pp. 

Wet meadow

Emergent marsh

Dry meadow

Other habitat types
Northern shoveler

©Britta Heise

Appendix L

The Ecology Work Group and

the State and Transition Model

Appendix L

Ecology Work Group

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix M

Climate Change

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix L. The Ecology Work Group and the State and Transition Model L-1 

Appendix L. The Ecology Work Group and the State and Transition Model 

L.1 Adaptive Management and the State and Transition Model 

Habitat management within the Malheur Refuge comprehensive conservation plan (CCP) will rest on 

an inductive ecological framework that uses a broad spectrum of relevant research from similar 

systems. This will enable the Refuge to form premises that assist in developing reasonable 

management strategies to meet various identified habitat objectives. The foundation from which 

habitat management approaches will arise within this CCP is “adaptive management.” 

The U.S. Department of the Interior recognizes that this concept “is much more than simply tracking 

and changing management direction,” and that it “focuses on learning and adapting, through 

partnerships of managers, scientists, and other stakeholders who learn together how to create and 

maintain sustainable resource systems” (Williams et al. 2007). 

The Malheur State and Transition Model (STM) will play a vital role in achieving this. The STM is a 

framework that is being developed by the Service with the assistance of ecologists from various State 

and Federal agencies and non-government organizations. As illustrated conceptually in Figure L-1, 

STM will: 

(1) describe various habitat types and associated plant communities; 

(2) discuss the conditions that likely cause transitions1

 to other plant assemblages; 

(3) identify existing information gaps in the scientific knowledge base that need to be 

addressed in further understanding the functionality of these habitat types and possible 

strategies for obtaining this critical information; 

(4) develop management strategies by combining individual tools/treatments to meet the 

objectives specified in this plan; 

(5) analyze the success of initiated management strategies; and 

(6) modify management over time to meet CCP objectives. 

The benefits of the STM concept for Malheur Refuge expand beyond greater ecological 

understanding of Refuge habitat. It also provides transparency, heightened and continued interaction 

with partnering agencies/organizations (i.e., Oregon State University, U.S. Department of 

Agriculture’s Agricultural Research Service, Oregon Heritage Program, Ducks Unlimited, Wetlands 

Conservancy, etc.), and accountability for continued monitoring of management actions. The STM is 

a living model that is continually transformed as new information is gleaned over time, and because 

of this, it introduces an amplified dependence on actualized adaptive management. It also provides us 

with a framework for organizing our results and reporting them to the interested public. 

L.2 The Ecology Work Group 

As mentioned above, the STM is developed by ecologists and fish/wildlife biologists from the 

Service and partnering entities. It is a product of the Service, created in cooperation with the Ecology 

Work Group, which was created during the development of the 2012 Malheur CCP. This group is 

designed to assist Refuge staff in carrying out adaptive management by providing experience, vital 

 

1

 These transitions are called thresholds when severe climatic or management stresses cause the composition of 

species within a particular assemblage to change radically, and they are often difficult to reverse without a lot of 

external input (labor and funding). 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

L-2 Appendix L. The Ecology Work Group and the State and Transition Model 

connections to best available science, and increased opportunities for acquiring the resources needed 

in pursuing dynamic management of Refuge habitats. The Ecology Group will meet prior to each 

field season to discuss data gathered in previous seasons and assess the effectiveness of current 

strategies. It will assist the Service in determining if objectives are being met or, in instances where 

long-term tenacity is required, if existing management is moving target habitats toward desired 

conditions over time. The Ecology Group will also analyze data and discuss management successes 

and challenges at the conclusion of each field season and consider if alterations to the STM need to 

be made as more information becomes available. 

Figure L-1. A conceptual diagram of the State and Transition Model as an adaptive 

management tool. 

L.3 References 

Williams B.K., R.C. Szaro, and C.D. Shapiro. 2007. Adaptive management: the U.S. Department of 

Interior technical guide. Adaptive Management Working Group, U.S. Department of the 

Interior. Washington D.C. 

Ecology Working Group

Identify Research/

Management Needs

USFWS

Develop

Site-Specific

Management

Strategies

Monitor Treatments and

Evaluate Effectiveness

Adjust Model

To Capture

New Insights
Western frittilary

©Roger Baker

Appendix M

Climate Change

Appendix M

Climate Change

Appendix L

Ecology Work Group

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix N

Common & Scientific Names

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-1 

Appendix M. Climate Change 

M.1 Introduction 

As required by DOI Secretarial Order 3226, issued in 2001, the Service requires consideration and 

analysis of climate change in long-range planning. 

M.1.1 Global Greenhouse Gases 

The greenhouse effect is a natural phenomenon that assists in regulating and warming the 

temperature of our planet. Just as a glass ceiling traps heat inside a greenhouse, certain gases in the 

atmosphere, called greenhouse gases (GHGs), absorb heat from sunlight, trapping heat in the 

atmosphere and warming the planet. The primary GHGs occurring in the atmosphere include carbon 

dioxide (CO2), water vapor, methane, and nitrous oxide. CO2 is produced in the largest quantities, 

accounting for more than half of the current impact on the Earth’s climate. 

A growing body of scientific evidence from basic theory, climate model simulations, and 

observations has emerged to support the idea that humans are changing the Earth’s climate (U.S. 

Global Change Research Program [USGCRP] 2009; Intergovernmental Panel on Climate Change 

[IPCC] 2007; National Academy of Sciences [NAS] 2008). The concentrations of heat-trapping 

GHGs have increased significantly over the last several hundred years due to human activities such 

as deforestation and the burning of fossil fuels (Figure M-1). 

Although climate alterations are well documented in the Earth’s history, even in relatively recent 

geologic time (e.g., the Ice Age of 10,000 years ago), the current warming trend differs from earlier 

shifts in two ways. First, this recent change in climate appears to be driven primarily by human 

activity, particularly the burning of fossil fuels, which results in a higher concentration of 

atmospheric GHGs). Second, atmospheric CO2 and other GHGs, levels of which are strongly 

correlated with the Earth’s temperature, are now higher than at any time in at least the last 420,000 

years (Figure M-2) (USGCRP 2009). 

Source: IPCC 2007. 

Figure M-1. Concentrations of important heat-trapping greenhouse gases over the last 2,000 

years. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-2 Appendix M. Climate Change 

Prior to the start of the Industrial Revolution in 1750, the amount of CO2 in the atmosphere was about 

280 parts per million (ppm). Current levels are about 390 ppm and are increasing at a rate of about 2 

ppm/year. Data from ice cores, which record prehistoric atmospheric conditions, show that for the 

last 800,000 years, CO2 concentrations have ranged from 180 ppm during cold, glacial periods to 300 

ppm during warm, interglacial periods. The current concentrations of CO2 and other GHGs, as well 

as the rapid rate of increase in recent decades, are unprecedented in the prehistoric record. 

M.1.2 Temperature and Precipitation 

There is a direct correlation between GHG concentrations and the temperature of the Earth’s surface. 

Global surface temperatures have increased about 1.3°F since the late nineteenth century (USGCRP 

2009), and the rate of temperature increase has risen in more recent years (Figure M-2). The IPCC, a 

large group of scientists in a panel created by the United Nations to evaluate the risk of climate 

change caused by human activities, reported in 2007 that “warming of the climate system is 

unequivocal, as is now evident from observations of increases in global average air and ocean 

temperatures, widespread melting of snow and ice and rising global average sea level.” (IPCC 2007). 

Source: USGCRP 2009. 

Figure M-2. Global average temperature 

and CO2 concentrations from 1880 to 2008. 

In the northern hemisphere, recent decades 

appear to be the warmest since about A.D. 

1000, and the warming since the late 

nineteenth century is unprecedented over the 

last 1,000 years. Globally, 2010 and 2005 tie 

as the warmest years in the instrumental 

record (1880 to the present), while 2009 was 

only a fraction of a degree cooler, matching 

1998, 2002, 2003, 2006, and 2007 for the 

second-warmest year on record, according to 

independent analyses by the National Oceanic 

and Atmospheric Administration (NOAA) and 

National Aeronautics and Space 

Administration (NASA) (Table M-1). The 

new 2010 record is particularly noteworthy 

because it occurred in the presence of a La 

Niña and a period of low solar activity, two 

factors that have a cooling influence on the 

planet. However, in general, decadal trends 

are far more important than any particular 

year’s ranking. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-3 

Table M-1. Top 10 Warmest Years in the Instrumental Record from 1880 to 2010a

Global Top 10 

Warmest Years (Jan-Dec) Anomaly (°C) Anomaly (°F) 

2010 0.62 1.12 

2005 0.62 1.12 

1998 0.60 1.08 

2003 0.58 1.04 

2002 0.58 1.04 

2009 0.56 1.01 

2006 0.56 1.01 

2007 0.55 0.99 

2004 0.54 0.97 

2001 0.52 0.94 

Source: National Climatic Data Center 2010. a

 The instrumental record refers to the period with recorded temperatures. 

Trends in precipitation are more difficult to detect than changes in temperature because precipitation 

is generally more variable. Over the last century, there have been increases in annual precipitation in 

the higher latitudes of both hemispheres and decreases in the tropical regions of Africa and southern 

Asia (USGCRP 2009). Most of the increases have occurred in the first half of the twentieth century, 

and it is not clear if this trend is due to increasing GHG concentrations. 

Just as important as precipitation totals are changes in the intensity, frequency, and type of 

precipitation. Warmer climates, owing to increased water vapor, lead to more intense precipitation 

events, including more snowstorms and possibly more flooding, even with no change in total 

precipitation (Figure M-3). On the other hand, more droughts and heat waves can be expected as 

hotter, longer-lasting high-pressure systems dry out the land. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-4 Appendix M. Climate Change 

Source: EPA 2010. 

Figure M-3. Percent of land area in the lower 48 states that has experienced greater than 

normal precipitation for the period 1910 to 2008. 

M.1.3 Emissions Scenarios 

When climate modelers project future climate, they make assumptions about future GHG emissions. 

These assumptions are called emission scenarios. A common set of emissions scenarios was 

developed in 2000 by the IPCC. Three scenarios from this set are frequently used by the modeling 

community: the A2 (high emissions scenario), A1B (medium emissions scenario), and B1 (low 

emissions scenario). Because of a lag between GHG emissions and climate response, the assumptions 

about future emissions will not influence the next 30 years or so. GHG concentrations and climate in 

the short term will be determined by emissions that have already occurred. Longer-term climate 

projections are more uncertain and vary because of uncertainty in future GHG emissions (and 

therefore future concentrations of GHGs). This is why, typically, there are differences in climate 

model projections beyond 2050. 

M.2 Pacific Northwest Climate Indicators and Observed Trends 

M.2.1 Observed Temperature and Precipitation Changes 

From a climate change perspective the Refuge is more closely aligned with changes that have 

occurred in the Pacific Northwest, rather than the desert regions of the Southwest. In the Pacific 

Northwest, the regionally averaged temperature rose 1.5°F between 1920 and 2000 (Figure M-4), 

slightly more than the global average. Warming was greatest for the winter months of January to 

March. Minimum daily temperatures have increased faster than maximum daily temperatures. 

Longer-term precipitation trends in the Pacific Northwest are more variable and vary with the period 

of record analyzed (Mote et al. 2005). Looking at the period 1920 to 2000, precipitation has 

increased almost everywhere in the region. Most of that increase occurred during the first part of the 

record. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-5 

 Source: Climate Impacts Group 2011. 

Note: Red (blue) circles indicate warming (cooling) air temperatures or decreasing (increasing) precipitation. 

Figure M-4. Trends in annual temperature or precipitation from 1920 to 2000. 

In the Pacific Northwest, increased GHGs and warmer temperatures have resulted in a number of 

physical and chemical impacts to the region. These include changes in snowpack, streamflow timing 

and volume, flooding and landslides, sea levels, ocean temperatures and acidity, and disturbance 

regimes like wildfires and insect and disease outbreaks (USGCRP 2009). 

M.2.2 Observed Snowpack, Streamflow, and Glacial Changes 

Snowpack Changes: One of the most important responses to warmer winter temperatures in the 

Pacific Northwest has been the loss of spring snowpack (Mote et al. 2005). As temperatures rise, the 

likelihood of winter precipitation falling as rain rather than snow increases. This is especially true in 

the Pacific Northwest where mountainous areas of snow accumulation are at relatively low elevations 

and winter temperatures are near freezing. Small increases in average winter temperatures can lead to 

increased rains, reduced snowpack, and earlier snowmelt. The loss of spring snowpack in the Pacific 

Northwest has been significant, with most stations showing, on average, a decrease (Figure M-5). 

Data recorded each April 1st show that snowpacks have declined 25 percent over the past 40 to 70 

years (Mote et al. 2005). The fact that the declines are greatest at low elevation sites and the trend has 

occurred in the absence of significant decreases in winter precipitation implicates temperature rather 

than precipitation as the cause of the trend. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-6 Appendix M. Climate Change 

Figure M-5. Trends in April 1st snow water 

equivalent (SWE) in the western United 

States from 1950 to 1997. Red (blue) circles 

indicate decreasing (increasing) SWE, with 

the size of the symbol indicating the 

magnitude of the trend 

Source: Mote et al. 2005. 

Streamflow Changes: The decrease in spring snowpack and earlier snowmelt have led to a change in 

streamflow in many systems, including earlier spring runoff peaks, increased winter streamflow, and 

reduced summer and fall streamflows. Stewart et al. (2005) examined 302 streamflow gages in the 

western United States and reported that the timing of winter runoff and annual streamflow had 

advanced by 1 to 4 weeks from 1948 to 2002. The degree of change depends on the location and 

elevation of the specific river basin. Basins located significantly above freezing levels have been 

much less affected by warmer temperatures than those located at lower elevations (Figure M-6). 

River basins whose average daily winter temperatures are close to freezing are the most sensitive to 

climate change, as is apparent from the dramatic shifts in streamflow timing that have resulted from 

relatively small increases in winter temperatures. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-7 

Source: Stewart et al. 2005. 

Figure M-6. Observed spring pulse of snowmelt-generated streamflow for (a) and (b) two high 

and (c) and (d) two mid-elevation Pacific Northwest streams, illustrating the much greater 

advance in timing in the mid-elevation streams. 

The advance in streamflow timing also results in decreased summer and fall base flows, at precisely 

the time when streamflow is needed most. In addition, warmer temperatures have lengthened the 

growing season (defined as the time between the last frost of spring and the first frost of fall) in the 

western United States by an average of about 10 to 15 days. Warmer temperatures and longer 

growing seasons increase water requirements for evapotranspiration, hydropower, and irrigation, 

resulting in potential water supply shortages and conflicts. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-8 Appendix M. Climate Change 

Figure M-7. Grinnell Glacier, Glacier National 

Park, photographs from 1940 and 2006. 

Source: U.S. Geological Survey (USGS) Northern Rocky Mountain 

Science Center 2011. 

Glacier Changes: Another indication of climate change in the Pacific Northwest is the decline and 

retreat of many of the region’s iconic glaciers, including those in Glacier National Park. Models 

predict that all of the Park’s glaciers will melt by 2030 (Hall and Fagre 2003). Scientists have begun 

the task of documenting glacial decline through repeat photographic images such as the pair shown in 

Figure M-7. 

M.3 Climate Change Indicators and Trends at Malheur Refuge 

M.3.1 Sources and References for Refuge Climate Data 

PRISM: There are several sources of historical climate data for the Refuge. The main data source 

used here is the Parameter-elevation Regressions on Independent Slopes Model (PRISM) (Daly 

2002; Daly et al. 2008). PRISM provides a complete record (i.e., no missing data) of temperature and 

precipitation data at 4-km resolution for the entire conterminous United States. We used monthly 

minimum and maximum temperature and monthly precipitation PRISM data from 1950 to 2009. 

Geographic information system (GIS) was used to delineate two areas—the area encompassed by the 

Refuge boundary and the Blitzen watershed upstream of the Refuge and Page Springs. We then 

intersected the 4-km gridded PRISM data and queried temperature and precipitation for all grid 

points within the boundaries of these two areas at each monthly time step, to calculate an average 

monthly temperature and total monthly precipitation for both the Refuge and the Blitzen watershed 

for every month from 1950 to 2009. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-9 

PRISM is a method developed by Oregon State University researchers for generating gridded 

estimates of historical precipitation and temperature at monthly and daily time steps. The method 

interpolates between point data from thousands of weather stations using a digital elevation model 

(DEM) and many other geographic data sets. The gridded estimates account for spatial variations in 

climate caused by elevation, terrain orientation, effectiveness of terrain as a barrier to flow, coastal 

proximity, moisture availability, atmospheric inversions, and topographic position (valley, mid-slope, 

ridge). PRISM provides a complete record (no missing data) of monthly minimum and maximum 

temperature and monthly precipitation data from 1895 to the present at a 4-km resolution for the 

conterminous United States. In addition to the time series data at a 4-km resolution, 30-year average 

monthly temperature and precipitation, based on the period 1971-2000, are available at an 800-m 

resolution for any point in the conterminous United States and the Pacific Islands. Because of the 

complete geographic coverage, PRISM can provide estimates of climate data for remote areas where 

there is often little or no data available. 

USHCN: A second source of daily and monthly climate data is the individual weather stations in the 

area. This includes Burns Municipal Airport, four National Weather Service/National Oceanic and 

Atmospheric Administration (NWS/NOAA) government weather stations on the Refuge (Buena 

Vista Station, P Ranch Substation, Double-O Station, and Refuge Headquarters), and the United 

States Historical Climatology Network (USHCN) Malheur Refuge Headquarters station (Station No. 

355162). We mainly relied on the USHCN station data because this station provides a complete 

record of high-quality climate data (Menne et al. 2009). The PRISM method described above likely 

used data from all these local stations, as well as snowpack telemetry (SNOTEL) station data 

described below, to develop the interpolated data set for the area. 

The USHCN is a high-quality data set of daily and monthly records of basic meteorological variables 

from 1,218 observing stations across the conterminous United States (Menne et al. 2011). The 

USHCN data have been corrected to remove biases or heterogeneities from non-climatic effects such 

as urbanization or other landscape changes, station moves, and instrument and time of observation 

changes. The network has been developed over the years at the NOAA National Climatic Data 

Center (NCDC) to assist in the detection of regional climate change. It is used by NOAA to monitor 

temperature and precipitation over the United States. This includes the calculation of trends over 

roughly the last century and regular updates to yearly and monthly state/regional rankings of 

temperature and precipitation. The USHCN network includes a complete record (no missing data) of 

monthly maximum, mean, and minimum temperature and monthly precipitation for the period 1895 

to the present. The only USHCN station close to Malheur is the Malheur Refuge Headquarters 

(USHCN Station No. 355162). 

Both the PRISM and USHCN have the advantage of being complete data sets with no missing 

records. In each of these data sets, missing data have been estimated in a sophisticated procedure 

using a weighted average of values from highly correlated neighboring stations. This is often a 

problem when using data from local stations. The estimation of missing data involves considerable 

effort and too often the problem is ignored, with no attempt to estimate missing values. This can 

skew estimates of averages and trends. 

SNOTEL: A third source of climate data is the two Natural Resources Conservation Service (NRCS) 

SNOTEL sites, Silvies SNOTEL (Site No. 759) and the Fish Creek SNOTEL (Site No. 477), located 

on Steens Mountain within the Blitzen watershed (NRCS 2011). The Silvies site is slightly lower 

(6,990 feet) than the Fish Creek site (7,660 feet) but both sites are at relatively high elevations for 

SNOTEL sites in Oregon. These sites have April 1 snow water equivalent measurements (SWE) 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-10 Appendix M. Climate Change 

from 1939 to the present, with daily SWE, precipitation, and air temperature measurements 

beginning in 1984. The statistically significant trend in the monthly temperature and precipitation 

PRISM data for the area of the Malheur Refuge from 1950 to 2009 is a 3.5°F increase (0.6°F per 

decade) in March monthly temperatures (Figure M-8). 

M.3.2 Observed Trends in Refuge Climate Data 

The PRISM data for the Blitzen watershed area show a statistically significant increase in March 

monthly temperatures (Figure M-8), as do the USHCN data from the Malheur Refuge Headquarters 

station (data not shown). The USHCN station data also show statistically significant increases in 

several other months. Precipitation data from PRISM and USHCN show opposite trends (one 

increasing and one decreasing) from 1950 to 2009, but neither trend is statistically significant. As 

discussed above, winter temperatures, particularly in January and March, have been shown by other 

studies to be increasing in the West (Hamlet and Lettenmaier 2007; Knowles et al. 2006). The 

increases can cause more precipitation to fall as rain instead of snow, resulting in reduced April 1st 

snow water equivalent (SWE), earlier snowmelt, and changes in streamflow. 

Year

Mar avg T (F)

1950 1960 1970 1980 1990 2000 2010

44

42

40

38

36

34

32

30

SLR

THEIL

LINE

.

..

DATA

Mar Average T (PRISM data for Malheur refuge) 1950-2009

SEN-THEIL-KENDALL LINE

SLR LINE

1950-09

Mar avg T (F)

1950 1960 1970 1980 1990 2000 2010

42

40

38

36

34

32

30

28

SLR

THEIL

LINE

.

..

DATA

Mar Average T (PRISM data for Blitzen) 1950-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Figure M-8. Trend in March monthly temperature for the Refuge and the Blitzen watershed 

(PRISM data) from 1950 to 2009. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-11 

The SNOTEL data on Steens Mountain suggest that warmer March temperatures may have impacted 

snowpack at least at lower elevations in the Blitzen watershed (NRCS 2011). There is a statistically 

significant decreasing trend (−5 percent per decade, or −34 percent) from 1950 to 2009 in the April 

1st SWE at the Silvies SNOTEL, the lower elevation site (Figure M-9). April 1st SWE at Fish Creek, 

the higher elevation site, shows a very slight decrease from 1950 to 2009, but the trend is not 

statistically significant. Note that the Blitzen PRISM data set shows an increase in precipitation over 

the same period. The fact that precipitation in the Blitzen watershed has increased or at least not 

changed while the SWE at the lower elevation site has decreased significantly indicates that the 

decreasing trend at the Silvies SNOTEL site is most likely related to warmer temperatures. Because 

of the relatively high elevation and cold climate of the Blitzen watershed and the Steens Mountain 

area, snowpack has not been affected by warming temperatures to the degree it has in other, lower 

elevation areas around the Pacific Northwest. However, as temperatures continue to warm, snowpack 

will likely continue to decline. Apr 1st SWE (in)

1950 1960 1970 1980 1990 2000 2010

50

40

30

20

10

SLR

THEIL

LINE

.

..

DATA

Fish Creek SNOTEL Apr 1st SWE 1950-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Apr 1st SWE (in)

1950 1960 1970 1980 1990 2000 2010

40

30

20

10

0

SLR

THEIL

LINE

.

..

DATA

Silvies SNOTEL Apr 1st SWE 1950-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Source: NRCS 2011. 

Figure M-9. April 1st SWE at Fish Creek SNOTEL (elevation 7,660 ft.) and Silvies SNOTEL 

(elevation 6,990 ft.) for the period 1950 to 2009. 

One of the expected impacts of declining snowpacks and earlier snowmelt is a change in streamflow 

timing and volume, specifically higher winter flows, an earlier snowmelt runoff peak, and reduced 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-12 Appendix M. Climate Change 

late season base flows. Because the USGS Blitzen River stream gage has a long period of record 

(continuous measurements from 1939 onward) and is upstream of any significant diversions or 

regulation, it provides an excellent record of the response of the river to climate. To date, few climate 

change impacts can be observed in the Blitzen River streamflow record, in contrast to other stream 

systems in the Pacific Northwest. There is no trend in the annual streamflow centroid (the date on 

which approximately half of the annual volume of streamflow occurs for the water year) or the 

annual minimum 7-day average flow (Figure M-10). There has been no change in the percentage of 

monthly flows to total annual flow for March to September over the same period (data not shown). 

There has been a slight decrease in the ratio of June/May flows, as might be expected with earlier 

runoff, and an increase in the annual maximum daily flow, as might be expected with more 

winter/spring rains (Figure M-11), but the statistical significance of both of these trends is weak (p = 

0.14). 

Centroid Date (Julian day of WY)

1930 1940 1950 1960 1970 1980 1990 2000 2010

230

220

210

200

190

180

170

SLR

THEIL

LINE

.

..

DATA

Annual Date of Streamflow Centroid Blitzen River 1939-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Minimum 7-D Avg Flow (cfs)

1930 1940 1950 1960 1970 1980 1990 2000 2010

70

60

50

40

30

20

10

SLR

THEIL

LINE

.

..

DATA

Annual Minimum 7-Day Average Flow Blitzen River 1939-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Figure M-10. Trends in the annual streamflow centroid (the date on which approximately half 

of the annual streamflow occurs) and the annual minimum 7-day average flow for the Blitzen 

River near Frenchglen, 1939 to 2009. Both data sets show no statistically significant changes for 

the period. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-13 Jun/May Flows

1930 1940 1950 1960 1970 1980 1990 2000 2010

1.8

1.6

1.4

1.2

1.0

0.8

0.6

0.4

0.2

SLR

THEIL

LINE

.

..

DATA

Ratio of Jun/May Monthly Flows Blitzen River 1939-2009

SEN-THEIL-KENDALL LINE

SLR LINE

         

WY

Maximum Daily Flow (cfs)

1930 1940 1950 1960 1970 1980 1990 2000 2010

3000

2500

2000

1500

1000

500

0

SLR

THEIL

LINE

.

..

DATA

Annual Maximum Daily Flow Blitzen River 1939-2009

SEN-THEIL-KENDALL LINE

SLR LINE

Figure M-11. Trends in the annual ratio of June/May monthly flows and the annual maximum 

daily flow for the Blitzen River near Frenchglen, 1939 to 2009. Both trends are only weakly 

significant. 

M.4 Projected Climate Changes for the Pacific Northwest and 

Malheur Refuge 

The Climate Impacts Group (CIG) has projected changes in mean annual temperature for the Pacific 

Northwest, based on several climate models and two emissions scenarios as described in Mote and 

Salathe (2010). By the 2080s, the temperature increase is about 6°F under the A1B medium 

emissions scenario and 4.5°F under the B1 low emissions scenario. Considering both scenarios, 

average annual temperature is projected to increase 2.0°F by the 2020s, 3.2°F by the 2040s, and 

5.3°F by the 2080s, relative to the 1970 to 1999 average temperature. The projected changes in 

average annual temperature are substantially greater than the 1.5°F (0.8°C) increase in average 

annual temperature observed in the Pacific Northwest during the twentieth century. The mean rate of 

warming is 0.5°F per decade through mid twenty-first century. Seasonally, summer temperatures are 

projected to increase the most. It is important to note that actual global emissions of GHGs in the past 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-14 Appendix M. Climate Change 

decade have exceeded even the highest emissions scenario (the A2 scenario), resulting in a scenario 

that wasn’t modeled by CIG. If this trend continues, the temperature increases could actually turn out 

to be much greater than those projected in Figure M-12. 

Projected changes in mean annual precipitation are less clear (Figure M-12). Precipitation trends are 

very small relative to the interannual variability in precipitation. Seasonally, precipitation is projected 

to decrease in the summer and increase in the winter by most climate models, although the average 

shifts are small. However, even small changes in seasonal precipitation could have impacts on 

streamflow flooding, summer water demand, drought stress, and wildland fire frequency. 

Source: Mote and Salathe 2010. 

Note: The black curve for each panel is the weighted average of all models during the twentieth century. The 

colored curves are the weighted average of all models in that emissions scenario (“low” or B1, and “medium” or 

A1B) for the twenty-first century. The colored areas indicate the range (5th to 95th percentile) for each year in 

the twenty-first century. All changes are relative to 1970 to 1999 averages. 

Figure M-12. Simulated temperature change (top panel) and percent precipitation change 

(bottom panel) in the Pacific Northwest using twentieth and twenty-first century global climate 

model simulations. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-15 

In addition to changes in the amount of precipitation, a major concern in the Pacific Northwest is the 

change in the form of winter precipitation expected due to warmer temperatures. CIG has modeled 

changes in the current and future peak SWE versus October to March precipitation for fourth-level 

HUC watersheds in the Columbia Basin Area, including the Blitzen watershed (Figure M-13). They 

have classified watersheds into three categories to reflect projections of the dominant precipitation 

regime: snow (peak SWE/O-M pcp >0.4), transition (peak SWE/O-M pcp = 0.1 to 0.4), and rain 

(peak SWE/O-M pcp <0.1). Generally, there is a large shift in the Pacific Northwest from snow and 

transition basins to rain basins. In basins where these changes occur, there will likely be a tendency 

for higher winter flows and possible increased risk of flooding, earlier snowmelt and runoff peaks, 

and lower summer streamflows. 

The Blitzen watershed is currently classified as a transition basin and is projected to remain that way 

until the 2080s under the A1B scenario and through the 2080s under the B1 scenario, when it will 

become a rain basin. This shift to a rain basin occurs more slowly than in many of the surrounding 

basins in the Pacific Northwest, and the Blitzen watershed appears to be more resilient to climate 

change, probably because of the higher elevation and cooler climate in the Steens Mountain area. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-16 Appendix M. Climate Change 

Note: The Blitzen watershed is not identified in this figure; however, it 

is the small, isolated basin in southeastern Oregon shown in red in the 

lowest right figure. 

Figure M-13. Ratio of April 1st SWE to total March to October precipitation for the historical 

period (1916–2006) for the A1B scenario (left panel), and for the B1 scenario (right panel) at 

three future time periods (2020s, 2040s, 2080s). 

M.5 Observed and Predicted Ecological Response to Climate 

Change in the Region 

An emerging body of literature indicates that over the past three decades, the changes in the climate 

system described above—including the anthropogenic component of warming— have caused 

physical and biological changes in a variety of ecosystems (IPCC 2007; Parmesan 2006; Root et al. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-17 

2003) that are discernable at the global scale. These changes include shifts in genetics (Bradshaw and 

Holzapfel 2006), species’ ranges, phenological patterns, and life cycles (reviewed in Parmesan 

2006). Most (85 percent) of these observed ecological responses have been in the expected direction 

(e.g., poleward shifts in species distributions) and are very likely due to climate change. Climate 

change has and will continue to combine with other non-climate stressors to impact ecosystems and 

threaten biodiversity. In the Great Basin, climate change, invasive species, habitat fragmentation, and 

rangeland and riparian degradation have placed numerous species at risk, including sage grouse and 

redband trout (Chambers and Pellant 2008). 

Disturbances, both natural and human-induced, shape ecosystems by influencing their composition, 

structure, and function. One observed response to climate change in the Pacific Northwest is the 

change in disturbance regimes like fire and insect/disease outbreaks. Increased spring and summer 

temperatures, earlier snowmelt, and prolonged drought, have contributed to longer fire seasons and 

an increase in wildfire activity in the Pacific Northwest. Westerling et al. (2006) evaluated the effects 

of both land use histories and climate on wildfire and concluded that the increase in fire frequency in 

the past two to three decades has been driven primarily by recent changes in climate. Areas in 

southern Oregon, northern California, and the northern Rockies have been especially vulnerable to 

these changes. 

Since the mid-1990s, an outbreak of mountain pine beetles has reached unprecedented levels in terms 

of acreage, northern expansion and distribution, and number of trees killed (Bentz 2008) (Figure M14). In addition to lodgepole pine, the beetle is starting to cause mortality in whitebark and limber 

pine at high elevations. Climate change is partly responsible for these trends. Warmer temperatures 

have facilitated bark beetle outbreaks in three ways: 1) drought stress makes trees more vulnerable to 

attack; 2) warmer winters mean less mortality for overwintering insects; and 3) insect populations 

respond to increased temperatures by speeding up their reproductive cycles (e.g., to one-year life 

cycles). 

Source: British Columbia Ministry of Forests, Lands, and Natural Resource 

Operations 2011. 

Figure M-14. Mountain pine beetle damage in British Columbia. 

The effects of climate change and non-native invasive species may combine to increase invasion risk 

to ecosystems. Bradley (2009) showed that the potential area for cheatgrass (Bromus tectorum) 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-18 Appendix M. Climate Change 

invasion, which is sensitive to precipitation and temperature, increased up to 45 percent in the 

western United States with decreasing summer precipitation and warmer winter temperatures. 

Cheatgrass invasion also works in conjunction with climate change to alter fire regimes. Frequent 

fires promote invasive grasses like cheatgrass, and large grassland fires are more likely in a warmer, 

drier climate with exotic grasses present. The cheatgrass fire cycle has been a major factor in the 

decline of sagebrush steppe ecosystems, and climate change is likely to exacerbate this decline 

(Chambers and Pellant 2008). 

Climate change is also expected to cause major changes in grassland and sagebrush distribution 

across the landscape (Bachelet et al. 2001). Range expansions of woody species are predicted to 

continue, particularly the expansion of pinyon-juniper into sagebrush steppe and grasslands 

(Rowland et al. 2008), resulting in a decrease in sagebrush and an increase in woodlands across the 

West (Figure M-15). More frequent wildfires may favor non-native invasives and exacerbate the loss 

of big sagebrush, a keystone species that is not very fire-tolerant. In the Great Basin, current 

sagebrush habitat is predicted to decrease 12 percent for each 1°C increase in temperature, partly 

because of these factors (Chambers and Pellant 2008). However, more frequent fires might also limit 

juniper expansion. 

Source: Ashton 2010. 

Figure M-15. Illustration of climate change impacts to sagebrush/grassland communities. 

Another ecological response to climate change is the change in timing of phenological events like 

leaf-out, flowering, senescence, migration, hibernation, and insect emergence. These events are often 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-19 

sensitive to variations in temperature and precipitation. There are indications that some of these 

events are responding to climate change. From 1957 to 1994, flowering of lilacs (Syringa vulgaris) 

and honeysuckle (Lonicera tatarica and L. korolkowii) have shown an advance of 7.5 and 10 days, 

respectively, in the West. This is most likely due to the 2°F-5°F increase in spring temperatures 

during that period (Cayan et al. 2001). In Idaho, the average bloom date for lilacs advanced one week 

from 1957 to 1993 (Figure M-16). Warmer temperatures will continue to affect the timing of 

reproduction, emergence, and migration of numerous species, which may affect community structure 

and function. On the other hand, phenological events that are tied to day length rather than climate, 

such as the emergence of many plants, are not expected to change. These asynchronous responses of 

different species to climate change may alter species’ interactions (e.g., predator–prey relationships 

and competition) and have unforeseen consequences. 

Source: Gillis et al. 2011. 

Figure M-16. Average statewide bloom date of lilacs in Idaho, 1957 to 1993. 

Climate change has a large potential to impact aquatic ecosystems in the Pacific Northwest (Figure 

M-17). Although there have been few climate change impacts on Blitzen streamflow to date, aquatic 

habitats at Malheur NWR, including rivers, streams, springs, wetlands, and wet meadows, face future 

threats from climate change. River and stream temperatures may increase with warmer air 

temperatures and longer growing seasons, threatening redband trout. Water temperatures in the 

Blitzen River are already quite warm; 7-day average maximum temperatures are frequently near 

25°C in the summer (Mayer et al. 2007). Even at the upstream end, where the river enters the Refuge 

from the canyon, water temperatures exceeded the state standard of 20°C for an average of 64 days 

during the summers of 2003 and 2005 (Mayer et al. 2007). 

Evaporative and seepage losses in wetlands and wet meadows may increase due to warmer 

temperatures, longer growing seasons, drier soils, and lower water tables, potentially limiting the 

available habitat that can be sustained for migratory waterfowl. Changes in transpiration are 

uncertain. There may be less transpiration because of greater photosynthetic efficiency from higher 

CO2 concentrations in the atmosphere, but higher CO2 concentrations could also mean more plant 

growth, plant leaf area, and increased transpiration. Earlier runoff and higher evaporation losses 

could cause a decrease in wetland acreage that can be maintained on the Refuge given the Refuge’s 

water supply. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-20 Appendix M. Climate Change 

Source: Ashton 2010. 

Figure M-17. Illustration of climate change impacts to aquatic communities. 

M.6 Climate Change Adaptation Strategies 

The slower response and apparent resilience of the Blitzen watershed to climate change may provide 

the Refuge with an opportunity to develop and implement climate change adaptation strategies (or 

adjustments in management). The goal of adaptation is to reduce the risk of adverse environmental 

outcomes through activities that increase the resilience of ecosystems to climate change and other 

stressors (United States Climate Change Science Program [USCCSP] 2008). Resilience is defined as 

the amount of change or disturbance a system can absorb without undergoing a fundamental shift to a 

different set of processes and/or structures. One of the most effective means of increasing resilience 

is to reduce or eliminate non-climate stressors. 

Climate change will combine with other non-climate stressors to exacerbate existing problems with 

water supply, aquatic resources, invasive weeds, and ecosystem function on the Refuge. Even now, 

there are difficulties balancing the needs of water management for wetlands with the needs of instream flows for fish. Wetland irrigation and water management on the Refuge decrease river flows, 

exacerbate high water temperatures, and reduce dissolved oxygen concentrations in the river (Mayer 

et al. 2007). River temperatures are already at or near the limit of tolerance for redband trout on most 

of the Refuge. The river has been channelized to facilitate drainage and water delivery. Riparian 

vegetation is limited and the river habitat is degraded, with little complexity. Wetland and wet 

meadow habitats on the Refuge are threatened by several non-native invasive plant species including 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-21 

perennial pepperweed, Russian olive, and reed canarygrass. Aquatic and riverine habitats are 

threatened by non-native carp. 

Reducing non-climate stressors means controlling invasive species and could include restoring the 

river, rehabilitating riparian vegetation, reestablishing, where possible, the natural sinuosity of the 

channel, and reconnecting, where viable, valley wetlands and floodplains with the river channel. 

Reducing the impacts of current stressors is a “no regrets” adaptation strategy that could be taken 

now to enhance ecosystem resilience to climate change. These activities will require time. 

Fortunately, the fact that climate change impacts are slower to manifest themselves here compared 

with other areas would allow more time to implement these restoration activities. 

Key to the successful implementation of these adaptation and restoration strategies will be the 

monitoring of results. The National Weather Service (NWS) weather stations, the USGS Blitzen 

River gage, and the two Natural Resources Conservation Services (NRCS) SNOTEL sites on Steens 

Mountain will continue to provide very valuable climate and streamflow information on the local 

impacts of climate change. It is in the Refuge’s best interest to see that these sites are maintained and 

monitored in the future. The Water Resources Branch monitors streamflows and diversions at several 

sites on the Refuge—this should be continued as well. The Branch also monitored water 

temperatures in the river during the summers of 2002, 2003, and 2005. This seasonal water 

temperature monitoring should be continued in the future. Finally, ongoing efforts to monitor and 

contain invasive species will be important for providing information on the status of non-climate 

stressors. 

Monitoring may provide information that will require modification of adaptation strategies or point 

to new restoration needs. One method for integrating new information into resource management 

decisions, given uncertainty, is adaptive management. Adaptive management is a process that 

promotes flexible decision making so that adjustments are made to decisions as outcomes from 

management actions and other events are better understood. This method supports managers in 

taking action today using the best available information while also providing the possibility of 

ongoing future refinements through an iterative learning process. 

M.7 References 

Ashton, I.W. 2010. Observed and projected ecological response to climate change in the Rocky 

Mountains and the Upper Columbia Basin. Natural Resource Report NPS/ROMN/NRR—

2010/220. National Park Service. Fort Collins, CO. 

Bachelet, D., R.P. Neilson, J.M. Lenihan, and R.J. Drapek. 2001. Climate change effects on 

vegetation distribution and carbon budget in the United States. Ecosystems 4:164-185. 

Bentz, B. 2008. Western U.S. bark beetles and climate change. USDA Forest Service, Climate 

Change Resource Center. Available at: http://www.fs.fed.us/ccrc/topics/bark-beetles.shtml. 

Accessed 

Bowers, W., R. Smith, R. Messmer, C. Edwards, and R. Perkins. 1999. Conservation status of 

Oregon basin redband trout. Oregon Department of Fish and Wildlife. Hines, OR. 

Bradley, B.A. 2009. Regional analysis of the impacts of climate change on cheatgrass invasion 

shows potential risk and opportunity. Global Change Biology 15:196-208. 

Bradshaw, W.E. and C.M. Holzapfel. 2006. Evolutionary response to rapid climate change. Science 

312:1477-1478. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-22 Appendix M. Climate Change 

British Columbia Ministry of Forests, Lands, and Natural Resource Operations. 2011. Photos: aerial 

view of extensive attack by mountain pine beetle. Available at: 

http://www.for.gov.bc.ca/hfp/mountain_pine_beetle/images/Jul1-

8_roll1_Williams_Lake_MPB1.jpg. Accessed August 19, 2011. 

Cayan, D.R., S.A. Kammerdiener, M.D. Dettinger, J. Caprio, and D.H. Peterson. 2001. Changes in 

the onset of spring in the western United States. Bulletin of the American Meteorological 

Society 82:399-415. 

Chambers, J.C., B.A. Roundy, R.R. Blank, S.E. Meyer, and A. Whittaker. 2007. What makes Great 

Basin sagebrush ecosystems invasible by Bromus tectorum? Ecological Monographs 77:117-

145. 

Chambers J.C., and M. Pellant. 2008. Climate change impacts on northwestern and intermountain 

United States rangelands. Society of Range Management. Available at: 

http://www.treesearch.fs.fed.us/pubs/30834. 

CIG (Climate Impacts Group, University of Washington). 2010. Analysis of extreme events. 

Available at: http://www.hydro.washington.edu/2860/report/. Accessed August 19, 2011. 

CIG. 2011. Past and future trends in PNW climate. Available at: 

http://cses.washington.edu/cig/pnwc/pnwc.shtml#pastfuture. Accessed August 19, 2011. 

Daly, C. 2002. Climate division normal derived from topographically-sensitive grids. Proceedings of 

the 13th AMS Conference on Applied Climatology, American Meteorological Society, May 

13-16, 2002, Portland, OR, 177-180. 

Daly et al. 2008. Physiographically sensitive mapping of climatological temperature and precipitation 

across the conterminous United States. International Journal of Climatology. doi 

10.1002/joc.1688. 

EPA (Environmental Protection Agency). 2010. Climate change indicators in the United States. U.S. 

Environmental Protection Agency. Washington D.C. 

Gillis, S., B. Knapp, J. Wolf, J. Izo, K. McElligott, J. Reader, A.Peterson, D. VanSant, and N. 

Weller. 2011. Indicators of climate change in Idaho. Report Summary, University of Idaho, 

Moscow, ID. Available at: 

http://webpages.uidaho.edu/jabatzoglou/PDF/IndicatorsofClimateChangeIdaho.pdf. 

Hall, M.H.P. and D.B. Fagre. 2003. Modeled climate-induced glacier change in Glacier National 

Park, 1850-2100. Bioscience 53(2):131-140. 

Hamlet, A.F. and D.P. Lettenmaier. 2007. Effects of 20th century warming and climate variability on 

flood risk in the western U.S. Water Resources Research 43, W06427, 

doi:10.1029/2006WR005099. 

IPCC (Intergovernmental Panel on Climate Change). 2007. Climate change 2007: the physical 

science basis. Contribution of Working Group I to the fourth assessment report of the 

Intergovernmental Panel on Climate Change. Solomon, S., D. Qin, M. Manning, Z. Chen, M. 

Marquis, K.B. Averyt, M.Tignor, and H.L. Miller, eds. Cambridge, United Kingdom and 

New York: Cambridge University Press. 

Knowles, N., M.D. Dettinger, and D.R. Cayan. 2006. Trends in snowfall versus rainfall in the 

western United States. Journal of Climate 19(18):4545-4559. 

Mayer, T., K. Janssen, T. Hallock, and R. Roy. 2007. Blitzen River temperature monitoring. Pages 1-

24, Chapter 5 in: OR–Assessment of degraded water quality effects associated with habitat 

and water management of wetlands and meadows at Malheur National Wildlife Refuge. 

Regional One, Regional Office, U.S. Fish and Wildlife Service. Portland, OR. 

Menne, M.J., C.N. Williams, Jr., and R.S. Vose. 2009. United States Historical Climatology Network 

(USHCN) Version 2 Serial Monthly Dataset. Carbon Dioxide Information Analysis Center, 

Oak Ridge National Laboratory. Oak Ridge, TN. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix M. Climate Change M-23 

Menne, M.J., C.N. Williams, Jr., and R.S. Vose. United States Historical Climatology Network 

(USHCN) Version 2 Serial Monthly Dataset. Carbon Dioxide Information Analysis Center, 

Oak Ridge National Laboratory. Oak Ridge, TN. Available at: 

http://cdiac.ornl.gov/epubs/ndp/ushcn/monthly_doc.html. 

Mote, P.W., A.F. Hamlet, M.P. Clark, and D.P. Lettenmaier. 2005. Declining mountain snowpack in 

western North America. Bulletin of the American Meteorological Society 86(1):39-49. 

Mote, P.W. and E.P. Salathe. 2010. Future climate in the Pacific Northwest. Climate Change 109:29-

50. 

NAS (National Academy of Sciences). 2008. Understanding and responding to climate change: 

highlights of national academies reports. 2008 edition. Board on Atmospheric Sciences and 

Climate, National Academy of Sciences. Washington D.C. 

NCDC (National Climatic Data Center). 2010. State of the climate, annual 2010. Available at: 

http://www.ncdc.noaa.gov/sotc/2010/13. 

NRCS (Natural Resources Conservation Service). 2011. SNOTEL data and products. Available at: 

http://www.wcc.nrcs.usda.gov/snow/. Accessed August 19, 2011. 

Parmesan, C. 2006. Ecological and evolutionary responses to recent climate change. Annual Review 

of Ecology, Evolution, and Systematics 37: 637-669. 

Root, T.L., J.T. Price, K.R. Hall, S.H. Schneider, C. Rosenzweig, and J.A. Pounds. 2003. 

Fingerprints of global warming on wild animals and plants. Nature 421:57-60. 

Rowland, M.M., L.H. Suring, R.J. Tausch, S. Geer, and M.J. Wisdom. 2008. Characteristics of 

western juniper encroachment into sagebrush communities in central Oregon. USDA Forest 

Service Forestry and Range Sciences Laboratory. La Grande, OR. 

Stewart, I.T., D.R. Cayan, and M.D. Dettinger. 2005. Changes toward earlier streamflow timing 

across western North America. Journal of Climate 18(8):1136-1155. 

USCCSP (United States Climate Change Science Program). 2008. Preliminary review of adaptation 

options for climate-sensitive ecosystems and resources. United States Climate Change 

Science Program. Final Report, Synthesis and Assessment Product 4.4. Washington, D.C. 

USGCRP (U.S. Global Change Research Program). 2009. Global climate change impacts in the 

United States. Karl, Thomas R., Jerry M. Melillo, and Thomas C. Peterson, eds. New York: 

Cambridge University Press. 

USGS (U.S. Geological Survey) Northern Rocky Mountain Science Center. 2011. Grinnell Glacier 

from Overlook 1940-2006-old. Available at: 

http://www.nrmsc.usgs.gov/repeatphoto/gg_overlook_old.htm. Accessed August 19, 2011. 

Westerling, A.L., H.G. Hidalgo, D.R. Cayan, and T.W. Swetnam. 2006. Warming and earlier spring 

increase western U.S. forest wildfire activity. Science 313:940-943. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

M-24 Appendix M. Climate Change 

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White-faced ibis

©Dan Dzurisin

Appendix N

List of Common and

Scientific Names Used in the

Malheur National Wildlife Refuge CCP

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix L

Ecology Work Group

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix A

Appropriate Use Findings

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP N-1 

Appendix N. List of Common and Scientific Names Used in the Malheur National Wildlife Refuge CCP 

Table N-1. Birds 

Common Name Scientific Name 

American bittern Botaurus lentiginosus 

American coot Fulica americana 

American white pelican Pelecanus erythrorhynchos 

American wigeon Anas americana 

Bobolink Dolichonyx oryzivorus 

Burrowing owl Athene cunicularia 

California quail Callipepla californica 

Canada goose Branta canadensis 

Canvasback Aythya valisineria 

Cinnamon teal Anas cyanoptera 

Common raven Corvus corax 

Common snipe Gallinago gallinago 

Eastern kingbird Tyrannus tyrannus 

Gadwall Anas strepera 

Great horned owl Bubo virginianus 

Greater sandhill crane Grus canadensis tabida 

Lark sparrow Chondestes grammacus 

Long-billed curlew Numenius americanus 

Long-eared owl Asio otus 

Mallard Anas platyrynchos 

Northern harrier Circus cyaneus 

Northern pintail Anas acuta 

Northern shoveler Anas clypeata 

Pied-billed grebe Podilymbus podiceps 

Redhead Aythya americana 

Red-winged blackbird Agelaius phoeniceus 

Ring-necked pheasant Phasianus colchicus 

Ruddy duck Oxyura jamaicensis 

Sharp-tailed grouse Tympanuchus phasianellus 

Trumpeter swan Cygnus buccinator 

Western grebe Aechmophorus occidentalis 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

N-2 Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP 

Common Name Scientific Name 

White-faced ibis Plegadis chihi 

Willow flycatcher Empidonax traillii 

Wilson's phalarope Phalaropus tricolor 

Yellow warbler Dendroica petechia 

Table N-2. Mammals 

Common Name Scientific Name 

American badger Taxidea taxus 

American mink Neovison vison 

Beaver Castor canadensis 

Bighorn sheep Ovis canadensis 

Black-tailed jackrabbit Lepus californicus 

Bobcat Lynx rufus 

Bushy-tailed woodrat Neotoma cinerea 

Coyote Canis latrans 

Deer mouse Peromyscus maniculatus 

Desert woodrat Neotoma lepida 

Dusky-footed woodrat Neotoma fuscipes 

Elk Cervus canadensis 

Golden-mantled ground squirrel Callospermophilus lateralis 

Great Basin pocket mouse Perognathus parvus 

Kangaroo rat Dipodomys spp.

Least chipmunk Neotamias minimus 

Malheur shrew Sorex preblei 

Merriam’s shrew Sorex merriami 

Montane vole Microtus montanus 

Mountain lion (Cougar) Puma concolor 

Mule deer Odocoileus hemionus 

Muskrat Ondatra zibethica 

Northern grasshopper mouse Onychomys leucogaster 

Northern pocket gopher Thomomys talpoides 

Nuttal’s cottontail Sylvilagus nuttallii 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP N-3 

Common Name Scientific Name 

Preble’s shrew Sorex preblei 

Pronghorn antelope Antilocapra americana 

Pygmy rabbit Brachylagus idahoensis 

Raccoon Procyon lotor 

Red fox Vulpes vulpes 

River otter Lontra canadensis 

Sagebrush vole Lemmiscus curtatus 

Townsend’s ground squirrel Urocitellus townsendii 

Townsend’s pocket gopher Thomomys townsendii 

Weasel Mustela spp.

Yellow-bellied marmots Marmota flaviventris 

Table N-3. Bats 

Common Name Scientific Name 

Fringed myotis Myotis thysanodes 

Long-legged myotis Myotis volans 

Spotted bat Euderma maculatum 

Townsend’s big-eared bat Corynorhinus townsendii 

Western small-footed myotis Myotis ciliolabrum 

Yuma myotis Myotis yumanensis 

Table N-4. Fish 

Common Name Scientific Name 

Bluegill Lepomis macrochirus 

Bridge lip sucker Catostomus columbianus 

Brown bullhead Ictalurus nebulosus 

Chisel mouth sucker Acrocheilus alutaceus 

Coarse scale sucker Castostomus macrocheilus 

Common Carp Cyprinus carpio 

Green sunfish Lepomis cyanellus 

Large-mouthed bass Micropterus salmoides 

Longnose dace Rhinichthys cataractae 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

N-4 Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP 

Common Name Scientific Name 

Malheur mottled sculpin Cottus bendirei 

Mosquito fish Gambusia affinis 

Mountain whitefish Prosopium williamsoni 

Northern pike minnow Ptychocheilus oregonensis 

Pumpkinseed Lepomis gibbosus 

Rainbow trout Oncorhynchus mykiss 

Red-band trout Oncorhynchus mykiss gairdnerii 

Red-sided shiner Leuciscus elongatus 

Speckled dace Rhinichthys osculus 

Tui Chub Gila bicolor 

White crappie Pomoxis annularis 

Yellow bullhead Ictalurus natalis 

Yellow perch Perca flavescens 

Table N-5. Mollusks 

Common Name Scientific Name 

Bivalve mollusk Musculium spp.

Table N-6. Reptiles and Amphibians 

Common Name Scientific Name 

American bullfrog Rana catesbeiana 

Collared lizard Crotaphytus collaris 

Columbian spotted frog Rana luteiventris 

Common garter snake Thamnophis sirtalis 

Desert horned lizard Phrynosoma platyrhinos 

Gopher snake Pituophis catenifer catenifer 

Great basin spadefoot Spea intermontana 

Leopard lizard Gambelia wislizenii 

Long-toed salamander Ambystoma macrodactylum 

Night snake Hypsiglena torquata 

Pacific tree frog Pseudacris regilla 

Racer Drymobius spp.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP N-5 

Common Name Scientific Name 

Rubber boa Charina bottae 

Sagebrush lizard Sceloporus graciosus 

Short-horned lizard Phrynosoma hernandesi 

Side-blotched lizard Uta stansburiana 

Spade-foot toads Spea hammondii 

Striped whipsnake Masticophis taeniatus 

Western fence lizard Sceloporus occidentalis 

Western ground snake Sonora semiannulata 

Western rattlesnake Crotalus oreganus 

Western skink Plestiodon skiltonianus 

Western terrestrial garter snake Thamnophis elegans 

Western toad Anaxyrus boreas 

Western whiptail Aspidoscelis tigris 

Table N-7. Invertebrates 

Common Name Scientific Name 

Brine fly Ephydra spp.

Brine shrimp Artemia spp.

Thistle beetle Ceutorhynchus litura 

Thistle stem gall fly Urophora cardui 

Thistle weevil Rhinocyllus conicus 

Table N-8. Plants 

Common Name Scientific Name 

Alder Alnus 

Alkali bluegrass Poa juncifolia 

Alkali cordgrass Spartina gracilis 

Alkali sacaton Sporobolus airoides 

Alkali saltgrass Distichlis spicata 

American sloughgrass Beckmannia syzigachne 

American speedwell Veronica americana 

Antelope bitterbrush Purshia tridentata 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

N-6 Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP 

Common Name Scientific Name 

Arrow-grass Triglochin palustris 

Arrowleaf balsam root Balsamorhiza sagittata 

Baltic rush Juncus balticus 

Basin big sagebrush Artemisia tridentata 

Basin wildrye Leymus cinereus 

Bladderwort Utricularia spp.

Bluebunch wheatgrass Pseudoroegneria spicata 

Bluejoint Calamagrostis canadensis 

Bottlebrush squirreltail Elymus elymoides 

Bud sagebrush Picrothamnus desertorum 

Bull thistle Cirsium vulgare 

Bur-reed Sparganium eurycarpum 

Canada thistle Cirsium arvense 

Canadian waterweed Elodea canadensis 

Cattail Typha spp.

Cheatgrass Bromus tectorum 

Chokecherry Prunus virginiana L. var. demissa 

Cinquefoil Potentilla L. 

Common duckweed Lemna minor 

Common reed Phragmites australis 

Common snowberry Symphoricarpos albus 

Coontail (Hornwart) Ceratophyllum demersum 

Coyote willow Salix exigua Nutt. 

Creeping wildrye Leymus triticoides 

Crested wheatgrass Agropyron cristatum 

Diffuse knapweed Centaurea diffusa 

False lupine (bush pea) Thermopsis villosa 

Fourwing saltbush Atriplex canescens 

Fringed willow-herb Epilobium ciliatum 

Geyer’s milkvetch Astragalus Geyeri 

Golden currant Ribes aureum Pursh 

Goose berry Ribes hirtellum 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP N-7 

Common Name Scientific Name 

Greasewood Sarcobatus spp.

Greater duckweed Spirodela polyrhiza 

Hardstem bulrush Scirpus acuta 

Hawthorn Crataegus L. 

Horned pondweed Zannichellia palustris 

Hornwort fruits Ceratophyllum 

Indian ricegrass Achnatherum hymenoides 

Inland saltgrass Distichlis spicata 

Italian thistle Carduus pynocephalus 

Kentucky bluegrass Poa pratensis 

Lanceleaf goldenweed Pyrrocoma lanceolata 

Large-leafed avens Geum macrophyllum 

Leafy pondweed Potamogeton foliosus 

Lewis’ mock orange Philadelphus lewisii Pursh 

Locoweed Astragalus spp.

Lupine Lupinus spp.

Malheur wire-lettuce Stephanomeria malheurensis 

Mat muhly Muhlenbergia richardsonis 

Meadow barley Hordeum brachyantherum 

Meadow foxtail Alopecurus pratensis 

Medusahead rye Taeniatherum spp.

Milkweed Asclepias spp.

Oregon checkermallow Sidalcea oregana 

Mountain big sagebrush Artemisia tridentata ssp. vaseyana 

Nebraska sedge Carex nebraskensis 

Needle-and-thread grass Stipa comata 

Nevada bluegrass Poa nevadensis 

Northwest cinquefoil Potentilla gracilis 

Orchardgrass Dactylis glomerata 

Paiute suncup Camissonia scapoidea 

Perennial pepperweed Lepidium latifolium 

Phlox Phlox spp.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

N-8 Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP 

Common Name Scientific Name 

Pinyon Pinus spp.

Poison hemlock Conium maculatum 

Pondweed Potamogenton 

Povertyweed Iva axillaris 

Puncture vine Tribulus terrestris 

Quackgrass Agropyron repens 

Rabbitbrush Chrysothamnus spp.

Red top Agrostis gigantea 

Redosier dogwood Cornus sericea L. 

Reed canarygrass Phalaris arundinacea L. 

Russian knapweed Acroptilon repens 

Russian olive Elaeagnus angustifolia L. 

Russian thistle Salsola kali L. 

Sago pondweed Stuckenia pectinata 

Salt cedar Tamarix ramosissima 

Saltlover Halogeton glomeratus 

Sandberg’s bluegrass Poa secunda 

Saskatoon serviceberry Amelanchier alnifolia 

Scotch thistle Onopordum acanthium 

Scouler’s willow Salix scouleriana 

Sedge Scirpus 

Seepweed (wada) Sueda depressa 

Sharpleaf penstemon Penstemon acuminatus 

Shortspine horsebrush Tetradymia spinosa 

Shrubby cinquefoil Dasiphora fruticosa 

Silver buffaloberry Shepherdia argentea 

Silver sagebrush Artemisia cana 

Slender cinquefoil Potentilla gracilis 

Slender-beaked sedge Carex athrostachya 

Small pondweed Potamogeton pusillus 

Smooth brome Bromus inermis 

Spike bentgrass Agrostis exarata 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP N-9 

Common Name Scientific Name 

Three-tip sagebrush Artemisia tripartita 

Thurber’s needlegrass Achnatherum thurberianum 

Timothy grass Phleum pratense 

Tufted evening primrose Oenothera caespitosa 

Tufted hairgrass Deschampsia caespitosa 

Water birch Betula occidentalis 

Water milfoil Myriophyllum spp.

Water sedge Carex aquatilis 

Waterweed Elodea canadensis 

Western horsetail Equisetum arvense 

Western juniper Juniperus occidentalis 

Western needlegrass Achnatherum occidentale ssp.

Western yarrow Achillea millefolium 

Wheat sedge Carex atherodes 

White water buttercup Ranunculus aquatilis 

White water crowfoot Ranunculus aquatilis 

Whitetop Cardaria spp.

Widgeongrass Ruppia 

Willow Salix spp.

Wood’s rose Rosa woodsii 

Wooly sedge Carex pellita 

Wyoming big sagebrush Artemisia tridentata Nutt. ssp. wyomingensis 

Yellow monkey-flower Mimulus guttatus 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

N-10 Appendix N. List of Common and Scientific Names Used in the Malheur Refuge CCP 

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Cinnamon teal

©Peter Baer

Appendix O

Advancing Sustainability-Based 

Approaches and Practices

Appendix O

Sustainability

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix P

Hunting Plan

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix L

Ecology Work Group

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix O. Advancing Sustainability-based Approaches and Practices O-1 

Appendix O. Advancing Sustainability-Based Approaches and Practices 

O.1 Sustainability Philosophy 

From local to global and back again, our National Wildlife Refuges are a sanctuary of the past, a 

bridge to the future, and a natural laboratory with real consequences in which we test our ability to 

navigate successfully between the past and the future for the sake of our own and all other species. 

Refuge policy and practice are directly and indirectly responsible for being part of the solution and/or 

part of the problem. For example, what makes us think that the majesty of the Refuge is sustainable 

in the face of uncontrolled carp populations, or that polar bears are sustainable in the face of an icefree Arctic Ocean? 

The word “sustainability” has come into common use only in the past 25 years, most formally in 

1987 when the Brundtland Commission defined sustainable development as “... meeting the needs of 

the present without compromising the ability of future generations to meet their own needs.” 

This widely published definition says much about the ethics and responsibility of one generation to 

the next. Sustainability is how we commonly think in terms of leaving the nation and world a better 

place for our children and grandchildren, whether in regard to family, land, and finances, or in terms 

of public lands and resources. 

As such, it is a reinforcement of traditional American values of protection of our natural and cultural 

resources, self-sufficiency, self-determination, ingenuity, and responsibility in balance with life, 

liberty, and the pursuit of happiness. 

At the core of our deliberations must be how sustainability-based planning, design, and management 

practices are absolutely essential to biodiversity and to native species, the viability of their 

populations, and the habitats that must be conserved, protected, restored, and expanded if we are to 

live up to the traditional American values that preserved them in the first place. 

Sustainability-based planning, design, and management are also essential for, if not synonymous 

with, the local communities and native tribes and cultures that were indigenous to these lands for 

thousands of years before European settlement. All of these are major partners in Refuge 

sustainability initiatives. 

The planning, design, and management practices of the past have served us well. However, the best 

available science now indicates that there are fundamentally different questions that we need to 

address in regards to emerging issues, many of which have profound implications. 

Besides water, the most clear and present danger to the future of America’s natural heritage, if not 

our entire national security, is fossil fuel energy dependence (especially oil and coal) and climate 

change. If ever there was a role for America’s public lands to play in meeting both the natural and 

cultural heritage priorities of the past and present, it is now. 

There are numerous policy statements and initiatives that call for integrating sustainability-based 

principles and practices within the CCP. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

O-2 Appendix O. Advancing Sustainability-based Approaches and Practices 

 Malheur Refuge is one of seventeen U.S. Fish and Wildlife Service (USFWS) facilities 

chosen to implement the U.S. Department of the Interior’s (DOI’s) Environmental 

Management System; 

 Executive Order directing Federal Leadership in Environment, Energy, and Economic 

Performance (October 5, 2009); 

 Secretary of Interior Salazar’s speech at the United Nations Conference on Climate Change 

in Copenhagen (December 10, 2009), entitled “New Energy Future: The Role of Public 

Lands in Clean Energy Production and Carbon Capture”; 

 USFWS Directorate Working Group, and Strategic Plan for Climate Change; and 

 USFWS development of Landscape Conservation Cooperatives. 

The Refuge is taking a holistic systems approach to carbon neutrality (targeting carbon negative) and 

energy and material efficiency in all facets of Refuge planning, design, operation, and management 

for meeting our mission in collaboration with our local, regional, and national stakeholders. The 

latest scientific data and analysis regarding the rapid scale and impact of foreign energy dependence, 

climate change, and associated challenges leave us little room for compromise. 

As such, in the interest of contributing to national security and economic competitiveness through 

our mission, the Refuge must do its part in producing more energy than it consumes, storing more 

carbon than it produces, rapidly adapting to the range of projected climate change models, and 

maximizing the delivery of all other ecologic services, especially biodiversity and clean water. 

The Refuge is taking the approach of the old adage that if we are not part of the solution, then we are 

part of the problem. If we are part of the problem, then we risk being irrelevant, if not disposable, in 

the eyes of the general public. Our intent is to lead. 

O.2 Sustainability Actions 

By integrating our conservation-based mission with the best available science, the Refuge will 

become a leader in advancing best design and management practices for an innovative, sustainable 

Refuge and community development opportunities. 

 Achieve carbon neutrality (striving for carbon negative), meeting and exceeding energy and 

material efficiency and effectiveness as defined by U.S. DOI policies for all facets of refuge 

management. 

 Establish performance benchmarks within our Environmental Management Plan as part of 

the Environmental Management System’s critical first step, and then create metrics and 

benchmarks for all other sustainability-based practices (environmental, social, economic, and 

community). 

 Complete energy and material use, carbon footprint, and biomass-based carbon sequestration 

audits. 

 Integrate sustainable-based approaches and practices into partnerships, contracts, and other 

external stakeholder efforts. 

 Provide staff and external stakeholder training for sustainability-based principles and 

practices, ecosystem services, social justice/equity, community development, and partnership 

performance standards. 

 Develop projects to refit and right-size facilities, infrastructure, and vehicle fleet to maximize 

energy efficiency and production. Seek funding through Refuge Operations Needs and 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix O. Advancing Sustainability-based Approaches and Practices O-3 

Deferred Maintenance databases, Federal Business Management System, and other 

opportunistic/entrepreneurial funding sources. 

O.3 Sustainability Assessments 

The Refuge has already initiated steps toward improving sustainability. These steps are primarily 

focused on sustainability assessments and planning. Sustainability assessments include conducting a 

comprehensive energy and water evaluation as well as preparing a greenhouse gas (GHG) emission 

inventory. 

The findings of a Tier 1 energy and water evaluation indicate that there are many low-cost 

opportunities to improve energy and water performance within the Refuge’s building portfolio. Many 

opportunities have payback periods of less than five years while other opportunities require larger 

capital investment and have 5- to 20-year payback periods.1

 Malheur NWR has initiated efforts to 

implement the energy and water conservation measures recommended by the Tier 1 energy and water 

evaluation. 

The findings of a fiscal year (FY) 2008 baseline GHG emission inventory indicate that the Refuge’s 

scope 1 and scope 2 GHG emissions stem primarily from building energy consumption and fleet fuel 

consumption.2

 Scope 1 and scope 2 GHG emissions totaled 310 metric tons of carbon dioxide 

equivalent (MTCO2E). 

In accordance with Executive Order 13514, Federal Leadership in Environmental, Energy, and 

Economic Performance, the Refuge also estimated GHG emissions for six scope 3 emission sources, 

including employee commuting, contracted solid waste (landfilled waste), business air travel, 

business ground travel, transmission and distribution losses (electricity transmission), and contracted 

wastewater treatment (not applicable). GHG emissions from scope 3 emission sources totaled 158 

MTCO2E. Scope 1, scope 2, and scope 3 emission sources totaled 468 MTCO2E (Figure O-1). 

 

1

 U.S. Fish and Wildlife Service, 2010. 

2

 Scope 1 and 2 GHG emissions are primarily associated with on-site fossil fuel combustion and electricity 

consumption from the grid, respectively. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

O-4 Appendix O. Advancing Sustainability-based Approaches and Practices 

Figure O-1. Malheur NWR FY 2008 Greenhouse Gas Emission Inventory Results by Source 

Fleet fuel combustion was the single largest emission source. Malheur NWR is a large refuge that 

requires considerable staff travel to conduct routine management activities such as trail maintenance, 

patrols, and resource management. An analysis of 25 gasoline fleet vehicles driven from April 2011 

to September 2011 (6 months) indicated that on average each vehicle drives about 4,350 miles and 

consumes about 275 gallons of fuel—for an average fleet fuel economy of 15.8 miles per gallon 

(MPG), which is lower than the national average fuel economy for light-duty trucks (24.8 MPG) and 

passenger cars (32.9 MPG).3

 Fifteen of the gasoline vehicles had a fuel economy that fell below the 

refuge average while ten had a fuel economy that was above the refuge average. The most fuelefficient vehicle was a 2008 Ford Escape Hybrid, which was also one of the top three most driven 

vehicles. The vehicle that was driven the most during this period was a 2010 Ford F250 (11,416 

miles) (Figure O-2). 

 

3

 Bureau of Transportation Statistics, 2012 

MTCO2E

Scope 1 194 

Building Fuel Combustion 30 

Fleet Fuel Combustion 161 

Wastewater 3 

Scope 2 115 

Building Electricity 115 

Scope 3 158 

Employee Commuting 144 

Business Travel 1 

Electricity Transmission 8 

Landfilled Waste 6 

Total 468 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix O. Advancing Sustainability-based Approaches and Practices O-5 

Figure O-2. Gasoline Fleet Vehicle Fuel Economy and Miles Driven by Vehicle (Apr 2011 

through Sept 2011) 

The GHG emission inventory also assessed the GHG emission footprint of visitor vehicle travel to 

and within the Refuge. These estimates were prepared using data provided by the National Wildlife 

Refuge Visitor Survey (2010/2011): Individual Refuge Results for Malheur National Wildlife Refuge 

(Appendix Q). GHG emissions from visitor travel to the Refuge were approximated to be 9,500 

MTCO2E, annually, while emissions from visitor travel within the Refuge were approximated to be 

630 MTCO2E, annually. 

All GHG emission estimates were prepared using the draft Climate Leadership in Refuges (CLIR) 

Tool, which is a GHG management tool developed by the Fish and Wildlife Service in partnership 

with the Federal Lands Highway Program as part of the Climate Friendly Refuges (CFR) pilot 

initiative. 

O.4 Sustainability Planning 

The Refuge recognizes that to move toward a more sustainable future, sustainability-based practices 

must be integrated into the Refuge culture. Sustainability-based practices will address, and seek to 

improve performance within, the four aspects of sustainability identified by the Refuge—

environmental, social, economic, and community. Our approach to improving environmental, social, 

economic, and community performance will rest on five management areas—Purpose, Performance, 

Resources, People, and Leadership (Figure O-3). These management areas are introduced below: 

 Purpose refers to the drivers of the Refuge’s sustainability commitment. These drivers will 

establish a vision for instituting a culture of sustainability. 

 Performance refers to the Refuge’s efforts to demonstrate, implement, and measure the 

Refuge’s sustainability progress. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

O-6 Appendix O. Advancing Sustainability-based Approaches and Practices 

 Resources refers to the materials and information that will be needed to support the Refuge’s 

sustainability commitment. 

 People refers to the organizational capacity that is needed to support the Refuge’s 

sustainability commitment. 

 Leadership refers to the Refuge’s efforts to demonstrate leadership through the sustainability 

commitment. 

Figure O-3. Sustainability Management Areas and Aspects 

We have begun to identify sustainability practices within each of the management areas to further 

integrate sustainability into the Refuge culture, as described below: 

Purpose: The Refuge will clearly define the drivers of the Refuge’s sustainability commitment. 

Drivers include the USFWS mission, to “work with others to conserve, protect and enhance fish, 

wildlife, and plants and their habitats for the continuing benefit of the American people”, federal 

mandates, a commitment to improving refuge operational efficiency, and Malheur NWR’s enabling 

legislation. 

Performance: The Refuge will implement processes that allow the Refuge to implement, measure, 

and demonstrate sustainability performance. The primary implementation mechanism will be the 

Refuge’s Environmental Management System—Malheur NWR is one of seventeen refuges that are 

required to use an Environmental Management System to improve environmental performance. The 

Refuge will use sustainability indicators to measure performance. Sustainability indicators identified 

include building energy intensity (energy consumption per gross square foot of building space); 

scope 1, scope 2, and scope 3 GHG emissions; fleet fuel consumption; and solid waste diversion.4

The Refuge will demonstrate performance by tracking progress with respect to the sustainability 

indicators over time. 

 

4

 Solid waste diversion is the percent of total solid waste generated that is diverted from a landfill through recycling, 

composting, and other means. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix O. Advancing Sustainability-based Approaches and Practices O-7 

Resources: The Refuge will stay informed of resources (e.g., materials and information) that will 

assist the Refuge in improving sustainability performance. The Refuge will work with Region 1 staff 

to identify resource needs, such as information on best available technologies; expert consultations 

for fleet optimization, partnership development, renewable energy assessments, visitor engagement, 

and building commissioning; grant exposure and writing support; and case studies and lessons 

learned from other FWS sustainability activities. 

People: Malheur NWR’s staff consists of approximately 16 full-time employees as well as seasonal 

employees and volunteers. Refuge staff recognize the importance of integrating sustainability into the 

Refuge’s operations and have committed to identifying and implementing personal sustainability 

projects (PSPs). Examples of Malheur NWR staff PSPs include: 

 Prepare monthly energy consumption reports by building to help staff evaluate and monitor 

monthly energy consumption. 

 Coordinate travel across program areas to combine trips and combine tasks across program 

areas to reduce trips. 

 Monitor buildings for efficient use of lighting. 

 Review manufacturer specifications for vehicles and equipment to make sure they are being 

maintained and operated efficiently. Post instructions for proper use on dashboard and ensure 

a proper maintenance schedule. 

 Conduct or obtain a site evaluation of headquarters to look for opportunities to replace 

inefficient boiler system and use renewable energy. 

 Review fleet fuel consumption to look for optimization opportunities. 

Leadership: The Refuge will look for opportunities to engage with partners, the public, private 

landowners, sister agencies, and other individuals and organizations to collaborate on sustainability 

programs and practices. The Refuge will share best management practices, success stories, and 

lessons learned from implementing sustainability practices with interested parties using existing 

outreach mechanisms and media such as the Refuge website, local newspaper, school visits, and 

Friends Newsletter to highlight sustainability practices at Malheur NWR. 

We will use this management approach as a framework for further incorporating sustainability into 

Refuge culture while emphasizing continual improvement and striving to meet Objective 14a, 

Achieve Carbon Neutrality (striving for carbon negative), meeting and exceeding all energy and 

material efficiency and effectiveness as defined by 565 FW 1 and Executive Order 13514 for all 

facets of refuge management and operations. 

O.5 References 

Brundtland Commission. 1987. Our common future: Brundtland report. Available at: 

http://www.worldinbalance.net/intagreements/1987-brundtland.php. 

Bureau of Transportation Statistics. 2012. Average Fuel Efficiency of U.S. Light Duty Vehicles. 

Available online at: 

http://www.bts.gov/publications/national_transportation_statistics/html/table_04_23.html.

U.S. Fish and Wildlife Service. 2010. Comprehensive Energy and Water Evaluation for the Malheur 

National Wildlife Refuge. Conducted by Tetra Tech Engineering and Architecture Services. 

On file, Malheur Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

O-8 Appendix O. Advancing Sustainability-based Approaches and Practices 

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Ring-necked pheasant

©Dan Dzurisin

Appendix P

Hunting Plan

Appendix O

Sustainability

Appendix P

Hunting Plan

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix L

Ecology Work Group

Appendix P. Hunting Plan 

Hunting Plan 

for 

Malheur National Wildlife Refuge 

UNITED STATES FISH AND WILDLIFE SERVICE 

2012 
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Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-2 

P.1 Overview 

Malheur National Wildlife Refuge was created in 1908 primarily as a preserve and breeding ground 

for native birds at Malheur, Mud, and Harney lakes. In 1935, the Blitzen Valley was established as a 

refuge and breeding ground for migratory birds and other wildlife, and the Double-O Unit was 

established as a reservation for migratory birds in 1941. Map 1 in the Comprehensive Conservation 

Plan (CCP), shows the location of Malheur Refuge. 

The hunt programs addressed in this plan incorporate the hunt features (spatial layout, timing, types 

of hunts, etc.) as designed in the management direction of the CCP. Under the CCP, hunting will 

occur only in the Malheur Lake and Buena Vista hunt units. 

This hunt plan has been prepared as a step-down plan to the CCP. Further descriptions of Refuge 

history, programs, and habitats can be found in Chapters 1, 4, and 5 of the CCP. A detailed analysis 

of the effects of the hunt program is found in the compatibility determinations for upland game and 

waterfowl hunting. Pertinent conclusions of these analyses are presented below in Section P.6 

(Assessment). 

P.1.1 Species Covered by this Plan 

The species listed below have populations sufficient to allow for recreational harvest. No commercial 

harvesting of wildlife or use of hunting guides will be allowed, to ensure continued healthy 

populations and general public opportunity. 

Species That Can be Hunted on Buena Vista Hunt Unit 

 Dove, geese, duck, coot, snipe, pigeon, pheasant (rooster), California quail, and partridge 

(chukar and Hungarian partridge). 

Species That Can be Hunted on Malheur Lake Hunt Unit 

 Dove, geese, duck, coot, snipe, pigeon, pheasant (rooster), California quail, and partridge 

(chukar and Hungarian partridge). 

Species That Can be Hunted on Boundary Hunt Unit 

 Dove, geese, duck, coot, snipe, pigeon, pheasant, California quail, partridge, deer, pronghorn, 

coyote, black-tailed jackrabbit, and Nuttall’s cottontail. 

P.1.2 Game Species not Hunted 

Due to conflicts with Refuge purposes and other forms of wildlife-dependent recreation, hunting of 

any other species is not allowed on the Refuge. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-3 Appendix P. Hunting Plan 

P.2 Conformance with Statutory Authority 

P.2.1 Conformance with Statutory Objectives 

Any use of a national wildlife refuge must be compatible with resource protection and conform to 

applicable laws, regulations, and Fish and Wildlife Service (FWS) policies. Recreational use, in this 

case hunting, is allowed under the Refuge Recreation Act of 1962 (16 U.S.C. 460K, amended), 

which authorizes the Secretary of the Interior to administer refuges, hatcheries, and other 

conservation areas for recreational use. The Refuge Recreation Act requires: 1) that any recreational 

use permitted will not interfere with the primary purpose for which the refuge was established; and 2) 

that funds are available for the development, operation, and maintenance of the permitted forms of 

recreation. 

Likewise, statutory authority for FWS management and associated habitat/wildlife management 

planning on units of the National Wildlife Refuge System is derived from the National Wildlife 

Refuge System Administration Act of 1966, as amended by the National Wildlife Refuge System 

Improvement Act of 1997 (16 U.S.C. 668dd-668ee). The National Wildlife Refuge System 

Improvement Act provided a mission for the Refuge System and clear standards for its management, 

use, planning, and growth. The National Wildlife Refuge System Improvement Act recognizes that 

wildlife-dependent recreational uses—including hunting, fishing, wildlife observation and 

photography, environmental education, and interpretation—when determined to be compatible with 

the mission of the Refuge System and the purposes of the refuge are legitimate and appropriate 

public uses of national wildlife refuges. Sections 5(c) and (d) of the National Wildlife Refuge System 

Improvement Act state “compatible wildlife-dependent recreational uses are the priority general 

public uses of the National Wildlife Refuge System and shall receive priority consideration in 

planning and management; and when the Secretary [of the Interior] determines that a proposed 

wildlife-dependent recreational use is a compatible use within a refuge, that activity should be 

facilitated, subject to such restrictions or regulations as may be necessary, reasonable, and 

appropriate.” 

P.2.2 Conformance with Refuge Purposes 

Conformance of refuge uses with refuge purposes is determined through a formal compatibility 

determination process. Compatibility means that the use would not materially interfere with or 

detract from the fulfillment of the purposes of the refuge(s) or mission of the National Wildlife 

Refuge System (603 FW 2). 

Both the upland game and waterfowl hunts, as described below in Section P.4, were determined to be 

compatible with Malheur Refuge purposes, with stipulations. See the compatibility determinations in 

Appendix B for more detail. 

P.3 Statement of Goals and Objectives 

P.3.1 Refuge Goals 

Thirteen goals were developed for Malheur Refuge during the CCP process. They are: 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-4 

1. Enhance aquatic health and habitat conditions essential to the conservation of the flora 

and fauna that depend on Malheur Lake and associated water bodies. 

2. Protect, maintain, and rehabilitate riverine and riparian habitats to conditions essential 

for the conservation of native fish and wildlife species. 

3. Protect, maintain, and rehabilitate riparian habitats to conditions essential for the 

conservation of wildlife species. 

4. Enhance, protect, and/or maintain primary habitats essential to the conservation of a 

diversity of aquatic and terrestrial wildlife species. 

5. Enhance and maintain rare and unique habitats. 

6. Welcome visitors and help them safely experience the Refuge’s outstanding features—

diversity of wildlife, signs of earlier inhabitants, scenic landscapes, and solitude. As a 

result, visitors will leave the Refuge with a memorable experience that fosters a 

connection between themselves and nature, and an appreciation of Malheur Refuge’s 

unique resources. 

7. Connect the hearts and minds of visitors with places and resources the Refuge protects, 

and enlighten visitors’ experiences with an understanding, appreciation, and knowledge 

of historical and natural resources, and the importance of conservation and stewardship. 

8. Provide reasonable challenges and opportunities, and provide uncrowded conditions for 

the hunting and fishing public. 

9. Initiate and nurture relationships to build support of the Refuge, and fortify Refuge 

programs and activities to achieve the Refuge’s mission and goals. 

10. Manage prehistoric and historic cultural resources for their educational, scientific, and 

cultural values for the benefit of present and future generations of Refuge users and for 

the communities that are connected to these resources. 

11. Identify and protect prehistoric and historic resources on the Refuge that are eligible for 

or listed in the National Register of Historic Places. 

12. Manage the Refuge’s paleontological resources for their educational and scientific 

values for the benefit of present and future generations of Refuge users. 

13. Gather scientific information (surveys, research, and assessments) to support adaptive 

management decisions. 

P.3.2 Refuge Objectives for Hunting 

Goal 8 pertains directly to the provision of wildlife-dependent recreational opportunities on the 

Refuge. Two Refuge hunt program objectives were developed as part of the CCP development 

process and are repeated below. The objective numeric identifier (e.g., 8a, 8b) is consistent with the 

objective numbering system in the CCP. A more complete program description is found in Section 

P.4 of this hunt plan. 

Objective 8a. Provide Hunting Opportunities for Upland Game 

Provide high-quality hunting opportunities for upland game hunting in the Malheur Lake, Buena Vista, 

and Boundary hunt units, for the species, seasons, and other details described in the Hunt Plan. The 

program shall be managed such that: 

 Youth are provided added emphasis; 

 Conditions are uncrowed, with abundant opportunities for solitude on over 58,000 allowable 

hunting acres; 

 The hunt is safe and managed to minimize conflicts with wildlife and other priority wildlife-
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-5 Appendix P. Hunting Plan 

Objective 8a. Provide Hunting Opportunities for Upland Game 

dependent recreational uses; 

 Access is provided on suitable all-weather access roads; 

 Game are wild or naturalized (not stocked); 

 Most hunters reach their quota each day; 

 Refuge staff engages in close cooperation and coordination with State fish and wildlife 

management agencies for management of hunting opportunities on the Refuge and in setting 

population management goals and objectives; and 

 The hunt is consistent with State fish and wildlife laws, regulations, and management plans. 

Objective 8b: Provide Hunting Opportunities for Waterfowl 

Provide high-quality opportunities for waterfowl hunting in the Malheur Lake, Buena Vista, and 

Boundary hunt units for the species, seasons, and other details described in the Hunt Plan. The program 

shall be managed such that: 

 Youth are provided added emphasis; 

 Conditions are uncrowded, with abundant opportunities for solitude on over 63,000 allowable 

hunting acres; 

 The hunt is safe and managed to minimize conflicts with wildlife and other priority wildlifedependent recreational uses; 

 Access is provided on suitable all-weather roads; 

 Hunters can enjoy a range of waterfowl hunting experiences, from traditional setup with decoys 

and dogs to jump-shooting; 

 Parking areas are adequate, with parking at three existing locations and one new parking area and 

boat launch at the airboat launch site to access a new hunt opportunity on the southern side of 

Malheur Lake; 

 Most hunters reach their quota each day; 

 Refuge staff engages in close cooperation and coordination with State fish and wildlife 

management agencies for management of hunting opportunities on the Refuge and in setting 

population management goals and objectives; 

 Hunt is consistent with State fish and wildlife laws, regulations, and management plans. 

P.4 Description of Hunting Program 

The areas open to upland game and waterfowl hunting on the Refuge are shown in Map 3a. 

P.4.1 Upland Game Hunting: Proposed Program 

Tables P-1, P-2, and P-3 describe the proposed upland game hunt in the Malheur Lake, Buena Vista, 

and Boundary hunt units. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-6 

Table P-1. Northern Portion of Malheur Lake Hunt Unit 

Aspect Description 

Location A total of 22,500 acres (14% of the Refuge) would be open to upland 

game hunting on the northern portion of Malheur Lake (See Map 3b) 

Allowable species Pheasant, quail, chukar and partridge 

Season State pheasant season 

Bag Limits State upland game limits 

Fees None 

Permits None 

Other hunt regulations Per State regulations 

 Table P-2. Buena Vista Hunt 

Aspect Description 

Location A total of 36,000 acres (19% of the Refuge) would be open to upland 

game hunting (See Map 3b) 

Allowable species Pheasant, quail, chukar and partridge 

Season Fourth Saturday of October to the end of the State pheasant season 

Limits State upland game limits 

Fees None 

Permits None 

Other hunt regulations Per State regulations 

Table P-3. Boundary Hunt Unit 

Aspect Description 

Location A total of 2,626 acres (1.4% of the Refuge) would be open to upland 

game hunting (See Map 3b) 

Allowable species Pheasant, quail, chukar, partridge, deer, pronghorn, coyote, black-tailed 

jackrabbit, and Nuttall’s cottontail 

Season State seasons 

Limits State upland game limits 

Fees None 

Permits None 

Other hunt regulations Per State regulations 

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-7 Appendix P. Hunting Plan 

Stipulations Necessary to Ensure Compatibility

 Only federally approved nontoxic shot may be used or be in possession while hunting on the 

Refuge. 

 Vehicles would be allowed only on maintained public roadways. Parking is allowed only 

within one vehicle length of the roadway. Hunters would be instructed to not block dike and 

field accesses. 

 Overnight parking, camping, and campfires would not be permitted on the Refuge. 

 Hunting dogs are strongly encouraged to increase hunter success and retrieval rate. Dogs 

must be kept under close control. 

 Hunting closures would be in effect near Refuge Headquarters, Buena Vista Station, and the 

Malheur Field Station. Shooting from or across public roads or road rights-of-way would be 

prohibited. 

 Law enforcement patrols would ensure safety and minimize conflicts with other priority 

public uses by providing information about hunting boundaries and seasons to the general 

public and those using other Refuge programs. Information would be provided at interpretive 

kiosks, on the Refuge website, and in Refuge offices. 

P.4.2 Waterfowl Hunting: Proposed Program 

Tables P-4, P-5, and P-6 describe the proposed waterfowl hunting program on the Malheur Lake and 

Buena Vista hunt units, and Table P-7 describes the proposed youth hunt on the Malheur Lake Hunt 

Unit. 

Table P-4. Northern Portion of Malheur Lake Hunt Unit

Aspect Description 

Location A total of 26,200 acres (14% of the Refuge) would be open to 

waterfowl hunting on the northern portion of Malheur Lake (See Map 

4a) 

Allowable species Doves, geese, ducks, coots, snipe, and pigeons 

Season State waterfowl season 

Limits State waterfowl limits 

Boats Nonmotorized or electric boats will be permitted 

Blinds Temporary blinds may be erected on a day-to-day basis 

Fees None 

Permits None 

Other hunt regulations Per State regulations; at low water (<10,000 acres), Malheur Lake Hunt 

Unit will be closed to waterfowl hunting 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-8 

 Table P-5. Southern Portion of Malheur Lake Hunt Unit 

Aspect Description 

Location A total of 4,600 acres (2% of the Refuge) would be open to waterfowl 

hunting on the southern portion of Malheur Lake (see Map 3b) 

Allowable species Doves, geese, ducks, coots, snipe, and pigeons 

Season Fourth Saturday of October to the end of the State waterfowl season 

Limits State waterfowl limits 

Boats Nonmotorized or electric boats will be permitted 

Blinds Temporary blinds may be erected on a day-to-day basis 

Fees None 

Permits None 

Other hunt regulations Per State regulations; at low water (<10,000 acres), Malheur Lake Hunt 

Unit will be closed to waterfowl hunting 

Table P-6. Buena Vista Hunt Unit 

Aspect Description 

Location A total of 36,000 acres (19% of the Refuge) would be open to waterfowl 

hunting (see Map 3b) 

Allowable species Doves, geese, ducks, coots, snipe, and pigeons 

Season Fourth Saturday of October to the end of the State waterfowl season 

Bag Limits State waterfowl limits 

Boats Not permitted 

Blinds Not permitted 

Fees None 

Permits None 

Other hunt regulations Per State regulations 

Table P-7. Malheur Lake Youth Hunt 

Aspect Description 

Location A total of 26,200 acres (14% of the Refuge) would be open to waterfowl 

hunting on the northern portion of Malheur Lake (see Map 4a) 

Allowable species Doves, geese, ducks, coots, snipe, and pigeons 

Season State-designated weekend 

Bag Limits State waterfowl limits 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-9 Appendix P. Hunting Plan 

Aspect Description 

Boats Nonmotorized or electric boats will be permitted 

Blinds Temporary blinds may be erected on a day-to-day basis 

Fees None 

Permits None 

Other hunt regulations Per State regulations; at low water (<10,000 acres), Malheur Lake Hunt 

Unit will be closed to waterfowl hunting 

  

Stipulations Necessary to Ensure Compatibility

 Only federally approved nontoxic shot may be used or be in possession while hunting on the 

Refuge. 

 Vehicles would be allowed only on maintained public roadways. Parking would be allowed 

only within one vehicle length of the roadway. Hunters would be instructed to not block dike 

and field accesses. 

 Overnight parking, camping, and campfires would not be permitted on the Refuge. 

 Access would be by walk-in only. Electric motorized boating or nonmotorized boating would 

be permitted on Malheur Lake during the waterfowl hunt season. 

 Hunting dogs are strongly encouraged to increase hunter success and retrieval rate. Dogs 

must be kept under close control. 

 Seasonal hunting closures may occur to protect waterfowl populations when the Malheur 

Lake water level drops below 10,000 acres. 

 Hunting closures would be in effect near Refuge Headquarters, Buena Vista Station, and the 

Malheur Field Station. The new Caspian tern island in the South Malheur Lake Unit will be 

permanently closed to hunting. Shooting from or across public roads or road rights-of-way is 

prohibited. 

 Law enforcement patrols would ensure safety and minimize conflicts with other priority 

public uses by providing information about hunting boundaries and seasons to the general 

public and those using other Refuge programs. Information would be provided at interpretive 

kiosks, on the Refuge website, and in Refuge offices. 

P.4.3 Procedures for Consultation and Coordination with Oregon Department 

of Fish and Wildlife 

FWS staff will coordinate with Oregon Department of Fish and Wildlife (ODFW) staff regarding 

annual hunt season dates, areas open to hunting, etc. ODFW will publish information on the Refuge 

upland game and waterfowl hunts annually in State hunting regulations. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-10 

P.5 Measures Taken to Avoid Conflicts with Other Management 

Objectives 

P.5.1 Measures to Avoid Biological Conflicts 

The hunts have been designed to minimize biological conflicts through a variety of measures. A large 

portion of the Refuge, including the southern part of the Blitzen Valley, Harney Lake, and the 

Double-O Unit, will remain closed to hunting and will provide undisturbed habitat for migrating 

birds. In addition, at low water (<10,000 acres), Malheur Lake will be closed. The new Caspian tern 

island in the South Malheur Lake Unit will be permanently closed to hunting. Vehicles will be 

limited to roads. Boats will be restricted to Malheur Lake, and only electric or nonmotorized boats 

will be permitted. The opening date for both the waterfowl and upland game hunts for the Buena 

Vista Hunt Unit and the southern portion of Malheur Lake Hunt Unit is set as the last Saturday in 

October, which will prevent disturbance to staging sandhill cranes, who use these areas in early fall. 

Only federally approved nontoxic shot will be permitted to be in hunters’ possession while on the 

Refuge. 

Outreach with hunting brochures and timely information on the website would help educate hunters 

on hunting opportunities, regulations, and ethical hunter behavior. Youth hunters will also be 

required to complete a hunter education course. 

P.5.2 Measures to Avoid Public Use Conflicts 

Various aspects of the proposed hunt programs, including temporal restriction and spatial 

restrictions, combined with the seasonal nature of other wildlife-dependent recreation activities on 

the Refuge, will reduce the potential for conflict. Generally, late fall and winter use on the Refuge is 

only a fraction of the use during the spring and fall seasons. 

Hunting regulations would be established to provide a no-hunt buffer zone around the airboat launch 

site and observation tower. Persons not engaged in hunting would not be permitted to access the 

Malheur Lake Hunt Unit or the Buena Vista Hunt Unit, except where public roads border or traverse 

these units. State regulations also prohibit shooting from on and across roads, which would limit 

conflicts. Fishing along the Blitzen River from Sodhouse Lane to the Boat Landing Road would 

conclude prior to the hunting season opener. 

Other measures taken to avoid or reduce potential conflicts with other Refuge visitors include law 

enforcement patrols, posting hunt signs to maintain public awareness during the hunting seasons, and 

providing descriptive brochures explaining hunting opportunities. Regulations will be printed and 

dispensed at Refuge Headquarters and brochure boxes at Refuge parking lots, entrances to the hunt 

units, or online at the Refuge website. 

Conflicts between hunters themselves will be minimized by providing the staggered season openers 

described above. In addition, the relatively large hunt area compared to the expected number of 

hunters will minimize crowding and safety conflicts. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-11 Appendix P. Hunting Plan 

P.5.3 Measures to Avoid Administrative Conflicts 

Hunt closures will be in effect around Refuge Headquarters, Buena Vista Station, and the Malheur 

Field Station. The hunt program has the potential to conflict with some of the normal management, 

maintenance and biological monitoring activities that might be occurring in the same vicinity as the 

hunt program. Safety briefings for Refuge staff working in hunt areas will occur. Hunters will be 

warned of Refuge activities that might be occurring in the hunt units. These measures will ensure the 

safety of Refuge staff and Service-authorized agents and will allow for the completion of Refuge 

management activities as well as other Refuge uses. The project leader will retain the discretion to 

close areas to hunting when necessary for the protection of Refuge staff and authorized agents who 

are conducting Refuge management activities or for the safety of hunters who could be at risk from 

Refuge management activities (e.g., prescribed fire). Overall, there will be minimal administrative 

conflicts expected. 

P.6 Assessment 

P.6.1 Compatibility with Refuge Objectives 

Hunting is one of the six wildlife-dependent recreational uses included in the National Wildlife 

Refuge System Improvement Act of 1997. Conducting well-managed hunts on the Refuge will assist 

the Refuge in meeting one of the Refuge System’s primary goals (namely, providing the public 

opportunities to participate in compatible wildlife-dependent recreational programs). The Statedesignated youth waterfowl hunt also provides a unique opportunity for the Refuge to introduce 

young hunters to the Refuge System and educate them on the importance of wildlife conservation. 

Compatibility with other Refuge programs is addressed below. 

P.6.2 Biological and Other Considerations 

Upland Game 

Potential effects of upland game hunting to target populations, non-target species, listed species, 

Refuge habitats, and other public use programs are summarized below. Section P.5 examines 

measures to avoid conflicts with these resources. Also see the compatibility determination for upland 

game hunting (Appendix B in the CCP) for a detailed effects analysis. 

Effects Analysis Summary Conclusion 

Effects to target 

populations 

The estimated harvest for upland game birds would not likely increase from 

the current levels because the program would not markedly expand. The earlier 

season opening would provide additional hunting opportunities during the 

season and may increase hunters’ success rate, but the harvest is small overall; 

the estimated Refuge harvest of <600 gamebirds would only be likely to be 

<5% of the entire harvest in Harney and Malheur counties. 

Given the wide range of upland gamebirds and an average of 49,000 acres 

available to hunt, it is expected that the overall upland game hunting pressure 

under would be low. Given the small amount of the estimated take and the 

distribution of the hunt units, the hunt program as designed is not expected to 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-12 

Effects Analysis Summary Conclusion 

adversely affect the Refuge’s ability to sustain optimum population levels for 

maintaining populations of upland gamebirds. 

Although Refuge-specific population and past harvest data are unavailable for 

coyote and rabbits, neither of these hunts on the Boundary Unit is expected to 

negatively affect populations of the target species. 

Refuge-specific harvest data are also unavailable for deer and pronghorn. 

Pronghorn have showed a gradual increase in populations statewide, while 

mule deer are on a prolonged decline. However, given the low level of harvest 

that is expected to occur on these species on the available Refuge hunt area, 

hunting is not expected to significantly impact target populations. 

Effects to non-target 

species 

Potential minor disturbance to other foraging or resting birds would occur from 

dogs, human activity, and noise associated with hunting. Sandhill cranes stage 

on the southern portion of Malheur Lake and in the Buena Vista wetlands until 

mid-October. A late season opener for the southern portion of Malheur Lake 

and the Buena Vista Unit would allow sufficient protection of the sandhill 

cranes until they migrate farther south. Since most birds have migrated during 

the fall season, disturbance level would be minor overall. Disturbance to other 

taxa would be unlikely or negligible. 

Effects to Refuge 

habitats, vegetation, 

soil, and water 

No facilities would be added to support this use; therefore, there is no 

additional amount of habitat that will be lost due to facilities. Foot travel 

associated with upland game hunting could result in temporary and minor 

vegetation trampling. No impact is expected to soil or water resources as a 

result of this use.

Effects to listed species Due to the slight increase in upland game hunting opportunities, access, and 

visitation projected, disturbance impacts to greater sage-grouse would be 

expected to increase, although sage-grouse is not a huntable species on the 

Refuge and does not readily occur within Refuge boundaries. If off-trail use 

results in unacceptable adverse effects to candidate species or habitats, the 

Refuges would limit use to the trails. ODFW continues to closely track sagegrouse populations to ensure the numbers stay and increase to a sustainable 

level.

Effects to other priority 

public uses 

Use of the Refuge by non-hunting visitors is very light during hunting season, 

and this is expected to mitigate any conflict between hunting and other uses in 

the Buena Vista Unit. Hunt closures will be in effect around high-use areas 

such as the Headquarters and airboat launch/viewing tower. 

Waterfowl/Migratory Birds 

Potential effects of waterfowl hunting to target populations, non-target species, listed species, Refuge 

habitats, and other public use programs are summarized below. Section P.5 examines measures to 

avoid conflicts with these resources. Also see the compatibility determination for waterfowl hunting 

(Appendix B in the CCP) for more detail. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-13 Appendix P. Hunting Plan 

Effects Summary Conclusion 

Effects to target 

populations 

Near-term, the number of birds harvested would be expected to increase 

slightly but would still likely be <250 ducks and <200 geese annually. These 

estimated harvests represent <1% of the total midwinter population of 

wintering ducks and geese in the Regional Survey Unit (Klamath, Lake, and 

Harney counties) and an even smaller fraction of the State of Oregon and 

Pacific Flyway population. The overall impacts from the harvest estimates 

would be minor to negligible. Longer-term, as management activities work to 

control carp in Malheur Lake over the next 15 years, it would be expected that 

the number of nesting birds in this area would increase and consequently 

harvests would also increase. There are many unknowns in carp control, and an 

accurate estimate of waterfowl to be harvested under this scenario cannot be 

predicted at this time. In addition to direct mortality, hunting could result in 

redistribution of waterfowl and waterbirds at the Refuge. 

Effects to non-target 

species 

Potential minor disturbance to other foraging or resting birds would occur from 

dogs, human activity, and noise associated with hunting. Hunting seasons do 

not coincide with the nesting season; thus, reproduction will not be reduced by 

hunting. Disturbance to the foraging or resting activities of migrating or 

resident birds will increase with the new access for boats at the south end of 

Malheur Lake and the new opening of the Buena Vista Hunt Unit to waterfowl 

hunters. However, even with these changes, hunting is still expected to involve 

a small numbers of participants. On the north side of Malheur Lake, many of 

the hunters hunt the shoreline rather than using boats on Malheur Lake, thus 

limiting the area disturbed on that side. The Buena Vista Unit will remain a 

walk-in hunt, and hunters do not generally walk distances of more than a mile 

from roads to access hunting areas. Prohibiting overnight camping would also 

decrease the likelihood of hunters roaming long distances on the Refuge, 

particularly in the Buena Vista Unit. 

Disturbance to other taxa would be unlikely or negligible. Sandhill cranes 

stage on the southern portion of Malheur Lake and in the Buena Vista wetlands 

until mid-October. A late season opener for the southern portion of Malheur 

Lake and the Buena Vista Unit would allow sufficient protection of the 

sandhill cranes until they migrate. Other birds using the area may be disturbed 

from noise and human presence; however, since most birds have migrated 

during the fall, disturbance effects would be minor overall. 

Effects to Refuge 

habitats 

No facilities would be added to support this use; therefore, there is no 

additional amount of habitat that will be lost due to facilities. Foot travel 

associated with accessing Malheur Lake for waterfowl hunting could 

potentially result in temporary and minor vegetation trampling. Limiting boat 

type to electric or nonmotorized boats will prevent exhaust and emissions from 

entering Refuge waters. 

Effects to listed species Due to the increase in waterfowl hunting opportunities, access, and visitation 

projected, disturbance impacts to the candidate species greater sage-grouse and 

Columbia spotted frog would be expected to increase, but the total impacts 

related to waterfowl hunting are expected to be minor. Impacts can be reduced 

by locating public facilities away from habitats that host candidate species. 

Increasing specific public education can also assist in raising awareness and 

preventing undue impacts to the species. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix P. Hunting Plan P-14 

Effects Summary Conclusion 

Effects to other priority 

public uses 

Hunting has the potential to disturb Refuge visitors engaged in other priority 

public uses; however, given the season during which hunting occurs, the 

likelihood of conflicts is low. Hunt closures will be in effect around high-use 

areas such as the Headquarters and airboat launch/viewing tower. 

P.6.3 Funding and Staffing Requirements for the Hunt 

The proposed upland game hunt program at the Refuge would require administrative staff time from 

a biologist, visitor services manager, maintenance staff, and a law enforcement officer. The total 

annual cost to administer the hunt with the changes proposed is projected to be approximately $2,000 

per year. There are currently enough funds in Refuge operations to implement this program. 

The proposed waterfowl hunt at the Refuge would require administrative staff time from a biologist, 

visitor services manager, maintenance staff, and a law enforcement officer. With facility 

improvements, approximately $282,000 in one-time costs are projected, and the total annual cost to 

operate this program is estimated at $8,000. There are not currently enough funds in Refuge 

operations to implement this program; additional sources will be sought. 

Outreach about the new hunting programs will require minimal reprogramming of existing resources. 

P.7 Conduct of the Hunt 

Like any use of public lands, location-specific regulations allow for the safety of visitors and the 

accommodation of many uses. Hunting on the Refuge is no exception. 

P.7.1 Anticipated Public Reaction to the Hunt 

The existing hunting program is generally accepted locally and does not generate anti-hunting 

controversy. Nationally, there is a component of the population that is opposed to hunting, and some 

organizations are opposed to hunting, or at least expansion of hunting, on national wildlife refuges 

and other public lands. Thus, it is expected that some objections may be voiced to some or all of the 

hunts within this plan. 

P.7.2 Hunter Application Process 

No permits or fees are required to participate in the hunt. Areas available are open each day on a 

first-come, first-served basis. 

P.7.3 Media Selection for Publicizing the Hunt 

Newspapers and TV/radio stations throughout Oregon will be provided copies of an annual news 

release covering the hunts. Descriptive brochures explaining hunting opportunities and regulations 

will be printed and dispensed at Refuge Headquarters and brochure boxes at Refuge parking lots, 

entrances to the hunt units, or online at the Refuge website. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

P-15 Appendix P. Hunting Plan 

 P.7.4 Hunter Requirements and regulations 

1. Age: Youths must be accompanied by an adult, 21 years of age or older. 

2. All hunters must obtain a hunting or combination license and participate in the Harvest 

Information Program (HIP). Because of season dates and hunting regulations change annually, 

hunters must review all information and regulations in the Oregon’s statewide hunting booklets 

before the hunts. 
Appendix P

Hunting Plan

Appendix Q

NWR Visitor Survey

Wildlife observers

©Barbara Wheeler

Appendix Q

National Wildlife Refuge 

Visitor Survey

Appendix O

Sustainability

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix R

Improving Aquatic Health

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix L

Ecology Work Group

National Wildlife Refuge Visitor Survey 2010/2011: 

Individual Refuge Results for

Malheur National Wildlife Refuge

By Natalie R. Sexton, Alia M. Dietsch, Andrew W. Don Carlos, Lynne Koontz, Adam N. Solomon and Holly M. Miller

I love this refuge. The experience is life affirming. Not only do we love the experience of being in the 

unique landscape and viewing the birds, we have loved getting to know some of the local people we 

connect with again each year, and meeting other travelers.. Some years we have gone twice. Each trip I 

learn something new (often from another visitor) or recognize a bird that I could not identify before. It is 

an opportunity to be with our friends in an environment we love and appreciate. It is so interesting to see 

the differences through the years... Are the owls nesting in the same place? Will the area be dry or wet? 

Will the number of birds returning be similar in number or will events (natural or not) over the last year 

affect their population? My life experience would be greatly diminished if I could not come here.—Survey 

comment from visitor to Malheur National Wildlife Refuge. 

Horned Grebe at Malheur National Wildlife Refuge. Photo credit: 

U.S. Fish and Wildlife Service. 
ii

Contents

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

Organization of Results.................................................................................................................................................. 1

Methods ......................................................................................................................................................................... 2

Selecting Participating Refuges.................................................................................................................................. 2

Developing the Survey Instrument ............................................................................................................................. 2

Contacting Visitors ..................................................................................................................................................... 2

Interpreting the Results .............................................................................................................................................. 4

Refuge Description......................................................................................................................................................... 5

Sampling at This Refuge................................................................................................................................................ 7

Selected Survey Results ................................................................................................................................................ 7

Visitor and Trip Characteristics................................................................................................................................... 7

Visitor Spending in Local Communities .................................................................................................................... 14

Visitor Opinions about This Refuge .......................................................................................................................... 15

Visitor Opinions about National Wildlife Refuge System Topics ............................................................................... 20

Conclusion ................................................................................................................................................................... 24

Acknowledgments........................................................................................................................................................ 24

References................................................................................................................................................................... 24

Appendix A: Survey Frequencies for This Refuge...................................................................................................... A-1 

Appendix B: Visitor Comments for This Refuge ......................................................................................................... B-1 
iii

Figures

1. Map of this refuge............................................................................................................................................... 6

2. How visitors first learned or heard about this refuge........................................................................................... 8

3. Resources used by visitors to find their way to this tefuge during this visit......................................................... 9

4. Number of visitors travelling to this refuge by residence. .................................................................................. 10

5. Modes of transportation used by visitors to this refuge during this visit. ........................................................... 11

6. Activities in which visitors participated during the past 12 months at this refuge. ............................................. 12

7. The primary activity in which visitors participated during this visit..................................................................... 13

8. Use of the visitor center at this refuge.. ............................................................................................................ 13

9. Overall satisfaction with this refuge during this visit.......................................................................................... 15

10. Importance-satisfaction ratings of services and facilities provided at this refuge.............................................. 17

11. Importance-satisfaction ratings of recreational opportunities provided at this refuge........................................ 18

12. Importance-satisfaction ratings of transportation-related features at this refuge............................................... 19

13. Visitors’ likelihood of using alternative transportation options at National Wildlife Refuges in the future. ......... 21

14. Visitors’ personal involvement with climate change related to fish, wildlife and their habitats........................... 22

15. Visitors’ beliefs about the effects of climate change on fish, wildlife and their habitats..................................... 23

Tables

1. Participating refuges in the 2010/2011 National Wildlife Refuge Visitor Survey. ................................................ 3

2. Sampling and response rate summary for this refuge. ....................................................................................... 7

3. Influence of this refuge on visitors’ decision to take this trip. .............................................................................. 9

4. Type and size of groups visiting this refuge...................................................................................................... 11

5. Total visitor expenditures for this refuge expressed in dollars per person per day. .......................................... 14
iv

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1 

Introduction

The National Wildlife Refuge System (NWRS), established in 1903 and managed by the U.S. Fish 

and Wildlife Service (FWS), is the largest system of lands in the world dedicated to the conservation of 

wildlife. There are over 550 National Wildlife Refuges (NWRs) nationwide, encompassing more than 150 

million acres. The mission of the NWRS is to “administer a national network of lands and waters for the 

conservation, management and, where appropriate, restoration of the fish, wildlife, and plant resources and 

their habitats within the United States for the benefit of present and future generations of Americans.” Part of 

achieving this mission is the goal “to foster understanding and instill appreciation of fish, wildlife, and 

plants, and their conservation, by providing the public with safe, high-quality, and compatible wildlifedependent public use” (Clark, 2001). About 98% of the system is open to the public, attracting nearly 40 

million visitors annually. More than 25 million people per year visit refuges to observe and photograph 

wildlife, 8 million to hunt and fish, and more than half a million to participate in educational and 

interpretation programs (Uniack, 1999; U.S. Fish and Wildlife Service, 2007). Understanding visitors and 

characterizing their experiences on National Wildlife Refuges are critical elements of managing these lands

and meeting the goals of the NWRS. 

To address such information needs, the FWS Division of Visitor Services and Communications 

partnered with the Policy Analysis and Science Assistance Branch (PASA) of the U.S. Geological Survey’s 

Fort Collins Science Center to collect data on visitor experiences across the NWRS. PASA scientists have 

conducted biological, social, economic, and institutional analyses of conservation policies and management 

practices on numerous refuges across the nation in support of refuge planning and management. PASA’s 

mission is to integrate biological, social, and economic research so that natural resource professionals can 

use the resulting information to make informed decisions and resolve related conflicts.

The goal of the 2010/2011 National Visitor Survey is to provide refuge managers, planners, and 

visitor services specialists with reliable baseline data about refuge visitors and their experiences. The survey 

was conducted to provide information both at a national level and at a field station level to more effectively 

manage visitor services and facilities across the System and to inform site-specific management and planning 

decisions such as Comprehensive Conservation Plans (CCPs), Visitor Services step-down plans, and 

transportation plans. 

Organization of Results

These results are for Malheur NWR (this refuge) and are part of USGS Data Series 643 (Sexton and 

others, 2011). All refuges participating in the 2010/2011 surveying effort will receive individual refuge 

results specific to the visitors to that refuge. Each set of results is organized by the following categories: 

• Introduction: An overview of the NWRS and the goals of the national surveying effort.

• Methods: The procedures for the national surveying effort, including selecting refuges, developing the 

survey instrument, contacting visitors, and guidance for interpreting the results. 

• Refuge Description: A brief description of the refuge location, acreage, purpose, recreational activities, 

and visitation statistics, including a map (where available) and refuge website link. 

• Sampling at This Refuge: The sampling periods, locations, and response rate for this refuge. 

• Selected Survey Results: Key findings for this refuge, including: 

• Visitor and Trip Characteristics

• Visitor Spending in the Local Communities 

• Visitors Opinions about This Refuge 

• Visitor Opinions about National Wildlife Refuge System Topics 
2 

• Conclusion 

• Acknowledgements

• References

• Survey Frequencies (Appendix A): A copy of the survey instrument with the frequency results for this 

refuge. 

• Visitor Comments (Appendix B): The verbatim responses to the open-ended survey questions for this 

refuge. 

Methods 

Selecting Participating Refuges

The National Visitor Survey was conducted from July 2010 – August 2011 on 53 refuges across the 

NWRS (table 1). Based on the Division of Refuge’s 2008 Refuge Annual Performance Plan (RAPP; U.S. 

Fish and Wildlife Service, 2011, personal communication), 192 refuges with a minimum visitation of 25,000 

visitors were considered. This criterion was the median visitation across the NWRS and the minimum 

visitation necessary to ensure that the surveying would be logistically feasible onsite. Thirty-five of the 

participating refuges were randomly selected for national-level analyses. Fifteen additional refuges were 

selected for participation by regional office Visitor Services Chiefs based on the need to inform individual 

refuge planning processes. An additional three refuges were added to the effort by an interagency agreement 

with USGS.

Developing the Survey Instrument

PASA researchers developed the survey in consultation with FWS managers, planners, and visitor 

services professionals. The survey was peer-reviewed by academic and government researchers and was 

further pre-tested with NWRS Friends Group representatives from each region to ensure readability and 

overall clarity. The survey and associated methodology were approved by the Office of Management and 

Budget (OMB control #: 1018-0145; expiration date: 6/30/2013). 

Contacting Visitors

Refuge staff identified two separate 15-day sampling periods and one or more locations that best 

reflected the unique visitation patterns of each participating refuge. Sampling periods and locations were 

identified by refuge staff and submitted to PASA via an internal website that included a customized mapping 

tool. A standardized sampling schedule was created for all refuges that included eight systematically selected 

sampling shifts during each of the two sampling periods. Sampling shifts were three- to five-hour time bands 

that were stratified across AM and PM, as well as weekend and weekdays. Any necessary customizations 

were made, in coordination with refuge staff, to the standardized schedule to accommodate the identified 

sampling locations and to address unique spatial and temporal patterns of visitation. 

Twenty visitors per sampling shift were targeted, for a total of 320 willing participants per refuge—

160 per sampling period—to ensure an adequate sample of completed surveys. When necessary, shifts were 

moved, added, or extended to alleviate logistical limitations (for example, weather or low visitation at a 

particular site) in an effort to reach target numbers. 
3 

Table 1. Participating refuges in the 2010/2011 National Wildlife Refuge Visitor Survey. 

Pacific Region (R1)

Kilauea Point National Wildlife Refuge (HI) William L. Finley National Wildlife Refuge (OR)

Deer Flat National Wildlife Refuge (ID) McNary National Wildlife Refuge (WA)

Cape Meares National Wildlife Refuge (OR) Turnbull National Wildlife Refuge (WA)

Malheur National Wildlife Refuge (OR)

Southwest Region (R2)

Bitter Lake National Wildlife Refuge (NM) Aransas National Wildlife Refuge (TX)

Bosque del Apache National Wildlife Refuge (NM) San Bernard/ Brazoria National Wildlife Refuge (TX)

Wichita Mountains Wildlife Refuge (OK)

Great Lakes-Big Rivers Region (R3)

Desoto National Wildlife Refuge (IA) Upper Mississippi River National Fish and Wildlife Refuge -

Neal Smith National Wildlife Refuge (IA) McGregor District (MN)

Muscatatuck National Wildlife Refuge (IN) Big Muddy National Wildlife Fish and Wildlife Refuge (MO)

Rice Lake National Wildlife Refuge (MN) Horicon National Wildlife Refuge (WI)

Tamarac National Wildlife Refuge (MN) Necedah National Wildlife Refuge (WI)

Southeast Region (R4)

Wheeler National Wildlife Refuge (AL) Banks Lake National Wildlife Refuge (GA)

Big Lake National Wildlife Refuge (AR) Noxubee National Wildlife Refuge (MS)

Pond Creek National Wildlife Refuge (AR) Cabo Rojo National Wildlife Refuge (Puerto Rico)

Merritt Island National Wildlife Refuge (FL) Pea Island National Wildlife Refuge (NC)

St. Marks National Wildlife Refuge (FL) Cape Romain National Wildlife Refuge (SC)

Ten Thousand Islands National Wildlife Refuge (FL) Reelfoot National Wildlife Refuge (TN)

Northeast Region (R5)

Stewart B. McKinney National Wildlife Refuge (CT) Moosehorn National Wildlife Refuge (ME)

Bombay Hook National Wildlife Refuge (DE) Great Swamp National Wildlife Refuge (NJ)

Monomoy National Wildlife Refuge (MA) Montezuma National Wildlife Refuge (NY)

Parker River National Wildlife Refuge (MA) Wertheim National Wildlife Refuge (NY)

Patuxent Research Refuge (MD) Occoquan Bay/ Elizabeth Hartwell Mason Neck National 

Wildlife Refuge (VA)

Mountain-Prairie Region (R6)

Monte Vista National Wildlife Refuge (CO) Sand Lake National Wildlife Refuge (SD)

Quivira National Wildlife Refuge (KS) National Elk Refuge (WY)

Charles M. Russell National Wildlife Refuge (MT)

Alaska Region (R7)

Alaska Maritime National Wildlife Refuge (AK) Kenai National Wildlife Refuge (AK)

California and Nevada Region (R8)

Lower Klamath/Tule Lake National Wildlife Refuge (CA) Ruby Lake National Wildlife Refuge (NV)

Sonny Bono Salton Sea National Wildlife Refuge (CA)
4 

Refuge staff and/or volunteers (survey recruiters) contacted visitors on-site following a protocol 

provided by PASA to ensure a diverse sample. Instructions included contacting visitors across the entire 

sampling shift (for example, every nth visitor for dense visitation, as often as possible for sparse visitation), 

and only one person per group. Visitors were informed of the survey effort, given a token incentive (for

example, a small magnet, temporary tattoo), and asked to participate. Willing participants provided their 

name, mailing address, and preference for language (English or Spanish) and survey mode (mail or online). 

Survey recruiters also were instructed to record any refusals. 

Visitors were mailed a postcard within 10 days of the initial on-site contact thanking them for 

agreeing to participate in the survey and inviting them to complete the survey online. Those visitors choosing 

not to complete the survey online were sent a paper copy a week later. Two additional contacts were made 

by mail during the next seven weeks following a modified Tailored Design Method (Dillman, 2007): 1) a 

reminder postcard one week after the first survey, and 2) a second paper survey two weeks after the reminder 

postcard. Each mailing included instructions for completing the survey online and a postage paid envelope 

for returning the paper version of the survey. Those visitors indicating a preference for Spanish were sent 

Spanish versions of all correspondence (including the survey). Finally, a short survey of six questions was 

sent to nonrespondents four weeks after the second survey mailing to determine any differences between 

respondents and nonrespondents at the national level. Online survey data were exported and paper survey 

data were entered using a standardized survey codebook and data entry procedure. All survey data were

analyzed by using SPSS v.18 statistical analysis software. 

Interpreting the Results

The extent to which these results accurately represent the total population of visitors to this refuge is 

dependent on 1) an adequate sample size of those visitors and 2) the representativeness of that sample. The 

adequacy of the sample size for this refuge is quantified as the margin of error. The composition of the 

sample is dependent on the ability of the standardized sampling protocol for this study to account for the 

spatial and temporal patterns of visitor use unique to each refuge. Spatially, the geographical layout and 

public use infrastructure varies widely across refuges. Some refuges only can be accessed through a single 

entrance, while others have multiple unmonitored access points across large expanses of land and water. As a 

result, the degree to which sampling locations effectively captured spatial patterns of visitor use will likely 

vary from refuge to refuge. Temporally, the two 15-day sampling periods may not have effectively captured 

all of the predominant visitor uses/activities on some refuges during the course of a year. Therefore, certain 

survey measures such as visitors’ self-reported “primary activity during their visit” may reflect a seasonality 

bias. 

Herein, the sample of visitors who responded to the survey are referred to simply as “visitors.” 

However, when interpreting the results for Malheur NWR, any potential spatial and temporal sampling 

limitations specific to this refuge need to be considered when generalizing the results to the total population 

of visitors. For example, a refuge that sampled during a special event (for example, birding festival) held 

during the spring may have contacted a higher percentage of visitors who traveled greater than 50 miles to 

get to the refuge than the actual number of these people who would have visited throughout the calendar year

(that is, oversampling of nonlocals). In contrast, another refuge may not have enough nonlocal visitors in the 

sample to adequately represent the beliefs and opinions of that group type. If the sample for a specific group 

type (for example, nonlocals, hunters, those visitors who paid a fee) is too low (n < 30), a warning is 

included. Additionally, the term “this visit” is used to reference the visit on which people were contacted to 

participate in the survey, which may or may not have been their most recent refuge visit. 
5 

Refuge Description for Malheur National Wildlife Refuge

Malheur National Wildlife Refuge is located in the sagebrush country of eastern Oregon. The Refuge 

was established by Theodore Roosevelt in 1908 as a preserve and breeding ground for native birds. The 

Refuge has since grown through a 65,000-acre purchase in 1935 and a 14,000-acre purchase in 1942, 

covering a total of 187,000 acres. Malheur NWR attracts a variety of visitors, from bird watchers, hikers and 

bicyclists, to anglers and hunters. Over 320 species of birds and 58 mammal species call the refuge home, 

providing hunters and birders with ample recreation opportunities. Flocks of waterfowl and sandhill cranes 

use Malheur NWR as a resting point and feeding ground during their migration along the Pacific Flyway in 

the spring and fall, providing a range of visitors with unique recreation experiences. Malheur NWR attracts 

65,000 annual visitors (based on 2008 RAPP database; U.S. Fish and Wildlife Service, 2011, written 

comm.). Figure 1 depicts a map of Malheur NWR. For more information, go to http://www.fws.gov/malheur/. 
6 

Figure 1. Map of Malheur NWR, courtesy of U.S. Fish and Wildlife Service. 
7 

Sampling at Malheur National Wildlife Refuge

A total of 315 visitors agreed to participate in the survey during the two sampling periods at the 

identified locations at Malheur NWR (table 2). In all, 276 visitors completed the survey for an 89% response 

rate and ±5% margin of error at the 95% confidence interval.

1 The majority of the contacts were made at the 

Visitor Center (68%), whereas 20% were made at Krumbo Reservoir, 7% at Historic P Ranch, 3% along the 

Auto Tour Route, and 2% at the Historic Sod House Ranch. The refuge experienced flooding during 

sampling period 2 which may have affected participation in some activities on the refuge, such as use of the 

autor tour route. 

Table 2. Sampling and response rate summary for Malheur NWR. Sampling 

period

Dates

Locations

Total 

contacts

Undeliverable

addresses

Completed 

surveys

Response rate

1 

8/28/10

to 

09/11/10

Auto Tour Route, Center Patrol Road

144 2 126 89% 

Historic Sod House Ranch 

Krumbo Reservoir 

Visitor Center/Refuge HQ 

2 

05/21/11

to 

06/04/11

Historic P Ranch

Krumbo Reservoir 171 3 150 89%

Visitor Center/Refuge HQ

Total 315 5 276 89%

Selected Survey Results

Visitor and Trip Characteristics

A solid understanding of refuge visitors and details about their trips to refuges can inform 

communication outreach efforts, inform visitor services and transportation planning, forecast use, and 

gauge demand for services and facilities. 

Familiarity with the NWRS 

Visitors to Malheur NWR reported that before participating in the survey, they were aware of the role 

of the U.S. Fish and Wildlife Service in managing National Wildlife Refuges (92%) and that the Refuge 

System has the mission of conserving, managing, and restoring fish, wildlife, plants and their habitat (95%).

Positive responses to these questions concerning the management and mission of the NWRS do not 

necessarily indicate that these visitors fully understand the day-to-day management practices of individual 

 

1 The margin of error (or confidence interval) is the error associated with the results related to the sample and population size. A 

margin of error of ± 5%, for example, means if 55% of the sample answered a survey question in a certain way, then 50–60% of

the entire population would have answered that way. The margin of error is calculated with an 80/20 response distribution, 

assuming that for any given dichotomous choice question, approximately 80% of respondents selected one choice and 20% 

selected the other (Salant and Dillman, 1994). 
8 

refuges, only that visitors feel they have a basic knowledge of who manages refuges and why. Compared to 

other public lands, many visitors feel that refuges provide a unique recreation experience (96%; see 

Appendix B for visitor comments on “What Makes National Wildlife Refuges Unique?”); however, reasons 

for why visitors find refuges unique are varied and may not directly correspond to their understanding of the 

mission of the Refuge System. Most visitors to Malheur NWR had been to at least one other National 

Wildlife Refuge in the past year (78%), with an average of 6 visits to other refuges during the past 12 

months. 

Visiting This Refuge

Most visitors (72%) had only been to Malheur NWR once in the past 12 months, while others had 

been multiple times (28%). These repeat visitors went to the refuge an average of 3 times during that same 

12-month period. Visitors used the refuge during only one season (79%) and during multiple seasons (21%). 

Most visitors first learned about the refuge from friends/relatives (59%), refuge printed information 

(15%), or a recreation club/organization (13%; fig. 2). Key information sources used by visitors to find their 

way to this refuge include a road atlas/highway map (56%), previous knowledge (55%), or signs on 

highways (52%; fig. 3). 

Few visitors (4%) live in the local area (within 50 miles of the refuge), whereas 96% are nonlocal 

visitors. For most local visitors, Malheur NWR was the primary purpose or sole destination of trip (80%; 

table 3). For most nonlocal visitors, the refuge also was the primary purpose or sole destination of trip (50%).

Local visitors (n = 10) reported that they traveled an average of 41 miles to get to the refuge, while nonlocal 

visitors (n = 266) traveled an average of 437 miles. It is important to note that summary statistics based on 

a small sample size (n < 30) may not provide a reliable representation of the population. Figure 4 shows 

the residence of visitors travelling to the refuge. About 60% of visitors travelling to Malheur NWR were 

from Oregon. 

Figure 2. How visitors first learned or heard about Malheur NWR (n = 271). 
9 

Figure 3. Resources used by visitors to find their way to Malheur NWR during this visit (n = 272). 

Table 3. Influence of Malheur NWR on visitors’ decision to take this trip. 

Visitors

Visiting this refuge was...

the primary reason 

for trip

one of many equally 

important reasons for trip an incidental stop

Nonlocal 50% 44% 7%

Local 80% 20% 0%

Total 51% 43% 6%
10

Figure 4. Number of visitors travelling to Malheur NWR by residence. Top map shows residence by state and bottom 

map shows residence by zip codes near the refuge (n = 276). 
11

Visitors reported that they spent an average of 7 hours at Malheur NWR during one day there (a day 

visit is assumed to be 8 hours). However, the most frequently reported length of visit during one day was 

actually 8 hours (76%). The key modes of transportation used by visitors to travel around the refuge were 

private vehicle (83%) and walking/hiking (42%; fig. 5). Most visitors indicated they were part of a group on 

their visit to this refuge (74%), travelling primarily with family and friends (table 4).

Figure 5. Modes of transportation used by visitors to Malheur NWR during this visit (n = 273).

Table 4. Type and size of groups visiting Malheur NWR (for those who indicated they were part of a group, n = 202). 

Group type

Percent

(of those traveling

in a group) 

Average group size 

Number of adults Number of children Total group size

Family/Friends 85% 4 0 4 

Commercial tour group 1% 10 0 10

Organized club/School group 11% 12 1 13 

Other group type 2% 11 0 11
12

Visitors participated in a variety of refuge activities during the past 12 months (fig. 6); the top three 

activities reported were bird watching (93%), wildlife observation (87%), auto tour route/driving (61%) and 

photography (60%). The primary reasons for their most recent visit included bird watching (68%), wildlife 

observation (11%), and fishing (5%; fig. 7). The visitor center was used by 93% of visitors, mostly to visit 

the gift shop/bookstore (87%), stop to use the facilities (84%), and ask information of staff/volunteers (81%; 

fig. 8).

Figure 6. Activities in which visitors participated during the past 12 months at Malheur NWR (n = 271). See Appendix B 

for a listing of “other” activities.
13

Figure 7. The primary activity in which visitors participated during this visit to Malheur NWR (n = 260). See Appendix B 

for a listing of “other” activities. 

Figure 8. Use of the visitor center at Malheur NWR (for those visitors who indicated they used the visitor center, n = 

253).
14

Visitor Characteristics

Nearly all (98%) visitors to Malheur NWR indicated that they were citizens or permanent residents of 

the United States. Visitors were a mix of 53% male with an average age of 58 years and 47% female with an 

average age of 59 years. Visitors, on average, reported they had 17 years of formal education (graduate or 

professional school). The median level of income was $75,000–$99,000. See Appendix A for more 

demographic information. In comparison, the 2006 National Survey of Fishing, Hunting and WildlifeAssociated Recreation found that participants in wildlife watching and hunting on public land were 55% 

male and 45% female with an average age of 46 years, an average level of education of 14 years (associate 

degree or two years of college), and a median income of $50,000–$74,999 (Harris, 2011, personal 

communication). Compared to the U.S. population, these 2006 survey participants are more likely to be 

male, older, and have higher education and income levels (U.S. Department of Interior and U.S. Department 

of Commerce, 2007). 

Visitor Spending in Local Communities

Tourists usually buy a wide range of goods and services while visiting an area. Major expenditure 

categories include lodging, food, supplies, and gasoline. Spending associated with refuge visitation can 

generate considerable economic benefits for the local communities near a refuge. For example, more than 

34.8 million visits were made to National Wildlife Refuges in fiscal year 2006; these visits generated $1.7 

billion in sales, almost 27,000 jobs, and $542.8 million in employment income in regional economies 

(Carver and Caudill, 2007). Information on the amount and types of visitor expenditures can illustrate the 

economic importance of refuge visitor activities to local communities. Visitor expenditure information also 

can be used to analyze the economic impact of proposed refuge management alternatives. 

A region (and its economy) is typically defined as all counties within 50 miles of a travel destination

(Stynes, 2008). Visitors that live within the local 50-mile area of a refuge typically have different spending 

patterns than those that travel from longer distances. Approximately 4% of visitors to Malheur NWR

indicated that they live within the local area. Nonlocal visitors (96%) stayed in the local area, on average, for 

3 days. Table 5 shows summary statistics for local and nonlocal visitor expenditures, with expenditures 

reported on a per person per day basis. It is important to note that summary statistics based on a small 

sample size (n < 30) may not provide a reliable representation of that population. Nonlocal visitors spent 

an average of $65 per person per day and local visitors spent an average of $60 per person per day. 

Table 5. Total visitor expenditures for Malheur NWR expressed in dollars per person per day.

Visitors n1 Median Mean Standard 

deviation Minimum Maximum

Nonlocal 240 $52 $65 $51 $0 $375

Local 9 $44 $60 $53 $8 $155 1

n = number of visitors who answered both locality and expenditure questions. 
15

Visitor Opinions about This Refuge

National Wildlife Refuges provide visitors with a variety of services, facilities, and wildlife-dependent 

recreational opportunities. Understanding visitors’ perceptions of their refuge experience is a key 

component of the NWRS mission as it pertains to providing high-quality wildlife-dependent recreational 

opportunities. Having a baseline understanding of visitor experience can inform management decisions to 

better balance visitors’ expectations with the NWRS mission. Recent studies in outdoor recreation have 

included an emphasis on declining participation in traditional activities such as hunting and an increasing 

need to connect the next generation to nature and wildlife. These factors highlight the importance of current 

refuge visitors as a key constituency in wildlife conservation. A better understanding is increasingly needed

to better manage the visitor experience and to address the challenges of the future. 

Visitors’ overall satisfaction with the services, facilities, and recreational opportunities provided at 

Malheur NWR were as follows (fig. 9): 

• 97% were satisfied with the recreational activities and opportunities, 

• 94% were satisfied with the information and education about the refuge and its resources, 

• 94% were satisfied with the services provided by employees or volunteers, and

• 92% were satisfied with the refuge’s job of conserving fish, wildlife and their habitats. 

Though 14% of visitors indicated that they paid a fee to enter the refuge, Malheur NWR does not 

charge an entrance fee.

Figure 9. Overall satisfaction with Malheur NWR during this visit (n ≥ 269).
16

Importance/Satisfaction Ratings

Comparing the importance and satisfaction ratings for visitor services provided by refuges can help to 

identify how well the services are meeting visitor expectations. The importance-performance framework 

presented in this section is a tool that includes the importance of an attribute to visitors in relation to their 

satisfaction with that attribute. Drawn from marketing research, this tool has been applied to outdoor 

recreation and visitation settings (Martilla and James, 1977; Tarrant and Smith, 2002). Results for the

attributes of interest are segmented into one of four quadrants (modified for this national study): 

• Keep Up the Good Work = high importance/high satisfaction;

• Concentrate Here = high importance/low satisfaction; 

• Low Priority = low importance/low satisfaction; and

• Look Closer = low importance/high satisfaction. 

Graphically plotting visitors’ importance and satisfaction ratings for different services, facilities, and 

recreational opportunities provides a simple and intuitive visualization of these survey measures. However, 

this tool is not without its drawbacks. One is the potential for variation among visitors regarding their 

expectations and levels of importance (Vaske et al., 1996; Bruyere et al., 2002; Wade and Eagles, 2003), and 

certain services or recreational opportunities may be more or less important for different segments of the 

visitor population. For example, hunters may place more importance on hunting opportunities and amenities 

such as blinds, while school group leaders may place more importance on educational/informational 

displays than would other visitors. This potential for highly varied importance ratings needs to be 

considered when viewing the average results of this analysis of visitors to Malheur NWR. This consideration 

is especially important when reviewing the attributes that fall into the “Look Closer” quadrant. In some 

cases, these attributes may represent specialized recreational activities in which a small subset of visitors 

participate (for example, hunting, kayaking) or facilities and services that only some visitors experience (for 

example, exhibits about the refuge). For these visitors, the average importance of (and potentially the

satisfaction with) the attribute may be much higher than it would be for the overall population of visitors. 

Figures 10-12 depict importance-satisfaction results for refuge services and facilities, recreational 

opportunities, and transportation-related features at Malheur NWR, respectively. All refuge services and 

facilities fell in the “Keep Up the Good Work” quadrant (fig. 10). Many refuge recreational opportunities fell 

in the “Keep Up the Good Work” quadrant except hunting, fishing, bicycling, and volunteering 

opportunities, which fell into the “Look Closer” quadrant (fig. 11). The average importance of X activities in 

the “Look Closer” quadrant may be higher among visitors who have participated in these activities during 

the past 12 months; however, there were not enough individuals in the sample to evaluate the responses of 

such participants. Nearly all transportation-related features fell in the “Keep Up the Good Work” quadrant 

except condition of parking areas, which fell into the “Look Closer” quadrant (fig. 12).
17

Figure 10. Importance-satisfaction ratings of services and facilities provided at Malheur NWR. 
18

Figure 11. Importance-satisfaction ratings of recreational opportunities provided at Malheur NWR. 
19

Figure 12. Importance-satisfaction ratings of transportation-related features at Malheur NWR. 
20

Visitor Opinions about National Wildlife Refuge System Topics

One goal of this National Visitor Survey was to identify visitor trends across the NWRS to more 

effectively manage refuges and provide visitor services. Two important issues to the NWRS are 

transportation on refuges and communicating with visitors about climate change. The results to these 

questions will be most meaningful when they are evaluated in aggregate (data from all participating refuges 

together). However, basic results for Malheur NWR are reported here. 

Alternative Transportation and the National Wildlife Refuge System

Visitors use a variety of transportation means to access and enjoy National Wildlife Refuges. While 

many visitors arrive at the refuge in a private vehicle, alternatives such as buses, trams, watercraft, and 

bicycles are increasingly becoming a part of the visitor experience. Previous research has identified a 

growing need for transportation alternatives within the refuge system (Krechmer et al., 2001); however, less 

is known about how visitors perceive and use these new transportation options. An understanding of visitors’ 

likelihood of using certain alternative transportation options can help in future planning efforts. Visitors 

were asked their likelihood of using alternative transportation options at National Wildlife Refuges in the 

future. 

Of the seven NWRS-wide alternative transportation options listed on the survey, the majority of 

Malheur NWR visitors were likely to use the following options at National Wildlife Refuges in the future

(fig. 13): 

• an offsite parking lot that provides trail access; 

• a boat that goes to different points on Refuge waterways; and

• a bike share program. 

The majority of visitors were not likely to use a bus/tram that takes passengers to different points on National 

Wildlife Refuges in the future (fig. 13). 

When asked about using alternative transportation at Malheur NWR specifically, 38% of visitors 

indicated they were unsure whether it would enhance their experience; however, some visitors thought 

alternative transportation would enhance their experience (25%) and others thought it would not (37%).
21

Figure 13. Visitors’ likelihood of using alternative transportation options at National Wildlife Refuges in the future 

(n ≥ 261). 

Climate Change and the National Wildlife Refuge System

Climate change represents a growing concern for the management of National Wildlife Refuges. 

FWS’ climate change strategy, titled “Rising to the Urgent Challenge,” establishes a basic framework for 

the agency to work within a larger conservation community to help ensure wildlife, plant, and habitat 

sustainability (U.S. Fish and Wildlife Service, 2010). To support the guiding principles of the strategy, 

refuges will be exploring options for more effective engagement with visitors on this topic. The National 

Visitor Survey collected information about visitors’ level of personal involvement in climate change related 

to fish, wildlife and their habitats and visitors’ beliefs regarding this topic. Items draw from the “Six 

Americas” framework for understanding public sentiment toward climate change (Leiserowitz, Maibach, 

and Roser-Renouf, 2008) and from literature on climate change message frames (e.g., Nisbet, 2009). Such 

information provides a baseline for understanding visitor perceptions of climate change in the context of fish 

and wildlife conservation that can further inform related communication and outreach strategies. 

Factors that influence how individuals think about climate change include their basic beliefs, levels of 

involvement, policy preferences, and behaviors related to this topic. Results presented below provide 

baseline information on visitors’ levels of involvement with the topic of climate change related to fish, 
22

wildlife and their habitats. The majority of visitors to Malheur NWR agree with the following statements 

(fig. 14):

• “I am personally concerned about the effects of climate change on fish, wildlife and habitats;” 

• “I stay well-informed about the effects of climate change;” 

• “I take actions to alleviate the effects of climate change;” and

• “My experience would be enhanced if the Refuge provides information about how I can help address 

climate change effects.” 

Figure 14. Visitors’ personal involvement with climate change related to fish, wildlife and their habitats (n ≥ 264).

These results are most useful when coupled with responses to belief statements about the effects of 

climate change on fish, wildlife and their habitats, because such beliefs may be used to develop message 

frames (or ways to communicate) about climate change with a broad coalition of visitors. Framing sciencebased findings will not alter the overall message, but rather place the issue in a context in which different 

audience groupings can relate. The need to mitigate impacts of climate change on Refuges could be framed 

as a quality-of-life issue (for example, preserving the ability to enjoy fish, wildlife, plants, and their habitat) 

or an economic issue (for example, maintaining tourist revenues, supporting economic growth through new 

jobs/technology). 

For Malheur NWR, the majority of visitors believe the following regarding climate change related to 

fish, wildlife and their habitats (fig. 15):

• “Future generations will benefit if we address climate change effects;” 

• “We can improve our quality of life if we address the effects of climate change;” and

• “It is important to consider the economic benefits to local communities when addressing climate 

change effects.” 
23

The majority of visitors do not believe: 

• “There has been too much emphasis on the catastrophic effects of climate change;” or 

• “There is too much scientific uncertainty to adequately understand climate change effects.” 

Such information suggests that certain beliefs resonate with a greater number of visitors than other 

beliefs do. This information is important to note because the majority of visitors (58%) indicated that their 

experience would be enhanced if Malheur NWR provided information about how they could help address the 

effects of climate change on fish, wildlife, and their habitats (fig. 14), and framing the information in a way 

that resonates most with visitors may result in a more engaged public who support strategies aimed at 

alleviating climate change pressures. Data will be analyzed further at the aggregate, or national level, to

inform the development of a comprehensive communication strategy about climate change. 

Figure 15. Visitors’ beliefs about the effects of climate change on fish, wildlife and their habitats (n ≥ 264). 
24

Conclusion

These individual refuge results provide a summary of trip characteristics and experiences of a sample 

of visitors to Malheur NWR during 2010–2011. These data can be used to inform decision-making efforts 

related to the refuge, such as Comprehensive Conservation Plan implementation, visitor services 

management, and transportation planning and management. For example, when modifying (either 

minimizing or enhancing) visitor facilities, services, or recreational opportunities, a solid understanding of 

visitors’ trip and activity characteristics, their satisfaction with existing offerings, and opinions regarding 

refuge fees is helpful. This information can help to gauge demand for refuge opportunities and inform both 

implementation and communication strategies. Similarly, an awareness of visitors’ satisfaction ratings with 

refuge offerings can help determine if any potential areas of concern need to be investigated further. As 

another example of the utility of these results, community relations may be improved or bolstered through an 

understanding of the value of the refuge to visitors, whether that value is attributed to an appreciation of the 

refuge’s uniqueness, enjoyment of its recreational opportunities, or spending contributions of nonlocal 

visitors to the local economy. Such data about visitors and their experiences, in conjunction with an 

understanding of biophysical data on the refuge, can ensure that management decisions are consistent with 

the NWRS mission while fostering a continued public interest in these special places. 

Individual refuge results will be available for downloading as they are completed during fall/winter 

2011 at http://pubs.usgs.gov/ds/643/. Aggregated data from all participating refuges will be used to inform 

national-level NWRS goals, such as Goal 4: Welcome and Orient Visitors; Goal 5: Provide Quality Wildlife 

Dependent Recreation and Education Programs; and Goal 8: Provide Infrastructure and Equipment Adequate 

to Support Mission. The national-level report will be available spring 2012. PASA researchers are available 

at any time at national_visitor_survey@usgs.gov or 970.226.9205 to discuss the site-specific surveying effort 

at this refuge or the national-level results. 

Acknowledgments

This study was commissioned by the FWS Division of Visitor Services and Communications. The 

study design and survey instrument were developed collaboratively with representatives from FWS and 

researchers from the PASA Branch, U.S. Geological Survey. We would like to thank the staff and any 

volunteers at Malheur NWR who assisted with the implementation of this surveying effort. The success of 

this effort is largely a result of their dedication to the refuge and its resources as well as to the people who 

come to explore these unique lands. We also would like to thank the following PASA team members for 

their hard work throughout the surveying effort, which has included (among many things) the arduous tasks 

of stuffing more than 20,000 envelopes, managing multiple databases, and preparing numerous reports: 

Shannon Conk, Halle Musfeldt, Phadrea Ponds, Gale Rastall, Margaret Swann, Emily Walenza, and Katie 

Walters. 

References

Bruyere, B.L., Rodriguez, D.A., and Vaske, J.J., 2002, Enhancing importance-performance analysis through 

segmentation: Journal of Travel and Tourism Marketing, v. 12, no. 1, p. 81-95.

Carver, E., and Caudill, J., 2007, Banking on nature 2006: The economic benefits to local communities of 

National Wildlife Refuge visitation: U.S. Fish and Wildlife Service, Division of Economics, Washington, 

D.C., 372 p., accessed September 30, 2011, at http://www.fws.gov/refuges/about/ 

msWord/BankingonNature_2006_11-23.doc. 
25

Clark, J.R., 2001, Mission and Goals (National Fish and Wildlife Service Director’s Order #132–601 FW1), 

accessed November 18, 2011 at http://www.fws.gov/refuges/policiesandbudget/ 

HR1420_missionGoals.html. 

Dillman, D.A., 2007, Mail and Internet surveys: The tailored design method. (2nd ed.): Hoboken, N.J., John 

Wiley and Sons, Inc., 523 p. 

Krechmer, D., Grimm, L., Hodge, D., Mendes, D., and Goetzke, F., 2001, Federal lands alternative 

transportation systems study – Volume 3 – Summary of national ATS needs: prepared for Federal 

Highway Administration, and Federal Transit Administration in association with National Park Service, 

Bureau of Land Management, and U.S. Fish and Wildlife Service, 80 p. (Also available at 

http://www.fta.dot.gov/documents/3039_study.pdf.) 

Leiserowitz, A, Maibach, E., and Roser-Renouf, C., 2008, Global warming’s six Americas: An audience 

segmentation: New Haven, Conn., Yale University. 

Martilla, J.A., and James, J.C., 1977, Importance-performance analysis: Journal of Marketing, v. 41, p. 77–

79. 

Nisbet, M.C., 2009, Communicating climate change: Why frames matter for public engagement:

Environment, v. 51, p. 12-23. 

Salant, P., and Dillman, D.A., 1994, How to conduct your own study: New York, N.Y., John Wiley and 

Sons, Inc.

Sexton, N.R., Dietsch, A.M., Don Carlos, A.W., Koontz, L., Solomon, A. and Miller, H., 2011, National 

Wildlife Refuge visitor survey 2010/2011: Individual refuge results: U.S. Geological Survey Data Series 

643. 

Stynes, D.J., 2008, National Park visitor spending and payroll impacts, 2007: East Lansing, Mich., Michigan 

State University, Department of Community, Agriculture, Recreation and Resource Studies. 

Tarrant, M.A., and Smith, E.K., 2002, The use of a modified importance-performance framework to examine 

visitor satisfaction with attributes of outdoor recreation settings: Managing Leisure, v. 7, no. 2, p. 69–82. 

Uniack, T., 1999, The citizen's wildlife refuge planning handbook: Charting the future of conservation on the 

National Wildlife Refuge near you: Defenders of Wildlife, Washington, D.C., accessed April 2010 at 

http://www.defenders.org/resources/publications/programs_and_policy/habitat_conservation/ 

federal_lands/citizen's_wildlife_refuge_planning_handbook.pdf. 

U.S. Department of Interior, Fish and Wildlife Service and U.S. Department of Commerce, U.S. Census 

Bureau, 2007, 2006 National survey of fishing, hunting, and wildlife-associated recreation: U.S. 

Department of Interior, Fish and Wildlife Service, Washington, D.C., 168 p. 

U.S. Fish and Wildlife Service, 2007, America’s National Wildlife Refuges, Fact Sheet, last updated July 31, 

2007. 

U.S. Fish and Wildlife Service, 2010, Rising to the urgent challenge: Strategic plan for responding to 

accelerating climate change: U.S. Fish and Wildlife Service, Division of Refuges, Washington, D.C., 32 p., 

accessed April 2011 at http://www.fws.gov/home/climatechange/pdf/CCStrategicPlan.pdf. 

Vaske, J.J., Beaman, J., Stanley R., and Grenier, M., 1996, Importance-performance and segmentation: 

Where do we go from here?: in Fesenmaier, D.R., O’Leary, J.T., and Uysal, M., eds., Recent advances in 

tourism marketing research: New York, The Haworth Press, Inc., p. 225-240.

Wade, D.J. and Eagles, P.F.J., 2003, The use of importance-performance analysis and market segmentation 

for tourism management in parks and protected areas: An application to Tanzania’s National Parks:

Journal of Ecotourism, v. 2, no. 3, p. 196-212. 
26

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A-1 

National Wildlife Refuge 

Visitor Survey

Appendix A: Survey Frequencies for Malheur National Wildlife Refuge
A-2 

PLEASE READ THIS FIRST:

Thank you for visiting a National Wildlife Refuge and for agreeing to participate in this study! We hope that 

you had an enjoyable experience. The U.S. Fish and Wildlife Service and the U.S. Geological Survey would 

like to learn more about National Wildlife Refuge visitors in order to improve the management of the area and 

enhance visitor opportunities. 

If you have recently visited more than one National Wildlife Refuge or made more than one visit to the 

same Refuge, please respond regarding only the Refuge and the visit when you were asked to participate in 

this survey. Any question that uses the phrase “this Refuge” refers to the Refuge and visit when you were 

contacted.

2. Which of the activities above was the primary purpose of your visit to this Refuge? 

(Please write only one activity on the line.) __________________________________________ 

3. Did you go to a Visitor Center at this Refuge? 

  No

  Yes  If yes, what did you do there? (Please mark all that apply.)

 Visit the gift shop or bookstore  Watch a nature talk/video/presentation

 View the exhibits  Stopped to use the facilities (for example, get water, use restroom)

 Ask information of staff/volunteers  Other (please specify) _____________________________

SECTION 1. Your visit to this Refuge

1. Including your most recent visit, which activities have you participated in during the past 12 months at this Refuge? 

(Please mark all that apply.)

  Big game hunting  Hiking  Environmental education (for 

 example, classrooms or labs, tours)  Upland/Small-game hunting  Bicycling

  Migratory bird/Waterfowl hunting  Auto tour route/Driving  Special event (please specify) 

 _________________________  Wildlife observation  Motorized boating 

  Bird watching  Nonmotorized boating 

 (including canoes/kayaks) 

 Other (please specify) 

 _________________________  Freshwater fishing

  Saltwater fishing  Interpretation (for example, 

 exhibits, kiosks, videos)

 Other (please specify) 

 _________________________  Photography 

0%

See report for categorized results; see Appendix B for miscellaneous responses

0%

1%

87%

93%

6%

0%

60%

44%

4%

61%

0%

3%

47%

8%

1%

4%

1%

7%

93%

87%

76%

81%

4%

84%

26% See Appendix B

See Appendix B

See Appendix B

See Appendix B
A-3 

4. Which of the following best describes your visit to this Refuge? (Please mark only one.)

Nonlocal Local Total

50% 80% 51% It was the primary purpose or sole destination of my trip. 

44% 20% 43% It was one of many equally important reasons or destinations for my trip. 

7% 0% 6% It was just an incidental or spur-of-the-moment stop on a trip taken for other 

purposes or to other destinations.

5. Approximately how many miles did you travel to get to this Refuge? 

 

Nonlocal _______ number of miles

 Local _______ number of miles

6. How much time did you spend at this Refuge on your visit? 

 _______ number of hours OR _______ number of days

7. Were you part of a group on your visit to this Refuge? 

 No (skip to question #9)

 Yes  What type of group were you with on your visit? (Please mark only one.)

 Family and/or friends  Organized club or school group 

 Commercial tour group  Other (please specify) __________________________________

8. How many people were in your group, including yourself? (Please answer each category.)

 ____ number 18 years and over ____ number 17 years and under 

9. How did you first learn or hear about this Refuge? (Please mark all that apply.) 

  Friends or relatives  Refuge website

  Signs on highway  Other website (please specify) ___________________________

  Recreation club or organization  Television or radio 

  People in the local community  Newspaper or magazine

  Refuge printed information (brochure, map)  Other (please specify)__________________________________ 

10. During which seasons have you visited this Refuge in the last 12 months? (Please mark all that apply.) 

  Spring

 (March-May)

 Summer

 (June-August)

 Fall

 (September-November)

 Winter

 (December-February)

11. How many times have you visited...

...this Refuge (including this visit) in the last 12 months? _____ number of visits 

...other National Wildlife Refuges in the last 12 months? _____ number of visits 

437

26%

74%

85%

1%

11%

2%

5 0

59%

8%

13%

9%

15%

9%

3%

2%

10%

20%

58% 25% 43% 0%

2

5

See Appendix B

See Appendix B

See Appendix B

41

See Report for Results
A-4 

SECTION 2. Transportation and access at this Refuge

1. What forms of transportation did you use on your visit to this Refuge? (Please mark all that apply.)

  Private vehicle without a trailer  Refuge shuttle bus or tram  Bicycle

  Private vehicle with a trailer

 (for boat, camper or other)

 Motorcycle  Walk/Hike

 ATV or off-road vehicle  Other (please specify below)

  Commercial tour bus  Boat __________________________

  Recreational vehicle (RV)  Wheelchair or other mobility aid

2. Which of the following did you use to find your way to this Refuge? (Please mark all that apply.)

  Signs on highways  Directions from Refuge website

  A GPS navigation system  Directions from people in community near this Refuge

  A road atlas or highway map  Directions from friends or family

  Maps from the Internet (for example, 

 MapQuest or Google Maps)

 Previous knowledge/I have been to this Refuge before

 Other (please specify) _______________________________

3. Below are different alternative transportation options that could be offered at some National Wildlife Refuges in the 

future. Considering the different Refuges you may have visited, please tell us how likely you would be to use each 

transportation option. (Please circle one number for each statement.) 

How likely would you be to use... Very 

Unlikely

Somewhat 

Unlikely Neither

Somewhat 

Likely

Very 

Likely

...a bus or tram that takes passengers to different points on 

the Refuge (such as the Visitor Center)? 1 2 3 4 5

...a bike that was offered through a Bike Share Program for 

use while on the Refuge? 1 2 3 4 5

...a bus or tram that provides a guided tour of the Refuge 

with information about the Refuge and its resources? 1 2 3 4 5

...a boat that goes to different points on Refuge waterways? 1 2 3 4 5

...a bus or tram that runs during a special event (such as an 

evening tour of wildlife or weekend festival)? 1 2 3 4 5

...an offsite parking lot that provides trail access for 

walking/hiking onto the Refuge? 1 2 3 4 5

...some other alternative transportation option? 

 (please specify) ________________________________ 1 2 3 4 5

4. If alternative transportation were offered at this Refuge, would it enhance your experience? 

 Yes  No  Not Sure 

2%

42%

3%

83%

10%

1%

8%

52%

10%

56%

18%

1%

0%

0%

1%

0%

10%

8%

10%

55%

5%

34% 21% 5% 28% 12%

33% 12% 3% 31% 20%

30% 15% 5% 35% 15%

19% 9% 8% 41% 22%

28% 18% 8% 31% 15%

10% 6% 5% 35% 44%

17% 9% 0% 30% 43%

25% 37% 38%

See Appendix B

See Appendix B

See Appendix B
A-5 

5. For each of the following transportation-related features, first, rate how important each feature is to you when 

visiting this Refuge; then rate how satisfied you are with the way this Refuge is managing each feature. 

If this Refuge does not offer a specific transportation-related feature, please rate how important it is to you and then 

circle NA “Not Applicable” under the Satisfaction column.

Importance Satisfaction 

Circle one for each item. Circle one for each item.

Very 

Unimportant

Somewhat 

Unimportant

Neither

Somewhat 

Important

Very 

Important

Very 

Unsatisfied

Somewhat 

Unsatisfied

Neither

Somewhat 

Satisfied

Very 

Satisfied

Not 

Applicable

1 2 3 4 5 Surface conditions of roads 1 2 3 4 5 NA

1 2 3 4 5 Surface conditions of parking areas 1 2 3 4 5 NA

2 3 4 5 Condition of bridges 1 2 3 4 5 NA

1 2 3 4 5 Condition of trails and boardwalks 1 2 3 4 5 NA

1 2 3 4 5 Number of places for parking 1 2 3 4 5 NA

1 2 3 4 5 Number of places to pull over along Refuge roads 1 2 3 4 5 NA

1 2 3 4 5 Safety of driving conditions on Refuge roads 1 2 3 4 5 NA

1 2 3 4 5 Safety of Refuge road entrances/exits 1 2 3 4 5 NA

1 2 3 4 5 Signs on highways directing you to the Refuge 1 2 3 4 5 NA

1 2 3 4 5 Signs directing you around the Refuge roads 1 2 3 4 5 NA

1 2 3 4 5 Signs directing you on trails 1 2 3 4 5 NA

1 2 3 4 5 Access for people with physical disabilities or 

who have difficulty walking 1 2 3 4 5 NA

6. If you have any comments about transportation-related items at this Refuge, please write them on the lines below. 

__________________________________________________________________________________________________ 

__________________________________________________________________________________________________ 

__________________________________________________________________________________________________ 

__________________________________________________________________________________________________ 

3% 16% 12% 50% 19% 3% 14% 5% 30% 48%

15% 22% 17% 40% 6% 3% 0% 8% 24% 65%

3% 11% 11% 36% 39% 1% 1% 10% 20% 67%

2% 7% 8% 50% 33% 0% 3% 9% 35% 52%

5% 11% 9% 54% 21% 1% 2% 7% 24% 66%

3% 2% 3% 39% 53% 2% 15% 8% 39% 36%

2% 4% 6% 39% 49% 0% 4% 8% 31% 57%

1% 9% 8% 41% 41% 0% 1% 8% 25% 66%

6% 9% 11% 39% 36% 1% 6% 8% 29% 56%

4% 4% 4% 42% 45% 2% 12% 6% 37% 44%

2% 4% 12% 39% 43% 1% 12% 18% 35% 34%

6% 9% 29% 33% 23% 0% 7% 42% 24% 27%

See Appendix B
A-6 

SECTION 3. Your expenses related to your Refuge visit

1. Do you live in the local area (within approximately 50 miles of this Refuge)? 

 Yes

 No  How much time did you spend in local communities on this trip?

 ____ number of hours OR _____ number of days 

2. Please record the amount that you and other members of your group with whom you shared expenses (for example, 

other family members, traveling companions) spent in the local 50-mile area during your most recent visit to this 

Refuge. (Please enter the amount spent to the nearest dollar in each category below. Enter 0 (zero) if you did not 

spend any money in a particular category.) 

Categories

Amount Spent in 

Local Communities & at this Refuge

(within 50 miles of this Refuge)

Motel, bed & breakfast, cabin, etc. $ _________

Camping $ _________

Restaurants & bars $ _________

Groceries $ _________

Gasoline and oil $ _________

Local transportation (bus, shuttle, rental car, etc.) $ _________

Refuge entrance fee $ _________

Recreation guide fees (hunting, fishing, wildlife viewing, etc.) $ _________

Equipment rental (canoe, bicycle, kayak, etc.) $ _________

Sporting good purchases $ _________

Souvenirs/clothing and other retail $ _________

Other (please specify)________________________________ $ _________

3. Including yourself, how many people in your group shared these trip expenses? 

_______ number of people sharing expenses 

4%

96%

4 3

3
A-7 

4. As you know, some of the costs of travel such as gasoline, hotels, and airline tickets often increase. If your total trip costs 

were to increase, what is the maximum extra amount you would pay and still visit this Refuge? (Please circle the highest 

dollar amount.) 

$0 $10 $20 $35 $50 $75 $100 $125 $150 $200 $250 

5. If you or a member of your group paid a fee or used a pass to enter this Refuge, how appropriate was the fee? 

(Please mark only one.) 

  Far too low  Too low  About right  Too high  Far too high  Did not pay a fee 

 (skip to Section 4)

6. Please indicate whether you disagree or agree with the following statement. (Please mark only one.) 

The value of the recreation opportunities and services I experienced at this Refuge was at least equal to the fee 

I paid.

  Strongly disagree  Disagree  Neither agree or disagree  Agree  Strongly agree

SECTION 4. Your experience at this Refuge

1. Considering your visit to this Refuge, please indicate the extent to which you disagree or agree with each statement. 

(Please circle one number for each statement.)

Strongly 

Disagree Disagree Neither Agree

Strongly 

Agree

Not

Applicable

Overall, I am satisfied with the recreational 

activities and opportunities provided by this 

Refuge.

1 2 3 4 5 NA

Overall, I am satisfied with the information 

and education provided by this Refuge about 

its resources.

1 2 3 4 5 NA

Overall, I am satisfied with the services 

provided by employees or volunteers at this 

Refuge.

1 2 3 4 5 NA

This Refuge does a good job of conserving 

fish, wildlife and their habitats. 1 2 3 4 5 NA

1% 1% 5% 2% 16% 5% 34% 2% 7% 8% 19%

5% 18% 77% 0% 0% 86%

0% 0% 5% 36% 59%

1% 1% 1% 26% 71%

0% 3% 3% 29% 65%

0% 2% 4% 25% 69%

1% 2% 6% 23% 68%
A-8 

2. For each of the following services, facilities, and activities, first, rate how important each item is to you when 

visiting this Refuge; then, rate how satisfied you are with the way this Refuge is managing each item. 

If this Refuge does not offer a specific service, facility, or activity, please rate how important it is to you and then 

circle NA “Not Applicable” under the Satisfaction column.

Importance Satisfaction 

Circle one for each item. Circle one for each item.

Very 

Unimportant

Somewhat 

Unimportant

Neither

Somewhat 

Important

Very 

Important

Refuge Services, Facilities, and Activities

Very 

Unsatisfied

Somewhat 

Unsatisfied

Neither

Somewhat 

Satisfied

Very 

Satisfied

Not 

Applicable

1 2 3 4 5 Availability of employees or volunteers 1 2 3 4 5 NA

1 2 3 4 5 Courteous and welcoming employees or volunteers 1 2 3 4 5 NA

1 2 3 4 5 Knowledgeable employees or volunteers 1 2 3 4 5 NA

1 2 3 4 5 Printed information about this Refuge and its 

resources (for example, maps and brochures) 1 2 3 4 5 NA

1 2 3 4 5 Informational kiosks/displays about this Refuge 

and its resources 1 2 3 4 5 NA

1 2 3 4 5 Signs with rules/regulations for this Refuge 1 2 3 4 5 NA

1 2 3 4 5 Exhibits about this Refuge and its resources 1 2 3 4 5 NA

1 2 3 4 5 Environmental education programs or activities 1 2 3 4 5 NA

1 2 3 4 5 Visitor Center 1 2 3 4 5 NA

1 2 3 4 5 Convenient hours and days of operation 1 2 3 4 5 NA

1 2 3 4 5 Well-maintained restrooms 1 2 3 4 5 NA

1 2 3 4 5 Wildlife observation structures (decks, blinds) 1 2 3 4 5 NA

1 2 3 4 5 Bird-watching opportunities 1 2 3 4 5 NA

1 2 3 4 5 Opportunities to observe wildlife other than birds 1 2 3 4 5 NA

1 2 3 4 5 Opportunities to photograph wildlife and scenery 1 2 3 4 5 NA

1 2 63 4 5 Hunting opportunities 1 2 3 4 5 NA

1 2 3 4 5 Fishing opportunities 1 2 3 4 5 NA

1 2 3 4 5 Trail hiking opportunities 1 2 3 4 5 NA

1 2 3 4 5 Water trail opportunities for canoeing or kayaking 1 2 3 4 5 NA

1 2 3 4 5 Bicycling opportunities 1 2 3 4 5 NA

1 2 3 4 5 Volunteer opportunities 1 2 3 4 5 NA

5% 11% 11% 47% 25%

5% 6% 5% 44% 39%

3% 4% 3% 33% 56%

2% 4% 2% 35% 56%

3% 9% 10% 53% 24%

6% 11% 24% 36% 22%

3% 3% 4% 43% 48%

3% 8% 7% 52% 30%

4% 11% 13% 44% 28%

3% 1% 5% 44% 48%

3% 2% 3% 37% 55%

3% 7% 8% 44% 38%

2% 1% 2% 11% 84%

1% 2% 2% 35% 60%

4% 4% 6% 38% 48%

70% 3% 15% 7% 4% 

56% 10% 17% 10% 8%

2% 3% 7% 47% 41%

18% 15% 19% 36% 13%

23% 13% 21% 30% 13%

20% 10% 35% 22% 14%

1% 4% 6% 19% 70%

1% 0% 4% 8% 87%

1% 3% 4% 24% 68%

0% 4% 10% 29% 56%

2% 2% 37% 26% 33%

0% 1% 2% 18% 79%

0% 1% 5% 22% 72%

0% 1% 4% 16% 78%

1% 7% 14% 34% 43%

1% 2% 3% 23% 72%

0% 2% 7% 31% 59% 

0% 2% 18% 31% 50%

0% 0% 2% 21% 76%

0% 2% 8% 34% 56% 

1% 1% 7% 26% 66%

4% 1% 62% 14% 19%

2% 3% 59% 13% 24%

3% 8% 13% 43% 33%

5% 11% 52% 20% 12%

3% 10% 53% 20% 15%

1% 3% 57% 17% 22%
A-9 

3. If you have any comments about the services, facilities, and activities at this Refuge, please write them on the lines 

below. 

__________________________________________________________________________________________________ 

__________________________________________________________________________________________________ 

__________________________________________________________________________________________________ 

SECTION 5. Your opinions regarding National Wildlife Refuges and the resources they conserve 

1. Before you were contacted to participate in this survey, were you aware that National Wildlife Refuges... 

...are managed by the U. S. Fish and Wildlife Service?  Yes  No

...have the primary mission of conserving, managing, and restoring fish, 

wildlife, plants and their habitat?  Yes  No

2. Compared to other public lands you have visited, do you think Refuges provide a unique recreation experience? 

 

 Yes  No

3. If you answered “Yes” to Question 2, please briefly describe what makes Refuges unique. _____________________ 

______________________________________________________________________________________________ 

 ______________________________________________________________________________________________ 

______________________________________________________________________________________________ 

______________________________________________________________________________________________ 

92%

95%

8%

5%

96% 4%

See Appendix B

See Appendix B
A-10

4. There has been a lot of talk about climate change recently. We would like to know what you think about climate 

change as it relates to fish, wildlife and their habitats. To what extent do you disagree or agree with each statement 

below? (Please circle one number for each statement.) 

SECTION 6. A Little about You

** Please tell us a little bit about yourself. Your answers to these questions will help further characterize visitors to 

 National Wildlife Refuges. Answers are not linked to any individual taking this survey. ** 

1. Are you a citizen or permanent resident of the United States? 

 Yes  No  If not, what is your home country? ____________________________________

 

2. Are you?  Male  Female 

3. In what year were you born? _______ (YYYY) 

Statements about climate change Strongly 

Disagree Disagree Neither Agree

Strongly 

Agree

I am personally concerned about the effects of climate change on 

fish, wildlife and their habitats. 1 2 3 4 5

We can improve our quality of life if we address the effects of 

climate change on fish, wildlife and their habitats. 1 2 3 4 5

There is too much scientific uncertainty to adequately understand 

how climate change will impact fish, wildlife and their habitats. 1 2 3 4 5

I stay well-informed about the effects of climate change on fish, 

wildlife and their habitats. 1 2 3 4 5

It is important to consider the economic costs and benefits to local 

communities when addressing the effects of climate change on fish, 

wildlife and their habitats.

1 2 3 4 5

I take actions to alleviate the effects of climate change on fish, 

wildlife and their habitats. 1 2 3 4 5

There has been too much emphasis on the catastrophic effects of 

climate change on fish, wildlife and their habitats. 1 2 3 4 5

Future generations will benefit if we address the effects of climate 

change on fish, wildlife and their habitats. 1 2 3 4 5

My experience at this Refuge would be enhanced if this Refuge 

provided more information about how I can help address the effects 

of climate change on fish, wildlife and their habitats.

1 2 3 4 5

2% 4% 4% 25% 66%

3% 3% 6% 27% 61%

36% 32% 7% 17% 9%

0% 5% 18% 50% 26%

2% 12% 13% 49% 23%

1% 6% 17% 51% 24%

50% 29% 9% 7% 5%

2% 4% 4% 25% 65%

6% 9% 27% 43% 14%

98% 2%

53% 47%

1952

See Figure 4 in Report
A-11

4. What is your highest year of formal schooling? (Please circle one number.) 

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20+

(elementary) (junior high or

middle school)

(high school) (college or 

technical school)

(graduate or 

professional school)

5. What ethnicity do you consider yourself?  Hispanic or Latino  Not Hispanic or Latino 

6. From what racial origin(s) do you consider yourself? (Please mark all that apply.) 

  American Indian or Alaska Native  Black or African American  White

  Asian  Native Hawaiian or Pacific Islander

7. How many members of your household contribute to paying the household expenses? ______ persons

8. Including these members, what was your approximate household income from all sources (before taxes) last 

year?

  Less than $10,000  $35,000 - $49,999  $100,000 - $149,999

  $10,000 - $24,999  $50,000 - $74,999  $150,000 - $199,999

  $25,000 - $34,999  $75,000 - $99,999  $200,000 or more

9. How many outdoor recreation trips did you take in the last 12 months (for activities such as hunting, fishing, wildlife 

viewing, etc.)?

 _______ number of trips 

Thank you for completing the survey. 

There is space on the next page for any additional comments you 

may have regarding your visit to this Refuge. 

0% 5% 39% 56%

0% 100%

2% 0%

3% 1%

2

99%

0%

3%

6%

15

10%

26%

21%

19%

7%

7%

See Appendix B for Comments
This page left blank intentionally. 
Appendix R

Improving Aquatic Health

Appendix Q

NWR Visitor Survey

Malheur Lake

©Barbara Wheeler

Appendix R

Improving the Aquatic Health of 

Malheur National Wildlife Refuge

Appendix P

Hunting Plan

Appendix O

Sustainability

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix S

Response to Comments

Appendix B

Compatibility Determinations

Appendix L

Ecology Work Group

Improving the Aquatic Health of Malheur 

National Wildlife Refuge 

Authored by Linda Beck, Adam Daniel, and Shannon Hurn 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Acknowledgements: Malheur National Wildlife Refuge would like to thank all the collaborators 

who contributed to the completion of this document. A special thanks goes to Bruce Taylor, 

Gary Ivey, Jenny Barnett, Peter Sorensen, Bridgette Flanders-Wanner, Joe Engler, Tim Mayer, 

Lara Bjork, and Sharon Selvaggio for providing edits. 

Title page photos, clockwise from top left: 1. Canvasback duck, 2. Western grebes, 3. American white 

pelican, 4. White-faced ibis and snowy egret, 5. River otter, 6. American coot with chicks, 7. American 

avocet with chicks.
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-1 

R.1 Executive Summary 

This plan for carp control and improving aquatic health in the Harney Basin (the Basin) was 

formulated by melding information from the Malheur National Wildlife Refuge 2010 Invasive 

Common Carp Workshop, the 2008 Refuge Carp Management Plan (updated from January 1998), 

the 2010 Harney Basin Common Carp Management Plan to Improve Malheur Lake Water Quality, 

and the 2012 Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan and 

Environmental Impact Statement. 

The non-native common carp (Cyprinus carpio, L.) established breeding populations in the Basin 

during the first half of the twentieth century. As a result, Malheur Lake (the Lake) and most 

connecting waterways and water bodies have transitioned from a macrophyte-dominated, clear-water 

state to a phytoplankton-dominated, turbid-water state. The ecological collapse caused by common 

carp has reduced waterfowl production at Malheur National Wildlife Refuge (the Refuge) to an 

estimated one-tenth of the average 100,000 ducklings produced annually in the 1940s, before carp 

populations reached high densities (Cornely 1982). After decades of opportunistic carp control 

(including five rotenone treatments), managers, partners, and other collaborators are proposing a 

Basin-wide, long-term carp control plan to improve water quality not only on the Refuge, but also 

within the surrounding Basin. The Refuge’s highest priority management action is to control the carp 

population to return the Refuge to its full biological potential as habitat for migratory and resident 

birds. If the overall aquatic health of Refuge waters is improved, bird populations would have the 

habitat they need. This document outlines the historical perspective, management action priorities, 

and a path forward to address this invasive species problem. This plan’s integrated pest management 

control strategy is based on the assumption that eradication is realistic in some areas but not in other 

areas due to the high degree of complexity and extreme variability in waterway and water body 

interconnectivity within the Basin. The plan’s sustainable carp control priorities and actions are 

congruent with the Refuge’s Comprehensive Conservation Plan aquatic health goals and objectives. 

Although there is wide recognition and support for a comprehensive carp control management 

program in the Basin, implementation is challenged by a lack of funding. Sustainable implementation 

funding would need to be acquired 

opportunistically and entrepreneurially from 

public and private funding sources. 

The Refuge was established because it provided 

outstanding habitat for wildlife, particularly 

migratory birds, but because of common carp, the 

Refuge’s aquatic health has deteriorated greatly 

since its establishment. Controlling carp is not 

simple, but the Refuge’s carp population must be 

controlled, so that these lands and waters can 

once again be home to flourishing populations of 

native species that the Refuge is intended to 

support. 

 

Figure R-1. Refuge Manager herding carp to 

sample for fish health and population 

dynamics at Crane Pond in 2010. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-2 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Contents 

R.1 Executive Summary .......................................................................................................................................... R-1

R.2 Introduction ....................................................................................................................................................... R-5

R.3 The Problem: Carp Impacts ............................................................................................................................... R-7

R.4 Plan Goals and Management Priorities ........................................................................................................... R-10

R.5 Information Needs ........................................................................................................................................... R-11

R.6 The Solution: A Scientific, Strategic Approach to Aquatic Health Improvement ........................................... R-12

R.6.1 Overview of Approach ............................................................................................................................... R-13

R.6.2 Role of Adaptive Management and Integrated Pest Management ............................................................. R-13

R.6.3 Methods for Baseline Data Inventories and Ongoing Monitoring ............................................................. R-14

Water Quality .................................................................................................................................................. R-14

Aquatic Vegetation .......................................................................................................................................... R-15

Macroinvertebrates .......................................................................................................................................... R-15

Birds ................................................................................................................................................................ R-16

Fish .................................................................................................................................................................. R-16

R.6.4 Carp Population Determination .................................................................................................................. R-17

R.6.5 Carp Movement and Aggregation Determination ...................................................................................... R-18

R.6.6 Carp Dynamics Modeling .......................................................................................................................... R-18

R.7 Carp Control Strategies ................................................................................................................................... R-19

R.7.1 Techniques and Technologies in Use ......................................................................................................... R-20

Water Manipulation ......................................................................................................................................... R-20

Traps ................................................................................................................................................................ R-20

Netting ............................................................................................................................................................. R-21

Fish Screens and Barriers ................................................................................................................................ R-21

Electro-shocking .............................................................................................................................................. R-21

Bait Stations ..................................................................................................................................................... R-22

R.7.2 Techniques and Technologies That May Be Used to a Limited Extent ..................................................... R-22

Rotenone .......................................................................................................................................................... R-22

Water Pumping ................................................................................................................................................ R-22

R.7.3 Techniques and Technologies That Are Unlikely to Be Used Again ......................................................... R-23

Poison Bait Stations ......................................................................................................................................... R-23

R.7.4 Planned New Techniques and Technologies .............................................................................................. R-23

Commercial Harvest ........................................................................................................................................ R-23

Robotic Carp .................................................................................................................................................... R-23

R.7.5 Potential New Techniques and Technologies ............................................................................................ R-24

Catchment Basins ............................................................................................................................................ R-24

Barriers ............................................................................................................................................................ R-25

Fish Wheels ..................................................................................................................................................... R-25
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-3 

Sex Pheromones/Attractant ............................................................................................................................. R-25

Koi Herpes Virus ............................................................................................................................................. R-26

Daughterless Carp............................................................................................................................................ R-26

R.8 Summary ......................................................................................................................................................... R-26

R.9 References ....................................................................................................................................................... R-26

Figures 

Figure R-1. Refuge Manager herding carp to sample for fish health and population dynamics at Crane 

Pond in 2010. ............................................................................................................................................ R-1

Figure R-2. East Knox Pond flourishes with life due to water manipulations. ......................................... R-5

Figure R-3. Examples of the 1992 drought year and 1984 high water levels at Malheur Refuge. ........... R-6

Figure R-4. Carp research being conducted by Refuge staff and a University of Minnesota post-doctoral 

fellow in Malheur Lake. Notice no vegetation and very turbid water. ..................................................... R-7

Figure R-5. Explanation of common carp impacts on the aquatic environment. ...................................... R-8

Figure R-6. An estimated 1.5 million mortalities caused by 1955 rotenone treatment. ............................ R-9

Figure R-7a. Trumpeter swan with cygnets swimming in a healthy, vegetated water body. Figure R-7b. A 

view of a healthy marsh with open water and islands of vegetation. ...................................................... R-10

Figure R-8. Common carp impact areas. ................................................................................................ R-11

Figure R-9. Refuge fish biologist in the process of implanting a telemetry tag in a fish caught and released 

in Boca Lake. .......................................................................................................................................... R-12

Figure R-10. Refuge Manager and fish biologist removing fish netted in a trammel net on Boca 

Lake. ....................................................................................................................................................... R-13

Figure R-11. Submergent vegetation in Malheur Lake. .......................................................................... R-15

Figure R-12a. Collaboration by USGS and USFWS collecting aquatic macroinvertebrates on the 

Refuge. .................................................................................................................................................... R-15

Figure R-12b. Collaboration with retired ODFW biologist on native freshwater mussel monitoring. ... R-15

Figure R-13. Youth Conservation Corp students helping collect fish data. ............................................ R-16

Figure R-14. Pied billed grebe with chicks getting a ride from mom. .................................................... R-16

Figure R-15. Mark and recapture study being conducted by the University of Minnesota. Fish are netted 

below the ice, fins are clipped, and fish are measured prior to being rereleased. ................................... R-18

Figure R-16. Summer interns collecting water chemistry and telemetry data. ....................................... R-18

Figure R-17. A simplified visual representation of the carp modeling system. ...................................... R-19

Figure R-18. A water control structure at Barn Yard Spring in the Double-O Unit. .............................. R-20

Figure R-19. Operating fish screen on the West Canal at Page Springs Dam. ....................................... R-21

Figure R-20. Electro-shocking for carp below Sodhouse Dam. ............................................................. R-21

Figure R-21. In 1992 Refuge staff made a huge effort to drain Headquarters Pond with two Crissafulli 

pumps to remove carp. ............................................................................................................................ R-22

Figure R-22. Prototype of the robotic carp. ............................................................................................ R-24

Figure R-23. Native redband trout. ......................................................................................................... R-24

Figure R-24. Computer simulated design of experimental carp wheel. .................................................. R-25

Figure R-25. Blood sample of common carp submitted to Oregon State University for koi herpes virus 

genetic testing. ........................................................................................................................................ R-26

 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-4 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Plan continues on following page. 
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-5 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge

R.2 Introduction 

The vast wetlands and wet meadows of the Harney Basin (the Basin) in southeast Oregon have long 

been recognized as some of the most important wetland habitat for migratory birds in the Pacific 

Flyway. The lakes, rivers, and marshes within the Malheur National Wildlife Refuge (the Refuge), 

and other seasonal floodplain wetlands and wet meadows found on private lands across the Basin, are 

used by hundreds of thousands of migrating and breeding waterfowl, shorebirds, and other water 

birds. These same wetted habitats sustain a rich diversity of native fish and wildlife, ranging from 

redband trout to yellow-headed blackbirds and spotted frog. However, invasion of the Basin’s 

wetlands by non-native common carp (Cyprinus carpio) in the late 1930s triggered long-term 

negative ecological changes that have dramatically reduced wetland habitat productivity for 

migratory birds and other native fish and wildlife. 

Figure R-2. East Knox Pond flourishes with life due to water manipulations. 

High densities of common carp in Malheur Lake (the Lake), a 32,000-acre marsh at average water 

levels, have caused increased turbidity in the Lake, which in turn has harmed the Lake in three key 

ways: the Lake is void of submergent and emergent aquatic vegetation, water quality is degraded, 

and waterfowl productivity has severely decreased. These impacts can also be found in other 

wetlands and rivers throughout the Basin. The Lake and its connecting waterways and water bodies 

have transitioned from a macrophyte-dominated, clear, stable state to a phytoplankton-dominated 

turbid state. The ecological collapse of this highly productive system is reflected in waterfowl 

production on the Refuge, which has declined by an estimated 90 percent from its historically 

documented peak (Cornely 1982). 

From an ecological perspective, the highest priority is to restore water quality in the Lake, the 

biological heart of the Refuge and historically the most productive wetland habitat in the Basin. 

Efforts to reach this goal will rely on three key principles. First, control is more realistic than 

complete eradication. Second, collaboration throughout the Basin is essential. Finally, all decisions 

and actions must be part of a cycle of adaptive management that is informed by scientifically valid 

data and analysis. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-6 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Eradication of common carp in the Basin as a whole is considered nearly impossible using current 

methods, because of the complexity of the waterways connecting to the Lake and wide annual 

fluctuations in water levels (Figure 3). Carp control technologies are evolving, and may eventually 

provide methods to control carp populations over large water systems. The relatively long life-span 

and high fecundity of common carp will require a multifaceted sustainable approach to population 

control, including but not restricted to harvesting, trapping, piscicide application, hormone 

attractants, and barrier infrastructure, all of which could be employed to remove carp from the Basin. 

Implementation of carp control efforts to restore the health of aquatic habitats in the Lake and Basin 

wetland systems will require investments on a scale that is beyond the capacity of any single agency 

or organization. Successful, sustainable implementation will require partnerships among public 

agencies, nongovernmental organizations, and private landowners, with funding from a variety of 

Federal, state, and private sources. Development of these collaborative partnerships is already 

underway. 

In March 2010, the Refuge hosted an invasive common carp workshop that produced broad 

agreement among a wide variety of stakeholders, collaborators, and interested parties about the 

pressing need to improve the Refuge’s and the Basin’s aquatic health by controlling carp. This 

workshop also spurred the establishment of the Aquatic Health Coalition. 

Figure R-3. Examples of the 1992 drought year and 1984 high water levels at Malheur Refuge.

The Refuge, with its 60 collaborators, has drafted a comprehensive conservation plan (CCP) that will 

guide Refuge management over the next 15 years. This collaborative planning group quickly 

identified the Refuge’s poor aquatic health as the most pressing and immediate issue to address. The 

CCP’s management direction focuses future staff time and resources on reducing the carp density to 

<100 pounds per acre. A study by Bajer et al. (2009) suggests that at this biomass level, the negative 

impacts of carp are mitigated, allowing aquatic plant and animal populations to maintain reasonable 

levels. The Refuge, in cooperation with its public and private collaborators, will seek to achieve this 

goal using replicable protocols for data gathering during inventory and monitoring, as well as testable 
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-7 

methods of carp control. Through the combination of maintaining biological integrity, using best 

available science, and employing adaptive management, the Refuge will make data-driven 

adjustments to carp control. 

This document is considered a “step-down” plan from the CCP, which means that this plan provides 

additional details on how the Refuge will implement strategies to reduce carp biomass to <100 

pounds per acre. The CCP goals and objectives that relate to carp management are presented in 

Chapter 2 of the CCP, and information on the implementation and priorities related to aquatic health 

is included in Appendix C. This document also complements the 2010 Harney Basin Common Carp 

Management Plan to Improve Malheur Lake Water Quality developed by the Natural Resources 

Conservation Service (NRCS). The NRCS and the Refuge will work together closely to implement 

these two plans; in fact, the Refuge is the lead agency for the NRCS plan. The carp control strategy 

outlined in this document focuses heavily on the Lake and other wetlands within the Refuge. These 

aquatic habitats were identified as the highest priority for initial control efforts. Initial population 

assessment work is already underway, and the Refuge has identified specific options for carp control 

at numerous sites, including some on adjacent lands. In the long run, however, control of carp will 

require cooperative efforts across the Basin with involvement of private landowners as well as public 

agencies. Because funding for these efforts will necessarily come from a variety of sources, 

implementation will occur as opportunities arise. As part of the work of the Aquatic Health Coalition, 

collaborators will coordinate their efforts to identify, pursue, and direct funding to the highest 

priority actions. 

R.3 The Problem: Carp Impacts 

The negative impacts of common carp have been apparent at the Lake for decades. The Silvies River 

provided an entry point into the Lake, where carp were acknowledged to be invasive in 1952 

(Thompson and Littlefield 1980). Due to a lack of natural or artificial physical barriers, carp migrated 

up the Blitzen River and spread throughout the Blitzen Valley wetlands over the next 10 years. 

During the years of 1952, 1957, and 1958, the natural land bridge between Harney and Mud lakes 

was breached, allowing carp to invade the Double-O Unit wetlands. By the early 1960s, carp were 

established in large numbers throughout the Refuge and began to have an adverse impact on 

production of aquatic plants and aquatic invertebrates. In the 1980s, high water levels again resulted 

in a barrier breach. At that time, ice shears may have changed both the bathymetry and chemistry of 

the Lake; since that time, the water has been very turbid (Figure S-4). 

Figure R-4. Carp research being conducted by 

Refuge staff and a University of Minnesota 

post-doctoral fellow in Malheur Lake. Notice 

no vegetation and very turbid water.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-8 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Carp have many negative impacts on aquatic habitats, namely by competing with other species for 

food, causing turbidity to increase, and ultimately decreasing waterfowl productivity and use (Figure 

S-5). As carp search for aquatic invertebrates, they compete directly with other aquatic wildlife by 

consuming and uprooting submersed aquatic plants. These plants, especially sago pondweed 

(Potamogeton pectinatus), are important foods for other wildlife and provide a critical part of the 

subsurface habitat used by aquatic invertebrates and native fish. 

Carp alter the aquatic ecosystem when feeding by causing water turbidity. While feeding on the 

bottom, they vigorously roil the water in search of food, which stirs up the sediment and organic 

material and suspends this material in the water column. Consequently, subsurface sunlight needed 

for plant growth is reduced or eliminated, and photosynthetic plant production and oxygen levels 

decrease. With high concentrations of carp, the effects of swimming and spawning also contribute to 

increased turbidity. Eventually carp can change the physical environment of an aquatic system to a 

point where only a few species of fish, invertebrates, and plants can survive in low numbers; the 

Lake and other water bodies on the Refuge have reached these conditions. Even after carp are 

removed from a wetland system it may take several years for the wetland to return to a clear-water 

system. This is a result of the long-term presence of carp, the shift from a submerged aquatic vascular 

plant–dominated system to one dominated by phytoplankton, and the loss of wave dissipation 

provided by the submerged aquatic plants. 

Habitat impacts of carp at the Refuge have been monitored using data collected from annual pond 

surveys, which measure several factors affecting water quality, including carp numbers, temperature, 

turbidity, pH, plant cover, abundance, and diversity. These surveys indicate that ponds with high carp 

numbers have poor quality rating (Wenick 2010). 

During the 1940s, duck production on the Refuge averaged over 100,000 ducklings1

 (Cornely 1982). 

Today, the Refuge annually produces approximately 10 percent of the ducklings (8,000 to 12,000) it 

                                                           

1

 Cornely (1982) notes that methods of estimating duck and goose production varied through the years: 

 1942-1945: Estimates based on general field observations; no standardized sampling procedures were used. 

Figure R-5. Explanation of 

common carp impacts on the 

aquatic environment.
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Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-9 

is estimated to have produced annually during the 1940s, with breeding primarily restricted to the 

managed wetlands in the Blitzen Valley and Double-O units. Waterfowl production and waterfowl 

use are directly related to the total number of acres of sago pondweed produced annually on the 

Refuge; the more aquatic vegetation available, the higher the level of waterfowl use. Prior to a major 

influx of carp in 1952, the Lake was noted for high levels of vegetation, especially sago pondweed. 

Between 1953 and 1954, sago pondweed declined by 80 percent, with no evidence of this plant 

remaining in the Lake by 1955 (Ivey et al. 1998). However, sago pondweed will rebound if carp 

biomass is decreased. As shown from analysis of historical data from the Refuge (see Chapter 6 of 

the Malheur Refuge CCP/EIS), there is a statistically significant relationship between acres of sago 

pondweed and breeding pairs of diving ducks on the Lake (Ivey et al. 1998). 

Previous Refuge experience has shown that reducing the number of carp has a positive effect on bird 

populations and vegetation. There have been several good years of production (up to 60,000 birds) 

after large rotenone projects on the Lake (Ivey et. al.1998). The use of the Lake by dabbling ducks 

and diving ducks post-rotenone treatment increased by as much as 116 percent and 70 percent, 

respectively. Sago pondweed acreage has also increased substantially after carp control treatments; in 

1955 and 1992, for instance, there was no sago pondweed in the Lake, but after rotenone treatments 

in those years, sago pondweed covered 16,900 and 10,000 acres, respectively (Ivey et al. 1998). 

Unfortunately, positive responses to carp control treatments have been short-lived. 

Figure R-6. An estimated 1.5 million mortalities caused by 1955 rotenone treatment.

                                                                                                                                                                                               

 1946-1952: Estimates based on nest success from nesting studies. No standardized routes were used for 

breeding pair or brood counts. 

 1953-1955: Dearth of information. Estimate based on general observations during routine field activities. 

 1956 -1960: Estimates based on pair, nest, and brood observations from sample plots checked twice a month 

during the breeding and brooding season. Those results were supplemented with general observations during 

aerial, boat, and ground surveys. 

 1961-1967: Estimates based on random ground and aerial surveys of breeding pairs and random brood counts 

on the principal brooding areas. 

 1968-1971: Breeding pairs and broods were censused along standard aerial, boat, and ground routes, and 

nesting success was determined from sample plots. Production estimates were based on extensive brood counts. 

 1972-1980: Estimates calculated by multiplying the breeding pair estimate by nest success by mean brood size 

just prior to fledging. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-10 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Avian species are particularly important because the Refuge was established to protect birds (see 

Chapter 1). Improved aquatic health results in better habitat for these birds, as well as other native 

species of fish, macroinvertebrates, plants, and other organisms that are currently being negatively 

affected by carp. 

Figure R-7a. Trumpeter swan with cygnets swimming in a healthy, vegetated water body. 

Figure R-7b. A view of a healthy marsh with open water and islands of vegetation.

R.4 Plan Goals and Management Priorities 

To improve aquatic health, the Refuge has established a quantitative objective of reducing carp in 

lacustrine habitats to a level not to exceed 100 pounds of carp per acre. The 100 pounds per acre 

figure is an estimate of the appropriate threshold, or the theoretical biomass of common carp that can 

be tolerated by the system and still maintain acceptable conditions for aquatic vegetation and 

waterfowl use. This estimate was made based on the 100 kilogram per hectare threshold noted in 

Bajer et al. (2009). The Bajer study was based on observations of a smaller Midwestern system in 

decline as opposed to a large Great Basin system in recovery, so the figure may need adjustment over 

time. The Refuge has set this goal as a means to restore the biological integrity of its water bodies 

and adjacent lands in a way that should be sustainable for the long term. If achieved and sustained 

over time, the Refuge should have increased bird use, increased vegetation, larger populations of 

native fish, better water quality, and a healthier ecosystem. Although it is recognized that other 

factors may be contributing to declining waterfowl use, carp are known to be a dramatic perturbation 

in the system that must be addressed. 

The different areas impacted by carp have been identified by level of importance to help formulate a 

strategic path forward. The most ecologically important portion of the Basin impacted by carp is 

Malheur Lake. The Refuge and collaborating members of the Aquatic Health Coalition have agreed 

that funding should be prioritized based on connectivity and potential impacts to water quality within 

the Lake, as follows: 1) Malheur Lake, 2) Blitzen Valley, 3) Silvies River, and 4) Double-O (Figure 

S-8). 

 
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Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-11 

Figure R-8. Common carp impact areas.

R.5 Information Needs 

To reach the goal of improved aquatic health (with attendant benefits to waterfowl and other native 

species), the Refuge needs pre-treatment data (current or baseline conditions) and post-treatment data 

for the following parameters: 

 Water quality, as indicated by dissolved oxygen, conductivity, water temperature, and 

salinity, pH, turbidity, chlorophyll A, and total suspended solids 

 Aquatic vegetation abundance and species types 

 Macroinvertebrate abundance and family to genus types 

 Point count for passerines and secretive marsh birds 

 Total count for large birds (waterfowl, water birds, wading birds) 

 Bird brood counts (productivity estimates) 

 Fish assemblage 

 Carp age structure 

 Carp location and movement patterns 

 Carp biomass 

Estimating the biomass of carp before and after treatment is especially important for assessment of 

success toward the 100 pounds per acre target. Removing the first 80 percent of the carp population 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-12 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

will be exponentially cheaper than eradicating the last 20 percent, so it will be important for 

managers to determine the most cost-effective methods for reducing carp biomass in the Lake and the 

Basin. The Refuge has two key questions to answer in pursuing the 100 pounds per acre threshold: 

 How many pounds of carp must be removed each year to reach the 100 pounds per acre 

threshold? 

 Do the key biotic and abiotic parameters listed above improve sufficiently with a threshold of 

100 pounds per acre, or should the threshold be adjusted? In essence, is 100 pounds per acre 

the right threshold for the Refuge’s water bodies? 

To obtain all of this information, the Refuge needs a scientifically valid approach to data gathering. 

Please see Appendix C for the implementation table of CCP goals and objectives that pertain to 

aquatic health improvement. 

R.6 The Solution: A Scientific, Strategic Approach to Aquatic 

Health Improvement 

This plan differs from previous management plans by acknowledging that complete eradication of 

common carp is impractical, that much collaboration throughout the Basin is needed for long-term 

success, and that scientifically valid approaches must be employed. Adaptive management and 

integrated pest management (IPM) will be applied throughout these efforts to optimize applied 

science and aquatic health. All protocols and data gathering will follow strict quality control and 

quality assurance guidelines. 

Figure R-9. Refuge fish biologist in the 

process of implanting a telemetry tag 

in a fish caught and released in Boca 

Lake.
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Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-13 

R.6.1 Overview of Approach 

While exact time lines are dependent on many factors (most notably funding), the Refuge’s approach 

will consist of the following steps: 

1. Compilation of historical data on aquatic health on the 

Refuge, evaluation of the protocols used to collect those 

data, and development of protocols to collect new data that 

will be comparable to historical data. 

2. Pilot study at Boca Lake, because it is similar to Malheur 

Lake but smaller, easier to access, and therefore more 

manageable. The pilot study will involve: 

A. Baseline data inventory 

B. Implementation of carp control strategies 

C. Effectiveness evaluation and monitoring 

3. Application of Boca Lake protocols to other Refuge 

locations, with Malheur Lake as the top priority, including 

the following steps: 

A. Review of Boca Lake results to determine 

applicability to new setting(s): What adjustments, if any need 

to be made? 

B. Baseline data inventory 

C. Implementation of carp control strategies 

D. Effectiveness evaluation and monitoring 

4. Review of Refuge results to determine applicability to locations in the Harney Basin outside the 

Refuge. This review will be conducted by the Refuge and collaborating members of the Aquatic 

Health Coalition, with implementation steps to be followed in the NRCS Harney Basin plan. 

Although this approach is presented here as distinct steps, the process of implementation will be 

more dynamic and iterative, to account for learning, adjustments and funding availability along the 

way, in part because of the use of adaptive management and IPM. 

R.6.2 Role of Adaptive Management and Integrated Pest Management 

The Refuge will be melding adaptive management principles with IPM to restore the aquatic health 

and biological integrity of Refuge habitats. Adaptive management is a decision process that promotes 

flexible, informed decision making and that allows adjustment as outcomes from management 

actions and other events become better understood. Careful monitoring of these outcomes advances 

scientific understanding and helps adjust policies or operations as part of an iterative learning 

process. Adaptive management recognizes the importance of natural variability in contributing to 

ecological resilience and productivity. It is not a “trial and error” process but, rather, emphasizes 

learning while doing. Adaptive management does not represent an end in itself, but is a means to 

more effective decision making, more efficient management, and other enhanced benefits. It helps 

meet environmental, social, and economic goals; increases scientific knowledge; and reduces 

tensions among stakeholders (Williams et al. 2007). 

Figure R-10. Refuge Manager and 

fish biologist removing fish netted 

in a trammel net on Boca Lake.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-14 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

IPM is an interdisciplinary approach using methods to prevent, eliminate, contain, and/or control pest 

species in concert with other management activities on Refuge lands and waters to achieve wildlife 

and habitat management goals and objectives. IPM is also a scientific, adaptive management process 

where available scientific information and best professional judgment of the Refuge staff as well as 

other resource experts are used to identify and implement appropriate management strategies that can 

be modified and/or changed over time to ensure effective, site-specific management of pest species to 

achieve desired outcomes. An IPM approach will be used, where practicable, to eradicate, control, or 

contain pest and invasive species on Refuge lands. IPM involves using methods based upon 

effectiveness, cost, and minimal ecological disruption, which consider minimum potential effects to 

non-target species and the Refuge environment in accordance with 517 DM 1 and 569 FW 1. 

Adaptive management and IPM both rely on scientifically verifiable information to determine a 

method’s effectiveness, and they both involve taking a system-level perspective to understand 

impacts. The management approaches differ in that IPM can provide a great deal of detail about 

particular methods and how to evaluate their impacts, whereas adaptive management takes a broader 

view of methods and their impacts. For example, IPM provides a structured procedure to evaluate the 

potential effects of proposed uses of a pesticide on biological resources and environmental quality; 

an IPM approach to pesticide use involves determining the smallest amount of a chemical that would 

have the desired effect on the target species. After a pesticide is applied according to an IPM 

protocol, the adaptive management framework involves evaluating the technique’s success and, if 

appropriate, identifying either modifications to the technique or a new method to be used in the 

future. 

R.6.3 Methods for Baseline Data Inventories and Ongoing Monitoring 

Together, baseline inventory data and ongoing monitoring data will present a complete picture of the 

effectiveness of carp control methods and the state of aquatic health before and after carp control 

treatments. 

Inventory is defined as: “a survey that documents the presence, relative abundance, status, and/or 

distribution of abiotic resources, species, habitats, or ecological communities at a particular time” 

(701 FW 2, in draft). Inventories will be conducted prior to any control measures for common carp. 

Monitoring is defined as “a survey repeated through time to determine changes in the status and/or 

demographics of abiotic resources, wildlife or plants, habitats, or ecological communities” (701 FW 

2, in draft). The Refuge will monitor all baseline data parameters for specific amounts of time posttreatment. Collaborators will assist the Refuge in determining the methods and duration of 

monitoring for specific projects. 

The following methods will be used to establish baseline data and conduct post-treatment 

monitoring. Note that these methods may be modified if evaluation of historical collection protocols 

reveals a meaningful difference that would prevent comparison between new and old data. 

Water Quality 

Using ArcGIS-generated randomized sampling locations in a given water body, water samples will 

be collected at the same time as vegetation samples. The number of sampling locations will be 

determined for each water body, depending on its size. Using a YSI 85 digital meter, the following 

parameters will be tested: dissolved oxygen (percent and mg/L), conductivity (S), water 
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Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-15 

temperature (C), and salinity (ppt); pH will be tested using a Piccolo plus HI 1295 amplified 

electrode. Turbidity will also be evaluated using a secchi disc. Samples of chlorophyll A and total 

suspended solids taken at a subset of the randomized points will be collected in accordance with 

laboratory sampling procedures of the contracted laboratory (available online at 

http://www.aquaticresearchinc.com/). 

Aquatic Vegetation 

At the same locations where water samples 

will be collected for the water body being 

studied, aquatic vegetation will be sampled 

following the method described below. The 

site will be sampled once during the peak 

annual abundance (mid to late June). A 1 m2

polyvinyl chloride (PVC) pipe–constructed 

square will be placed at the global 

positioning system (GPS)–identified sample 

location. A visual estimate to the nearest 10 

percent of vegetative cover will be made. A 

rake will be used to sample the benthic 

vegetation by twisting the rake three times 

in the square and pulling it up. The water 

will be drained for 20 seconds, and the 

weight of the vegetation will be collected 

using a digital scale. Species collected will 

be identified, and all data recorded, as 

outlined in Bajer et al. (2009). 

Macroinvertebrates 

Using a D-frame aquatic 

net, 15 samples of 1 m2

 of 

benthic environment in a 

given water body will be 

sampled for 30 seconds 

using a randomized 

sampling design for 

quantitative numbers of taxa 

and individuals, as 

explained by Rabeni (1996). 

The samples collected will 

be stored in 1,000-mL 

heavy-duty, wide-mouth 

Nalgene high-density 

polyethylene (HDPE) 

bottles. Two identical labels will be used, one on the inside and one attached to the outside of the 

container. The samples will be preserved in 95 percent ethanol and shipped to a contracted lab for 

Figure R-11. Submergent vegetation in Malheur 

Lake.

Figure R-12a. Collaboration by USGS and USFWS collecting 

aquatic macroinvertebrates on the Refuge. 

Figure R-12b. Collaboration with retired ODFW biologist on 

native freshwater mussel monitoring.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-16 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

identification. Different protocols for flowing water and standing water will be observed, following 

Rabeni (1996). 

Birds 

The Refuge will use standardized protocols to determine 

baseline relative bird abundance by habitat type for each 

water body being studied. These data will be compared to 

post-treatment data to assess the effects of carp control 

practices and to determine long-term trends after carp 

removal. Under the important bird area (IBA) protocol, each 

observation point will be recorded with a GPS unit and 

marked with a survey marker around the perimeter of the 

given water body. Each point shall be monitored for 8 

minutes after waiting 1 minute post arrival to the point. The 

points will be surveyed from sunrise till 10 am during 

suitable weather conditions. Points will be monitored a 

maximum of once a week for the duration of the project. 

Data collected will be the date, name of observer(s), start 

time and end time of survey, weather conditions (drizzle, 

overcast, broken, scattered, clear), air temperature at start 

and end of survey, and wind speed (0-5 miles per hour 

[mph] or 6-12 mph). Counts of passerines, secretive marsh birds, waterfowl, water birds, wading 

birds, and broods will be conducted. 

Fish 

Multiple methods are necessary to obtain all the data needed regarding fish species. At least nine 

species of fish could be encountered during fish assemblage work. Data collected will be species, 

length, and sex when visible. 

Figure R-13. Youth Conservation Corp students helping collect fish data. 

Figure R-14. Pied billed grebe 

with chicks getting a ride from 

mom.
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Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-17 

R.6.4 Carp Population Determination 

Prior to treatment, it is important to obtain an accurate estimate of the total biomass of carp present in 

Refuge water bodies. These data will be essential for assessing whether the 100 pounds per acre 

target has been achieved and whether this threshold of carp biomass is sufficient to the overall goal 

of improved aquatic health. 

For small water bodies, carp population will be determined by sampling annually for 1 year pre-carp 

removal and 2 years post-removal; these methods are summarized from Hayes et al. (1996). For 

young-of-the-year and 1-year-old carp and other smaller sized fish, three trap nets will be set for 24 

hours at two positions in a given water body pre-carp removal. Post-treatment monitoring will entail 

using the same protocol and sampling each fall. Fish species and length data will be collected. All 

carp will be culled from the water body, anesthetized, and measured. Adult carp will be netted using 

a 100-m trammel net. Any non-carp fishes captured will be identified, measured, and released. 

For Malheur Lake, the Refuge will conduct a mark-recapture study. Mark-recapture studies require a 

significant investment of time and labor that could be used to remove carp from Malheur Lake, but 

without a solid estimate of carp biomass, such carp removal actions would not be grounded in data 

and it would be difficult, if not impossible, to assess success or failure. 

The mark-recapture study will involve netting fish, taking lengths, clipping a fin or putting a tag in 

the dorsal muscle, and releasing the fish. It will be important to use numbered tags or unique marks 

for each tagging location in the mark-recapture study to identify movement within and between 

management units. It is also important to sample multiple locations within each management unit to 

better estimate the biomass over varied habitat rather than marking all of the fish at the most 

convenient location. The recapture phase should be scheduled between 2 weeks and 1 month after 

marking. 

If connectivity exists between Malheur Lake and other management units, it will be important to 

mark individuals from all connected units. It would be ideal to mark at least 5 percent of the 

estimated population for each management unit. If Malheur Lake is the only management unit 

evaluated for a biomass estimate, it will be essential to monitor a subset of fish from connecting 

management units to estimate immigration (through a habitat use study). 

Because access to Malheur Lake can be difficult, it may be advantageous to conduct the marking 

and/or recapture during freezing temperatures. Carp typically aggregate when temperatures are low 

and can be easier to find; for instance, if a portion of a lake is frozen, carp will often cluster in the 

portion that still has open water. Under such conditions, it may be possible to identify aggregations 

located in deep holes or springs within each management unit. It may be possible to forego the initial 

mark-recapture study in the Malheur Lake management unit if Malheur Lake is at a very low level 

and a thorough chemical treatment can be conducted. An aerial count of carcasses could then be 

conducted (with ground verification in vegetated areas), and population structure could be 

determined from carcasses (length, weight, and age). However, unless the Blitzen Valley can be 

treated, it will still be necessary to conduct a separate population estimate and determine immigration 

rates using telemetry before the chemical treatment. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-18 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Figure R-15. Mark and recapture study being conducted by the University of Minnesota. Fish 

are netted below the ice, fins are clipped, and fish are measured prior to being rereleased.

R.6.5 Carp Movement and Aggregation Determination 

Forty-one advanced telemetry systems (ATS) low-frequency body cavity telemetry tags will be 

surgically implanted into the peritoneal cavity of adult common carp (larger than 1.5 pounds) 

randomly dip-netted out of the given water body. Fish will be caught, measured, and anesthetized. A 

1.5-inch superficial incision will be made behind the pelvic fin in the ventral surface. A telemetry tag 

will be aseptically planted into the cavity, and the incision will be sutured. The fish will be allowed 

to recover and then released. The telemetry tracking will be performed once a week to once a month 

for the life of the tags (~2 years). Results will be tracked by GPS units, and evidence of aggregations 

will be determined (Guy et al. 1996). 

 

Figure R-16. Summer interns collecting water chemistry and telemetry data.

R.6.6 Carp Dynamics Modeling 

Due to the size and the dynamic fluctuations of water in the Harney Basin, a dynamic model of carp 

population/biomass based on estimated common carp immigration, emigration, growth, mortality, 

and recruitment (population structure and habitat use data) would be a powerful tool for the 

management of carp in the Harney Basin. Such a model has been developed by Iowa State University 
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-19 

doctoral student Mike Colvin to aid the Refuge in understanding its carp population(s) (Figure S-17). 

To inform adaptive management decisions, the data collected for the baseline inventory and posttreatment monitoring will be integrated into this model as results are available. It is relatively easy to 

update models with refined data on an annual basis, and assuming funding is available for ongoing 

data collection, this model will be a valuable tool for the Refuge and its collaborators to use during 

ongoing carp management. 

Figure R-17. A simplified visual representation of the carp modeling system.

R.7 Carp Control Strategies 

The current aquatic ecosystem of the Refuge is out of balance due to the invasive common carp. 

Native fish species are being outcompeted by the highly fecund invasive carp. In addition, the 

environmental instability of the watershed due to extreme drought and wet years constitutes the 

perfect scenario for carp super-reproduction. Bajer et al. (in review) determined that in a stable 

environment, native predatory fish species prey on carp eggs and fry to suppress the population. 

However, in locations around the world that have environmental instability (i.e., winter hypoxia), the 

native predatory fish die during the winter due to lack of oxygen in cold water, while the carp 

migrate outside those areas in the winter, moving to deep water. The carp then spawn in the spring 

where native predation is suppressed. The Refuge’s carp control strategy must focus on a long-term 

sustainable solution, such as increasing native predatory fish species and finding ways to regain the 

balance of native organisms to keep the carp species suppressed. 

Under this plan, carp control will focus not only on immediately suppressing common carp, but also 

on impeding carp recovery. Carp control at the Refuge will include the following types of strategies, 

among others: 

 Manipulating water levels to reduce amount of carp habitat. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-20 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

 Annually removing carp, with nets, traps, commercial fishing, or other techniques. 

 Removing connectivity between water bodies. 

 Improving environmental conditions to favor native predatory fish. 

 Preventing successful spawning through chemical spot treatment. 

A multifaceted, sustainable approach will be the key to sustaining acceptable water quality in 

Malheur Lake. Additional techniques for carp control may be added if inventory and monitoring 

results show that adjustments are appropriate, as is consistent with adaptive management. A more indepth explanation of the control techniques, and the Refuge’s experiences with them, is provided 

below. 

R.7.1 Techniques and Technologies in Use 

These techniques have been used at some point on the Refuge and will continue to be part of carp 

control efforts. 

Water Manipulation 

The most effective and commonly used method on the Refuge has been seasonal or prescriptive 

draining of ponds and canals. The irrigation schedule alters from year to year depending on water 

availability and habitat needs; before manipulating water levels, the Refuge has to consider overall 

aquatic habitat needs as well as any bird species that have been identified as high priorities for the 

Refuge (also called focal species) when planning carp control. Yearly seasonal draining of water 

bodies is optimal, but some water bodies may only be drained and dried every 5 to 6 years due to the 

need for waterfowl habitat. 

Figure R-18. A water control structure at Barn Yard Spring in the Double-O Unit.

Traps 

Fish traps used on the Refuge have produced limited success, because they only catch a small 

proportion of fish and require daily maintenance when in use. Large permanent metal traps have been 

designed for Sodhouse, Busse, and Grain Camp dams on the Blitzen River to aid in the control of 

carp movement and will be installed as funding becomes available. 
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-21 

Netting 

Multiple types of netting have been used in the past and will continue to be used in the future. Hoop 

nets have been used in the main channel of the Blitzen River to collect carp. Gill nets have been used 

experimentally but proved unsuccessful. Trammel nets, which are a modified gill net, are very 

successful in netting carp and other species of fish. These nets are set up and checked daily for catch. 

Most fish can be released with minimal or no damage, but some incidental mortality to native species 

has occurred. Block nets are used to block off sections of the river for population surveys, creating a 

temporary barrier for all fish passage. 

Fish Screens and Barriers 

Fish screens and barriers are essential elements for the success of carp control efforts because they 

prevent movement of carp from one water body to another. A major factor that probably contributed 

to the short-term benefits to any previous treatments at the Refuge was the lack of properly designed, 

constructed, and maintained infrastructure to prevent carp re-invasion post-treatment. Vertical 

rotational screens have been highly effective at decreasing the spread of carp and decreasing the 

entrainment of native fish species by acting as barriers to fish movement. For smaller diversion 

ditches off the mainstem of the Blitzen River and canals, these screens have been highly efficacious, 

require minimal maintenance, and can be fabricated at the Refuge by the maintenance staff. 

Vertical traveling screens have been placed at the west 

canal diversion at Page Springs Dam. The Highline 

Ditch, Stubblefield Canal, Rheinman Ditch, and Buena 

Vista Canal are all in different stages of screen 

construction. Although these screens are very expensive 

and require power via solar collector or power line, they 

are very effective at screening the large water volumes 

being diverted from the Blitzen River. Priority areas for 

additional screening, barriers, and/or other infrastructure 

changes have been identified. These infrastructure 

elements will be added as time and funding allow. 

Electro-shocking 

Fish electro-shockers are effective tools for 

removing carp from water systems that 

contain non-target species. They are also 

useful in conducting fish surveys to 

determine the presence or absence of target 

and non-target species in a specific project 

area. The Refuge owns a backpack electroshocker and an electrofishing barge. 

Figure R-19. Operating fish screen on 

the West Canal at Page Springs Dam.

Figure R-20. Electro-shocking for carp below 

Sodhouse Dam.
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-22 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Bait Stations

Bags of corn are set out in specific areas of the Refuge to attract higher numbers of fish into the area. 

Food types that have also been tried, but have not been as successful as corn, include dog food, 

flavored commercial foods, and dough balls. These stations have been used when trying to catch carp 

in specific areas in Malheur Lake for telemetry work. 

R.7.2 Techniques and Technologies That May Be Used to a Limited Extent 

These techniques and technologies have been a part of the Refuge’s carp control efforts in the past. 

As discussed below, their use will be minimal under this plan. 

Rotenone 

Rotenone is a biodegradable pesticide used to kill undesirable fish. It is extremely toxic to fish and 

other organisms that require dissolved oxygen. It should be used in closed systems or predetermined 

reaches of rivers that have been surveyed for non-target species. Rotenone has been used in the 

Blitzen River and many small ponds, canals, ditches, and lakes on the Refuge from 1955 to 1999. 

Training is required to plan and execute a rotenone treatment, and a certified applicator is needed. 

Accurate determination of the volume of water to be treated is essential for calculating the correct 

amount of rotenone to apply. Normally 1 gallon of rotenone treats 6 acre-feet, or 2 to 8 parts per 

million of a 2.5 percent concentrate. The amount of rotenone necessary varies depending on the 

water temperature, turbidity, pH, aquatic vegetation, and oxygen levels. Live-boxes containing the 

target species provide a test for determining exact levels of toxicity during a project. Any application 

of rotenone will be conducted consistent with the procedures outlined under the Refuge’s IPM plan 

(see Appendix G of the CCP). Use of rotenone may only occur under low-water conditions and when 

100 percent mortality of carp can be achieved. Due to the non-selectivity of fish species targeted by 

rotenone, the project would have to determine risks and potential successes of the treatment. 

Application techniques include backpack pumps, drip stations, all-terrain vehicles (ATV) sprayers, 

aerial sprayers, and fire engine pumps. Application by boats in deep water requires the use of an 

ATV sprayer with a weighted discharge hose. 

Water Pumping 

Pumping is the most effective control method 

for small to medium-sized ponds that cannot 

be completely drained or treated with 

rotenone, but the labor required is substantial, 

especially when compared to the results. Due 

to the size and bulk of the equipment 

involved in this type of operation, significant 

time is required for site preparation. This 

includes developing access to the site for 

heavy equipment, construction of a ramp and 

suction hole, and construction of a trench 

connecting the deepest part of the pond to the 

pump intake. Depending on the site, an outlet 

ditch may be required in conjunction with the 

Figure R-21. In 1992 Refuge staff made a huge 

effort to drain Headquarters Pond with two 

Crissafulli pumps to remove carp.
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-23 

use of outlet hoses. 

R.7.3 Techniques and Technologies That Are Unlikely to Be Used Again 

The Refuge has already determined that certain techniques are not appropriate for carp control. These 

techniques and technologies have been ruled out as options for future carp control efforts. 

Poison Bait Stations 

When using carp feeding stations in the past, the Refuge has sometimes laced the food with small 

amounts of rotenone to kill carp. A feeding station was tested at Double-O Spring, but it was 

abandoned when large numbers of native fish were observed feeding at the station, which is not 

consistent with the Refuge’s IPM approach. Because this type of control also attracts and kills nontarget species, it is unlikely that rotenone or other piscicides will be added to the bait at any carp 

feeding stations in the future. 

R.7.4 Planned New Techniques and Technologies 

Commercial Harvest 

Seine nets operated by commercial fishing operations are effective for carp removal and for catching 

carp during mark-recapture studies. After telemetry studies identify carp aggregations, a commercial 

fisherman will be contracted to fish carp aggregates out with a seine net (see section S.6.3). This will 

theoretically happen in the winter or early spring. The Refuge will record the total weight of fish 

caught during commercial fishing, as well as the species of fish (because this method cannot be 

limited to carp completely). A subset of carp caught during commercial fishing will also be tagged as 

part of mark-recapture studies. 

Robotic Carp 

In addition to the techniques and technologies that have already been used at the Refuge, a new 

method will also be tested. The robotic carp is a proposed technology from the University of 

Minnesota that attempts to develop a new generation of robotic sensors that could track, record data, 

and evaluate carp behavior in Malheur Lake. This will be a non-disruptive way to continually track 

telemetry-tagged fish throughout the year and receive data in real time to determine management 

actions. The University of Minnesota was recently awarded a grant of $2.2 million by the National 

Science Foundation to develop and test this technology. Field testing at the Refuge will begin in the 

summer of 2013. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-24 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

Figure R-22. Prototype of the robotic carp.

Fish Piscivory 

Pending funding, a study will be conducted in collaboration with the University of Minnesota to 

evaluate the probability that other fish on the Refuge will prey on the invasive common carp eggs 

and fry. There is evidence that sustainable control may occur if there are enough piscivorous fish 

species to decrease carp numbers (Bajer et al. in review). The fish that would be evaluated are native 

tui chub, redband trout, dace, and non-native sunfish. 

Figure R-23. Native redband trout.

R.7.5 Potential New Techniques and Technologies 

Common carp have invaded water bodies in many locations throughout the world. As a result, there 

are numerous ongoing efforts to develop new methods of reducing their impact. As is consistent with 

adaptive management, the Refuge is committed to incorporating new methods that have scientific 

merit and are appropriate for the Refuge’s physical and biological conditions. Generally, upon 

learning about a new technique or technology, the Refuge reviews available information to determine 

if the method is likely to be effective in a setting that is present on the Refuge. If a suitable location 

or use can be identified, the Refuge and other members of the Aquatic Health Coalition will pursue 

funding. Any of the following new methods could become part of the Refuge’s strategy if a suitable 

use can be found and a corresponding funding source can be secured. 

Catchment Basins 

A field or pond will be used to attract carp and hold them, and they will be harvested fresh. Carp 

would be attracted to the area by water temperature, flow, or bait. Crane Pond will be an excellent 

site to perform this technique. 
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-25 

Barriers 

There are two types of barriers that could potentially be used at the Refuge (pending further 

analysis): electrical barriers and bubble barriers. Electrical barriers restrict upstream migration and 

can be designed to fit rivers as large as the Blitzen River. They operate on AC or DC power and are 

the most effective fish barriers because they do not interfere with aquatic debris. State-of-the-art 

design includes backup generators that provide electricity during power failures; however, these 

barriers are very expensive, and depending on location, they could pose a safety risk to visitors. 

The bubble barrier, which has been used in Minnesota to stop the spread of Asian carp, uses air 

bubbles to create sound and water displacement to deter carp movement with much success (More 

information is available at http://carpbarriers.com). These barriers or bubble curtains are safer and 

more cost effective than other barrier technology and can be portable. 

Fish Wheels 

In 2010, Industrial Power Systems donated over 200 hours of time to develop an electronic portable 

fish wheel design for the Refuge’s carp control program. This fish wheel will use cutting-edge 

technology to sort fish species by color. Fish migrating upstream would swim into the fish wheel, 

and as the wheel rotates, the fish would be picked up by the wheel, sorted by color, and released. 

Carp would be culled from the wheel, and native fish would be released upstream (Figure S-24). If 

funding is obtained, a fish wheel will be built according to this design. 

Figure R-24. Computer simulated design of experimental carp wheel. 

Sex Pheromones/Attractant 

Carp sex pheromone technology developed by Dr. Peter Sorensen’s laboratory at the University of 

Minnesota has been laboratory- and field-tested. This technique uses a pheromone plug surgically 

implanted into a female to simulate ovulation and to attract other carp. This will be a potential 

strategy to attract carp in low density areas. Pheromones used for pest control in the United States are 

considered “pesticides” by the Environmental Protection Agency (EPA) and must pass through the 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-26 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

normal pesticide registration process. Normal procedures prior to 

use of a pesticide would apply, requiring considerable time and 

funds. Experimental use in the research phase may be possible at 

the Refuge, but must be approved for use under a special permit. 

Pheromones and identical or substantially similar compounds 

labeled for use only in pheromone traps and pheromone traps in 

which those chemicals are the sole active ingredients are not 

subject to regulation under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) (40 CFR 152.25 (b)). 

Koi Herpes Virus 

Koi herpes virus is a DNA virus that is highly pathogenic to 

common carp, causing mass mortality. In Australia this biological 

agent is being tested in laboratory conditions as a potential 

biological control for common carp. It has not been approved as a 

biological control in the United States, and it may take years to 

get approval in the United States if it is proved efficacious in 

Australia. 

Daughterless Carp 

A genetic manipulation with aromalase stops estrogen production, which biases the carp population 

to all males. Daughterless carp technology is just in the beginning phases of being tested by a 

laboratory in Australia in collaboration with Auburn University. 

R.8 Summary 

The Refuge is committed to implementing effective solutions for sustainable carp control; the value 

of the Refuge’s lands and waters to native species demands this commitment. Realizing this goal is 

possible, but only with the help of other stakeholders who are concerned about the aquatic health of 

the Refuge and the Harney Basin. 

This plan is best viewed as a living document, because each phase of data gathering will change our 

understanding of the dynamic forces involved in the Refuge’s complex ecosystem. With information 

grounded in the best available science, the Refuge and its partners will be able to respond to these 

forces and make decisions that take new information into account, which is a key aspect of applying 

adaptive management. Together, we will be able to re-establish the biological integrity of the Refuge. 

R.9 References 

Bajer, P.B., C.J. Chizinski, J.J. Silbernagel, and P.W. Sorensen. In review. Native micro-predator 

abundance explains recruitment of a mobile invasive fish, the common carp, in a naturally 

unstable environment. Biological Invasions. 

Bajer, P., G. Sullivan, and P. Sorensen. 2009. Effects of a rapidly increasing population of 

common carp on vegetative cover and waterfowl in a recently restored Midwestern shallow 

lake. Hydrobiologia 632(1): 235-245. 

Figure R-25. Blood sample of 

common carp submitted to 

Oregon State University for koi 

herpes virus genetic testing.
Malheur National Wildlife Refuge Draft Comprehensive Conservation Plan 

Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge R-27 

Beklioglu, M., O. Ince, and I. Tuzun. 2003. Restoration of the eutrophic Lake Eymir, Turkey, by 

biomanipulation after a major external nutrient control I. Hydrobiologia 490(1): 93-105. 

Cornely, J. 1982. Waterfowl production at Malheur National Wildlife Refuge, 1942-1980. K. 

Sabol, ed. Transactions of the 47th North American Wildlife and Natural Resources 

Conference. Washington, D.C. 

Guy, C.S., H.L. Blankenship, and L. Nielson. 1996. Tagging and marking. Pages 353- 383 in: 

B.R. Murphy and D.W. Willis, eds. Fisheries techniques, 2nd edition. Bethesda, MD: 

American Fisheries Society. 

Hayes, D.B., C.P. Ferreri, and W.W. Taylor. 1996. Active fish capture methods. Pages 193-220 

in: B.R. Murphy and D.W. Willis, eds. Fisheries techniques, 2nd edition. Bethesda, MD: 

American Fisheries Society. 

Ivey, G.L., J.E. Cornely, and B.D. Ehlers. 1998. Carp impacts on waterfowl at Malheur National 

Wildlife Refuge, Oregon. North American Wildlife and Natural Resources Conference 

63:66-74. 

Rabeni, C.F. 1996. Invertebrates. Page 336 in: B.R. Murphy and D.W. Willis, eds. Fisheries 

techniques, 2nd edition. Bethesda, MD: American Fisheries Society. 

Thompson, S.P. and C.D. Littlefield. 1980. Historical review and status of colonial nesting birds 

on Malheur National Wildlife Refuge, Oregon. Proceedings of the Colonial Waterbird Group 

3:156-164. 

Wenick, J. 2010. Annual pond surveys, Malheur National Wildlife Refuge. Unpublished data on 

file, Malheur National Wildlife Refuge. Princeton, OR. 

Williams, B.K., R.C. Szaro, and C.D. Shapiro. 2007. Adaptive management: U.S. Department of 

the Interior technical guide. Adaptive Management Working Group, U.S. Department of the 

Interior. Washington, D.C. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

R-28 Appendix R. Improving the Aquatic Health of Malheur National Wildlife Refuge 

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Appendix R

Improving Aquatic Health

Appendix S

Response to Comments

Killdeer

©Blake Matheson

Appendix S

Response to Comments

Appendix Q

NWR Visitor Survey

Appendix P

Hunting Plan

Appendix O

Sustainability

Appendix N

Common & Scientific Names

Appendix M

Climate Change

Appendix K

Wet Meadow Treatment

Appendix J

Public Involvement

Appendix I

Contributors

Appendix H

Glossary

Appendix G

Integrated Pest Management

Appendix F

Statement of Compliance

Appendix E

BIDEH

Appendix D

Wilderness Review

Appendix C

Implementation

Appendix A

Appropriate Use Findings

Appendix B

Compatibility Determinations

Appendix L

Ecology Work Group

Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-1 

Appendix S. Comments Received During the Public/Agency Review Period and Service Responses 

Input was encouraged and used throughout the entire development of the Malheur Refuge 

comprehensive conservation plan/environmental impact statement (CCP/EIS). Input was 

incorporated through a transparent collaborative process beginning with scoping and continuing with 

finalization of the CCP/EIS alternatives and through the determination of the final management 

direction. A formal public comment period was also used upon release of the Draft CCP/EIS in 

March 2012. 

The Service issued a planning update summarizing the CCP/EIS preliminary draft alternatives 

developed through the collaborative process in March 2012. In this planning update, the Service 

informed the public that comments and suggestions would continue to be incorporated through the 

collaborative process with other comments received during the formal public comment period 

required by the National Environmental Policy Act (NEPA). The Service released the Draft CCP/EIS 

on March 15, 2012, for formal public review and comment. This comment period closed on May 4, 

2012. During the formal comment period, the Service received 136 comments from 41 agencies, 

organizations, and individuals.

The majority of comments focused on respondents’ opinions toward support of the collaborative 

process and Alternative 2 of the Draft CCP/EIS. Many of the substantive comments were directed 

toward carp control, grazing and haying management tools, inventory and monitoring processes, and 

river functionality. Where the opinion expressed provided some level of detail or was based on a real 

or perceived fact, the Service has provided a response. Where the comment expressed solely an 

opinion and was not supported by any assertion, the Service considered the comment in selection of 

the management direction, but did not respond to the comment in this appendix. 

A minority of comments provided factual information (both real and perceived), questioned 

statements and facts presented in the Draft CCP/EIS, or questioned the accuracy of information used 

in formulating the alternatives and/or conducting analyses as part of the EIS. 

Comments received were grouped into 13 categories based upon actions considered in the Draft 

CCP/EIS alternatives or based on topics of particular interest as indicated by comments themselves. 

These categories are: Aquatic Health/Carp; Collaboration/Process; Meadow Management/Grazing 

and Haying; Inventory/Monitoring/Adaptive Management; Wildlife; River Function; Hunting; 

Fishing; Interpretation; Facilities; Wilderness; Water Management; and General. Comments 

presented in this appendix have been paraphrased from the originals, and in some cases were 

consolidated with others where the Service’s response is the same. 

S.1 Aquatic Health/Carp 

1. Comment: The Service should consider placing a greater emphasis on water manipulation as a 

viable carp control method. 

Response: The term “lacustrine” within the CCP addresses Malheur and Mud Lakes. Water 

manipulation does take place throughout other parts of the Refuge as a means for controlling carp 

and would continue to be used under this plan (Chapter 2 Objective 4c). The number one focus 

area for carp control is Malheur Lake; the Blitzen Valley is second and Double-O third inside 

refuge boundaries. The goal in the next 15 years is to acquire the resources necessary to 

implement science-based changes for the improvement of bird habitat. The Refuge will pursue 

carp control strategies in Malheur and Mud Lakes that are science based and enable biological 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

S-2 Appendix S. Response to Comments 

objectives to be met while keeping costs to a minimum. With the development of new 

technologies for controlling carp, the Refuge will be exploring new alternatives before strategies 

such as repairing Cole Island dike and pumping water are pursued. Water manipulation/control in 

other portions of the Refuge that already have existing infrastructure will be a key component of 

a comprehensive carp management strategy. 

2. Comment: The Service should consider using commercial harvest of carp as part of a strategy to 

improve aquatic health on the refuge. 

Response: Commercial harvest is one option for controlling carp. The Refuge has received many 

inquiries from commercial fish operations since the beginning of the planning process. Many 

structures within the Refuge and outside of its boundaries, such as along Rue Red Road, have 

been identified as possible sites for physical barriers/screens through Refuge and The Natural 

Resources Conservation Service carp management plans. 

3. Comment: Commercial carp fishing is not a viable option in Malheur Lake because it already 

failed in the 1980s. 

Response: The Refuge is exploring the possibilities of commercial fishing strategies that have 

been recently developed specifically for carp. The latest scientific research indicates that carp 

concentrate in small areas underneath the ice during winter months. Commercial fishermen have 

developed techniques to net carp under the ice. Other commercial technologies such as fish 

wheels with electronic scanning eyes and portable fish processing plants are also examples of the 

more recent technologies the Refuge is exploring. 

4. Comment: The Proposed Staffing in Appendix C under Alternative 2 does not reflect an 

adequate number of staff for the fisheries program if aquatic health is a priority. 

Response: All additional positions are aligned with the Refuge Operational Needs database. 

Positions that will help support the aquatic health program are Geographic Information System 

Specialist, Natural Resource Specialist, Private Lands Biologist, Volunteer Coordinator, 

Hydrological Technician, and the Biological Technician (habitat). The Refuge also will continue 

to hire temporary staff and interns (not reflected in Table C-1) to assist with fieldwork. There is 

also the possibility that private sector contractors will be engaged in carp control strategies. 

5. Comment: Tables C-2 and C-3 in Appendix C should be revised to reflect the high priority of 

aquatic health. 

Response: In the Final CCP, Table C-2 was adjusted to reflect the most recent cost estimates for 

the aquatic health/carp program. Table C-3 deals specifically with visitor services and cultural 

resources. 

S.2 Collaboration/Process 

6. Comment: The Service is strongly encouraged to build on the very successful collaborative 

planning process throughout the entire implementation of the CCP. Implementation needs to 

include strong facilitation, independent science advisory process and addressing issues in an open 

transparent manner. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-3 

Response: The Refuge recognizes the significance of the highly successful collaborative 

planning process. Continuing relationships with organizations such as the High Desert 

Partnership and Oregon Consensus will enable the Refuge to move forward with implementation 

in a transparent manner. The already established Ecology Working Group and Carp Coalition are 

examples of how the science advisory process will continue through implementation. A visual of 

this overall collaborative process can be found in Figure 2.1 in Chapter 2 of the CCP. 

S.3 Meadow Management/Grazing and Haying 

7. Comment: More information is needed about the potential impacts to current refuge haying and 

grazing permit holders with the expiration of current cooperative land management agreements 

when the final CCP is signed. 

Response: There will be no impact to Refuge permittees in regard to the land exchange between 

the Refuge and the Bureau of Land Management (BLM). These areas fall outside of the habitat 

treated via the haying and grazing program. 

8. Comment: Include a clause in the compatibility determination for the haying and grazing 

program that cooperative land management agreements could be modified within the initial 5-

year timeframe if significant unanticipated impacts to plant communities are documented. 

Response: Changes to the haying and grazing compatibility determination were made to 

differentiate between trend and operational changes to CLMAs. Trend involves the 5-year 

timeline for assessing response of plant communities to treatment. Operational changes will take 

place within the 5-year window if the physical management of the CLMAs needs to be adjusted 

(e.g., are non-target habitats being impacted?). 

9. Comment: The compatibility determination for grazing and haying on the refuge is not 

supported by information in the CCP. 

Response: In Chapter 6 of the CCP and in the compatibility determination for haying and 

grazing, the anticipated environmental effects associated with the haying and grazing program 

are described in detail. Based on the effects disclosed in the CCP, the haying and grazing 

program as described in the management direction will contribute to achieving Refuge purposes 

and the Refuge System mission by providing valuable foraging, resting, pairing, nesting, and 

brood-rearing areas and conditions for the sandhill crane, bobolink, cinnamon teal, and other 

meadow-dependent species. The benefits of using grazing and haying as appropriate management 

tools on Malheur Refuge are based on Refuge-specific knowledge from seven former biologists 

with 50 collective years of experience along with the sound professional judgment of current 

biologists and ecologists using the best available science to manage the site-specific conditions 

on Malheur Refuge. The Refuge has also committed to an adaptive management process that 

allows for future changes based on site-specific science. 

10. Comment: The Service should conduct pre-treatment inventories of wildlife populations as well 

as monitoring during and after haying and grazing treatments. 

Response: The following language has been added to the Haying and Grazing Compatibility 

Determination under Stipulations Necessary to Ensure Compatibility (page B-102): “A pre-
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

S-4 Appendix S. Response to Comments 

treatment inventory of local wildlife populations within the proposed warm season treatment area 

will take place prior to the initiation of treatments.” This will aid in understanding potential 

wildlife impacts to ensure that the specific habitat improvements that are being sought justify 

localized, short-term wildlife production losses. 

11. Comment: In the justification section of the haying and grazing compatibility determination 

concerning the impacts of treatments on wildlife populations, behavior and welfare were not 

supported by data currently available from the refuge. 

Response: Conclusions drawn within the second paragraph of the justification found within the 

haying and grazing compatibility determination are based on 50 collective years of experience of 

past and present Refuge wildlife biologists and ecologists for dormant season haying and rakebunch grazing and associated wildlife monitoring. The Refuge has also committed to the 

implementation of an extensive neutral third-party habitat inventory and monitoring program. 

The results of this program will be reviewed on an annual base through a continuing 

collaborative process with Refuge stakeholders. Experimental warm-season treatments will occur 

only on a very small scale (approximately <500 acres). Please refer to Section B-7 of the CCP, 

“Overview of the Four Treatment Types.” 

12. Comment: The Service should insert a Table in Appendix K - Wet Meadow Treatment Ratios 

comparing the present acreages hayed, grazed or farmed under Alternative 1 with the 

corresponding acres planned for Alternative 2. 

Response: Appendix K now includes a table that will be used to capture all treatments during the 

life of the CCP. 

13. Comment: The Service should increase the use of fire and decrease the use of haying and 

grazing. 

Response: Prescribed fire is a tool that is pursued to the fullest extent feasible within the CCP. 

Funding limitations, site-specific issues (e.g., dominance of annual grasses in sagebrush 

lowlands, perennial pepperweed in wet meadows), and strategic containment requirements 

prevent this tool from being used in a way that replaces other vegetation management strategies 

such as haying and grazing. 

14. Comment: The CCP needs to reference the grazing plans developed for the Blitzen Valley and 

Double-O portions of the Refuge. 

Response: The Blitzen Valley and Double-O management plans were utilized in the 

development of the CCP. They are cited as Rule et al. 1990 and David J. and Gary Ivey 1995, 

respectively. 

S.4 Inventory/Monitoring/Adaptive Management 

15. Comment: Through inventory and monitoring data should be collected to determine the 

effectiveness of all treatment tools such as fire, flooding, prescribed drought, grazing etc. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-5 

Response: This suggestion will be given to the Ecology Work Group and will be factored into 

the continued formulation of the Inventory and Monitoring Plan. It is agreed that documentation 

of all management activities will be critical in developing the State-and-Transition Model and 

understanding habitat responses. 

16. Comment: Are survey transects for wildlife use as outlined in the draft Inventory and 

Monitoring plan large enough to sufficiently determine the effectiveness of treatment tools. 

Response: The Refuge’s inventory and monitoring program will be based on established 

scientific protocols used to evaluate effectiveness of management strategies. 

17. Comment: Are species identified in the Draft Inventory and Monitoring plan representative of 

the full suite of species for which the refuge is managed? 

Response: The process used for selecting priority resources of concern (i.e., focal species) is 

found in Section 4.2 of the CCP. The tables that follow identify a suite of other benefiting species 

that are represented by the focal species chosen. 

18. Comment: The Service needs to consider identifying area-specific vulnerabilities (habitats and 

species) in developing adaptive management strategies. 

Response: Goals and objectives found within the CCP are organized by habitat types (e.g., 

lacustrine, wet meadow, etc.). Each objective and corresponding management strategies have 

been established with consideration to the unique needs and sensitivities of the plant communities 

and associated wildlife (i.e., habitat) within which they are placed. 

19. Comment: The use of cattle as a tool to meet habitat objectives needs to scientifically justified. 

Response: In adopting the 60:40 ratio to begin the implementation of the CCP, the Refuge relied 

on the reasonable opinions of its own qualified experts, both past and present. Appendix K states 

that “this figure is based on the sound professional judgment of seven past and present Refuge 

wildlife biologists with 50 collective years of experience managing Refuge meadows. This ratio 

is relevant only when considering all wet meadows within the Refuge and differs across fields 

and area-specific management units. The needs of focal species, the suite of wildlife they 

represent, and the nature of habitats they depend on determines the use and extent of these tools 

in realizing or maintaining attributes identified under Objective 4a.” This ratio provides an 

understanding of the overall use of haying and grazing but does not address the specific needs of 

wildlife in specific areas. This is why the ratio is only being used as a starting point. The meadow 

treatments will be adjusted as area-specific needs and Inventory and Monitoring data are 

considered during the annual review process involving the agency, the Ecology Work Group, and 

the collaborative group. This will lead to an adjustment to the ratio to provide clarity regarding 

the extent of treatments taking place over time. As discussed in Appendix K, the actual ratio 

currently varies widely from 90:10 in wet meadows within the southern Blitzen Valley to 30:70 

in the North Blitzen Valley. The 60:40 ratio is meant to be illustrative, not definitive. The CCP 

has been revised to eliminate describing the 60:40 ratio as an objective. 

20. Comment: The implementation priority for studies of seasonally flooded wet meadows should 

be “very high” instead of “high.” 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

S-6 Appendix S. Response to Comments 

Response: Because inventory and monitoring activities associated with wet meadows are 

centered on third-party science and are being established based on a commitment of continuity, it 

is appropriate to classify the implementation priority for this habitat type as “very high.” 

21. Comment: The Service should use the National Vegetation Classification System for identifying 

vegetation types. 

Response: The Cowardin system (1979) recognizes hydrological features within its 

classifications, which aligns naturally with the habitat types identified within this CCP 

(differentiating lakes versus small ponds, wet meadows versus marshes, etc.). The National 

Vegetation Classification System is based on the expression of vegetation and does not lend itself 

as naturally to separating habitats across hydrological gradients. Crosswalks can be provided to 

enable land managers and interested public to understand how habitats and associated vegetation 

communities fall within both widely used systems. 

22. Comment: The Service needs to establish a scientifically based inventory and monitoring plan 

that will allow for informed adaptive management decisions. The inventory and monitoring 

process needs to be done in collaboration with both scientist and stakeholders. 

Response: The collaborative nature of the Inventory and Monitoring Plan will be a tremendous 

strength as the Refuge moves forward with the implementation of the CCP. Third-party experts 

from various universities, nongovernmental organizations, and other government entities have 

become very active in assisting in the design and methodology of the Inventory and Monitoring 

Plan to maximize the efficiency of data collection and analysis in addressing whether 

management actions are meeting objectives and, ultimately, if the objectives themselves are 

sufficient. Finalizing the Inventory and Monitoring Plan is a top priority for the upcoming 2013 

field season. 

S.5 Wildlife 

23. Comment: Additional rational is needed in the compatibility determination for grain farming to 

show what the impacts would be to sandhill cranes and waterfowl species if farming is not 

conducted on the refuge. 

Response: The rationale for the use of grain on Malheur NWR is based on both Refuge and 

Pacific Flyway Council plans (see Farming Compatibility Determination, Section B.10 of the 

CCP). In the Pacific Flyway Plan, Malheur Refuge is identified as one of only four autumn 

staging and migration stopover sites for greater sandhill cranes. It is also recognized for the 

ability to provide the necessary feeding/grain sites adjacent to large isolated wetlands secure from 

human disturbance. If Malheur Refuge does not provide both feeding and roosting sites for 

greater sandhill cranes, the birds will be required to seek other areas to meet these needs. These 

areas will not likely be under management strategies with a primary purpose of providing for the 

needs of wildlife and therefore are at risk of not being secure in meeting the needs of migrating 

cranes. 

24. Comment: The three focal species listed for wet meadows all prefer short vegetation and do not 

reflect species which may use the taller, untreated vegetation in wet meadows. The focal species 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-7 

used for monitoring this habitat type should reflect the entire guild of birds which may be 

present. 

Response: Cinnamon teal was selected to represent the suite of species that use idle meadows 

(tall vegetation for nesting cover). The Draft CCP Table 4-4 did not provide a description of 

habitat structure and attributes that describe breeding habitat. This has been addressed in the 

Final CCP. 

25. Comment: The Service should remove abandoned and interior fences to reduce impacts to 

wildlife. 

Response: The Refuge incorporates the removal of old fences with any new replacement fence 

projects. The Refuge continues to work on the removal of fences that were abandoned many 

years ago as resources are available. Through the use of interior fence the Refuge is better able to 

achieve habitat objectives. Herding has and will continue to be used in specific situations. 

26. Comment: The Refuge should use artificial goose nest structures. 

Response: Waterfowl populations nest very successfully on the Refuge. Artificial nesting 

structures are generally used as a substitute for the lack of proper or sufficient conditions for a 

group of birds or an individual nesting species. Structures also require cleaning, maintenance, 

and replacement, which cannot be justified with limited refuge resources available and nesting 

waterfowl populations doing well. 

27. Comment: Opening Krumbo reservoir to winter vehicle access will cause negative impacts to 

wintering waterfowl. 

Response: The Refuge is not known as a large wintering waterfowl area. The birds using the 

refuge during this period scatter throughout the Blitzen Valley and Double-O area. They remain 

on the Refuge over the winter period only as long as there is open water available. During the 

winter, consistent open water is available around hot springs, the river, and a few channels with 

flowing water. The Refuge has a number of impoundments and water bodies such as Boca Lake 

used by wintering waterfowl as roosting sites that are close to these open water areas. Opening 

Krumbo Reservoir to winter vehicle access will not negatively impact refuge overwintering 

waterfowl populations. 

S.6 River Function 

28. Comment: The CCP should reflect a stronger commitment to the restoration of the Blitzen River 

to natural conditions. 

Response: The Refuge recognizes the importance of proper functioning ecological systems. The 

Refuge is committed to prioritizing and refining a set of priority questions/objectives creating a 

scientific foundation to construct a comprehensive riverine strategy. Based on these 

questions/objectives the Refuge will take advantage of new resource opportunities to implement 

appropriate science-based steps to continue the advancement of a comprehensive river strategy. 

To reflect this, adjustments were made to Goal 2 Objective 2a. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

S-8 Appendix S. Response to Comments 

S.7 Hunting 

29. Comment: The Service should use a 5 year average of hunting conditions on the refuge to better 

discuss waterfowl hunt days and hunter usage rather than using only 2011 data which only 

represents one year for a hunting program that has taken place over many years. 

Response: Since the flood events in the late 1980s, the lake topography has been altered due to 

ice and wave action. Changes in topography combined with dramatic fluctuations in water level 

and impacts of common carp have had a negative impact to the plant communities that support 

waterfowl. During this same timeframe, dramatic fluctuations in water levels have also limited 

hunting access to the lake. These two factors (limited waterfowl food and reduced access) have in 

general resulted in low hunter use of the area during most years. An exception would be in the 

year 2011 when higher numbers of waterfowl hunters did use the area because of improved 

conditions. It is also possible hunter visits may increase with the addition of a stable boat launch 

site and a larger hunting area. Waterfowl and associated hunting use of the area would also be 

expected to increase as habitat conditions improve as a result of carp control. 

30. Comment: The Double-O unit of the Refuge should be opened for public hunting. 

Response: The Double-O Unit was excluded due to the conflict with the values in the area, both 

biological and cultural. Allowing hunting in this area was not determined to be appropriate 

through our compatibility determinations. 

31. Comment: The area between Diamond Lane and Krumbo Lane should be open to upland game 

hunting. 

Response: The existing upland game hunt in the Buena Vista hunt unit consists of 36,000 acres 

and is a quality program. Additionally, under Objective 8a, the hunt season will extend the 

season opener from the fourth Saturday of October to the end of the State pheasant season, which 

will provide an additional hunting opportunity. The P Ranch Unit was also considered for 

hunting opportunity, but was rejected due to conflicts with wintering waterfowl, which use the P 

Ranch Unit more heavily than other units because of the access to open water. 

32. Comment: The Buena Vista unit should not be open to public hunting to avoid conflicts with 

photographers. 

Response: The Buena Vista Unit hunt season will be from the fourth Saturday of October to the 

end of the State pheasant season. The hunt area contains 36,000 acres, which allows hunters to 

disperse. This dispersed hunting activity is not expected to conflict with other compatible 

wildlife-dependent recreation, including viewing wildlife or photography. 

S.8 Fishing 

33. Comment: The Service should consider opening Malheur Lake to carp and trout fishing. 

Response: Per the management direction, the Refuge will be creating additional fishing 

opportunities. Krumbo Reservoir will now be open to year-round fishing and the Blitzen River 

from Sodhouse Lane to the boat landing bridge will be open from August 1 to September 15 to 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-9 

enhance carp fishing opportunities. The Refuge may at some future point reevaluate fishing in 

Malheur Lake as carp control strategies become finalized. 

34. Comment: The Service should consider not opening the Krumbo Road during winter months to 

vehicle access to prevent road damage. 

Response: Year-round access to Krumbo Reservoir would provide greater opportunity for 

wildlife viewing, boating, and fishing. As noted in Objective 8d, the access would close when 

road conditions are hazardous to prevent road damage. We also expect wintertime visitor use to 

be light, and any road damage that may occur is not expected to significantly impact the road. 

35. Comment: Opening East canal to vehicle access will ruin the fisheries. 

Response: Prior to 1999 East Canal was open to vehicle access. During this time East Canal was 

a good fishery. Since 1999 additional habitat improvement projects have occurred in East Canal 

to improve upon the existing fishery. 

36. Comment: The East Canal access should allow vehicle access to public lands south of Bridge 

Creek. 

Response: The opening of East Canal to vehicle access will allow the public to access the 

crossing south of Bridge Creek that could access Granddad Reservoir on BLM lands (dependent 

upon BLM regulations). East Canal road north of Bridge Creek will remain closed to vehicle 

access to enable the Refuge to meet wildlife objectives. 

S.9 Interpretation 

37. Comment: The Service should incorporate interpretive themes that include the importance and 

connectivity of Basin and upland watershed agricultural flood irrigation practices. 

Response: Please see Objective 7c. 

38. Comment: A high priority should be placed on interpretation that engages the public in the 

specific priorities of the CCP (for example carp control) as well as on the cultural, historic, 

natural history and ecology of the area. 

Response: Please see Objectives 7c and 7d. 

39. Comment: Outreach materials should be developed that promote the broadest aspirations of the 

CCP including restoration in the Blitzen River Valley and the Double-O. 

Response: Please see Objective 7c. 

40. Comment: Brush should be removed to improve wildlife viewing/photography opportunities 

along center patrol road. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

S-10 Appendix S. Response to Comments 

Response: Under Objective 7a, it is stated that we will provide a variety of vehicle pull-offs on 

the 42-mile Blitzen Valley auto tour route (Center Patrol Road) at key locations to enhance the 

birding experience, including photography; this will include clearing areas of willow overgrowth. 

S.10 Facilities 

41. Comment: The Service should consider creation of additional pullouts along State Highway 205 

north of the Narrows. 

Response: Under Objective 7a, it is stated that we will participate in the Basin and Range 

Birding Trail on-refuge with Harney County Chamber of Commerce and other partners. This will 

include providing additional areas for vehicle access and pull-offs. The consideration to provide 

pull-offs off-Refuge, including along State Highway 205, was addressed. However, to 

accomplish public use goals and objectives identified within the 15-year plan, we focused on 

enhancing experiences on-Refuge. 

42. Comment: Signage should be increased to support direct engagement of Refuge visitors. 

Response: Please see Objective 6a. 

43. Comment: The wildlife observation blind at the Headquarters should be reconstructed. 

Response: A wildlife observation blind on the pond at Headquarters, with an accompanying trail, 

was completed in September 2012. 

S.11 Wilderness 

44. Comment: Would wilderness designation benefit Refuge management? 

Response: On a national wildlife refuge, a unit of land must meet the “purpose” for which the 

refuge was created. If a parcel of land is not meeting refuge purpose it cannot be moved forward 

for potential wilderness designation. Currently the only portion of Malheur Refuge that is 

meeting Refuge purpose and has wilderness character is the Harney Lake Unit. Wilderness 

designation of this unit would not impact Refuge management. Malheur Lake may have 

wilderness character but is not currently meeting Refuge purposes due to impacts from invasive 

species. 

S.12 Water Management 

45. Comment: There are opportunities in the Double-O portion of the Refuge to manage water 

jointly while meeting objectives on both private and Refuge lands. 

Response: Because of a lack of a defined water delivery system in the Double-O area it is 

necessary to manage water jointly between private and public (Refuge) or private and private 

water users. There are a variety of mechanisms such as easements, water sharing agreements, etc. 

that would have to be put in place. For these mechanisms to be implemented there would have to 

be benefits to the involved parties. 
Malheur National Wildlife Refuge Comprehensive Conservation Plan 

Appendix S. Response to Comments S-11 

S.13 General 

46. Comment: Portland Audubon Society’s Dave Marshall Internship should be added to the list of 

objectives under Goal 9a. 

Response: Because the Portland Audubon Dave Marshall Internship is not specific to Malheur 

NWR, this internship along with all other possible internships is included in the more general 

heading of building partnerships and public outreach. 

47. Comment: Maintenance costs and staffing of facilities were not included in the plan under 

Appendix C - Implementation. 

Response: Staffing needs/costs are reflected in Appendix C Table C-1. Facilities costs are shown 

in Appendix C Table C-3. 

48. Comment: CCP/EIS document needs to be formatted in a manner the reader can find important 

information. 

Response: It is acknowledged that the CCP/EIS is a very large document. The complexity of 

management at Malheur NWR combined with the legal requirements of the National 

Environmental Policy Act has resulted in a lengthy document. 

S.14 References 

Cowardin, L.M., V. Carter, F.C. Golet, E.T. LaRoe. 1979. Classification of Wetlands and Deepwater 

Habitats of the United States. U.S. Department of the Interior, Fish and Wildlife Service, 

Washington, D.C. Jamestown, ND: Northern Prairie Wildlife Research Center Online. Available 

at: http://www.npwrc.usgs.gov/resource/1998/classwet/classwet.htm (Version 04DEC98).