United States 

Department of 

Agriculture 

Forest 

Service 

December 2013

Final Environmental

Impact Statement

Volume III

North Billings County Allotment

Management Plan Revisions

FEIS Vol. III North Billings County Allotment Management Plan Revision

North Billings County Allotment Management Plan Revisions

Final Environmental Impact Statement

Volume III

Lead Agency: USDA Forest Service

Dakota Prairie Grasslands

Medora Ranger District

Responsible Official: Dennis D. Neitzke

Grasslands Supervisor

1200 Missouri Ave

Bismarck, ND 58504

For information contact: Nickole Dahl, Project Leader

Medora Ranger District

99 23rd Ave W. Suite B

Dickinson, ND 58601

701-227-7800

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

USDA Non-Discrimination Policy

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

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

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

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

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

employment or in any program or activity conducted or funded by the Department. (Not all 

prohibited bases will apply to all programs and/or employment activities.) 

Persons with Disabilities

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

either an EEO or program complaint please contact USDA through the Federal Relay Service 

at (800) 877–8339 or (800) 845–6136 (in Spanish). Persons with disabilities who wish to file 

a program complaint, please see information above on how to contact us by mail directly or 

by email. If you require alternative means of communication for program information (e.g., 

Braille, large print, audiotape, etc.) please contact USDA’s TARGET Center at (202) 720–

2600 (voice and TDD)

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

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

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

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

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

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

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

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

Contents| i

Table of Contents 

VOLUME III ....................................................................................................................................................................... 1

TABLE OF CONTENTS .................................................................................................................................................... I

LIST OF TABLES ............................................................................................................................................................II

CHAPTER 4 CONSULTATION AND COORDINATION ...................................................................................................... 1

PREPARERS AND CONTRIBUTORS............................................................................................................................................ 1

DISTRIBUTION OF THE SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT STATEMENT ...................................................................... 2

REFERENCES AND LITERATURE CITED .......................................................................................................................... 1

GLOSSARY ................................................................................................................................................................... 1

ACRONYMS ................................................................................................................................................................. 1

APPENDIX A ALTERNATIVES 3 AND 3A ......................................................................................................................... 1

INITIAL PERMITTEE MEETINGS............................................................................................................................................... 1

GRAZING ASSOCIATION BOARD OF DIRECTOR DISCUSSIONS ........................................................................................................ 2

DEVELOPMENT OF ALTERNATIVE 3A....................................................................................................................................... 4

SUMMARY OF FS REVIEW OF MGA’S COMMENT – EXHIBIT 2 ................................................................................................... 18

APPENDIX B ALLOTMENT MAPS ................................................................................................................................19

APPENDIX C SRT RECOMMENDATIONS........................................................................................................................ 1

APPENDIX D GRAZING MANAGEMENT TOOLBOX ........................................................................................................ 1

DROUGHT STRATEGY........................................................................................................................................................... 1

ADJUST SEASON OF USE........................................................................................................................................................ 3

ADJUST AUTHORIZED USE .................................................................................................................................................... 7

ADJUST FOR COW SIZE ......................................................................................................................................................... 9

UTILIZE NON-NATIVE GRASS PASTURES EARLY TO DEFER GRAZING ON NATIVE GRASSES .................................................................... 10

ALLOW EARLY TURNOUT ON NATIVE PASTURES ONE OUT OF THREE YEARS ON INVENTORY PERMITS.................................................... 12

DEFER NATIVE PASTURE TURN-IN UNTIL JUNE 1

ST OR UNTIL DEVELOPMENT OF THE THREE AND A HALF LEAF STAGE FOR KEY GRAMINOID 

SPECIES........................................................................................................................................................................... 13

REST FOR ONE OR MORE SEASONS ........................................................................................................................................ 14

REALLOCATION OF PASTURES (CHANGE ALLOTMENT BOUNDARY) ................................................................................................ 16

CONSTRUCT TEMPORARY FENCE TO CONTROL LIVESTOCK DISTRIBUTION PATTERNS ......................................................................... 18

CONSTRUCT OR REMOVE CROSS FENCES ................................................................................................................................ 19

CONSTRUCT LIVESTOCK WATER DEVELOPMENT (WELL, PIPELINE, TANKS, WINDMILL, RESERVOIR, DUGOUT, OR SPRING) ......................... 20

REMOVE/RECLAIM WATER DEVELOPMENT (WELL, PIPELINE, TANKS, WINDMILL, RESERVOIR, DUGOUT, OR SPRING) ............................... 22

MANAGE WATER AVAILABILITY/ACCESS AT WATER DEVELOPMENTS............................................................................................. 23

MAINTAIN EXISTING DEVELOPMENTS TO REESTABLISH USE ........................................................................................................ 24

IMPLEMENT DEFERRED GRAZING SYSTEM ............................................................................................................................... 24

IMPLEMENT REST-ROTATION GRAZING SYSTEM ....................................................................................................................... 28

IMPLEMENT TWICE-OVER GRAZING SYSTEM............................................................................................................................ 29

INCORPORATE PRIVATE “OFF PERMIT” LAND INTO ROTATION ..................................................................................................... 30

FERTILIZE CRESTED WHEATGRASS AREAS ................................................................................................................................ 31

HAY OR CUT-&-LEAVE CRESTED WHEATGRASS AREAS ............................................................................................................... 32

INTERSEED PASTURE WITH NATIVE GRASS SPECIES .................................................................................................................... 34

SCARIFY CLUBMOSS AREAS WITHIN A PASTURE ........................................................................................................................ 35

IMPLEMENT PRESCRIBED BURNS........................................................................................................................................... 36
 FEIS Vol. III North Billings County Allotment Management Plan Revision 

ii | Contents 

MECHANICAL BRUSH MANAGEMENT..................................................................................................................................... 38

INCORPORATE A RANGE RIDER TO DISPERSE LIVESTOCK THROUGHOUT A PASTURE (HERDING) ........................................................... 39

MANAGE SALT AND SUPPLEMENT LOCATIONS ......................................................................................................................... 40

CONSTRUCT FENCE TO CREATE RIPARIAN UNIT – ALLOW GRAZING UNDER RIPARIAN GRAZING DATES .................................................. 41

IMPLEMENT BMPS FOR RIPARIAN PASTURES .......................................................................................................................... 42

RESTORE/ENHANCE RIPARIAN VEGETATION I.E. WILLOW PLANTING ............................................................................................. 43

CONSTRUCT/HARDEN STREAM CROSSINGS ............................................................................................................................. 44

CONSTRUCT WATER GAP TO LIMIT LIVESTOCK ACCESS ON STREAM............................................................................................... 44

CONSTRUCT FENCE TO EXCLUDE LIVESTOCK FROM AREAS OF CONCERN (RIPARIAN, WOODED DRAWS, SPRINGS, WETLANDS, ETC) ............. 44

MOVE WINTER FEEDING AREAS OFF OF NATIONAL FOREST SYSTEM LANDS ................................................................................... 46

UTILIZE BIOLOGICAL CONTROLS FOR NOXIOUS WEED CONTROL IN WOODY DRAWS.......................................................................... 47

INDEX ..........................................................................................................................................................................1

List of Tables 

TABLE 4.1 — LIST OF PREPARERS 1

TABLE 4.2 — PEOPLE AND ORGANIZATIONS CONSULTED 2

TABLE 4.3 — INDIVIDUALS TO WHOM THE SDEIS WAS SENT 2

TABLE 4.4 — AGENCIES AND ORGANIZATIONS TO WHOM THE SDEIS WAS SENT 3

TABLE 4.5 — AGENCIES TO WHOM AN EXECUTIVE SUMMARY AND URL WERE SUPPLIED 3

ALLOTMENT 14

INITIAL ACTIONS HIGHLIGHTED IN EXHIBIT 2 OF MGA COMMENTS 14

FS RESPONSE 14

APPENDIX E RESPONSE TO COMMENTS for the Draft Environmental Impact Statement..............................................1
FEIS Vol. III North Billings County Allotment Management Plan Revision

Chapter 4| 1

CHAPTER 4

Consultation and Coordination

PREPARERS AND CONTRIBUTORS

The following table identifies the individuals on the North Billings County Allotment Management 

Plan Revisions interdisciplinary team.

Table 4.1 — List of Preparers

NAME TITLE BACKGROUND ROLE(s)

Jeff Adams

National 

Environmental 

Policy Act 

Specialist

B.S Wildlife 

Management/Forestry

M.S. Natural Resource 

Management and Planning

30 Years Experience

Co-IDT leader, ensured 

NEPA compliance, 

Writer /Editor, wrote 

Climate Change Report

Jack Dahl Range Management 

Specialist

A.S. Wildlife Management

B.S. Animal & Range Science 

with Range Emphasis

M.S. Range Science

11 Years Experience

IDT member, Data 

Collection, Range 

Analysis, co-author 

Range Report

Nickole Dahl Range Management 

Specialist

B.S. Animal & Range Science 

with Science Emphasis

11 years experience

Co-IDT leader, Data 

Collection, Range 

Analysis, co-author 

Range Report

Mervin 

Floodman Archeologist

B.S Archeology

M.S. Archeology 

35 years experience

Ad hoc IDT member, 

wrote Archeology

Report

Tam Frager Editor 

A.A. Communications with 

Writing Emphasis

11 years experience

Edits and Layout

Mark Gonzalez Grasslands 

Hydrologist

B.A. Geology,

M.S. Geography,

M.S. Land Resources,

Ph.D. Earth & Planetary 

Science, 27 years experience

IDT member, Data 

Collection, wrote 

Watershed Report

Keith 

Stockman

Acting Regional 

Economist

B.A. Economics,

M.S. Environmental Science,

Ph.D. Applied Wildland Econ.

14 years experience

Ad hoc IDT member, 

wrote Economics 

Report. 

Arden Warm Wildlife Biologist B.S. Wildlife Biology

20 Years Experience

IDT member, Data 

Collection, wrote 

Wildlife Report
FEIS Vol. III North Billings County Allotment Management Plan Revision

2 |Chapter 4

NAME TITLE BACKGROUND ROLE(s)

Joe 

Washington Botanist

B.S. Geology

M.S. Range Science

30 years experience

IDT member, Data 

Collection, Woody 

Draw and Seral Stage 

Analysis, wrote Botany 

Report

The Forest Service consulted the following people and organizations during the development of this 

environmental impact statement.

Table 4.2 — People and Organizations Consulted

People consulted Organization they're with

Billings County Commissioners Cooperating Agency

Board of Directors Medora Grazing Association

Jeff Dibenedetto USDA Forest Service, Custer National 

Forest

Alexis Duxbury North Dakota Game & Fish Dept.

Mike Ell North Dakota Dept. of Health

Amanda Gearhart North Dakota State University

Grazing permittees and lessors Medora Grazing Association

Dr. John Hendrickson USDA Agricultural Research Service.

Jeff Printz Natural Resource Conservation Service

Arron Robinson North Dakota Game and Fish

Dr. Kevin Sedivec North Dakota State University

Dan Uresk USDA Forest Service, Rocky Mountain 

Experiment Station

DISTRIBUTION OF THE SUPPLEMENTAL DRAFT ENVIRONMENTAL IMPACT 

STATEMENT

The Supplemental Draft Environmental Impact Statement (SDEIS) has been distributed to those 

who provided comment on the DEIS, grazing permittees, and to individuals or organizations who 

specifically requested a copy of the document. Notice of Availability was published in the Federal 

Register and a Notice of Comment in the Bismarck Tribune of Bismarck, North Dakota. The SDEIS 

has also been placed on the internet at 

http://www.fs.fed.us/r1/dakotaprairie/projects/index.shtml

Table 4.3 — Individuals To Whom the SDEIS Was Sent

Jerry Anheluk Albert & Pat Kessel Dennis O'Brien

James Arthaud Kevin Kessel Tim O'Brien

Dale Baranko Tony Kessel Tom Osdachuk
FEIS Vol. III North Billings County Allotment Management Plan Revision

Chapter 4| 3

Orest Baranko Roger Klym Cody & Julie Reis

Don Basaraba Kurt Kordon Clint Ridl

Roy Basaraba Mark Kordon Dave Rodakowski

Edwin Egly Roy Krivoruchka Les Simnioniw

Johnny Ewoniuk James Lowman Don Stigen

Harris & Ron Goldsberry Kasey Malkowski Cody Tachenko

Marvin Gregory Pete Malkowski Steve Tachenko

JoAnne Gregory Qwain Malkowski Troy Tescher

Neal Haverluk Roger Malkowski Allan Thompson

Dwight Hecker Pat Marx Joe & Emily Vesey

Ken Johnson William Meyer Tim Wyse

Larry Johnson Randy Mosser Cecilia Yourk

Kevin Kanski Bill O'Brien

Table 4.4 — Agencies and Organizations to Whom the SDEIS Was Sent

Billings County Commissioners North Dakota Parks and Recreation 

Department

Badlands Conservation Alliance North Dakota State Land Department

Golden Valley Board of County 

Commissioners

Slope County Commissioners

Little Missouri Grazing Association Teddy Roosevelt Group of Sierra Club

Medora Grazing Association U.S. Environmental Protection Agency, 

Region 8,Denver, CO

ND Chapter of the Society for Range 

Management

U.S. Environmental Protection Agency, 

Washington D.C.

North Dakota Game and Fish Department USDA, National Agricultural Library

North Dakota Department of Health Western Watersheds Project

The following agencies were supplied an executive summary of the project and web site address for 

the location of the SDEIS.

Table 4.5 — Agencies to Whom an Executive Summary and URL Were Supplied

Director, Planning and Review Advisory Council on Historic 

Preservation, Washington, DC

Division Administrator Federal Highway Administration

Deputy Director USDA APHIS PPD/EAD

USDA Natural Resources Conservation Service National 

Environmental Coordinator, Washington D.C.

Great Lakes Region Regional Administrator Federal Aviation 

Administration

NOAA Office of Policy and Strategic Planning, NEPA 

Coordinator

Rural Utilities Service (RUS)
FEIS Vol. III North Billings County Allotment Management Plan Revision

4 |Chapter 4

U.S. Army Engr. Northwestern Division

USDA, National Agricultural Library, Beltsville, MD

USDA Office of Civil Rights

U.S. Coast Guard (USCG) Environmental Management CG443

U.S. Department of Energy Director, Office of NEPA Policy 

and Compliance

ND Governor’s Office

ND Senator Kent Conrad

ND Senator John Hoeven

ND Representative Rick Berg
FEIS Vol. III North Billings County Allotment Management Plan Revision

References and Literature Cited

FEIS Vol. III North Billings County Allotment Management Plan Revision

References and Literature Cited| 1

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FEIS Vol. III North Billings County Allotment Management Plan Revision

Glossary

FEIS Vol. III North Billings County Allotment Management Plan Revision

Glossary| 1

Glossary

Action Alternative — Alternatives 3, 3A, and 4.

Actual Use — Is the grazing use made on an area by all classes of forage consumers. Including 

where, how many, what kind or class of livestock, and how long livestock graze on an allotment, or 

on a portion or pasture of an allotment. (43 CFR 4100.0-05)

Adaptive Management — A type of natural resource management in which decisions are made as 

part of an ongoing process. Adaptive management involves testing, monitoring, evaluating, and 

incorporating new knowledge into management approaches based on scientific findings and the 

needs of society. Results are used to modify management policy. 

Adaptive Management (as defined in this EIS) — Adaptive management is defined as a process 

where land managers implement management practices that are designed to meet LRMP standards 

and guidelines, and would likely achieve the desired conditions in a timely manner. If monitoring 

shows that desired conditions, as described by LRMP Direction, are not being met, then an alternate 

set of management actions, the effects of which are analyzed in this EA, would be implemented to 

achieve the desired results. 

Adjustment — Change in animal numbers, seasons of use, kinds or classes of animals, or 

management practices as warranted by specific conditions. 

Affected Environment — The biological and physical environment that may be changed by 

proposed actions and the relationship of people to that environment.

Allocation — The assignment of a land area to a particular use or uses to achieve management 

goals and objectives. 

Allotment — A designated area of land available for livestock grazing upon which a specified 

number and kind of livestock may be grazed under a range allotment management plan. It is the 

basic land unit used to facilitate management of the range resource on National Forest System 

lands, including national grasslands. 

Allotment Management Plan (AMP) — The document containing the action program needed to 

manage the range resource for livestock utilization, and possibly wildlife utilization, while 

considering the soil, watershed, wildlife, recreation, timber, and other resources in a range 

allotment. 

Alternative — A combination of management prescriptions applied in specific amounts and 

locations to achieve a desired management emphasis as expressed in goals and objectives. One of 

several policies, plans, or projects proposed for decision-making. An alternative need not substitute 

for another in all respects.

Animal Unit Equivalent — A number relating the forage dry matter intake (oven-dry basis) of a 

particular kind or class of animal relative to one AU. If intake is not known, it can be estimated 

from the ratio of the metabolic weight of the animal in question to the metabolic weight of one AU 

(450 kg to the .75 power).
FEIS Vol. III North Billings County Allotment Management Plan Revision

2 |Glossary

Animal Unit Month — The amount of feed or forage required by an animal-unit for one month. 

Animal Month — A month's tenure upon the rangeland by one animal. Must specify kind and class 

of animal. Note: This term is not synonymous with animal unit month (AUM). 

Animal Unit — Considered to be a mature 1,000-pound cow, either dry or with a calf less than six 

months old, based on an average daily forage consumption of 26 pounds dry matter per day. 

Annual (plant) — A plant that completes its life cycle and dies in one year or less. 

Aquatic Ecosystem — An ecosystem (biological and physical components and their interactions) 

in which water is the principal medium. Examples include wetlands, streams, reservoirs, and areas 

with plants or animals suited to either permanently or seasonally inundated soils.

Aquifer — A geologic formation capable of transmitting water through its pores at a rate sufficient 

for water-supply purposes. The term water-bearing is sometimes used synonymously with aquifer 

when a stratum furnishes water for a specific use. Aquifers are usually saturated sands, gravel, 

fractures, caverns, or vesicular rock (rock with cavities).

Archeological Resource — Any physical remains of past human life or activities. 

At-Risk — Woody draws that do not meet LRMP goals and objectives for desired woody draw 

conditions. Lack of desired woody species regeneration and low population age structure suggests 

the potential for the woody draw community to regress from the landscape.

Authorized Use — This is the amount of animals and months, expressed in Animal Months (AMs) 

or Animal Unit Months (AUMs), that the permittee is authorized to utilize though grazing of 

livestock for a specific grazing season on an allotment.

Available Forage — That portion of the forage production that is accessible for use by a specified 

kind or class of grazing animal. 

Base Property — This is the original property owned or leased by the original permittee on which 

grazing privileges were issued and grazing association preference was established.

Belt Transect —A strip, typically 1 m wide, that is marked out across a habitat and within which 

species are then recorded to determine their distribution in the habitat. A long, narrow, rectangular 

plot that is divided into regular blocks for the purpose of studying the vegetation and its associated 

biotic and abiotic factors.

Best Management Practices — Land management methods, measures or practices intended to 

minimize or reduce water pollution as well as practices that result in healthy ecosystems. Usually, 

BMPs are applied as a system of practices rather than a single practice. BMPs are selected based on 

site-specific conditions that reflect natural background conditions and political, social, economic, 

and technical feasibility. 

Biennial (plant) — A plant that lives for two years, usually flowering and fruiting only in the 

second year and then dying. 

Big Game — Certain wildlife that may be hunted for sport under state laws and regulations, 

including elk, mule and white-tail deer, turkey, and bighorn sheep. 
FEIS Vol. III North Billings County Allotment Management Plan Revision 

Glossary| 3

Biological Control Agents — Natural organisms, such as animals, insects, diseases, parasites and 

predators, that reduce pest populations of insects, diseases, and noxious weeds. 

Biological Control Methods — Use of natural organisms, such as insects, diseases, parasites, and 

predators to reduce pest populations of insects or weeds or to control diseases. Methods may 

include importation and release, conservation of native natural-enemy species, and augmentation 

(supplementation through rearing and release or genetic improvements) of biological control agents. 

Biological Diversity — The full variety of life in an area, including the ecosystems, plant and 

animal communities, species and genes, and the processes through which individual organisms 

interact with one another and their environments. Emphasis is on the diversity of native or endemic 

species. 

Biologically Capable — Any site classified as one of the following habitat types: western 

wheatgrass/green needlegrass, western wheatgrass/needle-and-thread grass, needle-andthread/sedge, silver sage/western wheatgrass, big sage/western wheatgrass or western snowberry. 

Sites dominated by crested wheatgrass were also considered biologically capable. 

Biomass — The total amount of living plants and animals above and below ground in an area at a 

given time. 

Broken Lands — Lands located in the project area that have been cultivated at some point in the 

past. Most of the lands were seeded to crested wheatgrass during the 1930s as a soil conservation 

measure. 

Browse — Twigs, leaves, and young shoots of trees and shrubs upon which animals feed: in 

particular, those shrubs that are utilized by some livestock and big game animals for food. 

Butte — An isolated hill with relatively steep sides. A mesa. 

Cactus — A spiny, succulent plant of the Cactaceae family. 

Candidate Species — Species for which the U.S. Fish and Wildlife Service has on file sufficient 

information on biological vulnerability and threat(s) to support issuance of a proposed rule to list 

the species for protection under the Endangered Species Act. 

Capable Rangeland — The potential of an area of land to produce resources, supply goods and 

services and allow resource uses under an assumed set of management practices and at given levels 

of management intensity. Capability depends on current conditions and site conditions such as 

climate, slope, landform, soils, and geology, as well as the application of management practices 

such as silviculture or protection from fire, insects, and disease. 

Carrying Capacity (as defined in this EIS and by Society for Range Management) — The 

average number of livestock and/or wildlife that may be sustained on a management unit 

compatible with management objectives for the unit. In addition to site characteristics, it is a 

function of management goals and management intensity 

Class of Animal — Description of age and/or sex-group for a particular kind of animal. Example: 

cow, calf, yearling, ewe, doe, fawn, etc. 
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Class of Livestock — Type of animal permitted to graze e.g. cow/calf pair, bull, yearling, horse, 

bison.

Common Allotment (commons) — An allotment where two or more operators are permitted to 

graze livestock.

Community (Biological) — Any assembly of organisms living together. 

Community (Social) — The people who reside in one locality and are subject to the same laws or 

who have common interests, etc. 

Community Stability — The capacity of community to absorb and cope with change without 

major hardship to institutions or groups within the community.

Complementary Pasture — Short-term forage crop (not necessarily annual) planted for use by 

domestic stock to enhance the management and productivity of the ranch.

Composition Timing Conflict — Poor coordination of grazing periods with invasive grass 

palatability when these species comprise significant portions of the potential forage resource. 

Results in an increased potential for excessive utilization of the native forage component. 

Conservation — The aggregate of practices and customs to perpetuate sustained yield of renewable 

resources and prevent waste of nonrenewable resources. 

Conservation Practices — Required land use practices on the national grasslands that are imposed 

upon the persons or organizations holding grazing permits (including grazing agreements) in order 

to protect, improve, develop, and administer the land and thus assist in furthering the program of 

land conservation and good land utilization. 

Consumptive Uses — Uses of a resource that reduce the supply. Examples include irrigation, 

domestic and industrial water use, grazing, and timber harvest. 

Continuous Grazing — The grazing of a specific unit by livestock throughout a year. 

Continuous Stocking — A method of grazing livestock on a specific unit of land where animals 

have unrestricted and uninterrupted access throughout the time period when grazing is allowed. The 

length of the grazing period should be defined.

Cool-Season Plant — A plant that generally makes the major portion of its growth during the late 

fall, winter, and early spring. Cool-season species generally exhibit the C3 photosynthetic pathway. 

Cost — The negative or adverse effects or expenditures resulting from an action. Costs may be 

monetary, social, physical, or environmental in nature. 

Cost Efficiency — The usefulness of specified inputs (costs) to produce specified outputs 

(benefits). In measuring cost efficiency, some outputs, including environmental, economic, or social 

impacts, are not assigned monetary values but are achieved at specific levels in the least-cost 

manner. Cost efficiency is usually measured using present net value, although use of benefit-cost 

ratios and rates of return may be appropriate. 
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Council on Environmental Quality — An advisory council to the President established by the 

National Environmental Policy Act of 1969. 

Cover Type — The vegetative species that dominates a site. Cover types are named for one plant 

species or non-vegetative condition presently (not potentially) dominant, using canopy or foliage 

cover as the measure of dominance. In several cases, sites with more than one dominant species 

have been lumped together into one cover type. Co-dominance is not necessarily implied. 

Cover/Forage Ratio — The ratio of tree cover (usually conifer types) to foraging areas, such as 

natural openings. 

Crested Wheatgrass Pasture — A grazing unit that is composed of at least 70 percent crested 

wheatgrass.

Cropland — Land primarily used for the production of cultivated crops.

Cross Fence — A fence that divides an allotment or pasture into smaller units.

Cross Fence (as defined in this EIS) — A temporary or permanent fence used to subdivide a 

pasture.

Cultural Resources — See Heritage Resources. 

Cumulative Effect — The impact on the environment that results from the incremental effect of the 

action when added to other past, present, and reasonably foreseeable future actions regardless of the 

source (federal or nonfederal agencies, individuals). Cumulative effects can result from individually 

minor but collectively significant actions taking place over time. 

Cured Forage — Forage, either standing or harvested, that has been naturally or artificially dried 

and preserved for future use.

Daubenmire Plot Frame — Is a 25 x 50 centimeter (10 x 20 inch ) internal dimension frame made 

out of rebar or PVC which can be randomly thrown in a patch of vegetation to be sampled, 

systematically placed along a transect, or placed in a randomized grid. Visual estimates are then 

made of the percent cover of desired vegetation components occurring within the Daubenmire 

Frame.

Diameter at Breast Height — Diameter at breast height of a tree.

Decadent Tree Layer — Old trees declining in health due to old age, disease, effects of the 

elements, etc.

Deciduous (Plant) — Plant parts, particularly leaves, that are shed at regular intervals or at a given 

stage of development; that is, a deciduous plant regularly loses or sheds its leaves. 

Decision Documents — Documents that provide the criteria and information used in the 

formulation and evaluation of alternatives and the preferred alternative. 

Decreaser (Plant) — Plant species of the original or climax vegetation that will decrease in relative 

amount with continued disturbance (heavy defoliation, fire, drought) to the norm. Some agencies 

use this only in relation to response to overgrazing. 
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Deferment — Delay of livestock grazing on an area for an adequate time to allow plant 

reproduction, establishment of new plants, or restoration of vigor of existing plants. 

Deferred Rotation — To discontinue grazing on various parts of a range in succeeding years,

allowing each part of the range to rest successively during the growing season to permit seed 

production, establishment of seedlings, or restoration of plant vigor. Each rested part of the range is 

grazed during the year. At least two, but usually three or more, separate grazing units are required. 

Defoliation — The removal of plant leaves by grazing or browsing, cutting, chemical defoliant, or 

natural phenomena, such as hail, fire, or frost. 

Demand — The amount of output that users are willing to take at a specified price, time period, and 

conditions of sale. 

Dependent Communities — Communities whose social, economic, or political life would become 

discernibly different in important respects if market or no market outputs from the national forest or 

national grasslands were significantly disrupted. 

Desired Condition — A portrayal of the land or resource conditions that are expected to result if 

goals and objectives are fully achieved. 

Desired Plant Community — A plant community that produces the kind, proportion, and amount 

of vegetation necessary for meeting or exceeding the land use plan/activity plan objectives 

established for an ecological site. The desired plant community must be consistent with the site's 

capability to produce the desired vegetation through management, land treatment, or a combination 

of the two. 

Desired Plant Species — Species that contribute positively to the management objectives. 

Deteriorated Range — Range where vegetation and soils have significantly departed from the 

natural potential. Corrective management measures, such as seeding, would change the designation 

from deteriorated range to some other term. 

Detrimentally Impacted Soils — An increase in bulk density from the average undisturbed bulk 

density values and the removal of soil from a continuous area of 100 square feet or more.

Developed Recreation — This type of recreation is dependent on facilities provided to enhance 

recreational opportunities in concentrated use areas. Examples include campgrounds and picnic 

areas. Facilities in these areas might include roads, parking lots, picnic tables, toilets, drinking water 

and buildings. 

Developed Recreation Sites — Relatively small, distinctly defined areas where facilities are 

provided for concentrated public use, such as campgrounds, picnic areas, and swimming beaches. 

Direct Effects — Environmental effects caused by an action and that occur at the same time and 

place. 

Dispersal — Leaving an area of birth, origin, or activity for another area. 

Dispersed Recreation — This type of recreational use requires few, if any, improvements and may 

occur over a wide area. This type of recreation involves activities related to roads, trails and 
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undeveloped waterways, and beaches. The activities do not necessarily take place on or adjacent to 

a road, trail, or waterway, only in conjunction with them. Activities are often day-use oriented and 

include hunting, fishing, boating, off-road vehicle use, hiking, and others. 

District Ranger — The official responsible for administering the National Forest System lands, 

including national grasslands, on a ranger district. 

Disturbance — A discrete event, either natural or human induced, that causes a change in the 

existing condition of an ecological system. 

Diversity — Diversity refers to the distribution and abundance of different plant and animal 

communities and species within the area covered by land and resource management plans. This 

term is derived from the National Forest Management Act (NFMA). This term is not synonymous 

with biological diversity. 

Domestic — Refers to those animals and plants that are under the control of humans throughout 

their life cycle. Animals whose breeding is controlled by humans. 

Draft Environmental Impact Statement — The statement of environmental effects required for 

major federal action under Section 102 of the National Environmental Policy Act and released to 

the public and other agencies for comment and review.

Drift Fence — An open-ended fence used to retard or alter the natural movement of livestock.

Generally used in connection with natural barriers.

Drought — Any year or sequence of years when annual precipitation amounts are less than 75

percent below average. 

Dugout — An artificially constructed depression that collects and stores water and differs from a 

reservoir in that a dam is not relied upon to impound water.

Early Grazing — Turn out on these pastures will occur in late April or the first of May to take 

advantage of the crested wheatgrass forage.

Ecological Diversity — The variety of ecosystems occurring within a given landscape. 

Ecological Functionality — Interaction and role of the environment, habitat, and species in 

gathering, storing, and releasing energy components over time, such as nutrient cycling, soil 

development, water budgets.

Ecology — The study of the interrelationships of organisms with their environment.

Economic Efficiency — The usefulness of inputs (costs) to produce outputs (benefits) and effects 

when all costs and benefits that can be identified and valued are included in the computations. 

Economic efficiency is usually measured using present net value, though use of benefit-cost ratios 

and rates-of-return may sometimes be appropriate.

Ecosystem — 1) A community of living plants and animals interacting with each other and with 

their physical environment. A geographic area where it is meaningful to address the 

interrelationships with human social systems, sources of energy, and the ecological processes that 
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8 |Glossary

shape change over time. 2) A community of organisms and its environment functioning as an 

ecological unit in nature. 

Ecosystem Health — A condition where the parts and functions of an ecosystem are sustained over 

time and where the system's capacity for self-repair is maintained, such that goals for uses, values, 

and services of the ecosystem are met. 

Ecosystem Management — Scientifically based land and resource management that integrates 

ecological capabilities with social values and economic relationships to produce, restore, or sustain 

ecosystem integrity and desired conditions, uses, products, values, and services over the long term. 

Effects — Physical, biological, social, and economic results (expected or experienced) resulting 

from achievement of outputs. Effects can be direct, indirect, and cumulative. 

Effects (Heritage Resources) — Impacts to the characteristics that qualify a heritage resource for 

the National Register of Historic Places. These can include alterations in location, setting, use 

design, materials, feeling, and association. Adverse effects include: Physical destruction or damage; 

Isolation from or alteration of setting; Introduction of visual, audible, or atmospheric elements; 

Physical deterioration from neglect or from any action; and Transfer, lease, or sale. 

Eligible (Heritage Resources) — Indicates that a specific heritage resource qualifies for or is 

already listed in the National Register of Historic Places. 

Endemic — Plants or animals that occur naturally in an area and whose distribution is relatively 

limited to a particular locality. 

Environment — All the conditions, circumstances, and influences surrounding and affecting the 

development of an organism or group of organisms. 

Environmental Analysis — An analysis of alternative actions and their predictable short- and 

long-term environmental effects, which include physical, biological, economic, social, and 

environmental design factors and their interactions. 

Environmental Impact Statement — A public document, for which a federal agency is 

responsible, that serves to disclose the effects of a federal action, and alternatives, on the human 

environment. It is used by federal officials to plan actions and make decisions. 

Ephemeral Streams — Streams that flow only as a direct response to rainfall or snowmelt events. 

They have no base flow.

Erosion — The wearing away of the land surface by running water, wind, ice, gravity, or other 

geological activities. 

Evapotranspiration — Total water loss from the soil, including that by direct evaporation and that 

by transpiration from the surfaces of plants

Exclosure — An area fenced to exclude livestock grazing.

Executive Order — An order or regulation issued by the President or some administrative 

authority under presidential direction. 
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Exotic — Not native to the place where it is found. Often in reference to a specific race or variety 

of an organism that has been transplanted to a new region. 

Exotic Species — An organism that exists in a free state in an area in which it is not native. Also 

refers to animals from outside the country in which they are held captive or in free-ranging 

populations. 

Extensive Grazing Management — Extensive range management carries the goal to control 

livestock numbers within the present capacity of the range, but little or no attempt is made to 

achieve uniform distribution of livestock. Range management investments are minimal and only to 

the extent needed to maintain stewardship of the range in the presence of grazing. Past resource 

damage is corrected and resources are protected from natural catastrophes.

Extinction — Disappearance of a taxon of organisms from existence in all regions. 

Fair Market Value — The amount or value for which, in all probability, a property would be sold 

by a knowledgeable owner willing but not obligated to sell to a knowledgeable purchaser who 

desires but is not obligated to buy. 

Family Living Withdrawals — Cash withdrawals paid by the business to cover family living 

expenses.

Fauna — All vertebrate and invertebrate animal species. 

Fertilizer — Mineral nutrients added to the substrate of plants to enhance growth and vitality. 

Fire-dependent Systems — Forests, grasslands, and other ecosystems historically composed of 

species of plants that evolved with and are maintained by fire regimes. 

Floodplain — The area adjacent to a stream/river channel effective in carrying flow, within which 

carrying capacity must be preserved and where the flood hazard is generally highest; that is, where 

flood depths and velocities are the greatest (FSH 2520). 

Flora — All plant species. 

Fluvial — Of, relating to, or inhabiting a river or stream.

Forage — Vegetation used for food by wildlife and livestock, particularly ungulate wildlife and 

domestic livestock. 

Forage Production — The weight of forage that is produced within a designated period of time on 

a given area. The weight may be expressed as green, air dry, or oven dry. The term may also be 

modified as to time of production such as annual, current year, or seasonal forage production. 

Forbs — Any herbaceous plant other than those in the grass, sedge, and rush families. For example, 

any non grass-like plant that has little or no woody material.

Fragmentation — The breakup of a large land area (such as a grassland) into smaller patches 

isolated by areas converted to a different land type. The opposite of connectivity. 

Free-flowing — Existing or flowing in natural condition without impoundment, diversion, 

straightening, rip-rapping, or other modification of the waterway.
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Functional-At Risk — Riparian areas are in a functional condition but one or more properties, i.e., 

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

Geographic Information System — A spatial type of information management system that 

provides for the entry, storage, manipulation, retrieval, and display of spatially oriented data. 

Goal — A concise statement that describes a desired condition to be achieved sometime in the 

future. A goal is normally expressed in broad, general terms that are timeless in that there is no 

specific date by which the goal is to be achieved (36 CFR 219.3). The Region 2 Desk Guide has this 

to say about goals: "Desired conditions and processes are measurable, have a timeless nature, and 

describe a resource condition or ecological process. In the first round of (land and resource 

management) planning, these statements were often termed 'goals.' They describe the conditions or 

processes we expect to achieve through resource management. Complete accomplishment of 

desired conditions is not mandatory during the current planning phase, but it is our ultimate intent."

Graminoid — Grass or grass-like plant, such as Poa, Carex, or Juncus species 

Grass — A member of the grass family, Poaceae. 

Grassland — Any land on which the dominant plants are grasses or on which grasses originally 

dominated.

Grasslands Plan (Land and Resource Management Plan) — A document that guides natural 

resource management and establishes standards and guidelines for a national forest or national 

grassland. Required by the National Forest Management Act.

Grazing — The act of animals consuming plants on range or pasture. 

Grazing Agreement — Authorizes livestock grazing on a given area of National Forest System 

lands for a group of permittees known as a Grazing Association (Region 2).

Grazing Capacity — The maximum number of livestock under management that a given range 

area is capable of supporting within guidelines found in the allotment management plan. 

Grazing Distribution — Dispersion of livestock or wild herbivores grazing within a given area. 

Grazing Fee — A charge, usually on a monthly basis, for grazing use by a given kind of animal. 

Grazing Land — An area of rangeland, public or private, that is used by animals for grazing. 

Grazing Permit — Official, written permission to graze a specified number, kind, and class of 

livestock for a specific period on a defined range allotment. 

Grazing Season — 1) A period of grazing to obtain optimum use of the forage resource. 2) On 

public lands, an established period for which grazing permits are issued. 

Grazing System — A specialization of grazing management that defines systematically recurring 

periods of grazing and deferment for two or more pastures or management units. Some examples 

are: deferred grazing, rotation grazing, deferred-rotation grazing, and short-duration grazing. 

Grazing Unit — An area of rangeland, public or private, that is grazed as an allotment or pasture. 
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Grazing, Short-duration — A grazing system in which animals are concentrated on less than onehalf of the total land area and the lengths of deferment exceed the lengths of grazing. 

Ground Cover — The percentage of material, other than bare ground, covering the land surface. It 

may include live and standing dead vegetation, litter, cobble, gravel, stones, and bedrock. Ground 

cover plus bare ground would total 100 percent. 

Groundwater — Water in the Earth that supplies wells and springs. Specifically, water in the zone 

of saturation where all openings in soils and rocks are filled. The upper surface level forms the 

water table. 

Growing Season — In temperate climates, that portion of the year when temperature and moisture 

permit plant growth. 

Guideline — Advisable actions that should be followed to achieve grassland or forest goals and 

objectives. Deviations from guidelines must be analyzed during project-level analysis and be 

documented in a project decision document but do not require management plan amendments. 

Habitat — The sum total of environmental conditions of a specific place occupied by a wildlife 

species or a population of such species. 

Habitat Capability — The capacity of a vegetative community to support selected wildlife and fish 

species for all or a part of its life cycle. Habitat capacity is normally expressed as projected 

populations or densities of animals. 

Habitat Effectiveness — As used in this document, habitat effectiveness refers to the capability of 

an area to support big game based on forage, cover, open roads, and the spatial distribution of the 

three factors, regardless of the time of year. 

Habitat Suitability — A measure of current habitat quality relative to local biological potential of 

an area to provide habitat for a species. Usually expressed as low, moderate or high or is 

quantitatively presented as an index value scaled from 0 (unsuitable) to 1.0 (optimum habitat). 

Hardened Water Crossings — Livestock watering sites where techniques have been used to 

protect stream banks and stream beds from sloughing and erosion. For example, livestock may be 

confined to one short section of a stream where rock, gravel, or concrete has been placed on the 

banks of the stream. 

Hardwood — Pertains to broadleaf trees or shrubs.

Hardwood Draws — Upland drainages containing deciduous trees and shrubs. Synonymous with 

green ash hardwood draws. 

Harvest Efficiency — The total percent of vegetation harvested by a machine or ingested by a

grazing animal compared to the total amount of vegetation grown in the area in a given year. For 

continuous grazing, harvest efficiency usually averages 25 percent on rangeland, 30 percent on 

pastureland, and 35 percent on grazed cropland.

Hay — Herbage, especially grass and legumes, mowed, cured, and stored for fodder.

Haying — The mowing, baling, and storage of hay to be used as a product.
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Headquarters — Is the historic wintering and feeding land. It includes the base property and may 

include other commensurate property. Originally a headquarters would have included buildings and 

other improvements.

Headquarters Allotment — This type of allotment has units that are associated with common 

allotment for eight months of summer grazing and livestock units from the common return to this 

allotment for the winter months. This type of allotment also designated summer livestock units and 

summer pastures.

Healthy — Woody draws that meet the LRMP goals and objectives for desired conditions 

involving thick and brushy understories and multi-story and multi-age structure of the tree canopy 

as site potentials warrant.

Herb — A plant with one or more stems that dies back to the ground each year. 

Herbaceous — Non-woody plant growth.

Herbicide — A chemical substance used for killing plants. 

Herbivore — An animal that subsists principally or entirely on plants or plant material. 

Herd — An assemblage of animals usually of the same species. 

Herding — The handling or tending of a herd.

Heritage Resources — The physical remains and conceptual content or context of an area. Physical 

remains may include artifacts, structures, landscape modifications, rock art, trails, or roads. 

Conceptual content/context includes the setting for legendary, historic, or prehistoric events, such as 

a sacred area for American Indians. 

High Structure — Herbaceous structure that averages greater than 3.5 inches along a visual 

obstruction reading (VOR) transect measured in the autumn.

High Value Woody Draws — Woody draws in a Healthy condition or with a high potential to 

achieve Healthy conditions with changes in management based on current species composition and 

the potential for increased regeneration of desired woody species. Maintenance or achievement of 

Healthy conditions would appreciably add to ecologic conditions within the effected landscape or 

allotment that would contribute to the achievement of resource objectives.

Historic Property — Any prehistoric or historic district, site, building, structure, or object included 

in or eligible for inclusion in the National Register. This term includes artifacts, records, and 

remains related to and located within such properties. 

Home Range — The geographic area within which an animal restricts its activities. 

Human Environment — Includes the natural and physical environment and the relationship of 

people within that environment. 

Hydrologic Cycle — The ecological cycle that moves water from the air, by precipitation, to the 

earth and back to the atmosphere. A variety of processes are involved, including evaporation, 

runoff, infiltration, percolation, storage, and transpiration. 
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Implementation — Those activities necessary to initiate the actions in the approved land and 

resource management plan. 

Inaccessible Range — Rangeland that is not grazed by livestock because of barriers, distance to 

water or steep slopes. 

Increaser (Plant) — Plant species of the original vegetation that increase in relative amount, at 

least for a time, under continued disturbance (heavy defoliation, fire, drought) to the norm. 

Indigenous Species — Animals or plants that originated in the area in which they are found; for 

example, animals or plants that were not introduced after frontier settlement of the Northern Great 

Plains and that naturally occur on the Northern Great Plains. 

Indirect Effects — Environmental effects caused by an action but resulting later in time or farther 

away in place, yet which are still reasonably foreseeable. 

 Informing the public of Forest Service activities, plans, and decisions. 

Induced Economic Impacts — Impacts of household expenditures, from the income earned in a 

directly or indirectly affected industry. The spending and re-spending of these dollars in the local 

and state economies.

Instream Flows — The minimum water volume (cubic feet per second) in each stream necessary to 

meet seasonal stream flow requirements for maintaining aquatic ecosystems, visual quality, 

recreational opportunities, and other uses. 

Intensity (Fire Management) — A measure (in BTUs per foot per second) of the energy released 

per unit of time in an area of actively burning fire; the amount of heat released per foot of fire front 

per second. 

Intensive Grazing Management — Grazing management that attempts to increase production or 

utilization per unit area or production per animal through a relative increase in stocking rates, forage 

utilization, labor, resources, or capital. Intensive grazing management is not synonymous with 

rotation grazing. Grazing management can be intensified by using any one or more of a number of 

grazing methods that use relatively more labor or capital resources. 

Interdisciplinary Team — A group of people with different specialized training assembled to 

solve a problem or perform a task. The team is assembled out of recognition that no one discipline 

is sufficiently broad to adequately solve the problem. Through interaction, participants bring 

different points of view and a broader range of expertise to bear on the problem. 

Intermittent Stream — 1) A stream that flows only 50 to 90 percent of the year when it receives 

water from some surface source, such as melting snow. 2) A stream that does not flow continuously, 

as when water losses from evaporation or seepage exceed the available stream flow. 

Introduced Species — A species not a part of the original fauna or flora of the area in question. 

Invaded Grass State — Plant community where invasive grass species comprise more than 30% of 

the total plant production when all species are measured, or less than 40% of the total grass 

composition when only grasses and select species are measured.
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Invader (Plant) — Plant species that were absent in undisturbed portions of the original vegetation 

of a specific range site and will invade or increase following disturbance or continued heavy 

grazing. 

Invasive Plant — A species that displays rapid growth and spread, free from natural controls and 

enhanced by abundant seed production and germination. 

Inventory Allotment — An allotment with private and National Grassland land on which the total 

number of animals is limited by the grazing permit.

Inventory Permit — A permit that has eight months of summer grazing (May 1st to December 

31st), two months of winter grazing (January and February), and two months of winter feeding 

(March and April). Under this type of permit, livestock are located within the allotment twelve 

months out of the year. Typically, there are intermingled land ownerships, and wintering on NFS 

lands may occur.

Irretrievable Commitments — Applies to losses of production or use of renewable natural 

resources for a period of time. For example, road construction leads to an irretrievable loss of the 

productivity of the land under which the road is located. If the road is later obliterated, the land may 

eventually become productive again. The production lost is irretrievable, but the action is not 

irreversible. 

Irreversible Commitments — Decisions causing changes that cannot be reversed. For example, if 

an area is mined, that area cannot, at a later date, be allocated to some other resource activities, such 

as Wilderness. Once mined, the ability of that area to meet Wilderness criteria, for instance, has 

been irreversibly lost. Irreversible commitments often apply to some non-renewable resource, such 

as minerals and heritage resources. 

Landowner — Person who has title to land recognized by the prevailing legal system. 

Landscape — The landforms of a region in aggregate. 

Lek — A lek is an area of varying size where male sharp-tailed grouse gather for the purposes of 

competitive mating display. The term “dancing ground” is synonymous with a lek. 

Lentic —A Lentic Ecosystem has still waters. Examples include: ponds, basin marshes, ditches, 

reservoirs, seeps, lakes, and vernal / ephemeral pools.

Linear Stringer — Woodys occurring in a narrow line generally following a drainage.

Listed Species — Any species of fish, wildlife, or plant officially designated as endangered or 

threatened by the Secretary of the Interior or Commerce. 

Litter — A surface layer of loose organic debris consisting of freshly fallen or slightly decomposed 

organic materials. 

Livestock — Any animal raised for food or pleasure including, but not limited to, beef and dairy 

cattle, sheep, swine, poultry, and horses. The definition also includes fur animals raised for their 

pelts. 
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Livestock Use Permit — Used to document specific animal numbers, class, and seasons of use 

under a specified management plan for a given period (10 years). 

Lotic — A Lotic Ecosystem has flowing waters. Examples include: creeks, streams, runs, rivers, 

springs, brooks and channels.

Low Structure — Herbaceous structure that averages less than 1.5 inches along a visual 

obstruction reading (VOR) transect measured in the autumn.

Management — The organization of actions designed to reach a given set of objectives. 

Management Area — Area of the grassland that are managed for a particular emphasis. These 

areas have common management direction and may be non contiguous on the national forest or 

national grassland. 

Management Indicator Species — A plant or animal species selected because their status is 

believed to (1) be indicative of the status of a larger functional group of species, (2) be reflective of 

the status of a key habitat type, or (3) act as an early warning of an anticipated stressor to ecological 

integrity. The key characteristic of a MIS species is that its status and trend provide insights to the 

integrity of the larger ecological system to which it belongs. 

Management Indicators (Fish and Wildlife) — Plant or animal species or habitat components 

selected in a planning process used to monitor the effects of planned management activities on 

populations of wildlife and fish, including those that are socially or economically important. 

Marginal Land — Land of questionable physical or economic capabilities for sustaining a specific 

use. 

Market Value — The unit price of an output normally exchanged in a market after at least one 

stage of production, expressed in terms of what people are willing to pay as evidenced by market 

transactions. 

Memorandum of Understanding — A legal agreement between the Forest Service, other 

agencies, private parties, or individuals resulting from consultation between them that states specific 

measures they will follow to accomplish a project. A memorandum of understanding is not a fundobligating document. 

Migration — The movement of genotypes (as individuals) into or out of a population. 

Mitigate — To lessen the severity. 

Mitigation — Includes avoiding an impact by not taking certain actions; minimizing impacts by 

limiting the degree or magnitude of the action and its implementation; rectifying the impact by 

repairing, rehabilitating, or restoring the affected environment; reducing or eliminating the impact 

over time by preservation and maintenance operations during the life of the action; and 

compensating for the impact by replacing or providing substitute resources or environments. 

Mitigation (Heritage Resources) — Actions taken to reduce or eliminate adverse effects caused to 

heritage resources. Avoidance is not considered a mitigation measure. 
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Moderate Structure — Herbaceous structure that averages 1.5 inches to 3.5 inches along a visual 

obstruction reading (VOR) transect measured in the autumn.

Monitoring and Evaluation — The sample collection and analysis of information regarding 

LRMP management practices to determine how well objectives have been met, as well as the 

effects of those management practices on the land and environment. 

Monoculture — The cultivation of a single crop to the exclusion of other land uses. 

Mowing — The cutting of hay to be left on the ground.

Multiple Use — According to the Multiple Use Sustained Yield Act of 1960, multiple use is the 

management of all the various renewable surface resources of the National Forest System, including 

national grasslands, so that they are utilized in the combination that will best meet the needs of the 

American people. Such management makes the most judicious use of the land for some or all of 

these resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use to conform to changing needs and conditions. Some lands will be used for less 

than all of the resources. Harmonious and coordinated management of the various resources is 

employed, each with the other, without impairment of the productivity of the land. Consideration is 

given to the relative values of the various resources and not necessarily the combination of uses that 

gives the greatest dollar return or the greatest unit output. 

National Environmental Policy Act of 1969 — An act declaring a national policy to encourage 

productive harmony between people and their environment, to promote efforts that will prevent or 

eliminate damage to the environment and the biosphere and stimulate the health and welfare of 

people and to enrich the understanding of the ecological systems and natural resources important to 

the nation and to establish a Council on Environmental Quality. 

National Forest Management Act — A 1976 law that amended the Forest and Rangeland 

Renewable Resources Planning Act and requires the preparation of Regional and Forest Plans and 

regulations to guide forest plan development. 

National Forest System Lands — Federal lands designated by Executive Order or statute as 

national forests, national grasslands, or purchase units, or other lands under the administration of the 

U.S. Forest Service. 

Native — A plant or animal indigenous to a particular locality.

Native Invaded — This state is very similar to the reference state. The invasion of introduced cool 

season sodgrasses has altered the natural range of variability for this ecological site. This state is 

still dominated by native cool season grasses, but invasive introduced cool season sodgrasses are 

now present in all community phases of this state. The primary disturbance mechanisms for this 

state include grazing by domestic livestock and infrequent fires. Timing and duration of grazing 

coupled with weather events dictate the dynamics that occur within this state. The cool season 

native grass can decline and an increase in introduced sod grasses will occur. Many times, this state 

appears as a mosaic of community phases caused primarily by continuous season-long grazing.
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Native-Invaded State — Plant community at any seral stage largely dominated by native grass 

species with subordinate amounts of invasive grasses. Invasive grass species comprise less than 

30% of the total plant production when all species were measured, or less than 40% of the total 

grass production when only key or primary species were measured. 

Native Pasture — A pasture primarily composed of native grass, sedges, forbs, and shrubs.

Native Seed — Seeds of plants considered indigenous to the Northern Great Plains. 

Natural — Occurring in conformity with the ordinary course of nature. An area having undergone 

no, or at least minimal, disturbance by anthropogenic forces. 

Natural Barrier — A natural feature that will restrict livestock movements, such as a dense stand 

of trees or downfall, or a feature that will stop the spread of fire, such as a talus slope, water course, 

or areas otherwise devoid of fuel. 

NEPA Process — Means all measures necessary for compliance with the requirements of Section 2 

and Title I of NEPA. 

No Action Alternative — An alternative that maintains established trends or management 

direction. 

Non-consumptive Use — Those resources that do not reduce the supply. Non-consumptive uses of 

water include hydroelectric power generation, boating, swimming, etc. 

Nonfunctional — The riparian area is not functioning properly. Typically, nonfunctioning riparian 

areas do not provide adequate vegetation, channel properties, or woody debris to dissipate stream 

energy associated with high flows and thus do not reduce erosion, improve water quality, capture 

sediment, etc.

Non-point Source Pollution — Pollution whose source is not specific in location. The sources of 

the pollutant discharge are dispersed, not well-defined or constant. Examples include sediments 

from logging activities and runoff from agricultural chemicals. 

Noxious Weeds — Those plant species designated as weeds by federal or state laws. Noxious 

weeds generally possess one or more of the following characteristics: aggressive and difficult to 

manage, poisonous, toxic, parasitic, a carrier or host for serious insects or diseases, and generally 

non-native. 

Nutrient Cycling — Is the movement of those materials that are essential to organisms.

Objective — A concise, time-specific statement of measurable, planned results that respond to preestablished goals. An objective forms the basis for further planning to define the precise steps to be 

taken and resources to be used in achieving identified goals. 

Other Grass State — Used to reference areas of broken land that were seeded to crested 

wheatgrass and generally now contain a mixture of crested wheatgrass, other invasive grasses, and 

native grasses. 

Overgrazing — Continued heavy grazing that exceeds the recovery capacity of the community and 

creates a deteriorated range. 
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Overstocking — Placing a number of animals on a given area that will result in overuse if 

continued to the end of the planned grazing period. 

Overstory — The portion of vegetation in a forest that forms the uppermost foliage layer. 

Pasture — A land area consisting of grass or other growing plants used as food by grazing animals. 

Also an area used for grazing, often enclosed and separated from other areas by fences, hedges, 

ditches, or walls. 

Perennial (plant) — A plant that lives for two or more years. 

Perennial Streams — Streams that flow continuously throughout most years. 

Permitted Grazing — Use of a National Forest System range allotment under the terms of a 

grazing permit. 

Permitted Use — This is the historical total amount of animals and months, expressed in Animal 

Months (AMs), that the permittee can utilize through grazing of livestock on an allotment.

Permittee (Grazing) — One who holds a permit to graze livestock on state, federal, or certain 

privately owned lands. 

Pioneer Species — The first species or community to colonize or recolonize a barren or disturbed 

area in primary or secondary succession. 

Plant Communities — Assemblages of plant species living in an area. A plant community is an 

organized unit to the extent that it has characteristics in addition to the individuals and populations 

and functions as a unit. 

Preference — Refers to the historical, maximum number of head of livestock for a given number of 

months on an allotment.

Preference Number — The annual grazing association grazing permit provides a Preference 

number that is the maximum number of livestock for a given amount of time allocated to that 

allotment. 

Preferred Alternative — The alternative recommended for implementation in the Forest Plan 

based on the evaluation completed in the planning process. 

Prehistoric Site — Archeology sites associated with American Indians and usually occurring 

before contact with Europeans. 

Prescribed Burning — Controlled application of fire to wild land fuels in either their natural or 

modified state, under specified environmental conditions, that allows the fire to be confined to a 

predetermined area and, at the same time, to produce the fire line intensity and rate of spread 

required to attain planned resource management objectives. 

Prescribed Fire — A fire burning with prescription, resulting from planned or unplanned ignition. 

Proper Functioning Condition — Riparian/wetland areas achieve proper functioning condition 

when adequate vegetation, landform, or large woody debris is present to dissipate stream energy 

associated with high water flows. This reduces erosion; improves water quality; filters sediment; 
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captures bed load; aids floodplain development; improves floodwater retention and groundwater 

recharge; develops root masses that stabilize stream banks against cutting action; develops diverse 

ponding and channel characteristics to provide habitat and water depth, duration, and temperature 

necessary for fish production, waterfowl breeding, and other uses; and supports greater biodiversity. 

The functioning condition of riparian/wetland areas is a result of the interaction among geology, 

soil, water, and vegetation. 

Properly Functioning — The stream has adequate streambank vegetation, proper stream 

morphology (structure), or instream structures (i.e. woody debris, rock, etc.) present to dissipate 

stream energy, during high flows. This results in benefits including, but not limited to, reduced 

erosion, sediment and bedload capture, floodplain development, improved water quality, groundwater recharge, and development of streambank root masses.

Proposed Action — In terms of the National Environmental Policy Act, the project, activity, or 

action that a federal agency intends to implement or undertake and which is the subject of an 

environmental analysis. 

Proposed Species — Any species of fish, wildlife, or plant that is proposed by the Fish and 

Public — The people of an area, state, or nation that can be grouped together by a commonality of 

interests, values, beliefs, or life-style. 

Public Involvement — A Forest Service process designed to broaden the information base upon 

which agency decisions are made. It includes the following steps: 

Quality Habitat — Habitat that is highly suitable for a plant or animal species or community based 

on the local biological site potential. 

Range — Any land supporting vegetation suitable for grazing including rangeland, grazeable 

woodland, and shrubland. 

Range Allotment — A designated area of land available for livestock grazing upon which a 

specified number and kind of livestock may be grazed under a range allotment management plan. It 

is the basic land unit used to facilitate management of the range resource on National Forest System 

lands, including national grasslands, and other associated lands administered by the Forest Service. 

Range Analysis — Systematic acquisition and evaluation of rangeland resources data needed for 

allotment management planning and overall land management. 

Range Condition — 1) A rangeland is considered to be in satisfactory condition when the desired 

condition is being met or short-term vegetative objectives are being achieved to move the rangeland 

toward the desired condition or trend. Unsatisfactory condition is when the desired condition is not 

being met and short-term vegetative objectives are not being achieved to move the rangeland 

toward the desired condition or trend. 2) Historically, range condition usually has been defined in 

one of two ways: (a) a generic term relating to present status of a unit of range in terms of specific 

values or potentials. Specific values or potentials must be stated or (b) the present state of 

vegetation of a range site in relation to the climax (natural potential) plant community for that site. 
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20 |Glossary

It is an expression of the relative degree to which the kinds, proportions and amounts of plants in a 

plant community resemble that of the climax plant for the site. 

Range Development, Nonstructural — Any practice designed to improve range condition or 

facilitate more efficient utilization of the range. 

Range Development, Structural — Any structure or excavation to facilitate management of range 

or livestock. 

Range Management — A distinct discipline founded on ecological principles and dealing with the 

use of rangelands and range resources for a variety of purposes. These purposes include use as 

watersheds, wildlife habitat, grazing by livestock, recreation, and aesthetics, as well as associated 

uses. Two kinds of range management can be described: 

Range Pipeline — Generally a one to two inch pipeline used to convey water from a range well to 

stock tanks.

Range Readiness — Indicators used to determine rangeland readiness are soils and vegetation 

conditions. Rangelands are generally ready for grazing when soils have become firm after winter 

and spring precipitation, and when plants have reached the defined stage of growth at which grazing 

many begin under the specific management plan without long-lasting damage 

Range Well — Water well developed to provide water for livestock use.

Rangeland — Lands on which the native vegetation is predominately grasses, grass-like plants, 

forbs, or shrubs suitable for grazing or browsing usage. Includes lands revegetated naturally or 

artificially to provide a forage cover that is managed like native vegetation. 

Rangeland Health — The degree to which the integrity of the soil, the vegetation, the water, and 

air as well as the ecological processes of the rangeland ecosystem is balanced and sustained. 

Integrity is defined as: Maintenance of the structure and functional attributes characteristic of a 

particular locale, including normal variability.

Ranger District — Administrative subdivision of the national forest or national grassland 

supervised by a district ranger who reports to a forest supervisor. 

Reclamation — Returning disturbed lands to a form and productivity that will be ecologically 

balanced, often in conformity with a predetermined reclamation plan.

Reference Plant Community — The expected plant community under natural disturbance regimes 

in pre-settlement times.

Reference State — Is the state where the functional capacities represented by soil/site stability, 

hydrologic function, and biotic integrity are performing at an optimum level under natural 

disturbance regime. This state usually includes, but is not limited to, what is often referred potential 

natural plant community (PNC).

Regeneration — The renewal of a tree crop, whether by natural or artificial means. This term may 

also refer to the crop itself.

Relative Frequency — The frequency of one species as a percentage of total plant frequency.
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Research Natural Area — A physical or biological unit in which current natural conditions are 

maintained insofar as possible. However, in the RPA program, the term is used to describe those 

matters within the scope of the responsibilities and authorities of the Forest Service as required by 

the Forest And Rangeland Resource Renewable Resources Planning Act of 1074. Consequently, the 

renewable resources include: timber, range, minerals, wildlife and fish, water, recreation, and 

Wilderness.

Reservoir — Water storage facility generally created by erecting an earthen dam across a drainage 

for the purpose of catching and storing water for livestock.

Residual Cover — Standing or lodged herbaceous vegetation left after livestock grazing and killing 

frost. 

Resource Values — The tangible and intangible worth of forest and grassland resources. 

Response Coefficient — The estimate of employment and labor income responses in an economy 

based on a specified amount of economic activity in a given economic sector.

Responsible Official — The Forest Service employee who has the delegated authority to make a 

specific decision. 

Rest — To leave an area of rangeland ungrazed by livestock or unharvested by mechanical methods 

for at least one year (12 consecutive months). 

Rest Rotation (Livestock Grazing) — An intensive system of management where grazing is 

deferred on various parts of the range during succeeding years, allowing the deferred part complete 

rest for one year. At least two, but usually three or more, separate grazing units are required. 

Restoration — Holistic actions taken to modify an ecosystem to achieve desired, healthy, and 

functioning conditions and processes. Generally refers to the process of enabling the system to 

resume its resiliency to disturbances. 

Revegetation — The reestablishment and development of plant cover. This may take place 

naturally through the reproductive processes of the existing flora or artificially through reforestation 

or reseeding. 

Riparian — The bands and adjacent areas of water bodies, water courses, seeps, and springs whose 

waters provide soil moisture in excess of what is locally available. This results in a moister habitat 

than that found on the contiguous flood plains and uplands. Refers to land bordering a stream, lake, 

or tidewater, and generally implies a particular type of habitat physiognomy often characterized by 

an over story of trees or other large woody plants with a complex under story of other woody and/or 

herbaceous species. 

Riparian Area — Areas of the aquatic and riparian ecosystems with distinctive resource values and 

characteristics that are geographically delineated (FSM 2526). Ecological units with distinctive 

vegetation, landform, soil, and water regimes consisting of the aquatic ecosystem and wet-to-moist 

areas located between aquatic ecosystems and adjacent terrestrial ecosystems. Includes floodplains 

and wetlands. Riparian ecosystems are distinguished by soil characteristics and distinctive existing 
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22 |Glossary

or potential vegetation communities that are adapted to soils with consistently high levels of 

moisture. 

Riparian Communities — Repeating, classified, defined and recognizable assemblages of plant or 

animal communities associated with riparian areas. 

Riparian Ecosystem — A transition between the aquatic ecosystem and the adjacent upland 

terrestrial ecosystem. It is identified by soil characteristics and by distinctive vegetative 

communities that require free or unbounded water. 

Ripping — The mechanical penetration and shearing of range soils to depths of 8 to 18 inches for 

the purpose of breaking hardpan layers to facilitate penetration of plant roots, water, organic matter, 

and nutrients. A range improvement practice used where native grasses of a rhizomatous nature can 

be spread into the ripped soil.

Risk Assessment — Process of gathering data and making assumptions to estimate short- and longterm effects on human health or the environment from particular products or activities. 

Road — A general term denoting a way with at least two-wheel tracks for purposes of travel by 

vehicles greater than 50 inches in width. 

Robel Pole — A device consisting of a 1 meter vertical pole possessing alternating horizontal bands 

and a 4 m line of rope or cord. It is used by range ecologists, field biologists and other scientists to 

measure the density of vegetation and to quantify the volume of ground cover in a particular habitat

using the visual obstruction (VO) measurement method. The Robel pole is named for Dr. Robert J. 

Robel, the scientist who developed the device and technique. Modifications of Robel's original 

design have been developed and published, but all utilize the VO method.

Rotation — The planned number of years between the formation or regeneration of a crop or stand 

and its final cutting at a specified stage of maturity. 

Rotation Grazing — A grazing scheme where animals are moved from one grazing unit (paddock) 

in the same group of grazing units to another without regard to specific graze/rest periods or levels 

or plant defoliation. 

Runoff — The total stream discharge of water, including both surface and subsurface flow, usually 

expressed in acre-feet of water yield. 

Rural Development — A partnership or program designed to enrich the cultural life, enhance the 

environment, provide employment, and improve living conditions in rural America. 

Scenery — General appearance of a place, a landscape, or features of a landscape.

Scenic Area — A unit of land with outstanding natural beauty that requires special management to 

preserve this beauty.

Scoping Process — An early and open process for determining the scope of issues to be addressed 

and for identifying the significant issues related to the proposed action. Identifying the significant 

environmental issues deserving of study and de-emphasizing insignificant issues, narrows the scope 

of the environmental impact statement accordingly. 
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Seasonlong Grazing (Livestock Grazing) — Allowing livestock to graze a single pasture 

throughout one growing season. 

Secondary Range — Range that is lightly used or unused by livestock under minimal management 

and will ordinarily not be fully used until the primary range has been overused. 

Sediment — Material suspended in water or deposited in streams and lakes. 

Sediment Load — The solid material transported by a stream and expressed as the dry weight of all 

sediment that passes a given point in a given period of time. 

Sediment Yield — Amount of sediment leaving an analysis area and entering a channel. 

Seeps — A spot where water or petroleum flows from the earth, often forming the source of a small 

stream. 

Self-sustaining Fish Population — A reproducing fish population that does not require 

supplemental hatchery stocking.

Sensitive Species — Those plant and animal species identified by Regional Foresters for which 

population viability is a concern, as evidenced by the following: 

Seral (Ecology) — A biotic community that is in a developmental, transitory stage in an ecological 

succession. 

Seral Stages (Ecology) — The sequence of a plant community's successional stages to potential 

natural vegetation. 

Sere — The series of stages that follow one another in an ecologic succession. A series of biotic 

communities that follow one another in time on any given area of the earth’s surface.

Shortgrass — Grasses which normally are only a few inches tall, including blue and hairy grama 

and buffalograss.

Shortgrass Prairie — Native grasslands which are dominated by shortgrasses.

Significant Archeological Sites — Sites eligible for inclusion in the National Register of Historic 

Places as determined by the Forest Service in consultation with the State Historic Preservation 

Officer.

 Significant current or predicted downward trends in habitat capability that would reduce a 

species' existing distribution. 

 Significant current or predicted downward trends in population numbers or density. 

Site Productivity — Production capability of specific areas of land. 

Social Analysis — An analysis of the social (as distinct from the economic and environmental) 

effects of a given plan or proposal for action. Social analysis includes identification and evaluation 

of all pertinent desirable and undesirable consequences to all segments of society. 

Soil Compaction — A physical change in soil properties that results in a decrease in porosity and 

an increase in soil bulk density and strength. 
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Soil Erosion — The detachment and movement of soil from the land surface by water or wind. Soil 

erosion and sediment are not the same. 

Soil Productivity — The inherent capacity of a soil to support the growth of specified plants, plant 

communities, or a sequence of plant communities. Soil productivity may be expressed in terms of 

volume or weight/unit area/year, percent plant cover, or other measures of biomass accumulation. 

Soil Profile — A vertical section of the soil from the surface down through all of its layers into the 

parent material. 

Soil Survey — A general term for the systematic examination of soils in the field and in 

laboratories; their description and classification; the mapping of soil types; the interpretation of soils 

according to their adaptability for various crops, grasses, and trees; their response to treatment for 

plant production or for other purposes; and their productivity under different management systems. 

Species — A group of potentially interbreeding populations that is reproductively isolated from 

other such groups. 

Species Composition — The proportions of various plant species in relation to the total on a given 

area. It may be expressed in terms of cover, density, weight, etc. 

Species Diversity — A measurement that relates the density of individuals of a species in a habitat 

to the number of different species present in the habitat. The number of different species in a given 

habitat. 

Species Viability — A species consisting of self-sustaining and interacting populations that are 

well distributed through the species' range. Self-sustaining populations are those that are sufficiently 

abundant and have sufficient diversity to display the array of life history strategies and forms to 

provide for their long-term persistence and adaptability over time. 

Standard — Actions that must be followed or are required limits to activities in order to achieve 

grassland or forest goals and objectives. Site-specific deviations from standards must be analyzed 

and documented in management plan amendments. 

State Historic Preservation Officer — A person appointed by a state's governor to administer the 

State Historic Preservation Program. 

Static — Staying the same. 

Stocking Rate (Livestock Management) — The actual number of animals, expressed in either 

animal units or animal unit months, on a specific area for a specific time. 

Stream Bank Alteration — Stream bank alteration consists of physical alteration of the bank by 

trampling that exposes bare soil. 

Stream Bank Stability — Stream bank stability refers to long-term bank structure, expressed as a 

percentage of the stream bank in one of six stability classes (Cowley and Burton 2005b). It is 

intended for long-term trend monitoring and is read on 3-5 year intervals. This method includes 

damage from natural processes, such as floods, and human caused impacts, such as mining or 

recreation vehicle crossings, as well as from livestock. 
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Stream Health — The condition of a stream, relative to robust health, for that stream type and 

landscape, considering indicators such as channel pattern, slope, particle size, pool frequency and 

depth, bank vegetation, and woody debris, which reflect the stability and habitat quality of the 

stream. 

Stream Order — A classification of the relative position of streams in a channel network. Each 

non-branching channel segment is designated as a first-order stream. The channel segment below 

the confluence of the two first-order tributaries. The channel segment below the confluence of two 

second-order streams is designated a third-order stream, etc. 

Stream Type — A class of stream reach having a discrete combination of valley geomorphology 

and climate, flow regime, stream size, and channel morphology, which differs from other stream 

types in its ability to support biota and respond to management. 

Structure — See Vegetation Structure.

Succession — The progress of vegetation development where different plant communities 

successively occupy an area. 

Successional Stages (Seral Stages) — The relatively transitory communities that replace one 

another during development toward a potential natural community. 

Suitable Lands — Lands that are appropriate for the application of certain resource management 

practices as determined by an analysis of the economic and environmental consequences and the 

alternative uses foregone. 

Suitable Rangeland — The appropriateness of applying certain resource management practices to 

a particular area of land, as determined by an analysis of the economic and environmental 

consequences and the alternative uses forgone. A unit of land may be suitable for a variety of 

individual or combined management practices. 

Summer Use — Livestock grazing that occurs between May 1st and December 31st.

Supplemental Draft Environmental Impact Statement — Supplemental information that is 

added to a Draft Environmental Impact Statement and released to the public and other agencies for 

comment and review.

Suspended Sediment — The very fine soil particles that remain suspended in water for a 

considerable period of time without contact with the bottom of the channel. 

Sustainability — Continuation of a desired level of productivity, quality, or variability, generally 

of organisms. 

Sustained Yield — The achievement and maintenance in perpetuity of a high-level annual or 

regular periodic output of the various renewable resources on National Forest System lands, 

including national grasslands, without impairment of the productivity of the land. 

Tallgrass — Grasses that normally grow over 23 inches tall, as in big bluestem.

Tallgrass Prairie — Native prairie grassland characterized by tall and midgrasses, located 

primarily in the eastern Great Plains; synonymous with true prairie.
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Ten-Point Pin Frame — This is a sampling frame 18 in long X 6 in wide.

Term Debt — A debt due to paid over a period of time, as opposed to one due to be paid entirely at 

one time in one lump sum.

Terrestrial — A land-based ecosystem. (See ecosystem). An interacting system of soil, geology, 

and topography with plant and animal communities.

Tiering — Refers to the elimination of repetitive discussions of the same issue by referencing the 

general discussion in an environmental impact statement of broader scope. For example, a project 

environmental assessment could be tiered to the Forest Plan EIS. 

Timing Limitation (Seasonal Restriction) — Prohibits surface use during specified time periods 

to protect identified resource values. The stipulation does not apply to the operation or maintenance 

of production facilities unless the finding analysis demonstrates the continued need for such 

mitigation and the insufficiency of less stringent, project-specific mitigation measures. 

Topography — The configuration of a land surface including its relief, elevation, and the position 

of its natural and human-made features. 

Traditional Use Areas — An area that is significant to a living community because of its 

association with cultural practices or beliefs that are rooted in the community's history and are 

important in maintaining the continuing cultural identity of the community. 

Trampling — Treading underfoot. The damage to plants or soil brought about by movements or 

congestion of animals. 

Treated Area — An area on which management, like timber harvesting or prescribed burning 

occurs.

Tree Regeneration — Refers to the amount of trees reproduction present in a woody draw as 

evidence by seedlings and saplings.

Turn In Allotment — An Allotment that is fenced separately from the Ranch Headquarters on 

which a permit to graze is issued.

Turn In Permit — A permit issued by a grazing association that the grazing season can be no 

longer than eight months (May 1st to December 31st), has no wintering on NFS lands, and the 

allotment consists typically of solely NFS lands, meaning that adjacent private lands are normally 

fenced out. Private and or state lands may be included within the allotment if they are not conducive 

to fencing out or the permittee chooses not to fence them out. Turn-in permits allow for a certain 

number of Animal Months (AMs) providing for some flexibility in management, such as an 

increased number of livestock for a shorter grazing season.

Turn out — Act of turning livestock out on the range at the beginning of the grazing season.

Understory — Herbaceous and tall and short shrub layers

Understory (Vegetation) — The lowest layer of vegetation in a forest or shrub community 

composed of grass, forbs, shrubs and trees less than 10 feet tall. Vegetation growing under the tree 

canopy. 
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Undesirable Species — 1) Species that conflict with or do not contribute to the management 

objectives. 2) Species that are not readily eaten by animals. 

Ungulate — A hoofed animal, including ruminants (cattle, but also horses, tapirs, elephants, 

rhinoceroses, and swine). 

Unhealthy — Woody draws that exhibits undesired characteristics of At Risk woody draws to a 

greater degree and with an increased potential or trend of regressing from the landscape. Decreased 

hydrologic function of the woody draw drainage can contribute to a rating of Unhealthy.

Unpalatable Species (Range Management) — Plant species that are not readily eaten by an 

ungulate animal. 

Utilization Levels (Livestock Grazing) — The portion of the current year's forage production by 

weight consumed or trampled by livestock. Utilization levels are usually expressed as a percentage. 

Vegetation Filter Strips — Riparian vegetation that grows adjacent to a stream.

Vegetation Structure — The vertical characteristics of vegetation. 

Vegetation Treatment — Any activities undertaken to modify the existing condition of the 

vegetation. 

Vegetative Buffer Zones — Strips of grass or other erosion-resisting vegetation between areas of 

ground disturbance and areas needing protection from sedimentation. 

Vegetative Management — Any activities undertaken to modify the existing condition of the 

vegetation. 

Viable Population — A group of individuals of a particular species that produces enough offspring 

for long-term persistence and adaptation of the species or population in a given place. For planning 

purposes, 36 CFR 219.19 defines a viable population as one that has the estimated numbers and 

distribution of reproductive individuals to ensure that a continued viable population is welldistributed in the planning area. A planning area is further defined by 36 CFR 219.3 as the "area of 

the National Forest System covered by a regional guide or forest plan." Direction estimated 

numbers and distribution of reproductive individuals to ensure the continued existence of the 

species throughout its existing range (or range required to meet recovery for listed species) within 

the planning area. 

Visual Obstruction Reading — A measurement of the height that herbaceous vegetation

completely obscures a round pole placed vertically in grassland vegetation.

Warm Season Plant — A plant that makes most or all its growth during the spring, summer, or fall 

and is usually dormant in winter. A plant that usually exhibits the C4 photosynthetic pathway. 

Water Development — A facility constructed or placed to hold water for livestock use. 

Water Gap — An opening or fenced area providing access to a developed or natural water supply 

permitting one watering facility to serve two or more pastures.
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28 |Glossary

Water Influence Zone — The water influence zone includes the geomorphic floodplain, riparian 

ecosystem, and inner gorge. Its minimum horizontal width (from top of each bank) is the greater of 

100 feet or the mean height of mature dominant late-seral vegetation. It includes adjacent unstable 

and highly-erodible soils. The water influence zone protects interacting aquatic, riparian, and upland 

functions by maintaining natural processes and resilience of soil, water, and vegetation systems. 

Water Table — The upper surface of the ground water or that level below which the soil is 

saturated with water. 

Watershed — The area of land, bounded by a divide, that drains water, sediment, and dissolved 

materials to a common outlet at some point along a stream channel (Dunne and Leopold, 1978), or 

to a lake, reservoir, or other body of water. Also called drainage basin or catchment. 

Weed — Any plant growing where unwanted and having a negative value. 

Wet Meadow — A meadow where the surface remains wet or moist throughout the growing 

season, usually characterized by sedges and rushes. 

Wetland Communities — Plant communities that occur on sites with soils typically saturated with 

or covered with water most of the growing season. 

Wetlands — Those areas that are inundated by surface water or groundwater with a frequency 

sufficient to support, and under normal circumstances do or would support, a prevalence of 

vegetative or aquatic life that requires saturated or seasonally saturated soil conditions for growth 

and reproduction. Wetlands generally include swamps, marshes, bogs, and similar areas such as 

sloughs, potholes, wet meadows, river overflows, mudflats, and natural ponds. 

Wildfire — Any wild land fire not designated and managed as a prescribed fire within an approved 

prescription. An appropriate suppression action will be applied to all wildfires.

Wildlife — Collectively the no domesticated vertebrate animals, except fishes. The natural 

community of animals. 

Wildlife Service or the National Marine Fisheries Service for listing as threatened or endangered. 

Winter Feeding — Providing supplemental feed for livestock on National Forest System lands 

during the winter.

Winter Range — Rangeland that is grazed during the winter months. 

Winter Use — Livestock grazing and feeding that occurs between January 1st and April 30th.

Xeric — Having very little moisture. Tolerating or adapted to dry conditions. 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Acronyms

FEIS Vol. III North Billings County Allotment Management Plan Revision

Acronyms| 1

Acronyms

AM — Animal Month

AMP — Allotment Management Plan

AOI — Annual Operating Instructions

AU — Animal Unit

AUE — Animal Unit Equivalent

AUM — Animal Unit Month

BE — Biological Evaluation

BMP — Best Management Practice

BTU — British Thermal Unit

CEQ — Council on Environmental Quality

CFR — Code of Federal Regulations

DBH –Diameter at Breast Height

DEIS — Draft Environment Impact Statement

DPG — Dakota Prairie Grasslands

DSD — Detrimental Soil Disturbance 

EIS — Environmental Impact Statement

FAR-D — Functional-At Risk-Downward Trend

FAR-NA — Functional-At Risk-Trend Not Apparent

FAR-U — Functional-At Risk-Upward Trend

FEIS — Final Environmental Impact Statement

FSH — Forest Service Handbook

FSM — Forest Service Manual

GA — Geographic Area

GIS — Geographic Information System

IDT — Interdisciplinary Team

LRMP — Land and Resource Management Plan

LUP — Land Utilization Program

MGA — Medora Grazing Association

MIS — Management Indicator Species
FEIS Vol. III North Billings County Allotment Management Plan Revision

2 | Acronyms

MLRA — Major Land Resource Area

MOU — Memorandum of Understanding

NB-FEIS — North Billings Final Environmental Impact Statement

NDSU — North Dakota State University

NEPA — National Environmental Policy Act

NF — Nonfunctional

NFMA — National Forest Management Act

NFS — National Forest System

NFSR — National Forest System Road

NGP — Northern Great Plains

PFC — Proper Functioning Condition

RNA — Research Natural Area

ROD — Record of Decision

SDEIS — Supplemental Draft Environmental Impact Statement

SHPO — State Historic Preservation Officer

SIA — Special Interest Area

SRT — Scientific Review Team

T&E — Threatened and Endangered 

USDA — United States Department of Agriculture

USFS — (USDA) Forest Service

VOR — Visual Obstruction Reading

WIZ — Water Influence Zone
FEIS Vol. III North Billings County Allotment Management Plan Revision

Acronyms| 3

FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A

Alternatives 3 and 3A

FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 1

Appendix A

Alternatives 3 and 3A

DEVELOPMENT OF ALTERNATIVE 3

The Demonstration Project is a supplement that was added to and made part of the 2006 Grasslands 

Plan Grazing ROD. The Demonstration project states that “...the Forest Service and the grazing 

association and their members proposals would be carried forward in the national Environmental 

Policy Act (NEPA) process as the Forest Service’s proposed action for the AMP and any related 

amendments, provided they are consistent with existing law”. The following reviews the process 

used to create Alternative 3.

This North Billings EIS analysis was under way when the DPG 2006 Grazing ROD was signed 

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

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

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

Initial Permittee Meetings

Initial permittee meetings were scheduled and performed during the fall of 2005. At these 

meetings, the Medora Ranger District Range staff explained the expected process for revising an 

individual’s AMP, discussed some of the applicable goals and objectives stated within the 

Grasslands Plan, and reviewed allotment range development maps, distribution maps, and any other 

notes with the effected permittee and their MGA district director. The FS Range staff also took 

notes on permittee’s comments, concerns, and requests for their particular allotment. 

A second round of permittee meetings was held the summer of 2006. The effected permittee, their 

MGA district director, and Medora Ranger District Range staff attended these meetings. During 

these meetings the FS Range staff identified the issues for a particular allotment, went over the 

IDT’s initial proposals to address these issues, discussed the pros and cons of these proposals, and 

took any additional input from the permittee and/or director to address the identified issues. A 

permittee also had the opportunity to challenge an identified issue, if he felt that his allotment was 

meeting Grassland Plan goals and objectives for that issue. A review by the IDT would then need 

to be performed on that particular allotment to address the challenge. Several permittees did issue 

challenges which were reviewed in the field by the IDT and the permittee. These challenges all 

involved herbaceous structure and the results of those reviews are discussed in the herbaceous 

structure section of the FEIS. The Range staff also shared the concepts of adaptive management, a 

range tool box, and how the future AMPs would be written adaptively to allow for flexibility within 

the NEPA decision. Information from the Allotment Summary Sheets (DEIS, Appendix A) sheets 

was used in developing the different alternatives.

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

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

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

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

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

members of the IDT presented information about the concept of adaptive management to the board 
FEIS Vol. III North Billings County Allotment Management Plan Revision

2 | Appendix A

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

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

pursuing an adaptive management based proposed action.

A third round of permittee meetings was held the winter of 2007. Since the last round of permittee 

meetings the Medora Ranger District Range staff had completed an initial estimated carrying 

capacity analysis, and this information was explained and shared with the permittees and their MGA 

district director. A tool within the grazing management toolbox, adjust AUMs based on average 

cow size, was explained to the permittee, and the Range staff also indicated that this information 

would be displayed in the Allotment Summary Sheet for their allotments (see DEIS Appendix A). 

The Range staff also reviewed the Allotment Summary Sheet that now included adaptive options. 

Once again any concerns, comments, or suggestions that the permittee had were received and 

discussed.

The notes associated with all of the above meetings are located in the Project Record.

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

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

letter on the proposed North Billings County Allotment Management Plan Revision Project Range 

(North Billings) project. An example of what the proposed action would look like in the scoping 

letter was given to the board and discussed. The team again briefed the board on the adaptive 

management based proposed action, as the board president and some of the directors had changed. 

The Forest Service asked if the board still agreed with using the adaptive management proposed 

action. On April 3, 2008, the president of the MGA sent a short e-mail to the Medora Ranger 

District range staff saying the board still agreed with the adaptive management based proposed 

action. 

Grazing Association Board of Director Discussions

Discussions with MGA’s Board of Directors took place all throughout the process of gathering 

information for the allotments and Medora Ranger District Range staff analyses. Allotment 

meetings were generally conducted with the District director and the affected permittee, however, 

all directors were invited to join in. At monthly MGA Board of Director meetings updates were 

given as far as data collection being done by Medora Ranger District staff and what was going on 

with the IDT at the time.

The 2006 Livestock Grazing Record of Decision (ROD) identified that it was the “.. Forest Service 

intent to implement the SRT’s recommendations consistent with our [FS] final response” to the 

SRT Report (Grasslands Plan 2006 ROD, p.6). One of the SRT recommendations(V-2) was to

“Redefine the Animal Unit to reflect current cow size along with older, larger calves and 

recalculate the corresponding authorized livestock numbers on allotments”. A discussion of cow 

size was held at the January 2007 board meeting to address this SRT recommendation. Medora 

Ranger District Range staff reviewed how other Ranger District offices were addressing this issue, 

some information from the Dickinson Research & Extension Center’s CHAPS program that 

provided area cow weights, and how this would be treated as a tool in the adaptive management

toolbox. Upon being asked what the Board of Directors felt was the average cow size in their 

grazing association, a range of 1,100 to 1,300 pounds with the median being 1,200 pounds was 

provided. Appendix C of the Grasslands Plan provides three different calculations to address cow 

size in determining animal unit equivalents (AUE). After discussion of the three methods of 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 3

calculation, the MGA Board of Directors chose method number 3, a metabolic weight formula, 

utilizing the 1,200 pound average size of a cow if this tool would be applied in the AMP. The 

animal unit equivalency factor would equate to 1.15 AUEs as the median within the above stated 

weight range.

Upon request, the MGA provided three years (2005 to 2007) of grazing association grazing permits 

within the project area to help the FS describe current management of the allotments. After 

inspection of the permitted numbers on the grazing permits a question came up as to what the label 

for the grazing association’s Preference should be (see FEIS glossary). The grazing permit displays 

the Preference as so many Animal Units for so many months on the allotment as a whole, which 

includes NFS, private, and state lands. To determine the portion of preference attributed to NFS 

lands in an allotment, the land record contained on the grazing permit was reviewed. However, the 

Federal portion of the preference is labeled as AUMs. It is believed by the Medora Ranger District 

Range staff that this label is not accounting for the true definition of an AUM, i.e., a 1,000 pound 

cow. After discussion at the March 2008 board meeting, an e-mail, and a telephone visit with the 

grazing association President, the FS was provided with this definition of grazing association 

Preference, “so many number of head for so many number of months on the allotment” (Clint 

Schneider personal communication, 2008). Upon receiving this definition of Preference, the 

Medora Ranger District Range staff determined that the label for current management permitted and 

or authorized use should be Animal Months (AMs) not AUMs since the grazing association 

Preference number did not account for the size of a cow. Animal Months was used for Alternative 

2, 3, and 3A.
FEIS Vol. III North Billings County Allotment Management Plan Revision

4 | Appendix A

DEVELOPMENT OF ALTERNATIVE 3A

The Medora Grazing Association comment on the DEIS states that the association wants 

Alternative 3 revised to reflect all of MGA’s recommendations. They provided Exhibit 2 in their 

comment which compares Alternative 3, Appendix A (DEIS) to the notes taken for each permittee 

meeting regarding the initial recommendations. In Exhibit 2 they specifically highlighted 

recommendations that they felt the Forest Service dropped from consideration, and also highlighted 

Forest Service additions to Alternative 3 which the MGA claims the MGA members did not agree 

to. 

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

SDEIS. The new alternative is identified as Alternative 3A. Alternative 3A was created by adding 

actions identified in MGA Exhibit 2 that MGA recommended be added to Alternative 3 (Table 1) 

and not including some actions identified in Alternative 3 that MGA did not agree with (Table 2). 

Tables 1 and 2 summarize the changes made. 

Tables 3 and 4 discuss each individual item highlighted in Exhibit 2 of MGA’s comment. Some of 

the items highlighted by MGA did not provide recommendations, and some of the highlighted items 

had already been addressed or included/excluded in Alternative 3, therefore Alternative 3A did not 

incorporate these highlighted items from MGA recommended proposal.

Table 1. Recommendations incorporated into Alternative 3A. 

Allotment # MGA Association/Member Recommendations Added to Alternative

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

pastures 2 and 3 in the northeast quarter of the southwest quarter of Section 17, T144N, 

R101W.

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

pasture 2 in Section 11, T144N, R101W.

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

Section 28, T143, R101W.

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

243 Develop a spring in pasture 1 in the southwest quarter of Section 3, T143N, R99W.

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

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

30, T143N, R99W.

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

quarter of Section 26, T143N, R101W.

Table 2. Actions not included in Alternative 3A 

Allotment # Forest Service Actions in Alternative 3 but not included in Alternative 3A 

126 Reclaim existing spring developments in pastures 4 and 6.

240 Reclaim reservoir(s) in pasture 1.

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

pasture on the east side of pasture 2, which will be grazed early. The additional pasture, 

created through the cross fence allows the implementation of a two pasture deferred 

grazing rotation between the remaining pastures.

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

electric fence.

 After construction of the pipeline is complete reclaim the dugout located in the 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 5

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

quarter of the southeast quarter of Section 30 pasture 2.

278 Reclaim reservoir in pasture 2.

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

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

stock tanks are full.

Table 3. Assessment of Comment M – MGA recommendations that were dropped from consideration in 

Alternative 3 by the Forest Service.

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

126

various water tanks in 128 to draw cattle

Comment is proposed in first two 

bullets of Allotment 128 

Alternative 3 Initial Actions 

which is managed together with 

Allotment 126.

Develop new water up out of bottoms

Comment is proposed in first two 

bullets of Allotment 126 

Alternative 3 Initial Actions & 

last bullet of Adaptive Options.

Potentially burn juniper

Comment is proposed in second 

bullet of Allotment 128 

Alternative 3 Adaptive Options 

which is managed together with 

Allotment 126.

127

potential water lot of spring to water Pastures 2 & 

3

possibly limit access in water draws

Comment has been addressed in 

Alternative 3A.

133

133-1 Water is an issue in full

Comment is a statement provided 

as information, no 

recommendation was made.

133-02 Reservoir, Water freezes, well private

Comment is a statement provided 

as information, no 

recommendation was made.

Has the county spray Burdock and Circan

Comment is a statement provided 

as information, no 

recommendation was made.

134 no fence between 134-04 and 134-03,

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS. 

135

Pasture 8 - missing artesian well, it is natural 

spring on creek, used most because of artesian 

well

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS. 

Pasture 10 - dam silted in, Comment is a statement provided 

as information, no 
FEIS Vol. III North Billings County Allotment Management Plan Revision

6 | Appendix A

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

recommendation was made.

electric, propose run pipeline from Pasture 8 to 

Pasture 10

Comment has been addressed in 

Alternative 3A.

Pasture 9 - dugout silted in,

Comment is a statement provided 

as information, no 

recommendation was made.

fence between Pasture 9 & 10 does not work 

because of natural barriers and creek

Comment is a statement provided 

as information, no 

recommendation was made.

Pasture 7 - tank doesn’t exist

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS.

Pasture 6 - dam washed out

Comment is a statement provided 

as information, no 

recommendation was made.

No fence between Pasture 3 & 6.

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS.

There is no pasture 5.

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS.

adjust dates a bit for weaning. 

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

136/139

proposing cross fence in 139-01 80/80,

Permittee requested to drop 

proposal at the third permittee 

meeting (see Project Record, 

Process Documentation –

Permittee Meeting Notes).

Proposed fence to split 139-01

Permittee requested to drop 

proposal at the third permittee 

meeting (see Project Record, 

Process Documentation –

Permittee Meeting Notes).

136/139 139 - no structure, just woody draws

Comment is a statement provided 

as information, no 

recommendation was made.

140 140-05 Dugout in South fence is NF - other Comment is a statement provided 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 7

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

reservoir is breached. The only water is on private 

land. Fence line in need of repair. 

as information, no 

recommendation was made.

140-04 has no water, use private. 

Comment is a statement provided 

as information, no 

recommendation was made.

Fence between Private and NFS using water tank 

in Fence line.

Comment is a statement provided 

as information, no 

recommendation was made.

Fence between 140-05 and 140 HQ

Comment is not a 

recommendation by the 

permittee. This was a comment 

made by the Forest Service to get 

the existing fence functional 

between the two pastures, which 

is the responsibility of the 

permittee as identified in the

MGA Grazing Agreement and 

Rules of Management.

Putting fence between 142-01 & -02 Maybe

At the time of this 

recommendation the permittee 

was unsure of its feasibility as 

indicated by the “Maybe” in the 

note. Alternative 3 does not 

preclude private landowners from 

fencing out their private land 

from NFS lands, as would be the 

case here.

141

Add water lot that feeds both pastures

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS.

22 for 8 - shorten season & increased

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

141 22 for a few weeks and then add #s

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

Would like to stay with 40 to June 1st then 22 + Under Adaptive Management, 
FEIS Vol. III North Billings County Allotment Management Plan Revision

8 | Appendix A

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

other #’s. Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

June 1 - defer

Comment is addressed in the 

Design Criteria common to all 

action alternatives. 

Carrying capacities

Comment is not a 

recommendation made by 

permittee, just Forest Service 

information that we would be 

looking at carrying capacity. 

Change season of use - is already doing - 1

st

pasture used is the last pasture ended fro year 

before

Comment is proposed in first 

bullet of Allotment 141 

Alternative 3 Initial Actions.

Might consider fewer #s, longer season and use of 

crop after hay

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

142 Would like to add electric fence to cross fence Comment has been addressed in 

Alternative 3A.

158

Concern about lack of water in Pasture 14, well 

may not be keeping up and a couple of reservoirs 

have dried up already.

Forest Service notes of the first 

permittee meeting proposed 

extending a pipeline from a 

private well (which the permittee 

was planning for the summer of 

2006). Per permittee 

consideration, the proposed 

pipeline extension into pasture 14 

was dropped due to the feasibility 

of the project. Maintenance 

authorization letters were 

provided to permittee, and 

maintenance of the 2 reservoirs 

was completed.

220 Flexibility in rotation

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 9

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

addressed in the AOI.

Dam in 220-02 is not good, in dry years not 

reliable

Comment is a statement provided 

as information, no 

recommendation was made.

Changes in season of use 

Comment is proposed in first 

bullet of Allotment 220 

Alternative 3 Initial Actions. 

- increased #’s, shorten season

Would like to keep May 15th

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

221

221-02 - dugout

Comment is a statement provided 

as information, no 

recommendation was made.

221-03 - dugout was fixed, small, dry op seasonal

Comment is a statement provided 

as information, no 

recommendation was made.

221-06 - dugout half

Comment is a statement provided 

as information, no 

recommendation was made.

221

Spoke about utilizing 221-04 in Spring and Fall,

Comment is about a private 

pasture. Alternative 3 does not 

preclude the permittee from 

managing private pastures as he 

chooses. 

also opening gates between 2 & 3 Comment would be addressed on 

an “as needed” basis in the AOI.

230 230-01 - Would like to fence out Federal Section 

32,

Alternative 3 does not preclude 

private landowners from fencing 

out their private land from NFS 

lands, as would be the case here. 

230 Would like to add on pipeline & tank to existing 

line, well feeds five tanks,

Alternative 3 does not preclude 

development of water on private 

land, but the water source for this 

pipeline system is on NFS lands. 

It was discussed at the permittee 

meeting that the system may not 

be able to handle additional tanks 

as indicated by the note that the 

well already feeds five tanks (see 

Project Record, Process 
FEIS Vol. III North Billings County Allotment Management Plan Revision

10 | Appendix A

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

Documentation – Permittee 

Meeting Notes).

would like to reclaim spring on NW corner of 

NFS

Proposal to reclaim the spring 

was dropped by the permittee at 

the third meeting. Phone call to 

permittee was made on 2/5/2010 

to reconfirm this action (see 

Project Record, Correspondence 

Permittee).

237

237-02 - Dugouts, the dugout in the SW is not 

good, sandy bottom, spring isn’t in good are for 

livestock,

Comment is a statement provided 

as information, no 

recommendation was made.

planned a pipeline on private to water livestock 

when in 237-03

Comment is not a 

recommendation for NFS lands.

239

Two reservoirs, SW corner has old dugout, NE 

reservoir doesn’t hold much water, maybe a clean 

out

Comment is a statement provided 

as information, no 

recommendation was made. 

Maintenance authorization letters 

were provided to permittee, and 

maintenance of 1 reservoir was 

completed.

Change distribution down in the SE corners from 

heavy to moderate

Comment is a distribution map 

correction, and was addressed on 

the distribution map at the time 

of the permittee meeting (see 

Project Record, Process 

Documentation – Permittee 

Meeting Notes).

Water backs up into NFS from Private - Seasonal

Comment is a statement provided 

as information, no 

recommendation was made.

Burdock weeds

Weeds are addressed 

cooperatively through Billings 

County and the Forest Service 

Noxious Weed Management 

Project FEIS.

240

Pasture 1 water is an issue.

Comment is proposed in second 

bullet of Allotment 240 

Alternative 3 Initial Actions.

Would still like to use 240-04 earlier

Alternative 3 Initial Actions is 

still allowing early winter use of 

pasture 4 from January 1st to 

March 15th in conjunction with 

other winter pastures.
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix A| 11

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

243

Section 3 dugout not very good

Comment is a statement provided 

as information, no 

recommendation was made.

- Add well and tank on Fence line on 243-01

Comment is a map correction, 

and was addressed in the creation 

of the allotment map in Appendix 

B of the DEIS.

- Couple dam with private

Comment is a statement provided 

as information, no 

recommendation was made.

Take pipeline from the tank south

Comment is proposed in second 

bullet of Allotment 243 

Alternative 3 Initial Actions.

243

Doesn’t like to be tied down to exact #s

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

Possible spring development Comment has been addressed in 

Alternative 3A.

244

Woody draws - not a very good proposed action

The proposed initial action was 

very vague at the second 

permittee meeting, as indicated 

by the note made by the Forest 

Service; this was addressed by 

the third permittee meeting (see 

Project Record, Process 

Documentation – Permittee 

Meeting Notes).

Dam fence on reservoir, already sent letter

Comment was a request for 

maintenance of the reservoir. A 

maintenance authorization letter 

has been provided to the 

permittee, and maintenance of 

the reservoir has been completed 

(see 2210 file).

256

Pasture 2 - Dam in Section 25 only 1 foot deep, 

split pasture, add tanks especially

Comment is proposed in first & 

second bullets of Allotment 256 

Alternative 3 Initial Actions.

No developed water, livestock goes to creek, need 

developed water

Comment is proposed in second 

bullet of Allotment 256 

Alternative 3 Initial Actions.

258 Add tanks in North pasture off of existing supply Comment is proposed in second 
FEIS Vol. III North Billings County Allotment Management Plan Revision

12 | Appendix A

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

and tie in to proposed well and add tanks in U. N bullet of Allotment 258 

Alternative 3 Initial Actions & 

last bullet of Adaptive Options.

Utilize water tank and lick tubs to move livestock 

around.

Comment is proposed in first 

bullet of Allotment 258 

Alternative 3 Initial Actions.

Request to fence out 60acres and not run in 

common

Comment was made by one 

member of this common 

allotment and was not agreed to 

by all members of the allotment. 

Comment cannot be proposed 

without agreement from all 

members of the allotment which 

was not noted in the permittee 

meeting notes (see Project 

Record, Process Documentation 

– Permittee Meeting Notes).

Continuing effort with noxious weeds

Weeds are addressed 

cooperatively through Billings 

County and the Forest Service 

Noxious Weed Management 

Project FEIS.

June 1st turnout could be difficult Comment has been addressed in 

Alternative 3A.

272

Develop natural spring. Comment has been addressed in 

Alternative 3A.

Re-drill well in 272-01?

Comment was completed in 2007 

as replacement water; therefore 

not proposed in Alternative 3.

277

Asked about proposed tank, Comment is proposed in first 

bullet of Allotment 277 

Alternative 3 Initial Actions.

rehabbed dam in SE 23 just N of large woody 

draw, suggested nearby trail in SESE 23

Comment is request for the 

rehabbed dam to be released 

which is addressed through the 

Forest Service minerals 

department, and is not a 

recommendation for the AMP 

revision.

277 Wants to fix a drift fence by North Creek

Comment is a request for 

maintenance. The permittee was 

provided verbal information that 

this type of request typically 

doesn’t require written 
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Appendix A| 13

Allotment Recommendations highlighted in Exhibit 2 of MGA 

comments FS Response

authorization, but is just expected 

to be done on an as needed basis 

(see Project Record, Process 

Documentation – Permittee 

Meeting Notes).

278 Re-drill existing well in Pastures 1 & 4 if the 

existing well fails.

Alternative 3 does not preclude 

replacement water projects if 

they are necessary in the future.

281

Concerns with club moss growing,

Comment is proposed in third 

bullet of Allotment 281 

Alternative 3 Adaptive Options. 

burdock

Weeds are addressed 

cooperatively through Billings 

County and the Forest Service 

Noxious Weed Management 

Project FEIS.

286 No water on the North portion of 286-01 except 

for a few holes along Betsy Creek

Comment is proposed in second 

bullet of Allotment 286 

Alternative 3 Initial Actions. 

287

Would like to extend pipeline into NW 26, 

Pasture 3

proposed to add tank in NW Pasture 3 and 

permittee agrees that this would be good to draw 

cattle up into that area

Comment has been addressed in 

Alternative 3A.

Increased #s and shorten season - keep with this

Under Adaptive Management, 

Alternative 3 would not specify 

this type of detailed information, 

but doesn’t preclude it. This kind 

of management would be 

addressed in the AOI.

289 prefers June 1st turnout

Comment is addressed in the 

Design Criteria common to all 

action alternatives. 

301 Would like to see additional water in 129-02 

Section 11

Comment is not applicable for 

this allotment but for Allotment 

129. Comment has been 

addressed in Alternative 3A.
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14 | Appendix A

Tables 3 and 4 only display those comments highlighted in MGA Comments Exhibit 2 (“MGA recommendations that were 

dropped from consideration by the Forest Service and Forest Service additions to which the MGA member did not 

agree”). Comments highlighted in Allotments 218, 224, and 285 will not be specifically addressed due to these 

allotments being conveyed to full private ownership in 2008; therefore, the allotments are no longer part of the 

project area.

Table 4. Assessment of Comment M – Forest Service additions to Alternative 3 which MGA member did not 

agree to

Allotment Initial Actions highlighted in Exhibit 2 of 

MGA comments FS Response
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Allotment Initial Actions highlighted in Exhibit 2 of 

MGA comments FS Response

126 Reclaim existing spring developments in 

pastures 4 and 6.

Alternative 3A does not include this 

action.

127 Implement a two pasture rotation between 

pastures 2 and 3.

Alternative 3 does not propose a 

change from the current 

management.

240

Complete grazing in pasture 4 by March 15.

Alternative 3 Initial Actions is still 

allowing early winter use of pasture 

4 from January 1st to March 15th in 

conjunction with other winter 

pastures.

Reclaim reservoir(s) in pasture 1.

Alternative 3A does not include this 

action.

244

Cross fence pasture 2, north to south. Cross 

fencing will create a crested wheatgrass pasture 

on the east side of pasture 2, which will be 

grazed early. The additional pasture, created 

through the cross fence, allows the 

implementation of a two pasture deferred 

grazing rotation between remaining pastures. 

Alternative 3A does not include this 

action.

249

Change season of use – Alternate turn-in dates 

over a three year period. First year turn in starts 

in June, second July, third August.

Alternative 3 Initial Action was 

acceptable to MGA member as 

indicated in 2006 permittee meeting 

note “Season of use acceptable” 

(see Project Record, Process 

Documentation – Permittee Meeting 

Notes).

256

Create a four pasture deferred rotation utilizing 

allotments 230 pasture 1, allotment 288 pasture 

2, allotment 256 pasture 2, and the proposed 

riparian pasture in allotment 256. 

Alternative 3 Initial Action was 

proposed by MGA members as 

indicated in 2006 permittee meeting 

note “What about keeping present 

pasture assignments but rotating HQ 

pastures so there is no SL grazing” 

(see Project Record, Process 

Documentation – Permittee Meeting 

Notes).

Fence existing reservoir and portion of adjacent 

woody draw in section 25 in pasture 2.

Alternative 3 Initial Action was 

proposed by MGA members as 

indicated in 2007 permittee meeting 

note “Should not reclaim dam along 

road, just fence and control use” 

(see Project Record, Process 

Documentation – Permittee Meeting
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Allotment Initial Actions highlighted in Exhibit 2 of 

MGA comments FS Response

Notes).

272

Fence woody draw located in the southwest 

quarter of Section 30 with temporary electric 

fence.

Alternative 3A does not include this 

action.

After construction of the pipeline is complete 

reclaim the dugout located in the southeast 

quarter of Section 29 pasture 1 and the reservoir 

located in the northwest quarter of the southeast 

quarter of Section 30 pasture 2.

Alternative 3A does not include this 

action.

277

Fence dam in southeast quarter of the southwest 

quarter of Section 24 to control livestock access 

to water.

Alternative 3 Initial Action was 

proposed by MGA member as 

indicated in 2005 permittee meeting 

note “Possible rehab of dam in S 

Central Section 24” (see Project 

Record, Process Documentation –

Permittee Meeting Notes). After 

permittee discussion during the 

second permittee meeting which 

provided potential initial actions, 

the proposal was changed to initial 

action provided in DEIS. 

278 Reclaim reservoir in pasture 2.

Alternative 3A does not include this 

action.

288

Create a four pasture deferred rotation utilizing 

allotment 230 pasture 1, allotment 288 pasture 

2, allotment 256 pasture 2, and the proposed 

riparian pasture in allotment 256.

Alternative 3 Initial Action was 

proposed by MGA member as 

indicated in 2006 permittee meeting 

note for Allotment 256 “What about 

keeping present pasture assignments 

but rotating HQ pastures so there is 

no SL grazing” (see Project Record, 

Process Documentation – Permittee 

Meeting Notes).

Manage stock tanks to control livestock 

distribution.

Alternative 3 does not propose a 

change from the current 

management.

300

Once well is developed reclaim spring in the 

southeast quarter of Section 28.

Alternative 3A does not include this 

action.

Rehabilitate entrenched livestock trails inside 

the water lot located in the northeast corner of 

the allotment.

This action included in Alternative 

3 Initial Actions is considered a 

“Best Management Practice” which 

doesn’t affect the livestock grazing 

system or livestock numbers. The 
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Allotment Initial Actions highlighted in Exhibit 2 of 

MGA comments FS Response

action does address resource 

damage/conditions which the Forest 

Service is obligated to do.

301

Fence out spring areas, install check valve to 

dump water back into riparian areas once stock 

tanks are full.

Alternative 3A does not include this 

action.
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SUMMARY OF FS REVIEW OF MGA’S COMMENT – EXHIBIT 2

The Forest Service reviewed Exhibit 2 of the Medora Grazing Association and Billings County 

comment letters. Exhibit 2 consisted of 101 highlighted actions which MGA felt were 

recommendations that had not been added to the proposed action or where actions that the Forest 

Service had added without MGA approval. The following is a summary of the Forest Service 

review of the highlighted items in Exhibit 2.

 Comment is proposed in Alternative 3 Initial Actions/Adaptive Options or Design Criteria 

common to all action alternatives. (18 highlighted items)

 Comment has been addressed in Alternative 3A. (16 highlighted items)

 Comment is a statement provided as information, no recommendation was made. (20 

highlighted items)

 Comment is a map correction, and was addressed in the creation of the allotment map in 

Appendix B of the DEIS. (8 highlighted items)

 Under Adaptive Management, Alternative 3 would not specify this type of detailed information, 

but doesn’t preclude it. This kind of management would be addressed in the Annual Operating 

Instructions. (10 highlighted items)

 Permittee requested to drop/change proposal. (4 highlighted items)

 Comment was made by the Forest Service not a recommendation made by the MGA member. (2 

highlighted items)

 Alternative 3 does not preclude private landowners from choosing to manage their private land 

as requested. (3 highlighted items)

 Comment is recommendation for private land not NFS lands. (2 highlighted items)

 Comment is about weeds which are addressed cooperatively through Billings County and the 

Forest Service Noxious Weed Management Project FEIS. (3 highlighted items)

 Comment on action was further developed between the second and third permittee meeting. (1 

highlighted item)

 Comment is request for maintenance of a range development. (2 highlighted items)

 Comment not agreed to by all common members of the allotment. (1 highlighted item)

 Comment is about a project request that has been completed outside of the AMP revision 

process. (1 highlighted item)

 Comment not applicable to AMP revision process. (2 highlighted items)

 Comment is not a change from current management. (2 highlighted items)

 Comment on action that was agreed to by permittee. (5 highlighted items)

 Comment on action that is considered a Best Management Practice that is addressing resource 

damage which the Forest Service is obligated to address. (1 highlighted item)
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix B

Allotment Maps

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Appendix C

SRT Recommendations
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Appendix C | 1

Appendix C

SRT Recommendations

Following are the applicable SRT recommendations associated with the North Billings FEIS.

SRT Recommendation I-1: The NRCS has completed Order 2 (five acre accuracy for dissimilar 

soils) soil surveys for all portions of the DPGs. Therefore, the SRT recommends using these maps 

and associated ecological site information in the development, implementation, monitoring, and 

refinement of pasture or allotment-level management plans.

The analysis utilized the recommended NRCS soil survey information in the calculation of carrying 

capacities for Alternative 4. See Chapter 3, Range, in the FEIS and the Range Report for a detailed 

discussion of how this information was applied. 

SRT Recommendation I -2: AMPs herbage production estimates should be estimates for all sites. 

If adjustments in livestock carrying capacities are necessary because of unsuitable terrain (i.e., 

unsuitable sites), adjustments should be made directly (i.e., no allowable forage) rather than 

indirectly (i.e., no herbage produced).

Herbage production was calculated for all ecological sites as part of the carrying capacity analysis,

NRCS soils and production information was used in the calculations. No adjustments, either 

directly or indirectly, were made to the livestock carrying capacity for unsuitable terrain or sites. 

Further detail is provided in Chapter 3, Range of the FEIS and in the Range Report.

SRT Recommendation I-3: The SRT recommends studying and revising the definition of 

"Biologically Capable" to accurately reflect the capability of the soils and plant communities to 

meet structure goals for the gallinaceous 2 Management Indicator Species.

The Forest Service defined “biologically capable” as any site classified as one of the following 

habitat types: western wheatgrass/green needlegrass, western wheatgrass/needle-and-thread grass, 

needle-and-thread/sedge, silver sage/western wheatgrass, big sage/western wheatgrass or western 

snowberry. Sites dominated by crested wheatgrass were also considered biologically capable (FS 

Final Response to SRT Reports, p. 5).

VOR readings taken in the allotments in 1996-1999, 2004, and 2005 years show that habitat types 

included in the definition of biologically capable can produce high structure. Chapter 3,

Herbaceous Structure of the FEIS provides more detail on the findings of these monitoring efforts. 

SRT Recommendation I-4: The SRT recommends the FS discard the FQI for determining seral 

stages and adopt a system such as the NRCS similarity index for seral state determinations.

As recommended the FQI was not used. The analysis did not use the NRCS similarity index instead

seral stages where determined by comparing relative plant composition from measurements of 

basal cover, canopy cover, or biomass production (from NDSU plots) with quantitative descriptions 

included in the NRCS ecological site descriptions, state and transition models, and/or USFS habitat 
FEIS Vol. III North Billings County Allotment Management Plan Revision

2 | Appendix C

descriptions (1992, 2003). Additional detailed information regarding the methodology used to 

determine seral condition is identified in Chapter 3, Seral Stages of the FEIS, and the Botany 

Report, located in the Project Record. 

SRT Recommendation II-1: Standardized protocols should be adopted and training provided for 

consistency among years and observers using the Robel pole method.

The collection of Visual Obstruction Readings (VOR) using the Robel Pole protocols was completed 

in accordance with direction provided by Robel et al. 1970, Benkobi and Uresk 2000, and Warm 

2000. The Robel pole protocols for this analysis are addressed in Chapter 3, Herbaceous Structure 

of the FEIS and in the Wildlife Report. A standardized form was utilized and training provided. 

SRT Recommendation II-2: Robel pole data should be summarized by frequencies of readings 

rather than by averaging readings.

Robel data was summarized by transect average in accordance with the Roble protocol. The 

analysis also provides the data summarized by frequency readings as recommended by the SRT. 

Detailed information is located in Chapter 3, Herbaceous Structure of the FEIS and in the Wildlife 

Specialist Report.

SRT Recommendation II-3: Associations between fall measurements and subsequent spring 

measurements should be determined in relation to vegetation type (e.g., Kentucky bluegrass (Poa 

pratensis) vs. green needlegrass (Stipa viridula)) (reference for plant scientific names is Flora of the 

Great Plains. 1986), winter precipitation, grazing after fall measurements, and other factors.

The DPG monitoring strategy, (Grasslands Plan, p. 4-21) provides for the collection of spring VOR 

information which is consistent with this recommendation. The Grasslands Plan identifies that this 

type of monitoring was to begin five years after the completion of the Plan which was in 2006. So 

the monitoring is not scheduled to start until 2011. 

However, some initial transects were collected in one block in 2007 by the Medora Ranger District. 

This sample is of insufficient size to draw any conclusions so the information was not used in this 

analysis. It will be of value in the future when combined with spring VOR readings that are to start 

in 2011.

SRT Recommendation II-4: All Robel pole data should be collected, summarized, and interpreted 

with full consideration given to potential influences of ecological sites on plant species 

composition, and current and potential vegetation structure. 

Based on input received from the SRT members in 2003, the VOR monitoring protocol was revised 

to not cross vegetative community boundaries. For this analysis the Forest Service used habitat 

types to map basic vegetative mapping units. Habitat types are delineated based on soils, landform 

type, aspect, and potential vegetative composition. For additional information see Chapter 3, 

Herbaceous Structure of the FEIS and the Wildlife Report.
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix C | 3

SRT Recommendation III-1: Monitoring of habitat features considered key to the success of 

gallinaceous MIS populations should be intensified. Intensification should include both an increase 

in the sampling intensity using current methodology as well as using additional techniques as 

necessary (e.g., June infrared photograph showed well-established dancing grounds in northwestern

North Dakota). Realizing that intensive monitoring each year is difficult on 1 million acres, 

monitoring 20 percent, as an example, of non-referenced areas each year over a five-year period 

will locate many lekking arenas on the entire DPGs. Over several years this should help detect any 

change in lekking arena numbers; thus management adjustments could be made accordingly, if 

necessary. Methodology for monitoring lekking arenas should be stringent, standardized across 

years and sites, and detailed in annual training workshops. In addition, a Geographic Information 

System driven data base system should be developed for permanent record-keeping of display 

grounds to evaluate changes in conditions affecting populations (e.g., number and location of 

arenas, and number of males on each display ground).

Lek surveys were conducted for the analysis area. The surveys were conducted by the Medora 

District wildlife biologist and were placed into a GIS system. The methodology and results are 

located in Chapter 3, Sharp-tailed Grouse of the FEIS and in the Wildlife Report. 

SRT Recommendation III-2: Monitoring protocols must include assessment of rate and extent of 

change of woody plant communities.

The IDT took a hard look at the rate and extent of change of woody plant communities by 

comparing aerial photos from 1939, 1953, and 2009 for sample drainages in the project area. This 

comparison shows that woody draws in general have expanded less than five percent and in some 

cases have decreased. The photos show that in some cases the density of plant vegetation in existing 

woody draws has increased over the decades represented by the photos, however, there are no new 

woodys in drainages previously unoccupied by trees. 

Woody vegetation also includes species such as snowberry. However, because it occurs in small 

patches across the landscape it is difficult to assess. Antidotal evidence suggests that snowberry has 

increased but there is no indication that the potential increase in snowberry has reached a 

threshold tolerance for sharp-tailed grouse.

Detailed information concerning woody plant communities is located in Chapter 3, Woody Draws 

of the FEIS. 

SRT Recommendation III-3: VOR field sampling and subsequent summarization and 

interpretation of data should be appropriately stratified in accordance with vegetation type (i.e., 

herbaceous vs. half-shrubs vs. shrubs, etc.). A maximum number of high-structure readings 

obtained from snowberry should be established.

VOR transects were done in 1996-1999, 2004 and 2005. The VOR transects are randomly placed in 

a single vegetative type biologically capable of producing high structure herbaceous vegetation 

(see recommendation I-3 above). 
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4 | Appendix C

The sampled vegetative communities are delineated by habitat type (which considers soil, landform, 

aspect, and potential natural vegetative community) and existing vegetation. Any inclusion of 

western snowberry encountered along a VOR transect was measured. Inclusions of other shrubs, 

such as buffaloberry or chokecherry (which provide different vegetative structure), were excluded.

SRT Recommendation IV-1: All parties should agree to share detailed (i.e., number and size of 

grazers, on and off dates, etc.) pasture-specific records on an annual basis.

Information regarding actual use is unavailable on the allotments. Actual use describes the number 

of livestock, the grazing season (turn on, turn off dates) and rotation that a permittee actually 

grazed on an allotment in the past grazing season. The MGA has stated that actual use is provided 

in the grazing association grazing permits and AOIs/Allotment Worksheets (AOIs/AWs).The MGA 

initially supplied the Forest Service with grazing permits for the years 2005 through 2007 and, after 

further requests for actual use, provided grazing permits and AOIs/AWs for the years 2005 through 

2009 for each allotment in the analysis area. The grazing permits contained information on the 

number and kind of livestock to be grazed, and on/off dates for the allotment as a whole. The 

grazing permits did not supply actual use or size of livestock as described above since the grazing 

permits are issued prior to the initiation of the grazing season. The AOIs/AWs provided pasture 

rotation information. AOIs/AWs are written during the winter preceding the upcoming grazing 

season as a tentative plan for the upcoming grazing season, and are recognized as needing updates 

as the season progresses. They are to be updated by the MGA throughout the season to reflect 

actual changes.

Between the DEIS and the SDEIS, the FS conducted a review of MGA files for actual use 

information. The review found the same AOI and permit information that was supplied by MGA and 

some additional information documenting changes to some of the AOIs. The review noted a general 

lack of documentation updating the AOIs or permits as the grazing season progressed. There was 

no evidence that the grazing association requests actual use from their members at the end of the 

grazing season.

It is possible to collect actual use data for the allotments in this analysis, however, that would take 

three to five additional years during which time existing adverse resource impacts would not be 

addressed. To address this concern, mechanisms are currently in place that will require the MGA to 

provide actual use at the end of the 2010 season and annually thereafter. A letter has been sent to 

the MGA detailing, as per the MGA Grazing Agreement, the required actual use information, and 

the need to complete year end reviews with each permittee to verify or amend the AOIs to reflect 

what actually occurred for the past grazing season

Permits present us with the maximum potential use for a given year. Therefore, in lieu of actual use 

the interdisciplinary team used the three year (2005-2007) average MGA permitted use and/or AOI 

information to compare to the authorized use under the different alternatives. The three year 

average MGA permitted use is information taken from grazing association grazing permits which 

are completed prior to turn out. The AOIs/AWs were used to help describe, under current 

management, how an allotment is managed as far as rotation and type/class of livestock.
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix C | 5

SRT Recommendation IV-2: The FS should collect, on a periodic basis, information that will 

permit them to determine the effectiveness of management actions (see specific recommendations 

related to monitoring below).

The general recommendations identified by the SRT Report (2005) identified that the objectives of 

monitoring need to be clearly stated. Protocols need to be objective, repeatable, and where ever 

possible quantitative. Procedures should be carefully described so they can be followed in 

subsequent years. Information derived from protocols should clearly demonstrate progress towards 

meeting the objectives. The SRT also recommended that the use of photo stations, Visual 

Obstruction Readings (VOR) and Species Composition should be considered for monitoring

The objective of monitoring identified in the FEIS is to determine if implementation of selected 

management actions are meeting or moving towards Grasslands Plan goals and objectives. 

Monitoring has been identified for each affected resource (seeFEIS, Chapter 2, Monitoring and 

Chapter 3, Part 2) which is repeatable, easy to learn, and produces information that will determine 

the effectiveness of implemented management actions.

VOR and species composition are specific monitoring activities that will occur in the allotments 

included in this project (see Ch 2, Monitoring Section, CH 3 Part 2). Photos of different resources 

were taken during field surveys for this analysis. If desired selected areas can be revisited and 

photo points established based on those pictures. 

SRT Recommendation V-1: Maintain and share detailed, pasture-specific grazing records by 

Grazing Association and FS personnel.

The Forest Service completely agrees. During the creation of the proposed action the Forest 

Service provided detailed information concerning resource conditions of the individual allotments, 

what was working and what wasn’t. The Grazing Association has provided five years of grazing 

permits, AOIs, and sporadic AOI updates. 

SRT Recommendation V-2: Redefine the Animal Unit to reflect current cow size along with older, 

larger calves and recalculate the corresponding authorized livestock numbers on allotments.

The widely accepted unit of measurement for grazing livestock is an “Animal Unit Month” (AUM). 

An AUM is the amount of oven-dry forage (approximately 780 pounds) required by one animal unit 

for a standardized period 30 animal-unit-days. This definition of an AUM is from the Society for 

Range Management (SRM), and is used by the Forest Service, Bureau of Land Management, and 

NRCS.

There is an advantage to using a standardized unit of measure to compare different grazing areas. 

Because cattle of different sizes (from 900 to over 1800 pounds per cow) are currently being grazed 

on the grasslands the standard AM is not reflective of actual forage being removed for livestock

weighing more or less than 1,000 pounds.

The analysis utilizes the SRM definition of an AUM. Under Alternative 4 the amount of AUMs 

utilized was adjusted to account for animal size. Adjustments were calculated using Animal Unit 

Equivalents (AUE) with one AUM equaling one AUE. It was agreed with the Medora Grazing 
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6 | Appendix C

Association that 1,200 pounds would be used to represent the average cow/calf unit. A 1,200 pound 

cow/calf unit is equivalent to an AUE of 1.15. Detailed information on livestock weight adjustments 

is contained in Chapter 3, Range of the FEIS and the Range Report located in the Project Record.

SRT Recommendation V-3: Increase the use of management tools such as temporary electric 

fencing, herding, combining allotments, prescribed fire and water developments (wells, pipelines 

and tanks) in order to achieve specific ecological improvement and restoration goals.

Alternatives 3, 3A, and 4 address this recommendation. Table 2.11 located in Chapter 2 of the FEIS 

identifies the different management tools proposed under those alternatives to address resource 

concerns. Chapter 3 Part 2 of the FEIS identifies the specific management tools proposed for use 

under both initial and adaptive actions by alternative by allotment. Chapter 2 of the FEIScontains a 

“Toolbox” listing all of the tools that are proposed or available for use under the adaptive 

alternatives.

SRT Recommendation V-4: Where possible, crested wheatgrass in native grasslands should be 

fenced separately, prescribed burned, or fertilized. Where this is not possible, grazing primarily 

native grassland should not occur before the 3.5 leaf stage of the management plant species or June 

1.

Depending on the allotment all of the above actions related to crested wheatgrass have been 

proposed as either an initial or adaptive options (see FEIS, Chapter 3 Part 2). Not grazing native 

species before the 3.5 leaf stage is identified in Chapter 2 of the FEIS as a design criteria that is 

common to the action alternatives. 

SRT Recommendation V-5: Efforts should be expanded to define relationships among production, 

grazing/harvest efficiency, and post-grazing structure within ecological sites.

Appendix I of the Grasslands Plan describes how vegetation structure can be achieved through the 

adoption of stocking rate guidelines. The analysis for this project evaluated the existing structure 

condition for the allotments (FEIS, Chapter 3 Part 2) and how grazing has affected structure. The 

alternatives include a monitoring strategy to evaluate how the initial actions and adaptive actions 

move the allotments towards structure objectives. 

SRT Recommendation VI-1: Use historical black-and-white aerial photographs and current 

Dragon data to document trends. Document historical woody trends using specific woody 

community types such as green ash (Fraxinus pennsylvanica) draws, willow (Salix spp.), quaking 

aspen groves, cottonwood (Populus spp.), creeping juniper (Juniperus horizontalis), juniper 

(Juniperus spp.), ponderosa pine (Pinus ponderosa) savanna, sagebrush (Artemisia spp.), bur oak 

(Quercus macrocarpa) savanna, low-shrub, tall-shrub.

See Recommendation III-2. 

Detailed information concerning the trend of woody plant communities is located in Chapter 3,

Woody Draws of the FEIS. 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix C | 7

SRT Recommendation VI-2: Develop quantitative objectives for each woody community type, 

and identify a range of patch sizes and distribution across the landscape for each type (see 

Recommendation VI - 1 of Woody and Riparian Communities for possible types).

The DGP Final Response to the SRT Reports identified that the DPG would consider woody plant 

community objectives and continue to collect and review data on woody communities. Plant 

community objectives for woody draws are contained in Chapter 1 and 2 of the Grasslands Plan. 

These objectives where considered in the analysis of woody data. The extensive woody draw 

information collected for this project has been used to evaluate the condition of woody draws 

including age class, structure and species.

SRT Recommendation VI-3: Determine if PFC rating is applicable to North Dakota, use 

multidisciplinary team to conduct PFC ratings, and develop a training manual and process.

PFC is applicable to North Dakota. The PFC methodology is a widely accepted, interagency 

protocol used to assess riparian conditions. It was developed in the American West by federal landmanagement agencies and has been used extensively for more than a decade. The methodology is 

universally applicable because all assessments are made with respect to potential condition.

The DPG uses a team of trained resource specialists to conduct PFC surveys. The team walks along 

a stream and evaluates a variety of attributes of the riparian area as well as the upland 

environment, such as the degree of bank sloughing and erosion, the amount and condition of 

streambank vegetation, and ability of the stream to handle flood events, etc. On the DPG, team 

members provide experience and knowledge of soils, hydrology, geomorphology, botany, ecology, 

geology, biology, and range management.

SRT Recommendation VI-4: Tailor grazing tactics to meet site-specific goals and objectives of 

riparian habitats.

The grazing tactics in Alternatives 3, 3A, and 4 were designed to address site-specific resource 

conditions in order to meet specific goals and objectives. They utilized a variety of different 

management tools including rotation changes, developing range water, pulling livestock out of 

riparian areas, riparian exclosures, creation of riparian pastures, etc. Part 2 of Chapter 3 identifies 

these actions by allotment and alternative.

SRT Recommendation VI-5: Develop specific guidelines for quick response by the Grazing 

Association members and FS to exclude livestock when suitable flooding event(s) occur.

This recommendation is associated with flooding that presents opportunities for the establishment 

of cottonwood regeneration. Within the project area this recommendation would apply to the Little 

Missouri River. To date no specific guidelines have been developed to address this 

recommendation, however, under the current Grazing Agreement the FS. However, under the 

Grazing Agreement the FS has the right to use or permit use of national forest system lands for a 

variety of activities including watershed protection and management (Grazing Agreement, pp.12, 
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8 | Appendix C

13). Further with the assistance of the grazing association AOIs can be quickly adjusted to respond 

to the situation (Grazing Agreement, p.9).

SRT Recommendation VII-1: Aggressively monitor [prairie dog] colony expansion and 

proactively develop rapid response control procedures that limit expansion to desired area(s) in a 

timely manner (see Appendix C for greater detail on prairie dog control).

Currently there is one small (< 1 ac.) prairie dog town in the project area. Periodic monitoring for 

prairie dogs is conducted on the DPG every five years. This town will be monitored as well as any 

new towns the FS becomes aware of, in the project are. Treatment response is addressed in the 

2006 Black-tailed Prairie Dog Assessment and Strategy for the Medora Ranger District. 

SRT Recommendation VIII-1: Develop viable, proactive drought management strategies and 

tactics that, when followed, reduce economic risks, minimize ecological risks, and enhance the 

long-term sustainability of both the responsible management enterprise and the grassland resource 

(see Appendix D for details regarding Drought Strategies).

The DPG is working with universities, the grazing associations, Forest Service specialists, the 

NRCS, and others to develop a drought strategy for the Dakota Prairie Grasslands. Once 

completed the strategy will be applied to this project. In the interim, a modification of the drought 

strategy presented in the 2005 NE McKenzie Allotment Management Plan Revisions FEIS will be 

used to address drought. Details of the drought strategy are contained in Chapter 2 of the FEIS.
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D

Grazing Management Toolbox

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Appendix D | 1

Appendix D

Grazing Management Toolbox

The Grazing Management Tool Box

Alternatives 3, 3A, and 4 are alternatives that are based on adaptive management. Briefly, under 

adaptive management an initial set of proposed actions (see FEIS, Chapter 3 Part 2) is put forth to 

address a resource concern. However, if an initial action(s), i.e. tool(s) is shown through 

monitoring not to be meeting or moving toward the desired condition, under adaptive management 

another management tool(s) can be selected from the Grazing Management Tool Box for 

implementation. Adaptive management is explained in depth in Chapter 2 of this document. 

The Grazing Management Tool Box is a collection of all the different management actions 

proposed for the 43 allotments within the project area. It is important to understand that many of 

the tools in the toolbox are interrelated to each other and that no single tool within the toolbox will 

address any and all issues identified in this analysis. For example, creating a riparian pasture may 

not effectively resolve riparian concerns for an allotment because the effectiveness of this action is 

interrelated to stocking levels, grazing duration, and timing of grazing in the pasture. If these other 

tools aren’t applied with the creation of the riparian pasture the effectiveness of the tool is reduced 

or nullified. The potential interactions of tools are extensive and attempting to analyze the effects 

of all possible combinations of tools would be a near infinite exercise. Presented below are 

discussions of the general effects of each individual tool within the tool box, the information is 

taken from specialist’s reports for range, botany, wildlife and watershed.

The potential interactions of the different tools supports the proposed approach of using a team of 

resource specialists along with the permittee and affected grazing association board director to 

evaluate tools when an adaptive management adjustment is needed to meet or move a resource 

towards Grasslands Plan resource objectives. This approach would provide a rounded 

recommendation(s) for the responsible official to consider when deciding how to address the 

resource concern. 

Drought Strategy 

Drought is a recurring fact of life on the grasslands of western North Dakota. Reece et.al. (1991) 

state that drought is generally defined as a prolonged period during which annual precipitation is 

less than 75 percent of average. Based on this definition, drought has occurred in 21 percent of the 

years in the northern Great Plains, since 1940 (Holechek et.al. 1989). Drought affects water 

availability which in turn affects the rangeland ecosystem and those who depend on it for life,

wildlife and ranchers alike. 

Heitschmidt et al (1987, 2005), notes that an understanding of drought’s impacts on the structure 

and function of rangeland ecosystems is paramount for developing effective management strategies 

and that all grazing systems will fail if stocking rates are sufficiently high to preclude the 
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2 | Appendix D

accumulation of a forage reserve for consumption during periods of dormancy induced by either 

temperature (winter) or water (drought) stress.

While the occurrence of drought can’t be predicted, it can be managed to reduce its effects. A 

drought management strategy is useful in maintaining appropriate stocking levels and curtailing 

excessive use of range vegetation during poor growth or low production years. Excessive use 

during any grazing year requires additional time for forage productivity to return to potential levels, 

so a drought management strategy is useful for maintaining long-term range production. 

Implementation of a drought strategy is important to the US Forest Service (FS), grazing 

associations, and permittees. The purpose of a drought-management strategy is to use the recent 

precipitation amounts to trigger early and proactive adjustments in stocking. Early response permits 

opportunities to retain some high structure, even during drought years, for wildlife needs; to 

exercise various livestock decisions, such as weaning times, culling practices, and marketing 

decisions; and to retain plant vigor and health to accelerate post-drought recovery. 

Currently a drought strategy doesn’t exist for the Dakota Prairie Grasslands (DPG); however, one is 

under construction. In the interim this project will use the drought management strategy that was 

developed on the McKenzie Ranger District. 

Range – A drought management strategy that would effectively maintain the current conditions or 

minimize a downward trend in Grasslands Plan goals and objectives would typically result in 

reduced authorized use for the grazing seasons that a drought management strategy is being applied. 

In the long term, though, this type of management should moderate authorized use by minimizing 

the extreme fluctuations in authorized use from below average to above average production years.

Botany – Climate or available moisture is the main factor affecting annual forage production and 

plant composition (Biondini and Manske 1996, Biondini et al 1998, Briske et al 2008, KSU 1994, 

Vermeire et al 2008). Forage plants are less tolerant of grazing during drought (Biondini and 

Manske 1996, NRCS, 1997), so stocking at typical grazing levels during these periods has the 

potential to decrease forage production and composition. 

Forage plants weakened by drought are susceptible to injury at grazing levels that would have no 

adverse impact during normal growth years (Biondini and Manske 1996, NRCS 1997). Decreased 

plant vigor and production due to drought can be exasperated by failing to adjust stocking levels to 

the level of decreased forage production can increase and extend the effects of drought on decreased 

plant vigor (NDSU 2009, NRCS 1997).

Further development of a drought management strategy may establish guidelines that are more 

precise or trigger points such as precipitation to date, soil moisture, or current range production, to 

establish expectations of stocking level adjustments according to the range of annual precipitation. 

This could influence long-range planning of the grazing permittees in regards to annual stocking 

levels or alternate forage reserves during years of drought, thereby contributing to the maintenance 

of forage resources. 

Wildlife – The focus of the drought management strategy is on minimizing impacts on forage for 

livestock and minimizing economic loss to the rancher with no apparent consideration given to 
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Appendix D | 3

wildlife habitat or other ecosystem attributes. Therefore, this somewhat narrow focus may result in 

a short-term effect to herbaceous structure. But minimizing the effects to the forage base during the 

drought should also allow for a relatively shorter time for recovery from the drought. Bottom line is, 

conceptually, having a strategy (Reece) is likely preferable to what has been historically done. It is 

potentially more proactive and could allow for more rapid recovery of resources. 

Soils/Hydrology –The purpose of a drought-management strategy is to use the recent precipitation 

amounts to trigger early and proactive adjustments in stocking. Early response permits 

opportunities to retain some high structure, even during drought years, for wildlife needs; to 

exercise various livestock decisions, such as weaning times, culling practices, and marketing 

decisions; and to retain plant vigor and health to accelerate post-drought recovery.

Adjust season of use

Range – Season of use is the period of time that livestock are in a given pasture during a specific 

time/season of the year. Proper season of use is directed at matching the timing of livestock grazing 

with the kind of plant community within the pasture taking into consideration the long term 

objectives for the pasture. Adjusting the season of use on pastures would allow species to be grazed 

at different phenological stages instead of being grazed at the same time of year, year after year. 

Sedivec and Manske (1990) stated that the most common grazing management problems are 

seasonlong grazing on one pasture from mid May to mid November, early grazing in April or May, 

annual repeated seasonal grazing in pastures (such as consistently using the same pastures for spring 

grazing, summer grazing, and fall grazing), and continually stocking a pasture higher than its 

carrying capacity. 

By adjusting the season of use in a pasture, native herbaceous plants have the opportunity to initiate 

growth until range readiness or the opportunity for plant recovery. The flexibility and changes 

made in the season of use would be dependent on the individual allotment, its pastures, type of

livestock being used, livestock water availability, and most importantly, the type of vegetative 

species making up the different plant communities. Authorized Use levels should not be affected 

by adjusting the season of use, just the management of the various pastures within an allotment may 

change. Livestock distribution may change depending upon the herbaceous plant community within 

the pastures.

Botany – Different plant species have optimum periods of grazing when they are most palatable to a 

class of livestock (KSU 1994, NRCS 2006, Heitschmidt 1987), so adjusting the season of use can 

change the degree that certain plant species are utilized or avoided. Composition or seral stage of 

the plant community can therefore be influenced by seasonally directing grazing pressure to alter 

the competitive relationship between different species. For instance, selective grazing of a species 

at a certain time of year has the potential to decrease its vigor and ability to compete with other 

species. Conversely, coordination of the grazing season with low palatability of a species facilitates 

its uninterrupted growth that can confer a competitive advantage against species that are selectively 

grazed. For instance, delaying turn-in until mid or late summer can facilitate the growth and vigor 

of cool season climax species and direct grazing towards warm season grass. In the case of invasive 
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4 | Appendix D

grasses, establishing the season of use during May could increase utilization of Kentucky bluegrass, 

thereby impeding the accumulation of plant litter that assists its maintenance or spread, while also 

deferring or decreasing a portion of the native grass utilization that therefore contributes to its 

maintenance or increase. Adjusting the season of use can also contribute to the maintenance of 

plant vigor and production by providing opportunities for the completion of critical growth stages 

that include the initiation of spring growth, replacement of defoliated leaf area, and the translocation 

of carbohydrates to the crown and root system for winter respiration and initiation of the following 

year's growth. Repeated seasonlong or seasonal grazing conducted during critical growth periods at 

moderate and greater utilization levels can alter plant composition and reduce forage production 

(Briske et al 2008, NRCS 1997, 2009, Vermeire et al 2008). Decreased competitive ability of the 

affected species can facilitate shifts to increased dominance of other species of varying desirability. 

Certain growth periods can also be selected for grazing to increase plant vigor. For instance, 

grazing of crested wheatgrass during May can promote tiller development and increase forage 

quality and quantity, while delaying or continued grazing into mid to late summer can result in 

relative stagnation of crested wheatgrass plants and increased levels of bare ground favorable for 

the outbreak of grasshopper populations (Manske 1995b, Manske and Onsager 1997). 

Adjusting the season of use can also affect woody draw conditions by changing the amount of time 

livestock spend in the draws. High temperatures during mid and late summer contribute to 

increased use of woody draws when livestock seek water, shade, cooler temperatures, escape from 

insect pests, and extended green periods compared to upland grasses that have dried or become less 

palatable. Although browsing of woody draw plants can increase during the fall after dormancy of 

upland grasses (Uresk 1986) spring, fall, and winter use have resulted in decreased livestock 

disturbances and increasing conditions within woody draw and riparian areas (Bailey 2004, 

Boettcher and Johnson 2005, Butler 1983, Elmore 1989, Severson and Boldt 1978, Swanson 1995). 

Holechek et al (1999) concluded that the primary benefit of rotational versus seasonlong grazing 

systems might be conferred to riparian woodland communities through increased opportunities for 

regrowth during the period of non-grazing. However, this potential can be limited by the relatively 

slow response of woody species to browsing and trampling disturbances that impedes their ability to 

escape the next browsing disturbance (Girard et al 1987). 

Wildlife – This is an important concept in the context of rotational grazing systems which provides 

for deferment so that species are grazed at a different phenological stage on a regular basis, 

contributing to rangeland health.

The benefit to herbaceous structure from this tool may come with the implementation of a grazing 

system such as a deferred rotation where the number of pastures may dictate the effectiveness of 

this for herbaceous structure. In the long-term, assuming compositional changes to a different state 

are achieved, perhaps there may be improvement in density of species increasing the height density 

of structure. 

But, under the assumptions of moderate grazing intensity (see Holechek 1999 and USDA 2001) and 

rotational grazing systems (see Briske et al 2008), the herbaceous structure distribution may not 

change appreciably (Grasslands Plan, Appendix I).
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Appendix D | 5

Soils/Hydrology –Riparian areas are especially sensitive to the season of use (see Wyman et al., 

2006, for details). Various grazing options include:

 Seasonlong grazing

 Spring grazing

 Hot-season grazing

 Fall- (late) season grazing

 Winter- (dormant) season grazing

 Deferred grazing

 Rest-rotation grazing.

Some of the potential advantages and disadvantages are summarized in Table 1 below. Additional 

details are provided in Wyman et al. (2006, pp. 36-62).

Table 1. Abbreviated comparison of various grazing treatments.

Grazing 

Treatment Potential Advantages Potential Disadvantages

Seasonlong  Generally none  Generally riparian areas suffer 

greatly with long seasonal 

use. Any pasture with >30 

days continuous use is at risk 

of riparian damage

Spring  Use of riparian vegetation 

limited as upland vegetation is 

generally palatable

 Riparian soil compaction 

might be reduced if livestock 

are utilizing uplands

 Ample time for regrowth

 Riparian vegetation in good 

shape during annual peak 

discharges

 High potential for soil 

compaction and bank 

trampling when soils are 

moist

 Livestock may impact fish 

spawning areas

 Repeated grazing of desirable 

herbaceous species in spring 

may affect plant vigor—a 

short grazing season is 

beneficial

Hot season  Stream banks generally more 

stable than in spring

 Riparian vegetation may be 

more palatable and nutritious 

than desiccated upland plants 

 Greater tendency for livestock 

loafing in riparian areas and 

channel

 Reduced plant vigor and 

possible changes in vegetation 

communities

 Possible damage to riparian 

vegetation that is needed for 

canopy and instream cover

 Adverse fish-livestock 

interactions are generally 

greatest at this time

Fall (late) 

season

 Most herbaceous vegetation  Great risk of heavy browsing 
 FEIS Vol. III North Billings County Allotment Management Plan Revision 

6 | Appendix D

Grazing 

Treatment Potential Advantages Potential Disadvantages

has completed its growth, 

therefore it is less susceptible 

to overgrazing

on woody species

 Regrowth of riparian

vegetation is unlikely

 Livestock distribution is poor

Winter 

(dormant)

 Minimal soil compaction and

bank trampling

 Complete growing-period rest

every year

 Use of herbaceous plants

generally non-detrimental

 Browsing of trees and shrubs

can be detrimental—must

monitor

 Livestock may be using key

wildlife winter habitat

 Soil compaction possible on

thawed soils

Deferred  Grazing season is shifted

leading to alternating impacts

and rests

 Livestock use may be less

selective when use in

concentrated in shorter

periods

 Every year there will likely be

one pasture where riparian

areas are at high risk of

damage from livestock

 Fence materials and

maintenance may be costly

 If pastures are few, the

duration of the grazing season

may be too long for some

riparian areas

Rest-rotation  Plants periodically receive a

full growing season of rest

 The duration of grazing is

shortened from a seasonlong

treatment and the frequency

of defoliation is decreased

 In some season, livestock will

concentrate in riparian areas.

 In some pastures, the duration

of grazing season may be too

long for some riparian areas.

Short-duration  Plants less impacted due to

few repeated defoliations

 Long periods of growth and

recovery

 Decreased time of exposure to

grazing and trampling

 Fly problems are decreased as

livestock rotation breaks the

fly larvae cycle

 Intensive management is

required (frequency of

monitoring and moving

animals high)

 High fencing requirements

 Mistakes in the timing of

moves can lead to excessive

grazing intensity with animal

concentration

 Cover for wildlife may not be

adequate during and right

after grazing
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 7

Adjust Authorized Use

Range – The selection of the correct stocking rate is the most important of all grazing management 

decisions from the standpoint of vegetation, livestock, wildlife, and economic returns (Holechek et 

al. 1989). One point made by leading range managers is that stocking is and always will be the 

major factor affecting the condition of rangeland resources (Pieper and Heitschmidt 1988, in 

Holechek et al. Range Improvement Task Force Report No. 57). No grazing system can counteract 

the negative impacts of long-term overstocking (Holechek et al. Range Improvement Task Force 

Report No. 57). An adjustment in Authorized Use within an allotment would affect the number of 

AUs allowed and/or the number of total grazing days for the season for those permittees that are 

issued a turn-in grazing association permit. For those permittees issued an inventory grazing 

association permit, adjusting authorized use would result in changing the number of AUs only 

because of the 12-month nature of the inventory permit.

Botany – Livestock grazing or other herbivory results in disturbance to the plant community, with 

the degree of affects correlated with the intensity, frequency, and seasonality of defoliation (Briske 

et al 2008, NRCS 1997, Vermeire et al 2008). Most leading range scientists recognize stocking rate 

as the principal variable under control of management that effects long-term range productivity, 

species composition or seral stage, and animal performance (Briske et al 2008, Hart 1999, Hart et al 

1993, KSU 1994, NRCS 1997, Pieper and Heitschmidt 1988, Smart et al 2005, Vermeire et al 2008, 

Whitman and Wali 1975, Wilson 1986). Increasing the number or density of livestock over the 

same grazing period increases the total amount of forage harvested. Species that are preferentially 

selected or that are least able to tolerate the level of increased grazing will therefore be 

competitively disadvantaged. This will generally result in a shift towards early seral stages and 

species that are able to escape or tolerate the increased grazing pressure through specific growth 

responses to grazing pressure, growth form, palatability, season of growth, or appendages such as 

thorns or awns that deter grazing. Non-selection of a species can provide a competitive advantage 

over selected species and allow the former to increase in relative dominance (Briske et al 2008, 

Dietz 1989, NRCS 1997, Trammel and Butler 1995). Thus, species that loose palatability such as 

crested wheatgrass and Kentucky bluegrass relative to native grasses may have an increased 

opportunity to spread.

Conversely, increased livestock density also increases the evenness of livestock distribution across 

the pasture, and competition between grazing animals for a limited forage resource can decrease the 

degree of selection for individual plant species, thereby increasing the evenness of species 

utilization and potentially maintaining composition of the community by not conferring a 

competitive advantage to one species over another. Increased livestock numbers and distribution 

can also influence the management of plant litter by harvesting greater amounts of the annual 

production that becomes unavailable for litter input. Increased trampling disturbances increase the 

rate of litter decomposition by decreasing the size of litter material and increasing contact with the 

ground surface that increases decomposition by bacteria, fungus, and micro fauna.

Decreasing the number of livestock over the same grazing period decreases the level of utilization 

and increases the potential maintenance or increase of preferentially selected species. Increased 
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8 | Appendix D

community development with decreased utilization can facilitate shifts towards late seral stages 

(Barker and Whitman 1989, Biondini and Manske 1996, Biondini et al 1998, Briske et al 2008, 

Brand and Goetz 1986, Hart 1999, Hart et al 1993, Lauenroth et al 1994, Rauzi 1963, Smart et al 

2005, Vermeire et al 2008).

Increasing the number of days in a pasture with the same number of livestock also increases the 

level of utilization with potential effects of altering the species composition or seral stage. The 

extended season can contribute to the utilization of different plant species as they increase and 

decrease in relative palatability, but selective utilization of one or a few species can also occur in 

areas of repeated spot grazing (NRCS 1997, Sedivec 2006). Lengthened grazing seasons also have 

the potential to overlap critical plant growth stages when grazing can decrease plant vigor and 

competitive ability (Vermeire et al 2007, Briske et al 2008), thereby favoring plant species that .

Decreasing the number of grazing days with the same number of livestock decreases the level of 

utilization, with potential shifts towards late seral stages. Shorter grazing seasons also increase the 

potential for scheduling outside the period of critical plant growth stages with positive benefits for 

the plant community (KSU 1994, Biondini and Manske 1996, NRCS 2007).

Increases and decreases in the Authorized Use would have potential effects of respectively 

decreasing and increasing woody draw conditions through changes in the level of woody draw use. 

Increasing the length of the grazing period may result in greater periods of mid and late summer use 

when livestock are likely to spend greater amounts of time within woody draws with greater levels 

of browsing and trampling disturbances (Boettcher and Johnson 2005, Butler 1983, Elmore 1989, 

Severson and Boldt 1978, Swanson 1995). Increasing the number of livestock over the same 

grazing period increases livestock density that can increase the intensity of woody draw browsing 

and trampling disturbances. The increase in livestock density can also contribute to increased 

livestock distribution, thereby increasing woody draw disturbances in secondary range.

Wildlife – Several authors (e.g. Holechek et al, 1999; Rangelands; SD State College 1956; 

Holechek, Pieper, Herbel 1989; Hart et al 1993; Salo 2004; Reece et al 2001; Van Poollen and 

Lacey 1979) indicate that lower production (or biomass/standing crop assumed = herbaceous 

structure: Robel et al 1971) occurs under heavy grazing, with moderate grazing resulting in stable to 

increasing production, and under light grazing, increased production. It follows, then, that adjusting 

Authorized Use can be an important tool to achieving a mosaic of herbaceous structure across the 

landscape. Increasing Authorized Use will result in lower herbaceous structure; whereas,

decreasing Authorized Use will result in increased herbaceous structure by providing opportunities 

for growth and regrowth of herbaceous plants.

Soils/Hydrology – Reducing Authorized Use should help improve the uplands vegetation which in 

turn reduces overland flow further benefitting the riparian conditions along streams. A reduction in 

overland flow delivered to the stream would result in reduced stream velocities allowing for the 

establishment of riparian vegetation and building stream banks.
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 9

Adjust for cow size

Range – This tool is essentially taking into consideration the actual animal unit equivalent (AUE) of 

the livestock being grazed. Through improved genetics, breeds, and selective breeding the average 

cow size has increased over the years meaning that more forage is required to maintain that cow; 

therefore, the preference needs to be updated to account for the increased forage consumption. 

Heavy grazing continues to be a problem on rangelands in the United States and in other parts of the 

world (Holechek et al 1999). This is somewhat puzzling in view of the fact that 25 long term 

grazing studies are consistent in showing it to be a losing proposition, financially, as well as 

biologically (Holechek et al 1999). As a result, adjusting for AUE is another step to assure that the 

allotments are stocked at the proper level for the class of livestock and available forage in each 

pasture to assure that over use doesn’t occur. Adjusting for cow size would affect Authorized Use 

by changing the number of AUs and/or the number of days grazed depending upon the type of 

grazing association permit as mentioned above in Adjust Authorized Use – Range.

Botany – Accurate calculation of forage utilization and permitted AUMs necessitates incorporation 

of actual livestock weight because by definition, an AUM is defined as the amount of forage 

utilized by one 1000 pound cow and calf (Biondini and Manske 1996, Carter 2008, Hancock 2006, 

KSU 1994, NRCS 2003, SRM 1974). Through increased breeding and selection, average livestock 

weights have increased in the U.S. (McMurry 2009). Average livestock weight reported by the 

USDA in North Dakota increased from 1,072 pounds in 1984 to 1,242 pounds in 2004 (Carter 

2008). Most cows on the Missouri Coteau in the central portion of the state average between 1,200 

to 1,400 pounds (Hancock 1994). 

Adjusting for average cow weight is critical for establishing stocking levels to maintain forage 

production and plant composition and predict the effects of a given level of use on future forage 

conditions. Not incorporating average livestock weight or the class of animal has the potential to 

underestimate actual levels of use that can contribute to shifts towards early seral stages and adverse 

effects to range conditions. Accurate assessment of total utilization should also incorporate forage 

harvested by calves. For instance, KSU (1994) identifies an AUE of 0.3 AUMs for a 400 pound 

calf at about four months of age. This value is increased to 0.5 AUMs at 500 pounds, and gradually 

increases thereafter with increasing weight.

Wildlife – Adjusting for livestock weight is a key factor in determining applicable stocking levels 

(Reece et al 1991). To not consider this factor in determining stocking levels risks over utilization 

of the forage resource. In brief, this could result in a loss of plant vigor, lost production, increased 

potential for establishment or spread of noxious or invasive species, lower herbaceous structure 

affecting wildlife habitat, increased overland flow which can result in gullying, pedestalling, etc. 

There is no positive effect for rangeland resources of not considering livestock weight in 

determining an appropriate stocking level. 

Having said this, there are some legitimate uses of heavy grazing that may help meet management 

objectives such as prairie dog management, providing low structure habitats for some species of 

wildlife, or restorative efforts aimed at reducing specific grass species. But heavy stocking over 
FEIS Vol. III North Billings County Allotment Management Plan Revision

10 | Appendix D

time (such as not accounting for increased forage demands of heavier livestock) could result in loss 

of productivity, a downward trend in range condition, lower economic returns on calves, etc 

(Holechek 1999).

Soils/Hydrology – Adjusting for cow size would typically result in a reduction in Authorized Use.

Reducing Authorized Use should help improve the uplands vegetation which in turn reduces 

overland flow further benefitting the riparian conditions along streams. A reduction in overland 

flow delivered to the stream would result in reduced stream velocities allowing for the 

establishment of riparian vegetation and building stream banks.

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

Range – Many of the allotments on the rolling prairie have been cultivated at one point in time and 

have been reseeded to graminoid species (crested wheatgrass) or allowed to “go back”; and as a 

result the plant communities in these pastures are a mixture of both introduced and native species. 

Manske and Sedivec (1999) state that introduced grass pastures reach grazing readiness two to four 

weeks earlier than does native range, permitting grazing in May and deferring native rangeland 

grazing until native grasses reach the three and a half leaf stage. They state that crested wheatgrass 

is the only introduced grass pasture ready to be grazed by May 1 in most years, and smooth 

bromegrass and meadow bromegrass are typically ready for grazing by the second week in May.

Additionally, they note that grazing native rangeland prior to range readiness will be the most costly 

alternative, with both economical losses (in most cases) and reductions in production associated 

with physical damage to the plants (Manske and Sedivec 1999).

Application of this tool would affect allotment management by utilizing those pastures deemed as 

non-native first before use of the native pastures potentially changing the season of use depending 

upon how the allotment is managed currently. Livestock distribution would potentially change as it 

should now be focused on the specific grass species in the pasture. For example, livestock would 

focus grazing pressure on crested wheatgrass in pastures grazed early and on native cool or warm 

season grasses in pastures that are deferred depending upon the season of use.

Not all allotments and pastures have been fenced to separate the introduced and native grasses, and 

would require additional fencing, as recommended by the SRT in their final report. An evaluation 

of the areas fenced would be needed to determine the proper stocking level for the forage available 

in each pasture. The SRT also indicated that if fencing out the crested wheatgrass from the native 

species isn’t possible, they don’t recommend early-season grazing of predominantly native 

grassland units. Essentially utilization of these pastures should be deferred until the three and a half

leaf stage or June 1st. Individual permittees in these situations would have to find other spring 

pastures to compensate for the delayed turnout. 

Botany – Greater utilization of invasive grass pastures through early season grazing would therefore 

contribute to the maintenance of native plant communities and would be a primary tool in reestablishing the dominance of native plant communities. 

Forage nutrition and palatability of all grasses is generally at its highest prior to the development of 

seed stalks (KSU 1994, NRCS 1997). Invasive grasses such as crested wheatgrass and Kentucky 
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Appendix D | 11

bluegrass initiate growth and seed development, and decrease in palatability earlier in the season 

than native grasses (Frank et al 1993, Manske and Sedivec 1999, Smoliak 1981). However, these 

species can be highly palatable, nutritious, and more desired by livestock than many native grasses 

during late April through mid-June (NRCS 2009, Sedivec 2006). Early season use of invasive 

dominated pastures should therefore increase the utilization of these species and increase the 

efficiency of harvesting the range of available forage components (Dekeyser et al 2010). Increased 

use of the invasive component can decrease the extent of selectively grazing native grasses that 

occur intermixed in these communities, thereby contributing to increased vigor and maintenance, 

and ideally, facilitating shifts back towards the native community by altering the competitive 

relationship between native and invasive grasses. 

Utilizing invasive-dominant pastures early in the season can also defer the use of other pastures that 

are dominated by native grass communities, thereby increasing opportunities for the completion of 

critical early season growth periods that maintains plant vigor. Further delays in the initiation of 

grazing allows greater amounts of growth and leaf production that can increase the tolerance to 

grazing disturbance by maintaining greater amounts of leaf area that increase the plants ability to 

replace tissue lost to grazing. Therefore, delaying turn-in onto native dominant pastures can 

enhance the maintenance of these communities. Early season use of Kentucky bluegrass, possibly 

in conjunction with prescribed burning, could help shift the community towards greater native 

species dominance (NRCS 2009, Smith 2010) desired for the maintenance of native plant diversity. 

Several pastures contain intermixed stands of invasive and native grasses, or intermingled patches 

of invasive versus native grass dominance. Early season grazing in these pastures presents the 

possibility of premature grazing of native grasses rather than selective utilization of invasive 

grasses. Livestock tend to graze what they are accustomed to eating, but some work in North 

Dakota has shown that they will begin to seek or selectively graze bluegrass when intermixed with 

native grasses during early grazing seasons (Brand 2006). Although Kentucky bluegrass may 

produce only 25 percent as much forage as the native community, grazing can promote regrowth 

and extend the green period of nutritious forage, potentially increasing the total production (Sedivec 

2006). Failure to incorporate utilization of invasive grasses in mixed pastures by missing their 

period of palatability has likely resulted in over-utilization of the native component. This can 

effectively increase the stocking rate on the native component and confers a competitive 

disadvantage that can provide positive feedback for continued invasive grass expansion (Belsky and 

Gelbard 2000, Brisk et al 2008, Dietz 1989, NRCS 1997, Trammel and Butler 1995). Only forage 

production from palatable or likely to be utilized forage species should be included when 

determining proper stocking levels (Hancock 2006, KSU 1994, NRCS 1997). Non-use of avoided 

species does not compensate for heavy use of highly selected species, and averaging use among 

differentially selected species does not address the effects of a utilization level on plant community 

composition (NRCS 2006). 

Early season grazing of invasive grass pastures would have the potential to decrease browsing and 

trampling disturbances in woody draws, thereby contributing to increased regeneration and 

improved conditions. Cooler temperatures, fewer insect pests, and high palatability of invasive 
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12 | Appendix D

grasses in the uplands would contribute to decreased woody draw use and disturbances compared to 

later season grazing

Wildlife – The earlier the livestock come off the early season pasture, and stay off, the more 

regrowth that could occur by fall. It is feasible that the early season non-native pasture(s) could 

provide higher structure in the fall and contribute to the diversity of herbaceous structure if 

sufficient time is provided for regrowth. Also, since native range will not be grazed until June 1st or 

later, the longer livestock are on the pasture(s), the less potential for regrowth there would be to 

achieve desired structure objectives (Reece et al 2001). 

It is assumed that every pasture within an allotment will be grazed at least once during a grazing 

year. It is also assumed that a stocking rate will be employed that allows for maximizing use of 

consumable forage without damaging the productivity of the plants and the soil (i.e. “proper 

stocking”; Launchbaugh Univ. ID). Regrowth may or may not occur on the non-native pastures to 

recover some fall structure (Reece et al 2001).

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

inventory permits

Range – Grazing native pastures in the absence of tame grass pastures earlier than June 1st or the 

three and a half leaf stage for key graminoid species one out of three years, relieves some of the 

grazing pressure on winter pastures which may contain National Forest System (NFS) lands. 

Although livestock are typically being fed hay and/or supplements while on winter pastures, 

livestock grazing pressure on winter pastures has the potential of increasing as the graminoid 

species green up whether or not the graminoid species are ready to be grazed. 

Botany – Premature grazing of native grasses can decrease plant vigor and production by 

interrupting critical early season growth stages when carbohydrate reserves for initiating new 

growth are low. Defoliation of limited leaf area early in the season is apt to result in small amounts 

of remaining leaf, thereby impeding a plants ability to recover. This effect can contribute to 

decreased plant vigor and production during the remainder of the season (Frank et al 1993, KSU 

1994, Manske 2001, NDSU 2009, NRCS 2007, Sedivec 1992). Manske (2001) measured 45 to 60

percent less forage production compared to the potential when grazing was initiated during mid 

May, but there was very little decrease in forage production when grazing was initiated in early 

June. Continued grazing through the second critical period in late summer/early fall can compound 

adverse effects of early season grazing, as can below normal precipitation that limits the potential 

for regrowth. Although early season use is proposed only once every three years, a relatively high 

potential exists for other factors such as low precipitation or high levels of grazing to act in 

combination with premature grazing to facilitate or maintain early seral stages and decreased plant 

production. Decreased levels of use and/or early removal of grazing are likely to be necessary to 

avoid excessive utilization and long-term adverse impacts to forage production and species 

composition (Manske and Sedivec 1999). Vermeire et al (2007) found unfavorable increases in 

annual brome and prickly pear (Opuntia polycantha) when grazing was conducted before June, 

particularly in areas with high stocking levels such as calving or feeding grounds. 
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Appendix D | 13

Several invasive grass pastures that are underutilized due to poor coordination of the grazing season 

with palatability of these species could eliminate the necessity of implementing this practice. 

However, a potential benefit of premature grazing might include increasing the utilization of 

invasive grasses. Most pastures contain an invasive grass component and early grazing could 

increase selection for this species, thereby increasing the utilization of undesirable species and 

potentially decreasing plant litter that contributes to their persistence or spread. Although livestock 

may become accustomed to grazing and selecting invasive grasses early in the season (Brand 2006), 

the potential exists for premature grazing and adverse effects to desired native grasses, with the 

degree of potential effect increasing with increasing proportions of native grasses. 

Early season grazing on native dominated pastures could have adverse effects on woody draw 

conditions by impeding the development of tree and shrub saplings that would also be at early 

stages of growth with low carbohydrate reserves. Conversely, relatively cool temperatures, fewer 

insect pests, and palatable upland forage may limit livestock use of woody draws (Swanson 1995). 

Wildlife – Premature grazing on a pasture prior to “readiness” could affect plant production for the 

current year and perhaps the following year, especially if stocking levels are heavy. This could 

affect regrowth and herbaceous structure levels the following fall with potential consequences for 

ground nesting species the following spring. Another factor would be the length of the regrowth 

period; whereas, the earlier the livestock leave the pasture, the higher potential for increased 

herbaceous structure readings. Though the winter grazed pasture may have more time for regrowth, 

that fall structure would be lost due to winter grazing the following winter and not be available for 

ground nesting species in the spring. 

Defer native pasture turn-in until June 1st or until development of the 

three and a half leaf stage for key graminoid species

Range – It is a general practice in rangeland management that native cool season graminoid species 

should not be grazed before reaching range readiness (grazing readiness) which is typically the 

three and a half to four leaf stage. Range readiness is defined by the Society for Range 

Management as “The defined stage of plant growth at which grazing may begin under a specific 

management plan without permanent damage to vegetation or soil; usually applied to seasonal 

range.” Range readiness is used to determine the actual allotment entry date in response to plant 

phenology. Methods of determining range readiness for native and tame pastures can be found in 

Frank et al. (1993). They conclude that using the growing degree day (GDD) approach to determine 

grazing readiness, managers have minimized the guess work about when grazing can begin on any 

pasture. They also conclude that if grazing starts at the proper development stage, the plants will be 

more tolerant of grazing stress and will maintain the higher vigor needed to continue forage 

production during the grazing season and in following years. As the spring season varies from year 

to year, and grazing readiness varies year to year, the GDD approach will help determine the best 

date to begin grazing (Frank et al. 1993). 

This tool would affect permittees that have a turn-in grazing association permit by shortening their 

grazing season typically by one month. However, because of the nature of the turn-in permit their 
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14 | Appendix D

Authorized Use would not change because they could run additional AUs for the shorter period of 

time. Permittees with an inventory grazing association permit would also see a shortened summer 

grazing season. But unless they were allowed to graze/feed on their winter pastures for the extra 

month, they would see a decrease in Authorized Use because they would have to run less AUs.

Livestock distribution would potentially change as it should now be focused on the specific grass 

species in the native pasture. For example, livestock would focus grazing pressure on native cool or 

warm season grasses in pastures that are deferred depending upon the season of use.

Botany – Deferring turn-in until sufficient growth is attained assists plants in meeting physiologic 

requirements of carbohydrate storage and transfer to initiate and maintain regrowth after grazing 

(KSU 1994, Manske 2001, 2009, NRCS 2007). Grazing schedules that meet minimum physiologic 

requirements of the plant contribute to the health and stability of a given plant community and 

associated forage production, animal performance, and economic returns (KSU 1994, Manske 2001, 

NRCS 1997). Meeting or exceeding plants’ minimum physiologic requirements is necessary to 

facilitate the development and maintenance of mid and late seral stages, while purposing not 

meeting these requirements will facilitate shifts towards early seral stages or the establishment of 

weedy species. Greater amounts of leaf area at the time of grazing are more likely to result in 

sufficient leaf area remaining on the plant to assist regrowth (Briske et al 2008). The greatest extent 

of both invasive and native grass production is achieved when plants reach the 3.5 leaf stage (Frank 

et al 1993, Manske 2001, NDSU 2009). Manske (2001) measured 45 to 60 percent less forage 

production compared to the potential when grazing was initiated during mid May prior to the 3.5 

leaf stage, but there was very little reduction in plant production when grazing was initiated in early 

June. Biondini and Manske (1996) found 72 percent of aboveground net primary production

occurred by mid-June in North Dakota. Thus, delaying grazing until this time should result in 

greater amounts of forage available to livestock production compared to earlier season grazing. 

Wildlife – Since this tool dictates that native range will not be grazed until after June 1st, depending 

on the length of time in the pasture, regrowth may not be sufficient to achieve structure objectives 

within the allotment (Reece et al 2001). Given these assumptions, it follows that this tool would 

typically continue to contribute to structurally homogenized native pastures because of a limited 

regrowth time for early season species.

At this time, it is assumed that every pasture within an allotment will be grazed at least once during 

a grazing year. It is also assumed that a stocking rate will be employed that allows for maximizing 

use of consumable forage without damaging the productivity of the plants and the soil (i.e. “proper 

stocking”; Launchbaugh Univ. ID). Appendix I of the Grasslands Plan states that “moderate 

grazing intensity” (assumed to be “proper”) would provide “limited opportunity to provide quality 

habitat for management indicator species needing high structure.”

Rest for one or more seasons

Range – Rest is defined in the Grasslands Plan as “To leave an area of rangeland ungrazed by 

livestock or unharvested by mechanical methods for at least one year (12 consecutive months) 

(Grasslands Plan, p. G-45). Holechek et al. (1989) defines rest, distinguished from deferment, as
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Appendix D | 15

the range receives nonuse for a full year rather than just during the growth period. They further 

explain that rest gives plants a longer period to recover from past grazing influences and provides 

wildlife with a pasture free from livestock use during the critical dormant period. A disadvantage of 

both deferment and rest is that the grazing load on other pastures must be increased during the 

critical growth period, and that it is questionable if periodic nonuse during critical periods 

compensates for periodic heavy use (Holechek et al. 1989). Holechek et al. (1989) explains that 

both deferment and rest do provide plants on sacrifice areas with some opportunity for recovery. 

Heitschmidt and Taylor (in Heitschmidt and Stuth 1991) concluded that forage quality is seldom 

directly enhanced by deferment from grazing although it may be indirectly enhanced if deferment 

induces a desirable qualitative change in species composition.

Authorized Use on the allotment receiving rest would be reduced based on the size of the pastures 

that rest is being applied to. The permittee would need to find other pasture land to place the 

permitted livestock onto. Continued long-term rest has the potential of negatively impacting the 

range developments within an allotment or pasture because of the non-use of the development, such 

as in range water wells and pipeline systems.

Botany – Providing rest can help restore plant vigor by providing periods for uninterrupted growth 

and the storage of carbohydrate reserves to weather stressful periods and initiate growth during the 

following year (Dietz 1989, Holechek 1989, NRCS 1997). Rest periods can also facilitate greater 

seed production and recruitment of new seedlings to replenish species populations (NRCS 1997). 

Grassland communities may start shifting towards late seral stages and increased plant structure 

with sufficient rest periods, but development of late seral stages would likely require several years 

depending on the starting point of plant composition. The potential for woody draw sapling 

recruitment would similarly increase with rest by increasing opportunities for saplings to grow 

above browsing heights. 

Holechek (1989) cites several studies where various rest-rotation grazing strategies involving an 

entire year of rest for one of four pastures on a rotating schedule resulted in increased plant vigor 

and density and improved range conditions compared to seasonlong grazing at moderate stocking 

rates. Although rest-rotation grazing systems did not significantly improve livestock performance 

in prairie ranges, periods of rest contributed to multiple use values of aesthetics and wildlife habitat 

quality. 

Wildlife – The lack of herbivory (and fire) for various time frames (rest) was a natural part of the 

ecosystem prior to the introduction of livestock and non-native flora to the Great Plains. The range 

of the temporal and spatial extent of those rest periods was highly variable, contributing to a shifting 

mosaic across the scale of the Great Plains. The rest periods provided certain wildlife species 

habitats generally free from disturbance and potential later successional habitats (USDA 2000b). 

Now that ecosystem is gone. Now invasive grasses place a risk to native species – flora and fauna. 

Now resting an area can favor certain aggressive non-native species such as Kentucky bluegrass and 

smooth brome. These species can potentially turn an area into an Invaded Grass State. Sites 

dominated by invasive grasses are generally not conducive to promoting native species because of a 

tendency to form monocultures and providing a different vertical and horizontal habitat structure. 

This, however, does necessarily nullify the potential benefits that rest could provide to flora and 
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fauna along with restoration of ecosystem processes – notably fire and rest (Fuhlendorf et al 2009). 

Although the specific time frame is ambiguous, we must distinguish between shorter term rest and 

long-term rest. Currently, in order to preserve the traditional range management paradigms, the 

range management literature seems biased toward the perceived, and probable negative impacts of 

long-term rest (greater than 10 years) in today’s ecosystem realities rather than rest-rotation and 

relatively short rest periods. Long-term rest (>10 years; No Grazing Alternative) may not be 

beneficial especially over large areas over longer time frames for two reasons: the potential for too 

much moderate and high structure at the expense of low structure (i.e. poor structural diversity); and 

two, the longer the rest period(s), the higher the probability, or risk, of favoring invasive grass 

species. Invasive grass species can provide high structure in the fall but due to its vegetative 

structure may not hold up over the winter. But studies are mixed on the value of Kentucky bluegrass 

to grouse (Uchytil 1993 plus see Rice and Carter 1984 compared to Kohn 1976). I suspect that the 

value of this invasive species may be relative to its presence within the plant community. But given 

the widespread presence of invasive grasses on the Little Missouri National Grassland (LMNG), 

and the project area, that long-term rest is favorable to herbaceous structure as measured in the fall, 

but its value for wildlife is highly suspect for upland nesting species.

Relative short-term rest (perhaps 1to 5 years) could provide ecosystem diversity in processes and 

habitats (Fuhlendorf and Engle 2001, Briske et al 2008). Short-term rest (e.g. 1-5 growing seasons) 

would provide increased amounts of high structure as measured in the fall and, assuming a strong 

native grass component, would provide increased quantities of potential habitat in the spring as well 

for species requiring higher structure habitats such as sharp-tailed grouse and Baird’s sparrow.

On the other hand, long-term rest would reduce the habitat suitability for some of the same species. 

Populations of Baird’s sparrow and Sprague’s pipit can peak at 1to 5 years after a fire, but they 

were absent from areas with long-term rest (80 plus years: Madden et al 1999). Increasing litter 

depth reduces habitat suitability for these species (DeChant 1998).

Soils/Hydrology – The cessation of grazing would have an immediate, short-term positive effect on 

riparian areas. Trampled banks, compacted soils, and trailing would heal within one or a few 

seasons. Riparian plant communities would begin to expand in areas where plant density is light, 

sparse, or absent. Woody riparian shrubs and trees would likely see a marked increase in 

population as seedlings would not be trampled and seedlings and saplings would not be browsed by 

livestock.

Long-term rest with sod forming invasive grasses such as Kentucky bluegrass invasion could lead 

to poor nutrient cycling in the soil and poor rangeland hydrology with excessive runoff and reduced 

infiltration in upland soils. Decreased infiltration reduces available soil moisture for upland plants. 

Increased runoff can initiate gullying of drainage ways and erosion of channels due to increases in 

peak stream discharge. 

Reallocation of pastures (change allotment boundary)

Range – Reallocation of pastures and changing an allotment boundary would provide more 

flexibility in the management of an allotment(s) in many ways. The decision to change allotment 
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Appendix D | 17

boundaries could be due to topography, distribution of livestock, or vegetative communities (native 

versus non-native). Several of the allotments within the project area were cultivated and planted 

back to crested wheatgrass. By combining allotments or changing boundaries, managers have the 

ability to utilize the non-native pastures and defer the native pastures instead of a typical eight 

month grazing season on a pasture that is crested wheatgrass or grazing native before range 

readiness has been achieved. In the case of topography, a rotation may be more easily achieved if 

pastures are reallocated since the topography may have restricted the movement of livestock to the 

next pasture in a rotation. Livestock distribution has the potential to change as well, depending on 

the topography and/or plant composition of the exchanged pastures. This tool was also one of 

several recommended in the Report of the Scientific Review Team (2005) under Issue V-3, where 

they state that one of the issues in the sample AMPs was the redistributing of animals over time and 

space in contrast to reducing animal numbers has been inadequately considered.

Depending on the pasture reallocation, a common allotment could be created which would require 

additional coordination with all common members for the grazing management to succeed. Grazing 

administration would need to be updated so that the grazing association grazing permits would 

reflect the reallocation of NFS acreage and associated AUMs. An analysis of available AUMs per 

pasture would be required, as well. Lastly, there could be costs associated with updating allotment 

boundary fences so that they are up to FS specifications. 

Botany – Pasture reallocations or boundary changes can assist efficient utilization of available 

forage. For instance, greater utilization of invasive grass forage might be achieved if existing 

permittees do not have a sufficient number of head to provide the desired level of utilization before 

these species decrease in palatability, or the permittee would not have a sufficient forage base to 

maintain an increased number of head during other times of the year. Reallocating under-utilized 

forage in one allotment may allow needed rest in other allotments to increase plant vigor, 

production, and composition of both grassland and woody draw communities. Changing pasture 

boundaries can assist separating invasive versus native grass communities for more efficient 

utilization of the former and protection from premature grazing for the latter. 

Fencing areas of similar topography and forage can assist more even utilization or decrease 

excessive utilization of preferred grazing areas (Bailey 2004). For instance, livestock are more 

likely to graze on gentle rather than rough topography when both are present, but splitting the area 

of more difficult terrain into a separate pasture can result in more efficient use of available forage. 

Hart et al (1993) found pasture size in relation to water availability had the greatest influence on 

livestock distribution and forage utilization. Thus, changing or dividing pasture boundaries could 

increase the uniformity of utilization. Although this would have the potential of decreasing the 

desired mosaic of different grazing pressure and seral stages, grazing levels could be specifically 

established in different pastures to facilitate a range of seral stages that could be rotated among 

different potential plant communities to promote a shifting mosaic of seral stages and plant 

diversity. 

Changing pasture boundaries can also alleviate high levels of concentrated trailing and erosion that 

result from topographic constraints or unusually shaped pasture boundaries. Changing pasture 

boundaries might also alleviate excessive use of sensitive areas such as woody draws or riparian 
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18 | Appendix D

habitats that might be less accessible from another pasture. Conversely, changing boundaries to 

achieve greater access to a given area would increase browsing and trampling disturbances within 

woody draws, and/or facilitate shifts towards early seral stages of upland grass communities. 

Wildlife – Reallocation of pastures can provide opportunities to adjust management to address 

various resource issues such as adjust for non-native cool season grass areas, take advantage of 

topography, reduce trailing, or permit better distribution of water sources.

This tool can also provide opportunities to adjust management to address similar resource issues. 

However, if issues exist prior to the adjustment, the potential for those issues still exists after the 

adjustment is made, as well. For example, if stocking rates are at the root of an issue, they may not 

be adjusted initially due to the perception that a new rotation will fix the issue (Briske et al 2008). 

This tool is dependent on many factors including stocking rate, water distribution, timing, etc. 

Given this dependency on other factors, it is uncertain at this time how specifically this tool will 

affect herbaceous structure and monitoring of the specific situation will be required. Potential exists

for improvement in the herbaceous structure distribution because of potential to better utilize tame 

grasses, water sources, etc. On the other hand, potential exists for no changes or negative impacts to 

herbaceous structure in some areas, as well.

Soils/Hydrology – The increase in number of pastures allows livestock to spend less time in each 

pasture and to increase the rest period. In general, plants are healthier when they have longer 

periods of rest between grazing intervals. Most native prairie plants can better rebuild aboveground 

biomass, recharge food reserves to root systems, and rebuild root structure during longer rest 

periods than shorter intervals.

Construct temporary fence to control livestock distribution patterns

Range – For distribution, fences serve to control seasonal drift of livestock, regulate use among 

forage types, protect choice grazing areas for special uses, and to separate units for special 

management (Holechek et al. 1989). Intensive and effective management of grazing lands is 

dependent on adequate fencing (Vallentine 1989). Although stock water developments, salting 

practices, placement of other supplements, and occasional drifting of livestock are useful indirect 

methods of controlling livestock, fencing and herding are the only direct means of regulating 

seasons, numbers, kinds, and distribution of grazing animals (Vallentine 1989). Vallentine explains 

that the uses and benefits that can be expected from fencing, are many. Some of the 19 benefits he 

identifies include: 1) permit rotation, deferment, and resting of grazing lands, 2) regulate season of 

grazing use, 3) regulate stocking rates, 4) provide better distribution of grazing, 4) protect soil and 

related resources on erosive sites, 5) reduce labor required in handling livestock, 6) protect new 

seedlings and other range improvements.

Livestock distribution would potentially change as it should now be focused on the specific grass 

species in the temporarily fenced off location. For example, livestock would focus grazing pressure 

on crested wheatgrass in areas grazed early and on native cool or warm season grasses in areas that 

are deferred depending upon the season of use. Temporary fencing, typically, would be an 

additional expense to the permittee in both installation and maintenance.
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Appendix D | 19

Botany – Temporary fencing can assist greater uniformity of utilization by enclosing livestock 

within a smaller area, but can also provide rest or deferment in other areas. Therefore, temporary 

fencing can promote late or early seral stages across different areas of a pasture. Fencing can be 

effective in delineating areas of different forage quality or seasonal use (Holechek 1989). For 

example, crested wheatgrass or other invasive grasses can be fenced from areas of native grass, 

thereby increasing utilization of invasive grasses while protecting native grasses from premature 

grazing. Temporary fencing can also remove grazing-related disturbances and improve conditions 

of sensitive areas such as riparian habitat, springs, woody draws, and sensitive plant habitat. 

Wildlife – If the objective of the fence is to create a more even utilization pattern, and given other 

assumptions of moderate grazing intensity and rotational systems (Bailey, 2003) and (Holechek et 

al, 1989), then the effect will be little, if any, improvement to overall herbaceous structure diversity. 

If the objective is to help rest another pasture, then effects would be more positive, assuming 

appropriate stocking for each pasture rather than increasing the grazing burden on the grazed 

pastures to make up for the deferred grazing from the rested unit. If the objective is to better utilize 

crested wheatgrass, then the effect may be mixed but perhaps generally positive because of likely 

regrowth from crested wheatgrass.

USDA (2001b) states that smaller pastures result in more uniform forage utilization. However, 

Briske et al (2008), Bleich (2005), McCuistion (2008), and Holechek (1989) suggest that rotational 

systems, albeit with smaller pastures, may be used to benefit conservation goals such as wildlife 

habitat if other tools (e.g. rest or variable stocking) are used alongside this management technique. 

Utilizing temporary fences would allow for more temporal control and management responsiveness 

and flexibility of specific situations.

Construct or remove cross fences

Range – Constructing fences has the same effects as discussed under the previous section, the 

exception being that these are permanent fences so the ability to change management actions 

requiring a fencing change is slower than with temporary fencing. Removing fencelines can 

facilitate simultaneous use of adjacent pastures, and may alleviate problems associated with water 

distribution providing other opportunities for improving resources towards desired conditions. 

Botany – Constructing new fences results in subdividing or splitting pastures and can have effects 

similar to the above, but of permanent duration. Subdividing a pasture into several smaller pastures 

can increase the evenness of livestock distribution and utilization, potentially decreasing over

utilization of key grazing areas (Holechek 1989). However, increased evenness of utilization can 

conflict with Grasslands Plan objectives for maintaining a mosaic of utilization levels and seral 

stages unless this goal is specifically incorporated in grazing management. Some studies have 

shown that subdividing pastures into several smaller pastures that rely on the same water can result 

in increased trailing and erosion impacts (Hart et al 1993). 

Removing fencelines can facilitate simultaneous use of adjacent pastures and may alleviate 

problems associated with water distribution. Increases in pasture size with limited water 

distribution can decrease the evenness of grazing distribution and utilization (Hart et al 1993), 
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20 | Appendix D

thereby facilitating a range of seral stages across the pasture. Although a mosaic of grazing 

intensity is desired to support a range of seral stages and plant communities, poor livestock 

distribution can result in excessive grazing in primary use areas (Holechek 1989). 

Wildlife – Constructing a cross fence would typically result in smaller management units and 

increased distribution of livestock and potential for increased herbaceous structure homogeneity. 

However, more units can also increase management flexibility with a clearly stated plan designed to 

meet desired objectives. With more units available, potential management options could include 

such tools as varying stocking rates/timing to influence the disturbance regime and provide a 

mosaic of herbaceous structure. Increased permanent fencing could increase grouse mortality (and 

big game) from collisions with permanent fencing.

Conversely, removing fences may enlarge management units and may result in decreased livestock 

distribution and increased potential for herbaceous structure heterogeneity. Depending on context, a 

loss of management flexibility to alter the disturbance regime at the management unit level may be 

experienced. There may be less mortality to grouse from collisions with permanent fencing.

Construct livestock water development (well, pipeline, tanks, windmill, 

reservoir, dugout, or spring)

Range – New water developments will typically be located in uplands away from woody draws and 

riparian areas. According to Holechek et al. (1989) livestock water is the center of grazing activity 

and additional watering locations will often improve livestock distribution. The location of water 

developments on rangeland is important in controlling the movement, distribution, and 

concentration of livestock, and that improper distribution of grazing frequently results from 

improper distribution of watering places (Vallentine 1989). Vallentine (1989) concludes that a 

good rule of thumb is that cattle should not have to travel more than one quarter to one half mile 

from forage to water in steep, rough country or more than one mile on level or gently rolling range 

according to the USDA Forest Service (1969) and the USDA Soil Conservation Service (1967). 

These findings indicate that livestock distribution would potentially change; however, to prevent

livestock from utilizing the woody draws and riparian areas the development should be at least one 

quarter of a mile away to minimize the disturbance by livestock in the Badlands geographic area 

and even farther in the Rolling Prairie geographic area. The location(s) of the water development(s) 

is site specific within an allotment and should be analyzed to assure proper placement to meet 

management goals. Utilization in the area of the water development would increase, however, with 

other management tools and the planned monitoring in place this should assure that over use doesn’t 

occur. For each water development there would be initial construction costs to the permittee and 

the FS, and continued maintenance costs to the permittee.

Botany – Adding water developments can result in more even livestock distribution and utilization 

throughout a pasture with increased livestock performance (Bailey 2004, Hart et al 1993, Holechek 

1989). Improved livestock distribution with additional water sources can also improve range 

conditions by alleviating excessive use and adverse impacts around limited water sources located in 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 21

typical grassland communities or near sensitive areas such as woody draws and riparian habitats. 

Development of off-site water away from riparian and woody draw sites can result in decreased 

browsing and trampling disturbances and an increased potential for improved conditions (Miner et 

al 1992, Porath et al 2002). Decreased turbidity and other improved water quality characteristics 

often obtainable with an alternative water source can significantly improve livestock performance

(Porath et al 2002, Surber et al, 1996). 

There is direction in the Grasslands Plan for maintaining or restoring riparian areas; therefore 

development of new springs may require some additional mitigation to follow plan direction. 

Plumbing systems designed with check valves to maintain flow at the spring while providing 

livestock water some distance away can improve the ecologic condition of undeveloped springs that 

experience high livestock disturbance, particularly if the spring and associated riparian habitat is 

fenced. Potential improvement of woody draw conditions adjacent to disturbed springs would most 

typically be confined to the immediate area that is fenced from continued livestock browsing and 

trampling disturbances associated with access and congregation around the water tank. 

Adverse effects of developing new water sources can include zones of high disturbance around the 

water source with decreased plant production and composition (Brooks et al 2006, Rinehart and 

Zimmerman 2001). Rinehart and Zimmerman (2001) measured decreased plant production, 

composition, and structure with decreasing distance to water sources on the LMNG. They 

concluded that the existing density of water developments was resulting in homogenization of 

disturbance patterns and were inhibitive of attaining a mosaic of grazing intensity and a range of 

seral stages and plant structure within western wheatgrass – needlegrass habitat types. 

Constructing new reservoirs or dugouts along drainages alters natural hydrologic characteristics of 

the system and has a high potential to increase woody draw disturbances from livestock trailing 

along the drainage and congregating around the reservoir. Interrupted hydrologic flow also has the 

potential to decrease downstream moisture availability for the regeneration of woody species. 

The addition of new water sources supplied by pipelines or water wells increases the reliability of 

water but also increases the potential for continued grazing during drought conditions compared to 

other water supplies that are likely to become dry during drought and expedite the removal of 

livestock under poor forage conditions. Forage plants are less tolerant of grazing during drought 

(Biondini and Manske 1996, NRCS, 1997), so continued use during these periods has the potential 

to decrease forage production and composition. Disturbances associated with pipeline construction 

have a high potential to assist the establishment and spread of invasive plants. 

Wildlife – Water developments influence the structure distribution by increasing livestock 

distribution (USDA 2001b, LMNG Rangeland Assessment 2002, Fontaine et al 2004). 

Homogenization effects are expected under traditional range management paradigms (e.g. "proper" 

stocking, goal of increased efficient use of the entire pasture, and most rotation systems -

Fuhlendorf and Engle 2001), particularly within a half-mile of a development (LMNG Rangeland 

Assessment 2002, Fontaine et al 2004). There is also the potential loss of secondary range (USDA 

2001b). On the other hand, water developments, by providing management flexibility, could aid in 

achieving herbaceous structure objectives if the disturbance regime (livestock management and fire) 
FEIS Vol. III North Billings County Allotment Management Plan Revision

22 | Appendix D

is variable over time (i.e. years; Fuhlendorf et al 2006 and Fuhlendorf et al 2009) within the sphere 

of the water development(s). To recreate secondary range may require reducing water density 

artificially and/or temporarily via rotations and/or shut-off valves. The objectives, along with the 

spatial, timing, and environmental context would be critical in determining the potential effects of 

infrastructure.

Soils/Hydrology – Constructing new water developments would pull livestock away from riparian 

corridors depending upon the particular location of the development thus reducing livestock use in 

these areas. Improvements in the desired conditions for riparian areas and streams should occur by 

minimizing bank trailing, trampling, and loafing in the riparian area, allowing for herbaceous and 

woody riparian vegetation maintenance.

Remove/reclaim water development (well, pipeline, tanks, windmill, 

reservoir, dugout, or spring)

Range – As stated in the standards and guidelines of the Grasslands Plan, areas such as seeps, 

springs, wetlands, and riparian areas need to be protected. Natural springs have been developed in 

these areas in the past, and livestock are attracted to these areas due to the water source. The 

removal/reclaiming of these water developments may or may not affect the distribution of livestock. 

Livestock distribution may not change because of the size of pasture, topography, climatic 

conditions, other existing water developments, or other management tools used within the 

management plan for the allotment. Distribution on larger pastures along with other management 

tools has the potential of changing livestock distribution; however, the extent of the change will 

depend on management and monitoring of the allotment.

The Grasslands Plan on pages 1-9 through 1-10 in section B, lists the standards and guidelines for 

water. The North Dakota Water Commission also has state laws that require abandoned wells to be 

plugged if the water well has been abandoned. If this has been the case for some time, the 

distribution of livestock will not change. On the Medora Ranger District livestock water wells are 

plugged if a new well is drilled to replace the old one, or if the well is abandoned, the DPG has a 

program to plug the wells due to state laws and regulations.

Botany – Removal of an upland water tank would facilitate shifts towards late seral stages in the 

surrounding area due to decreased grazing disturbances. However, high levels of previous 

disturbance around the tank would have the potential to support populations and seed banks of 

invasive grasses and weedy species. Although most early seral weeds would gradually decrease in 

occurrence with removal of the tank and plant succession, invasive grasses would have the potential 

to increase in vigor, dominance and extent. The removal of a water development has a high 

potential to result in increased disturbances around other water developments.

Reclaiming developed springs or various reservoirs along drainages has the potential to improve 

conditions of adjacent woody draws by decreasing livestock disturbances and restoring natural 

hydrologic conditions that can increase the growth and regeneration of woody species. 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 23

Wildlife – Reclaiming water developments and not replacing them with new water provides an 

opportunity to decrease water density and increase secondary range which could potentially contain 

higher herbaceous structure and contribute to the herbaceous structure distribution.

Removing or reclaiming a water source from woody draws or riparian areas should improve woody 

draw or riparian conditions and have a positive effect for those wildlife species that utilize these 

areas.

Manage water availability/access at water developments

Range – In review of Wyman (2006) techniques that attract livestock away from riparian areas and 

Ganskopp (2004) field day range report on affecting beef cattle distribution in rangeland pastures 

with salt and water, they indicate that this tool is effective in improving livestock distribution. 

Ganskopp (2004) reported this method can be used to temporarily lure livestock away from 

seasonally sensitive portions of a pasture. In this study they used portable stock tanks and closed 

off access to specific watering points within the pastures and initially herded livestock to the new 

salt location or water source. Ganskopp’s (2004) primary goal of the study was to evaluate the 

effectiveness of salt and water manipulating cattle distribution in large sagebrush/steppe pastures. 

Wyman (2006) also reported that this tool was successful in south-central South Dakota where a 

rancher distributed water tanks throughout a large pasture and turned the water on and off which 

distributed livestock to various portions of the pasture and decreased the amount of interior fence 

needed in rough terrain. In review of Ganskopp (2004) one will also see that this tool was used 

along with other management tools such as the placement of supplements and herding.

In the case of a range water pipeline system this tool would be easy to implement, but the permittee 

would need to monitor livestock use closely in the area of available water to prevent overuse. In 

other water development situations, additional input would be required to control livestock access 

of the water development, such as, water lot fences around reservoirs and dugouts resulting in 

additional construction and maintenance costs. Livestock distribution would be altered depending 

on the size of the individual pastures and topography. With the success of moving livestock use 

from one available water source to another there should no longer be a need to install extra interior 

fences in an allotment depending upon topography. 

Botany – Controlling flow or access to various water developments assists in controlling livestock 

distribution and the intensity of forage utilization and grazing disturbances (Bailey 2004, Holechek 

1989). Limiting access to a water site can therefore facilitate shifts towards late seral stages in the 

surrounding area, while increasing access can shift plant composition towards early seral stages. 

The affect of controlling water access can be similar to implementing a rotation grazing system 

without the need for subdividing a pasture with cross fencing because livestock grazing will shift to 

the area of present water availability (Hart et al 1993). 

Wildlife – See “Construct livestock water development” tool.

Managing water sources may add flexibility to an allotment or pasture by allowing the manager to 

control access to the water, thereby influencing distribution of livestock and, hence, herbaceous 

structure. The effectiveness of this tool for addressing the herbaceous structure distribution within 
FEIS Vol. III North Billings County Allotment Management Plan Revision

24 | Appendix D

an allotment or pasture would depend largely on two to three factors: distribution of manageable 

and fully accessible water sources; a clearly stated plan on how to manage the water sources so as to 

meet desired objectives; and management compliance.

Maintain existing developments to reestablish use 

Range – The lack of maintenance on developments leads to them becoming nonfunctional for 

livestock use or minimally functional. As the water developments decrease in functionality, 

livestock distribution will change leading to a concentration in use around areas where the 

developments are functional. Without adjusting for this change in livestock distribution, areas will 

become heavily used by livestock, and over time plant diversity will change. Maintenance of 

allotment boundary fences will prevent excess use within an allotment from livestock in adjacent 

allotments. Maintaining interior allotment fences will ensure that the planned rotation occurs.

Botany – This practice is primarily directed to reconstructing or repairing developed springs, 

dugouts, water wells, and fencelines that are in disrepair or no longer functioning effectively. 

Spring and dugout developments occur along drainages usually supporting woody draw 

communities where maintenance or repair of the development will likely ensure continued or 

increased livestock disturbances that impede the improvement or maintenance of woody draw 

conditions. However, as discussed above, reconstruction of spring developments can assist 

improved conditions of the wetland habitat and portions of adjacent woody draws. Repair of water 

wells to supply upland water tanks can reestablish livestock distribution and utilization patterns, 

with potential positive and negative effects as discussed above for the “Construct livestock water 

development” tool. Repairing fencelines allows for controlling the degree of use in different 

pastures of an allotment, thereby allowing for the control or management of desired plant 

composition and seral stages. 

Wildlife – This would essentially re-establish a development. See “Construct livestock water 

development” tool.

Implement deferred grazing system

Range – Grazing systems are often proclaimed to be viable options for enhancing the productivity 

and ecological condition of grasslands (Vermeire et al. 2008). Vermeire et al. (2008) explains, 

however, that no individual grazing system investigated in their study effectively altered standing 

crop or functional group composition relative to other grazing systems. Biondini and Manske 

(1996) concluded that their results clearly indicated that in the grasslands of western North Dakota, 

rainfall is more important than grazing or grazing systems in the control of ecosystem-level 

variables measured. The greatest changes in standing crop were climate-related and therefore, 

selection of grazing strategies should not be based primarily on the premise that a particular system 

or the implementation of pasture rotations will hasten alterations in standing crop or plant 

community composition (Vermeire et al. 2008). They concluded that the greatest opportunity for 

affecting the plant community appears to be through controlled timing of spring grazing and 

stocking rate (Vermeire et al. 2008)
FEIS Vol. III North Billings County Allotment Management Plan Revision 

Appendix D | 25

Specialized grazing systems have been a major focus of range research and managers since the 

1950s (Holechek et al. 1989). Holechek et al. (1989) stated that during the 1950s and 1960s, 

deferred-rotation systems received considerable attention and rest-rotation grazing was heavily 

applied on public lands in the intermountain West during the 1970s. According to Holechek et al. 

(1989) a disadvantage of both deferment and rest is that the grazing load on other pastures must be 

increased during the critical growth period. Deferment and rest, however, do provide plants on 

sacrifice areas with some opportunity for recovery (Holechek et al. 1989). Briske et al. (2008),

however, explains that there is a preponderance of evidence generated from grazing experiments 

over the past 60 years that has consistently indicated that rotational grazing is not superior to 

continuous grazing on rangeland at similar stocking rates. Briske et al. (2008) concludes that this 

intuitively leads us to conclude that management commitment and ability are the most pivotal 

components of grazing system effectiveness and that grazing systems do not possess unique 

properties that enable them to compensate for ineffective management (i.e., grazing systems do not 

provide a ‘‘silver bullet’’ to ensure attainment of desired goals). The basic principle of grazing 

management is control of the frequency and severity of defoliation of individual plants (Heitschmidt 

& Walker 1983). Sedivec (1992) states that a grazing system(s) must be adapted for individual 

farms or ranches and that the systems are developed to suit each particular set of pastures, the type 

of livestock operation, kind and type of forage available for grazing, number, size and/or carrying 

capacity of different pasture units available, and relative location of pastures for easy movement of 

livestock between pastures. 

Deferred rotation grazing systems provide an opportunity for preferred plants and areas to maintain 

and gain vigor compared to continuous grazing and works best where considerable differences exist 

between palatability of plants and convenience of areas for grazing (Holechek et al. 1989). This 

rotation requires a minimum of two pastures. Sedivec (1992) defines a deferred rotation grazing 

system as one that allows discontinuation of grazing on different parts of the range in succeeding 

years, which allows each grazed part to rest during the succeeding growing season. He further 

explains that traditionally, deferred rotation grazing generally implies no grazing until seed is 

mature on one unit during the first growing season or on another unit during the second year, and so 

on in the rotation. A pasture grazed early in the growing season but left ungrazed during rapid 

growth and flowering of key plant species would not be a deferred pasture (Sedivec 1992). 

Twice-over rotational grazing is a variation of deferred rotation grazing (Sedivec 1992). This 

system rotates the livestock faster, resulting in more acceptable forage for livestock throughout the 

grazing season (Sedivec 1992). Sedivec (1992) concludes that during the first grazing cycle, cool 

season grasses and sedges are utilized before they become too mature and unpalatable. At least 

three pastures are required. This system allows for an adequate period of rest between rotations, 

although one pasture is grazed during the critical period in plant development when carbohydrate 

root reserves are being used for spring growth, but the grazing sequence of the pastures will 

alternate from year to year (Sedivec 1992). 

Authorized Use levels should not be affected by the type of grazing system implemented; just the 

management of the various pastures within an allotment may change. Livestock distribution may 

change depending upon the herbaceous plant community within the pastures. Livestock may focus 
FEIS Vol. III North Billings County Allotment Management Plan Revision

26 | Appendix D

grazing pressure on crested wheatgrass in pastures grazed early and on native cool or warm season 

grasses in pastures that are deferred depending upon the season of use.

Botany – Grazing systems are a tool to improve range conditions by providing periods of nongrazing for growth and recovery of forage species and production (Dietz 1989, Dormaar 1997, 

Heitschmidt 1987). However, stocking rates will always be the main factor affecting the success of 

any grazing system, none of which can compensate for over-utilization (Briske et al 2008, Eckert 

and Spencer 1987, Hart et al 1993, Heitschmidt 1987, Holechek 1991, KSU 1994, Pieper and 

Heitschmidt 1988, Wilson 1986). 

Reviews of various grazing rotation studies across a range of ecosystems in the western U.S. 

showed that average forage production increased by about seven percent compared to seasonlong 

grazing (Holechek et al 1989, 1999). However, less improvement in forage production has been 

obtained from rotation systems in semiarid and prairie regions under moderate stocking levels, 

largely due to the importance of precipitation in affecting annual plant production (Biondini and 

Manske 1996, Derner and Hart 2007, Heitschmidt 1987, Holechek et al 1989, 1999, Hart et al 1993, 

Vermeire et al 2008). Smoliak (1960) summarized reports of other researchers ranging from 

beneficial to negative effects of rotational grazing studies on livestock gains and vegetation trends, 

and found no benefit of a deferred rotation conducted over a nine-year period. Continuous grazing 

resulted in less clubmoss and greater livestock gains than a deferred rotation. Holechek et al (1989, 

1999) concluded that forage production and economic returns have been slightly greater under 

seasonlong versus rotation grazing in the Northern Great Plains (NGP). Seasonlong use may have a 

greater tendency to result in uneven grazing distributions or excessive use of primary grazing areas 

compared to rotation systems (Holechek 1989), but Hart et al (1993) concluded that pasture size and 

water availability rather than grazing systems were the primary factors of uneven utilization and 

decreased livestock performance. 

While recognizing inconsistent or conflicting results, deferred rotation systems can result in 

increased opportunities for plant species to regain vigor and production by providing periods of rest 

during critical growth stages (Smoliak 1960). Although plant reproduction can be maintained 

vegetatively through the development of tillers from existing plants when the period of grazing is 

appropriately timed (Manske 1995b), sufficient rest of a pasture during late spring and early 

summer allows carbohydrate reserves to be replenished and provides a period of protection for 

establishing seedlings before grazing is initiated later in the year. Rest during late summer and 

early fall provide similar benefits during the second critical growth period and may provide an 

increased opportunity for seed production. Allowing for the completion of these critical growth 

periods helps to maintain plant vigor, composition, and long-term production (Briske et al 2008, 

Dormaar 1997, Holechek et al 1989, 1999, NRCS 1997). 

Deferred rotations may also assist in greater utilization of different species within a pasture when 

they exhibit different periods of palatability because the same species will not always be selected 

for grazing with a deferred rotation (Holechek et al 1989), thereby assisting the maintenance of a 

diverse plant community. However, among pastures with a high proportion of tame or invasive 

grasses, implementation of a deferred grazing system is likely to maintain or perpetuate poor or 

infrequent coordination of the grazing season with high palatability of these species, thereby 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 27

contributing to selective use of the native component when the pasture is used relatively late in the 

season. Potentially excessive use of the native component on an alternate year cycle can confer a 

sufficient competitive disadvantage to facilitate increases of the invasive component. These effects 

are further discussed above in the Botany section for the “Utilize non-native grass pastures early to 

defer grazing on native pastures” and “Adjust season of use” tools. 

Periods of rest may also assist woody draw and riparian vegetation (Holechek 1999). Livestock are 

likely to spend greater amounts of time within woody draws during hot summer months compared 

to early spring or fall-winter. Thus, changing the period of use on an annual basis is likely to result 

in decreased woody draw disturbances compared to seasonlong grazing. However, the slow growth 

response of woody plants to browsing and trampling disturbances can impede or stunt their rate of 

growth and escape from additional disturbances, with sufficiently repeated browsing leading to 

mortality (Girard et al 1987). This is in part due to growing points of woody plants located at the 

branch tips that are removed during browsing, compared to grasses that grow upwards from the 

base of the plant that is generally not grazed. 

Wildlife – “The four principles of grazing management are: 1) timing; 2) distribution; 3) kind/class 

of livestock; and 4) stocking rate. Stocking rate is the most important variable in grazing 

management” (Walker 1995). On page 3-86, the NGP FEIS (USDA 2001a) displays that for the 

Medora Ranger District, approximately two-thirds of the district uses a deferred rotation grazing 

system. With this established, theoretically then, the first two principles are addressed. 

Cattle have been used in western North Dakota since the late 1800’s and is a generally accepted 

ecological substitute for bison (Towne et al 2005), therefore another principle is addressed (class 

and kind). 

Analyses for this project indicate that many allotments are over stocked and the project area, has yet 

to meet the objectives of the Grasslands Plan. Hence, many of the allotments within the analysis 

area help elucidate the conclusions reached in Briske et al (2008), and others, that stocking is an 

over-riding factor in grazing management and that relying on grazing rotations will not alleviate 

higher stocking rates. However, Briske, and others, also indicate that rotations can be used to help 

achieve objectives. The final conclusion is that rotations are not generally superior to continuous 

grazing, though rotational systems certainly provide viable options for the manager. Stocking is, 

and always will be, a major factor affecting rangeland ecosystems (Pieper and Heitschmidt 1988) 

and the relative success of any grazing system (Heitschmidt 1987).

 Implement deferred grazing system – Kempema (2007) suggests that a four or five pasture 

deferred (or rest rotation) grazing system could provide the greatest landscape scale 

heterogeneity and that a combination of systems across the landscape may support a “universal 

management goal that enhances biodiversity and supports the ranching enterprise.” Partners in 

Flight (PIF 2000) also recommend rest rotation or deferred rotation, although the number of 

pastures is not stated. In contrast, Rice and Carter (1982) found that deferred rotation systems 

on the Fort Pierre National Grasslands did not leave enough residual cover for grouse (greater 

prairie chickens and sharp-tailed grouse) despite a lighter stocking rate than the preferred rest 

rotation scheme (see also Norton 2005).
FEIS Vol. III North Billings County Allotment Management Plan Revision

28 | Appendix D

 Implement 2-unit deferred grazing system – Due to a limited number of pastures which limits 

regrowth potential, this deferred rotation strategy is probably the least favorable to develop a 

diverse herbaceous structure distribution (Kempema 2007). This strategy is not likely to 

provide the length of time necessary for regrowth in early season pasture and would contribute 

to a uniform structure distribution. (e.g. Fuhlendorf and Engle 2001; Van Poollen and Lacy 

1979).

 Implement 3-unit deferred grazing system – Most literature indicates that rotations in semiarid 

regions show no definite advantage over continuous grazing in terms of desired forage species 

relative to seasonlong (e.g. Holechek et al 1999, Briske et al 2008, Kothman et al 2009). 

However, the more pastures there are, the better the opportunity for regrowth after cattle are 

rotated in the early grazed pasture. But with a typical eight month grazing season, regrowth 

may be limited, even in this pasture, which could limit herbaceous structure distribution.

 Implement 4-unit deferred grazing system – Similar to the three-unit deferred grazing system 

except adding another pasture increases the potential for regrowth, and contributing to 

diversifying the herbaceous structure distribution, in the early pasture after cattle leave.

Implement rest-rotation grazing system

Range – Rest-rotation grazing is unique in that one pasture receives twelve months of nonuse while 

the other pastures absorb the grazing pressure (Holechek et al. 1989). Holechek et al. (1989) also 

explains that most rest-rotation schemes involve four pastures and that the problem with restrotation grazing is that the benefits from rest may be nullified by the extra use that occurs on the 

grazed pastures. Sedivec (1992) states that in North Dakota a rest-rotation is normally designed to 

include four pastures of which three are grazed, leaving one idle each year. The first pasture is 

grazed in the spring, second in the summer, third in the fall, and the beginning pasture is alternated 

every year (Sedivec 1992). Authorized Use would not change, and livestock distribution would not 

be expected to change either.

Botany – This grazing system provides for a complete growing season of rest for each pasture in a 

rotation on a sequential basis. The completion of both spring and fall critical growth periods during 

years of rest allows for maximum potential regrowth and replenishment of carbohydrate reserves 

compared to seasonlong grazing or shorter periods of rest. The extended period of rest can assist in 

maintaining plant vigor, forage production, and plant composition. Additionally, the season of 

grazing each pasture is deferred or staggered under this system, such that the pasture rotation 

generally provides for the completion of at least one of the critical growth periods during years it is 

grazed. However, this would depend on the total number of pastures in the system that also affects 

the frequency of rest years. 

Holechek (1989) speculated that rest-rotation systems may help improve rangeland in relatively 

poor condition but would have less benefit in rangelands of good condition stocked at moderate 

levels. However, allowing pastures an entire year of rest may help achieve multiple use goals. 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 29

Wildlife – Holechek, Pieper, and Herbel (1989) state on pages 225 through 228, “Rest-rotation 

grazing has a number of multiple-use advantages” including wildlife habitat; “heavy stocking rates 

will prevent range improvement under an otherwise appropriate grazing strategy”; “...a good 

system for both vegetation and livestock in rugged...terrain...on flatter terrain there are better 

systems when goal is primarily livestock... however, when multiple use is an important 

consideration, rest-rotation grazing has important advantages even on these ranges.” Univ. of 

Arizona (2001) and Bleich et al (2005) reached the same conclusions. This tool, if exercised 

properly, has definite advantages for wildlife and other multiple-use objectives. Rest-rotation 

grazing has the potential to diversify herbaceous structure under the right circumstances.

However, if it is assumed that the grazing load on other pastures must be increased due to rest of 

one pasture, then the probability decreases for the allotment to meet the desired herbaceous 

structure spectrum. Holechek et al (1989) states that heavy stocking rates will not be overcome by 

an otherwise appropriate grazing strategy – which probably applies to all grazing strategies.

Implement twice-over grazing system

Range – Twice-over rotational grazing systems are a variation of deferred rotation grazing (Sedivec 

1992). This system rotates the livestock faster, resulting in more acceptable forage for livestock 

throughout the grazing season (Sedivec 1992). Sedivec (1992) concludes that during the first 

grazing cycle, cool season grasses and sedges are utilized before they become too mature and 

unpalatable. At least three pastures are required in a twice-over rotational grazing system. This 

system allows for an adequate period of rest between rotations within a pasture. One pasture is 

grazed during the critical period in plant development when carbohydrate root reserves are being 

used for spring growth, but the other pastures are allowed the potential for initial growth. This

grazing sequence will alternate from year to year to provide for adequate initial growth in all 

pastures over time (Sedivec 1992).

Authorized Use levels should not be affected by the type of grazing system implemented; just the 

management of the various pastures within an allotment may change. Livestock distribution may 

change depending upon the herbaceous plant community within the pastures. Livestock may focus 

grazing pressure on crested wheatgrass or native cool season grasses the first time through, 

especially in the first pasture, and on native cool or warm season grasses the second time through 

depending upon the season of use.

Botany – Each pasture in this system is grazed twice with a period of rest between the grazing 

periods. Sedivec and Barker (1991) noted apparent improvements in plant vigor and forage 

production with twice-over versus seasonlong grazing that allowed for 40 percent increases in 

stocking rates and improved economic returns on pastures already in good to excellent condition. 

However, Biondini and Manske (1996) found seasonlong versus twice-over grazing resulted in the 

same grazing intensity with no affect on species composition or plant production, but twice-over 

grazing and no grazing resulted in similar carbon and nitrogen flows compared to seasonlong 

grazing, suggesting greater long-term maintenance of range productivity with a twice-over system. 

Contrary to Holechek (1989) that reported uneven forage utilization with seasonlong grazing, 
FEIS Vol. III North Billings County Allotment Management Plan Revision

30 | Appendix D

Biondini and Manske (1996) reported less even utilization with twice-over grazing. However, 

increased stocking levels under the twice-over system due to shorter total grazing periods will result 

in increased livestock density that has the potential to increase the evenness of livestock distribution 

and utilization across a pasture. Thus, the mosaic of grazing intensity and seral stages is likely to be 

reduced under this system. 

Some research has shown that any period of rest is beneficial to plant health, but Holechek et al 

(1989) speculated that benefits of various rotation systems are most likely to occur in humid regions 

with greater precipitation compared to semi-arid regions. Depending on the period of rest, there 

may be little potential for regrowth in the semi-arid NGP, and periods of deferment during low 

growth or non-critical growth periods may provide minimal benefit to the plant resource (Briske et 

al 2008). If regrowth occurs but is grazed during late summer or fall, translocation of carbohydrate 

reserves for storage would be decreased, thereby increasing the difficulty of over-wintering and 

initiation of regrowth the following spring. 

Twice-over grazing systems are unlikely to have a large influence on woody draw conditions 

compared to seasonlong grazing due to the continued potential for repeated browsing and trampling 

under both systems. 

Wildlife – Most literature indicates that rotations in semiarid regions show no definite advantage 

over continuous grazing under similar stocking rates. Sedivec (1994) indicates that in central North 

Dakota that there may be little difference between seasonlong and twice-over grazing systems, even 

though the twice-over was stocked higher than the seasonlong system in his study. Though 

apparently taken, fall VOR readings were not provided in his dissertation. Manske (2000) asserts in 

his report that twice-over increases residual vegetation. On the other hand, Vermeire et al (2008)

found that none of seven investigated treatments effectively altered standing crop. Logically, it also 

seems that time for regrowth would be limited after the second (or third) rotation, thus limiting the 

recovery of a diverse structural condition (Reece et al 2001). Hence, in terms of altering herbaceous 

structure, the twice-over grazing system may require more monitoring and/or research. (See also 

Pieper and Hietschmidt 1988. But see also Salo 2004 and Messmer 1985, 1990).

Incorporate private “off permit” land into rotation

Range –This tool would allow for more flexibility in designing a rotation to meet the goals and 

objectives set for the allotment. This tool would add additional pastures to a rotation allowing for a 

change in season of use and recovery of desired plant communities in multiple pastures in any given 

year. Livestock distribution may change depending upon the herbaceous plant community within 

the pastures. Livestock may focus grazing pressure on crested wheatgrass or native cool season 

grasses on the pastures used early in the season, especially in the first pasture, and on native cool or 

warm season grasses as the season progresses depending upon the season of use. This tool has the 

potential of reducing the amount of time livestock are grazing on NFS lands because there would be 

an additional pasture(s) to run the livestock through within the grazing season.

Botany – Adding pastures to a rotation would result in decreased grazing periods within individual 

pastures, but likely with increased livestock densities corresponding to the increased total level of 
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use. Total forage harvest in individual pastures would remain similar to harvest levels prior to 

adding the additional pasture, but increased livestock density would contribute to an increased 

evenness of distribution and forage utilization, thereby decreasing the potential mosaic of seral 

stages. However, longer periods of non-use within individual pastures would increase the potential 

for regrowth or the completion of critical growth periods that could assist in maintaining or 

increasing plant vigor and facilitating shifts towards late seral stages. 

Wildlife – Adding pastures and reducing time and numbers on NFS lands have the potential to 

provide opportunity for obtaining the desired structure distribution. However, as with all the 

different rotations the effects to structure and wildlife depend on other associated factors such as 

stocking rate, timing, duration of grazing etc.

Fertilize crested wheatgrass areas

Range – In review of literature on fertilization there are many direct and indirect effects along with 

positive and negative results. Holechek et al. (1989) reported that fertilization can be used to 

improve livestock distribution by providing a longer green period of range grasses in parts of a 

pasture with light use, and that nitrogen fertilizer can make unpalatable species attractive to grazing 

animals by increasing their protein content and succulence. Vallentine (1989) reported that 

botanical composition greatly affects the response to fertilizer applications, and that the type of 

fertilizer can also greatly affect the grass to legume ratio in the forage mixture. Vallentine (1989) 

explains that fertilizer applications often fail in drought years when ample moisture supplies are 

required to maximize the benefits of fertilizer whether on irrigated pasture, introduced pasture on 

nonirrigated sites, or native range. On semi-arid sites, response to fertilizer may occur only in above 

average rainfall years (Vallentine 1989). Smoliak and Johnston (1981) suggest that unproductive 

stands of crested wheatgrass can be made more productive through the use of fertilizer, and under 

some conditions triple or even quadruple the yield. They also report initial and residual responses 

of crested wheatgrass to fertilizers are related to both seasonal precipitation and temperature 

(Smoliak and Johnston 1981). Research conducted in North Dakota has shown that fertilizing 

domesticated grasses can be beneficial in increasing production, palatability, and livestock 

distribution on crested wheatgrass, smooth bromegrass, and altai wildrye pastures (Sedivec and 

Manske 1990). Sedivec and Manske (1990) also report that on native rangeland studies, using 

nitrogen fertilizer, have shown that only native cool season graminoid species benefit from 

fertilizing, and that native warm season species of graminoids did not respond as did the cool season 

species. They also conclude that fertilizing consecutive years promotes a cool season graminoid 

response, which causes a direct change in species composition and an unbalanced combination of 

warm and cool season graminoids.

Botany – Productivity of crested wheatgrass stands tend to decline after initial establishment and 

nitrogen fertilizer has been an effective tool for improving forage quality and quantity, increasing 

utilization, livestock distribution, and livestock performance (Bailey 1994, Frank and Reis 1990, 

Holechek et al 1989, 2001, Nyren et al 1983, Lorenz and Rogler 1973, Rogler and Lorenz 1957, 

Smoliak 1981, Vallentine 1989.). 
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However, some experimental studies have shown mixed results. The positive effects on forage 

production are most apparent during the year of treatment and quickly decrease thereafter (Houston 

1953). The benefits of fertilizer also decrease with decreased precipitation (Houston 1953, Nyren et 

al 1983) and increasing coarseness of soil texture (Sedivec and Manske 1990). Lorenz and Rogler 

(1973) report that phosphorous only contributed to increased production when combined with 

nitrogen, and generally only after three years of annual treatments. Houston (1953) found plant 

production increased most significantly with nitrogen fertilizer when crested wheatgrass stands 

were also harrowed or disked, but these treatments also resulted in large increases of nonpalatable 

weed species for two years following treatment.

The large majority of crested wheatgrass stands on the LMNG contain a mixture of native and 

invasive grasses, and many native plants of the NGP are adapted to low nutrient levels (USNA 

2006), with potentially lower response to fertilizer treatments. However, western wheatgrass 

production has increased on fertilized native rangeland (Rauzi et al 1968, Vallentine 1989) and in 

conjunction with crested wheatgrass on seeded pastures (Frank and Reis 1990, Rogler and Lorenz 

1957, Sedivec and Manske 1990). Nonetheless, Sedivec and Manske (1990) recommended against 

fertilizing pastures with high amounts of native grasses due to adverse effects of nitrogen and 

phosphorous on mycorrhizal fungi to which many native grasses exhibit symbiotic relationships. 

Interruptions of this relationship can lead to decreased native plant productivity after growth effects 

of the fertilizer have ended. Several invasive grasses such as Kentucky bluegrass and annual brome 

are highly responsive to increased nitrogen levels (Belsky and Gelbard 2000), so the combination of 

fertilizing and decreased mycorrhizal activity can add to competitive advantages of invasive grasses 

over native grasses. 

A portion of the low forage production among mixed crested wheatgrass/native pastures can be 

associated with preferential selection of the native component due to low palatability of the crested 

wheatgrass at the time of grazing. Preferential selection of the native component has a high 

potential to result in excessive utilization and low plant vigor and production. At the same time, 

low utilization of crested wheatgrass can contribute to decreased vigor and production (Manske 

1995b). Taken together, low production, relatively early seral stages, and impairment of native 

plant establishment are likely to be maintained under this scenario. 

Wildlife – One of the major findings in Rogler and Lorenz (1969) was that fertilization increased the 

proportion of yield at the end of the grazing season to above the two-inch clipping height. When 

grazing commenced in the spring, approximately 50 percent more forage was available on the 

fertilized than on the unfertilized. Since fertilization has the potential to increase forage, the 

potential exists to contribute to diversifying the herbaceous structure distribution.

Hay or cut-&-leave crested wheatgrass areas

Range – Smoliak and Johnston (1981) concluded that mowing and fall burning are satisfactory 

treatments to remove old growth accumulated from previous years; however, production is not 

affected but consumption increases. This tool would remove decadent crested wheatgrass stands, 

which in return should improve the overall palatability of the stands. Cut-and-leave would provide 
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Appendix D | 33

additional litter material on the ground, and could provide the opportunity for better nutritional 

forage for the livestock if the pasture is not able to be grazed early in the season. Depending on the 

overall plant community composition of the pasture, livestock distribution may change as livestock 

focus use on more palatable herbaceous species. Deferred use, a reduction in Authorized Use, or 

rest may result from utilizing this tool depending on the size of the pasture and/or tool applied until 

the desired conditions are reached.

Botany – Some level of AUM equivalent is accounted for the amount of crested wheatgrass hayed. 

Although cutting and haying of crested wheatgrass do not immediately increase forage production, 

they can be effective in removing old growth stems and increasing vigor and palatability (Smoliak 

1981). However, the fact that these treatments are usually implemented every other year suggests 

that they are not very if at all effective in increasing the use of crested wheatgrass. If treatments 

were effective in promoting efficient use of crested wheatgrass there would be no need to repeat the 

treatment in alternate years. Development of wolfy or stemmy crested wheatgrass is generally the 

result of grazing seasons that are poorly coordinated with the palatability and potential utilization of 

the species.

Haying removes plant material that would have contributed to litter, soil organic matter, and 

nutrient availability. Haying therefore prevents excessive litter accumulation, but most hayed sites 

exhibit high levels of bare ground suggesting that more litter or plant basal area would be beneficial 

for general range health (NRC 1994). Haying obviously reduces the potential for high vegetative 

structure and observations of stands during the year of no haying generally suggest insufficient 

plant density to achieve high structure. Most if not all stands of crested wheatgrass contain varying 

amounts of Kentucky bluegrass, smooth brome, and annual brome, and haying contributes to the 

spread of these species through movement of seed propagules throughout both private and federal 

grasslands, thereby decreasing the maintenance of native plant communities and diversity. 

Cutting and leaving crested wheatgrass maintains litter inputs and may increase rates of 

decomposition and nutrient cycles by placing material on the soil surface with increased bacteria 

and microorganisms. Plant community composition might therefore increase through improved 

nutrient and moisture conditions, but the potential exists for invasive grasses to respond equally or 

greater than native grasses. 

Cutting is conducted after July 15 to protect potential bird nesting habitat. This late or dormant 

season cutting has been shown to reduce vigor and tillering of crested wheatgrass compared to 

spring grazing, with the decrease in plant biomass and basal area potentially facilitating the 

outbreak of grasshopper populations (Manske 1997). Clipping studies reviewed by Pellant and 

Lysne (2005) resulted in sharply decreased seed production of crested wheatgrass when treatments 

were repeated for five years during mid-June and early July, thus supporting Manske’s conclusion 

of decreased vigor when defoliation occurs during mid season. Decreased vigor of crested 

wheatgrass should inadvertently promote the expansion of other grasses, but again, invasive grasses 

have the potential to benefit as well as native grasses. Cutting and leaving crested wheatgrass 

during mid-summer every other year should not have a strong adverse effect on native grasses 

mixed in the community because plants should be between critical growth periods and have the 
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opportunity for regrowth in the fall. However, there is no evidence or research suggesting that 

cutting or haying of crested wheatgrass promotes the re-establishment of native plant communities. 

Wildlife – Because mowing or haying is typically conducted in mid-July, there would be limited 

regrowth time, plus, it homogenizes the structure within a site. However, there is still potential to 

contribute to the structure distribution. Cutting height could be altered to help diversify structure, 

perhaps more on an annual basis than within a single year. Cutting and leaving the residue may be 

helpful as a litter layer for some species. If continuously repeated, this would have to be monitored 

to ensure this doesn’t become excessive for some species. These tools are probably not a significant 

factor at the landscape scale. Crested wheatgrass sites could provide habitat for species such as 

Baird’s sparrow (Dechant et al 1998) and sharp-tailed grouse (Kohn 1976). However, mowing or 

haying would render these sites typically unsuitable for nesting purposes the following year.

Interseed pasture with native grass species

Range – The results from the Goetz and Whitman (1978) and Nyren et al. (1978, 1981) studies 

done on the Dickinson Research & Extension Center show that establishing native grass species by 

interseeding is difficult, and that native grasses established by interseeding produce less herbage 

than the previously intact native plant community (Manske 2005). They concluded from these 

studies that introduced species, such as smooth brome and crested wheatgrass are easier to establish;

however, they do not increase overall production. Interseeded areas would need to be deferred from 

livestock grazing until the desired conditions have been reached (Manske 2005). There would be 

initial implementation costs to the both the permittee and the FS. The permittee would need to find 

other pasture or reduce livestock numbers. In order for the treatment to be successful proper 

stocking levels are required to achieve and maintain the desired conditions of the treatment area.

Botany – Seeding native grasses within relatively poor condition crested wheatgrass or native 

pastures would have the potential to increase pasture productivity, available forage, and shift seral 

stage. In the case of interseeding crested wheatgrass pastures, increased proportions of native 

grasses could increase management flexibility by creating pastures with longer periods of 

appropriate use if stocked according to the proportion of species utilized during the grazing period. 

Although crested wheatgrass would remain in the pasture, greater proportions of native species 

could increase plant diversity, wildlife habitat, general aesthetics, and help shift the community 

towards late seral stages. Introduction of some native species may facilitate the natural 

establishment of other species (Pellant and Lysne 2005). Seeding techniques suitable for site 

conditions, and treatments applied to reduce competition from existing species are often necessary 

to ensure adequate success of plantings (Pellant and Lysne 2005). 

Wildlife – In terms of structure, the effects of this tool are not known. Also, given the cost and time 

required to potentially re-establish a native stand, it is likely prohibitive. Secondly, although (nonnative) crested wheatgrass is prevalent in the Rolling Prairie, this tool would likely occur on a very 

small scale and would not be significant at the landscape scale at this time. Lastly, it may be 

assumed that the goal would be to replace non-native species or clubmoss dominated sites. In the 

case of the non-native crested wheatgrass, there may be a loss of structure if the site was producing, 
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Appendix D | 35

or was capable of producing high structure to begin with, but it may also enhance some structure by 

filling in some of the more open sites within a “thin” stand. Also, reducing the amount of crested 

wheatgrass stands on the landscape may contribute to limiting management options for early season 

grazing, potentially impacting fall herbaceous structure in unknown ways. But the end result is not 

likely to be a significant factor to contributing to the herbaceous structure objective at the landscape 

level. This tool could promote a more diverse herbaceous structure distribution at the allotment 

level.

Scarify clubmoss areas within a pasture

Range – Brewer and Skeen (2005) indicate that clubmoss (Selanginella densa Rydb.) impedes the 

establishment of other plants and if dense enough inhibits plant succession. Brewer and Skeen 

(2005) report that clubmoss is largely unaffected by changes in the timing, intensity, or frequency of 

grazing, however prescribed livestock trampling is an effective tool for small localized infestations, 

and for large infestations chiseling has been the most common method of treatment. Both Crane 

(1990) and Brewer and Skeen (2005) indicate that mechanical treatment will reduce clubmoss. 

Crane (1990) reports that a combination of treatments (chemical, mechanical, interseeding, etc) are 

effective, and over 30 years, researchers concluded that clubmoss did not easily reestablish on 

northern mixed prairie following treatment. Lacey et al (1995) indicates that the implications of 

chiseling and other mechanical treatments is that they can improve forage production in the 

northern Great Plains, and that improvements are most feasible on productive sites where forage 

production is limited by blue grama, clubmoss, and other shallow rooted plants. Brewer and Skeen 

(2005) reported that some landowners and resource managers consider mechanical treatment (i.e. 

chisel plowing) unacceptable due to the amount of soil disturbance. In their study, they used two 

new mechanical treatments (Tar King Plant-O-Vator and Lawson Aerator). Brewer et al. (2007) 

indicated that treating dense clubmoss-infested rangeland with the Lawson Aerotor in the spring 

positioned at 10 degrees reduced dense clubmoss ground cover for three years. The Tar King PlantO-Vator also reduced dense clubmoss ground cover for two years compared with no treatment, but 

soil disturbance was insufficient to increase total herbaceous yield. Brewer et al. (2007) also report 

that treating dense clubmoss-infested rangeland in the fall or with the Lawson Aerator positioned at 

5 degrees was unsuccessful. Colberg and Romo (2003) conclude that range managers in the water 

limited northern Mixed Prairie may want to identify and implement grazing management practices 

that improve water relations, before considering mechanical modification of rangeland to reduce 

clubmoss.

Deferred use, a reduction in Authorized Use, or rest may result from utilizing this tool, depending 

on the size of clubmoss infestation within the pasture, until the desired conditions are reached. 

There would be initial implementation costs to the both the permittee and the FS. In order for the 

treatment to be successful, proper stocking levels are required post-treatment to achieve and 

maintain the desired conditions for the pasture/allotment.

Botany – Dense layers of clubmoss can reduce the productivity of grasses by trapping or 

intercepting precipitation and limiting soil moisture availability. Dense clubmoss layers can also 

inhibit seedling establishment by hindering seed-soil contacts and decreasing available moisture for 
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seedling growth and survival. Thus, scarifying clubmoss can “release” or increase the growth, 

productivity, and reproduction of grasses, thereby facilitating shifts towards late stages. 

However, even relatively light soil disturbances resulting from the scarification of clubmoss has the 

potential to also release or assist the spread of several invasive grasses. This would depend on the 

current presence and amount of such species, including existing seed banks, as well as the potential 

for their spread onto the site. Pasture aerator treatments followed by broadcast seeding in Wyoming 

resulted in increased cover and diversity of several desired species, but large increases in annual 

brome also occurred (Emme and Murray 2007). Clubmoss was not present in measurable amounts, 

but the site was dominated by thread leaf sedge and blue grama that tend to be major components of 

affected sites on the LMNG. 

Wildlife – Much like the previous tool, if successful, it may somewhat enhance structure distribution 

at the pasture scale to an unknown degree. But again, probably not a tool that would be used widely 

on a landscape basis until some testing and monitoring is done to check the resource effects and cost 

effectiveness.

Implement prescribed burns

Range – Burning is the oldest known practice used by humans to manipulate vegetation on grazing 

lands (Vallentine 1989). The effects of this tool would depend on the size of the proposed burn area 

and what the objectives and goals are of the prescribed burn. Temporary fences, a delayed turn out, 

or rest may be necessary due to concerns with not meeting vegetative objectives of the prescribed 

burn. Therefore, a temporary reduction in Authorized Use may occur. Temporary fencing, 

typically, would be an additional expense to the permittee in both installation and maintenance. 

Since forage quality is expected to improve after the prescribed burn, livestock distribution would 

probably change depending upon the size of the prescribed burn compared to the size of the pasture. 

Botany – Fire is a natural ecosystem process of the NGP that helped form or shape native grassland 

communities (Grant and Murphy 2005, Higgins 1984, Sieg 1997, Whisenant and Uresk 1990). 

Native Americans increased the frequency of fires in the region, but Higgins (1984) concluded that 

lightening strikes cause about 25 fire starts per year for every 2.5 million acres in western North 

Dakota. The control of wildfires since the early 1900s has likely had a large impact on the spread 

of woody species that have encroached into grassland habitats (Whisenant and Uresk 1990). 

Accumulations of plant litter resulting from the control of fire may also be assisting the 

establishment and spread of invasive grasses in some areas (Whisenant and Uresk 1990). 

Prescribed burning can control the encroachment of woody shrubs and trees such as Rocky 

Mountain juniper, snowberry, and silver sagebrush, thus helping to maintain native grass 

communities while also increasing herbaceous forage production, carrying capacity, and livestock 

distribution (Dietz 1989, Higgins et al 1989, Vallentine 1989). As multiple use goals include 

maintaining native communities and diversity, it is important to maintain the frequency and 

intensity of natural disturbance processes that helped shape these communities (Sieg 1997). 

Prescribed burning can be conducted in grassland habitats to increase plant vigor and production 

that can improve livestock distribution and utilization (Holechek 1989, Vallentine 1989). Although 
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Appendix D | 37

plant litter can improve soil moisture and nutrient availability, excessive amounts of litter can 

decrease soil temperatures with resulting decreases in bacteria activity that slow the rate of nutrient 

cycling and availability. Burning can result in a flush of released nutrients that increases forage 

production, nutrient content, and palatability that attracts grazing animals, thereby facilitating a 

shifting mosaic of grazing pressure. Prescribed burning may provide an economical means of 

invigorating stagnant crested wheatgrass stands or native grass communities persisting in relatively 

early seral stages or adversely affected by clubmoss. Increases in forb diversity and density often 

occur after burning. 

Prescribed burning in conjunction with a prescribed grazing system has the potential for controlling 

several invasive grass species (Higgins et al 1989, NRCS 2009, Smith 2010, Vallentine 1989). 

However, intensive planning in regards to the timing of burning and grazing in relation to plant 

physiology and affects on environmental conditions are needed to achieve success. Poorly timed or 

infrequent burning can increase rather than decrease Kentucky bluegrass (Smith 2010), and the 

potential exists for the unplanned spread of several other undesirable species after burning 

(Vallentine 1989). Although noxious weed increases would be controlled under current weed 

management on the LMNG, invasive grasses are not controlled and potential spreading of these 

species after fire would remain unchecked. Documented success of burning to control Kentucky 

bluegrass in the NGP has generally been lacking (Uchytil 1993, Higgins et al 1989), but recent 

reports of frequent fall burning conducted with spring livestock grazing are encouraging (NRCS 

2009, Smith 2010). Fire often assists the spread of annual brome, and the best that can generally be 

expected from infrequent burning for the control of this species is a one to two year reduction in 

brome density (Uresk 1990, Vallentine 1989). 

Prescribed burning has the potential to facilitate improved woody draw conditions by triggering 

basal sprouting among mature or decadent trees and shrubs (Fitzpatrick 2003, Vallentine 1989, 

Zimmerman 1981, Sieg 1997). Fire can also improve seedbed conditions for the germination of 

woody species, disrupt disease and parasite cycles, and increase nutrient cycling or availability that 

can facilitate a flush of new growth (Sieg 1997). Potential negative effects of fire on woody draws 

can include high mortality of trees and shrubs that are not appreciably compensated by basal 

sprouting or increased recruitment from seedlings (Lesica 2001b). Rocky Mountain juniper does 

not resprout after burning, and its competitive effects with desired deciduous species can therefore 

be reduced. 

Wildlife – Baird’s sparrow was found more frequently in areas that were burned four times in 15 

years compared to areas that were burned twice in 15 years (Madden et al 2000). However, this 

study was accomplished in an area (Lostwood National Wildlife Refuge, North Dakota) where there 

was no or little grazing pressure. But prescribed fire can also be used in conjunction with grazing to 

increase heterogeneity (Fuhlendorf et al 2009). This essay presented data from an experiment to 

somewhat mimic the natural disturbance regime in a tall grass system in Kansas, and thus, create 

the heterogeneous vegetative conditions, via the disturbance regime, as suggested in USDA (2000) 

and contribute to the “shifting mosaic” desired condition statement. 

Using prescribed fire to alter the landscape composition where junipers now dominate would be 

beneficial to bighorn sheep, deer, and native species diversity in general, since the fire return 
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interval in these areas has been interrupted significantly (Higgins et al 1989 and USDA 2000). 

Using fire to control silver sage does not kill this shrub as it is fire adapted and will regenerate 

readily (Howard 2002). More than one treatment is recommended. But on the other hand, 

prescribed fire needs to be carefully planned to avoid significant impacts to butterfly species (e.g. 

Dakota skipper; USFWS 2007).

Prescribed fire can be used in conjunction with livestock grazing to diversify the herbaceous 

structure distribution and change composition (Fuhlendorf et al 2009).

Mechanical brush management

Range – Effects of this tool will be dependent on the size of the treatment area. If the treatment area 

is kept to a small scale, Authorized Use would not have to be adjusted. If the treatment is large, 

however, there would be a need to adjust Authorized Use to assure goals and objectives will be met. 

A deferred turn out or rest may be required for the pasture. Livestock distribution should change as 

the plant community composition changes from a shrub dominated to a grass dominated plant 

community. 

Botany – Brush management such as mowing dense stands of silver sagebrush can increase 

herbaceous production and desirable forage. This practice can improve the condition or health of 

exceptionally dense silver sagebrush communities because they tend to exhibit high amounts of bare 

ground. Results of mechanical treatment can be preferable to prescribed burning because some of 

the brush and associated structure survives treatment and can continue contributing habitat and 

diversity for wildlife species. Mechanical treatments can be preferable to herbicide because the 

latter will generally result in non-selective control of several desirable species. 

However, some silver sagebrush communities proposed for control contain high amounts of annual 

brome or invasive bluegrass that is likely to be a principle species released from shrub competition 

(Vallentine 1989). Combining low applications of Plateau herbicide with the brush control 

treatments could provide control of annual brome (BASF 2001, Washington 2007). 

Mechanical brush treatment might also include cutting of Rocky Mountain juniper with machinerymounted equipment rather than burning. Cutting juniper would result in the competitive release of 

understory vegetation with benefits of increased forage production and plant composition depending 

on existing plant species. Livestock would be attracted to the increased herbaceous growth with the 

potential of changing livestock distribution from current areas of primary use. Increased forage 

production while maintaining constant stocking levels would decrease the level of utilization and 

assist in maintaining or slightly increasing herbaceous seral stages. Any invasive grasses present in 

the treatment area would also have the potential to increase and greater soil disturbances relative to 

prescribed burning might assist the spread or increase of invasive grasses. 

Wildlife – Reducing the amount of a woody vegetative community in favor of a more herbaceous 

community could change the habitat potential for a different suite of wildlife species. However, the 

effectiveness of mechanical treatment would likely leave just a less dense shrub community rather 

than a complete or nearly complete habitat change in the long-term. Mechanical control of silver 

sage via plowing, disking, and chaining is not recommended due to the promotion of sprouting 
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Appendix D | 39

(Howard 2002). However, intensive plowing may be partially effective. It would have an adverse 

affect on the sage grouse if accomplished in big sage stands (Nolte et al 1994, Allegretti et al 1997) 

within the range of sage grouse. 

Depending on the density of the pre-treatment stand, there may be a loss of structure, but a more 

diverse herbaceous structure distribution. The value for certain wildlife species such as Baird’s 

sparrow may be limited unless brush (e.g. silver sage brush) is very limited after treatment. 

Antelope habitat could also be reduced due to the loss of a forage species. But a landscape context 

is needed for assessment.

Incorporate a range rider to disperse livestock throughout a pasture 

(herding)

Range – Although herding has been used to manipulate livestock grazing distribution for centuries, 

its use on rangeland cattle operations has been limited (Bailey 2004). Herding requires additional 

labor and cost, and its effectiveness has been questioned according to Bailey (2004). Bailey (2004) 

states that some producers believe that herding cattle away from riparian areas is futile, because 

animals often return to streams shortly after being moved. Bailey (2004) also reports that others 

suggest that regular herding is a very effective practice to protect riparian areas (Skovlin, 1957;

Butler, 2000). Butler (2000) summarized that intensive cattle herding is an important tool that can 

be employed in the proper management of riparian zones which are a highly sensitive and 

vulnerable rangeland community. Butler (2000) also states, however, that it is not the cure-all for 

poor management, and it does not absolve us when we ignore the need to develop structural 

rangeland improvements such as fences and water developments. However, it may be one of the 

most effective complementary tools available to us in managing the rangelands of North America. 

Livestock distribution would be changed as the herding focuses livestock grazing based on 

identified objectives for the allotment. Herding would increase the management costs of the 

permittee and the level of management for the allotment.

Botany – Active herding can increase livestock distribution and decrease over utilization of primary 

grazing areas or sensitive woody draw and riparian habitat (Butler 2000, Holechek et al 1989, 

Skovlin 1957). Herding is most effective in large pastures with significant portions of secondary 

range that livestock tend to underutilize because decreasing pasture sizes tend to result in relatively 

even livestock distribution. Early seral stages likely to occur in habitual high use areas may have 

the potential to shift towards late seral stages, but late seral stages likely to occur in secondary range 

would have the potential to shift towards early stages. Thus, as with all tools increasing the 

evenness of distribution and utilization, plant composition and seral stage would have the potential 

to increase in uniformity in contrast to desired conditions of maintaining a mosaic of grazing 

patterns and associated seral stages and structure. However, this could be avoided by herding in a 

manner that ensures various intensities of grazing across the landscape. 

Wildlife – The effects of herding depends on the landscape context and management goals; 

however, under the traditional range management paradigm this would tend to encourage a more 

even utilization pattern at a landscape scale (Holechek et al 1989). Plus, the description of the tool 
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states “to disperse livestock throughout entire pasture” strongly implies distributing across the entire 

pasture. However, it is feasible this tool could potentially be used to achieve structural 

heterogeneity under guidelines to herders to manage livestock use levels in certain areas. Kauffman 

and Krueger (1984) state that herding livestock has been successful in mitigating impacts to stream 

bottoms and improving use on uplands. By extrapolation, then, herding can be useful in helping 

achieve resource objectives if those objectives are spelled out.

Manage salt and supplement locations

Range – After fencing, water and salt are two of the most frequently used tools for affecting cattle 

distribution (Ganskopp 2001). Research studies and technical references have suggested that 

mineral and salt along with protein supplements do attract livestock to areas and can have an affect

on forage intake in the areas they are placed (Bailey 2004 and Wyman 2006). Other reports, 

however, show that salt alone does not improve distribution (Ganskopp 2001 and Ganskopp 2004). 

Holechek et al. (1989) explains that certain principles can be useful in the placement of supplements 

on rangelands. They also explain that livestock usually go from water to grazing and then to salt; 

thus it is not necessary to place salt at watering points. By placing salt away from water, livestock 

can be enticed to use areas otherwise avoided. Wyman (2006) reports that protein supplements 

containing products such as cottonseed or soybean meal can increase consumption of cured, lowquality grasses and are especially attractive to livestock as forage matures and becomes dormant. 

This management tool is not a solve-all in attracting livestock away from woody draws, riparian 

areas, sensitive areas, or to minimize concentration of livestock on uplands. In combination with 

other range management tools, such as fencing and water developments, it would aid in drawing 

livestock away from such areas. By rotating the placement of such supplements, one can assure that 

over use of the placement areas doesn’t occur, and minimizes/avoids disrupting proper soils 

stability, hydrologic function, and biotic integrity. Logically, this is a sound management practice, 

however, it will require monitoring, increased management by the permittee, and may require 

additional cost to the permittee. Within the FS Handbook and the annual Allotment Worksheet, it is 

stated that supplemental feeds are required to be at least one quarter of a mile away from water 

developments. Livestock distribution would change as the salt and supplements are moved and 

rotated to varying areas within a pasture.

Botany – Moving salt and mineral supplement is effective in influencing livestock distribution and 

utilization and alleviating excessive use in primary grazing areas (Dietz 1989, Holechek 1989, 

Skovlin 1957), thereby helping to maintain or achieve desired seral stages in localized areas. 

Livestock generally move from watering to grazing to salt (Holechek et al 1989), with four to eight 

hours elapsing between salting and watering (Dietz 1989). Thus, placing salt near water 

unnecessarily intensifies use near the water source and is likely to contribute in excessive impacts 

whether located in upland grass communities, woody draws, or riparian habitats. 

Wildlife – The effects could depend on the landscape and grazing management context and 

emphasis, but under the traditional range management paradigms it would likely encourage a more 

homogenous utilization pattern (Holechek et al 1989). However, it could also be used as a tool to 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 41

achieve improved herbaceous structure heterogeneity with guidelines in the placement and duration 

of supplement locations designed to enhance diversity in use levels.

Construct fence to create riparian unit – allow grazing under riparian 

grazing dates

Range – Since the allowable days of grazing are typically limited, the remaining Authorized Use 

will have to be planned for in the other pastures or adjusted accordingly. There will be initial 

construction costs associated with fencing the riparian pasture and maintenance costs. Livestock 

distribution would be focused within the riparian pasture, but use will be limited. See also 

“Implement BMPs for riparian pastures” tool.

Botany – Constructing riparian pastures that are often grazed with compressed and deferred grazing 

seasons can assist the development and condition of riparian habitat including both herbaceous and 

woody vegetation by decreasing livestock browsing and trampling disturbances. Fencing of 

riparian areas facilitates the implementation of distinct grazing levels and seasons of use compared 

to the larger surrounding area in order to improve conditions of the riparian habitat that are more 

sensitive to grazing disturbances than upland grass communities. Woody draw communities are 

often situated along the perimeter of riparian habitat and could be similarly improved if included 

within the fenced pasture. However, many riparian areas contain invasive grasses that can increase 

in extent or dominance as a result of increasing plant litter that occurs with reduced grazing levels 

that are often implemented in riparian areas to help achieve desired conditions. Dense sod layers

associated with invasive bluegrass and smooth brome can impede the regeneration of woody species 

through direct competition and decreased availability of suitable seed germination sites. 

Wildlife – Depending on several factors, there may be an increase in the amount of high structure 

within the riparian unit, however it may not necessarily be where the wildlife habitat issues reside, 

which is primarily associated with upland vegetation for upland ground nesting species. Since 

riparian areas may contain more stands of woody species, adjacency to this habitat may not be 

preferred by some ground nesting bird species. However, riparian areas may provide important 

brooding and wintering habitat for sharp-tailed grouse. 

Riparian corridors may function as predator lanes which may tend to make these areas an ecological 

risk for some wildlife species (Manzer and Hannon 2005). The management strategy, geographic 

location, scale, and shape of the riparian pasture may dictate which wildlife species are adversely

affected and those that benefit from the riparian unit.

From other discussions, if there “must” be an increase in the grazing load on other pastures with the 

implementation of rest and/or deferred grazing systems, then utilizing this tool with the idea of

implementing grazing under “riparian grazing dates” may result in a similar management scenario 

where the riparian grazing dates results in a deferred or rest situation, thus increasing pressure on 

other pastures. Under this assumption, then, there may be a decrease overall in standing crop, or 

herbaceous structural diversity on the other pastures.
FEIS Vol. III North Billings County Allotment Management Plan Revision

42 | Appendix D

However, riparian areas are extremely important for many wildlife species such as big game, 

reptiles, amphibians, fish, and riparian bird species. If management improves riparian conditions,

then it follows that habitat for some wildlife species would likely improve within this zone, if not 

the herbaceous structure distribution.

Soils/Hydrology – Riparian pastures provide greater control of animal distribution by limiting the 

length of season and determining the season of use of riparian areas. If all other factors were equal, 

the best time to graze the riparian pastures would be late (after September 1st) or dormant (October 

15th to December 31st) seasons after riparian plants have completed their life cycle, set seeds, and/or 

propagated asexually through rhizomes, etc. Soil moisture typically is lower in the fall, so the 

damage from soil compaction is lower than during spring. The hot season (June 15th to August 15th) 

should be avoided because livestock tend to loaf near or in water during this season. Livestock 

spend a disproportionate amount of time in riparian areas, especially in the hot season, because they 

can easily access all their needs, particularly shade, water, and palatable forage. Damage to riparian 

areas can be severe when animals loaf for extended periods in the riparian area (Wyman et. al., 

2006).

Riparian pastures should improve riparian conditions locally. Other riparian exclosures throughout 

the DPG (including Ash Coulee) have proven highly successful in a matter of a few years, provided 

suitable weather conditions exist to promote recovery of riparian vegetation. 

Implement BMPs for riparian pastures

Range – In review of the Best Management Practices for Grazing (Montana Department of Natural 

Resources and Conservation 1999) publication, it describes several management options to improve 

the health of the riparian areas which should be considered, and that no single grazing schedule can 

be applied to all situations, and the grazing rotation should be adjusted to the management of 

objectives and resource concerns. In development of a rotation for an individual allotment with a 

identified riparian concern one may adjust the season of use to match the riparian plant community,

for example, herbaceous plant communities (sedges, rushes, etc,) versus woody plant communities 

(willows, cottonwoods, etc.). Prescribed grazing for these individual plant communities are 

different. For example, Montana Department of Natural Resources and Conservation (1999) 

recommends that when managing for a woody plant community along a riparian area, one should 

avoid hot summer use. Some of the management tools listed in this publication also are listed 

within this tool box include herding, placement of salt and supplemental feed, providing off-stream 

water sources, placement of natural materials on stream banks to limit access and number of 

crossings, and hardened stream crossings. A key in reaching the management objectives is 

monitoring, and critical monitoring points is choosing utilization standards.

The Montana Department of Natural Resources and Conservation (1999) list seven items to 

consider in development of best management practices of grazing management in riparian areas, as 

follows: 1) Tailor the grazing approach to the specific riparian area under consideration, 2) 

Incorporate management of riparian areas into the overall management plan for the whole 

operation, 3) Select a season or seasons of use so grazing occurs, as often as possible, during 
FEIS Vol. III North Billings County Allotment Management Plan Revision 

Appendix D | 43

periods compatible with animal behavior and conditions of the riparian area, 4) Control the 

distribution of livestock within the targeted pasture, 5) Ensure adequate residual vegetative cover, 6) 

Provide adequate regrowth time and rest for plants, and 7) Be prepared to play an active role in 

managing riparian areas. 

Depending on the number and size of pastures within the allotment, Authorized Use may need to be 

adjusted. Livestock distribution would be expected to change simply due to the focus of limited use 

within the riparian units, but the other pastures may not see any change. 

Botany – BMPs are implemented in riparian areas to improve the function and condition of these 

habitats. In many cases, woody draw species occur along the perimeter of riparian habitat and 

experience similar potentials for improvement. BMPs and expected effects are discussed in the 

Hydrology Report. 

Restore/enhance riparian vegetation i.e. willow planting 

Range – Restoring and enhancing riparian vegetation (example willow planting) would require 

designing a rotation (such as spring versus fall grazing) that fits the goals and objectives set forth 

for that segment of riparian area without creating other resource issues within the pasture or 

allotment. If the goal is to improve willow density, the grazing rotation should be designed to avoid 

hot summer use (Montana Department of Natural Resource and Conservation 1999) and according 

to Montana State University the season of use that would be advantageous for woody species in the 

riparian area would be spring use. There are, however, disadvantages to early season grazing on 

other native plant communities within the pasture. Monitoring and other management tools should 

be implemented, such as salt and mineral placement and proper stocking levels 

(http://www.animalrangeextension.montana.edu/riparianmgt/grazriparian/pg1-intro.htm). 

Deferment of the riparian area may be required to allow planted willows to get established. 

Authorized Use may be temporarily adjusted, as well, to allow for willow establishment. 

Botany – Important research has shown that riparian vegetation will naturally re-establish as a result 

of significant shifts in the grazing period from mid and late summer to spring or early summer 

(Elmore 1989). Thus, practices of fencing to create riparian pastures and implement distinct 

grazing periods and levels of use should be sufficient to promote and maintain increased 

establishment of woody species, without unknown effects and additional costs associated with 

introducing plant stock with uncertain origins and genetic compatibility. Poor success of naturally 

establishing woody species can be indicative of improper management and the need for additional 

grazing adjustments or strategies. Naturally establishing woody species are synchronized with 

hydrologic conditions of the affected site and are therefore likely to exhibit higher survival rates 

than planted stock that usually involve an excess number of plantings to compensate for low rates of 

expected survival. Thus, there may be a low return on limited finances associated with planting. 

However, the lack of local seed sources for woody species recruitment may necessitate planting. 

Soils/Hydrology – Willows along with other woody species are a component of many riparian areas 

on the LMNG. They hold stream banks together, shade the stream thereby reducing water 

temperatures, provide woody recruitment to streams, and many other functions. Planting or 
FEIS Vol. III North Billings County Allotment Management Plan Revision

44 | Appendix D

restoring the health of existing willows in riparian zones is an important step in maintaining or 

improving the health of streams and riparian areas. 

Construct/harden stream crossings

Range – Montana State University Grazing management for stream and riparian area management 

indicated that there is evidence that livestock prefer stable footing and clean water and will travel a 

considerable distance to reach them

(http://www.animalrangeextension.montana.edu/riparianmgt/grazriparian/pg1-intro.htm). Livestock 

distribution would be altered since the livestock will utilize these areas more readily as a water 

source. There would be initial costs of installing the stream crossing(s) and maintenance costs to 

keep the crossing hardened over time. This tool by itself is not a solve-all for every allotment, other 

management tools and monitoring should be in place. As stated in a video provide by Montana 

State University on grazing management for stream and riparian area management, this tool may 

work for one allotment, however, it might not work in another allotment.

Botany – This is essentially a BMP for riparian systems that can help reduce bank erosion, 

trampling, and high sediment loads. Some benefit may accrue to adjacent woody communities if 

livestock trailing becomes more concentrated along specific areas rather than dispersed along 

extensive stream segments. 

Soils/Hydrology – This BMP serves to limit the effects of livestock use on streams. Construction of 

stream crossings and/or hardening existing crossing areas by design minimizes livestock impacts 

such as degradation of stream banks and sedimentation, associated with crossings and use of a 

stream for watering. 

Construct water gap to limit livestock access on stream

Range – See discussion above for “Construct/harden stream crossings” tool.

Botany – This is also a BMP for riparian systems that limits erosion and trampling impacts along 

stream banks that can assist the development and maintenance of woody species through decreased

browsing and trampling disturbances. 

Soils/Hydrology – This is another BMP whose effects are similar to the previous discussion on 

construction or hardening of stream crossings. Limiting access reduces livestock impacts to selected 

areas along a stream. Hardening the water gaps provides additional mitigation which further reduces 

livestock impacts to the stream. 

Construct fence to exclude livestock from areas of concern (riparian, 

wooded draws, springs, wetlands, etc)

Range – Authorized Use would need to be adjusted if the size of the exclosure is large enough that 

it has removed a considerable amount of forage from livestock access. Livestock distribution may 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 45

change depending upon the size of the exclosure and the surrounding topography. See also 

“Implement BMPs for riparian pastures” tool.

Botany – Constructing fence exclosures around woody draws would remove browsing and 

trampling effects of livestock grazing with the potential for increased reproduction of tree and shrub 

species. Thus, fencing may provide a viable means of increasing woody draw conditions if grazing 

periods cannot be appropriately timed or decreased in length to achieve these goals. However, 

Kentucky bluegrass and lesser amounts of smooth brome are well established in the understory of 

most woody draws and have the potential to continue increasing as a result of increased plant litter 

with the removal of livestock grazing. Boldt et al (1978) measured increases in invasive grasses 

within fenced exclosures. Irby et al (2000) measured gradual increases of invasive grasses with and 

without light grazing by native wildlife. Dense sod and litter layers could increase the difficulty of 

successful seedling establishment, and affected woody draws may begin to stagnate without 

grazing, fire, or erosion disturbances that expose mineral soil where seedlings are more apt to 

successfully establish (Lesica 2009, Sieg 1997, personal observations). If monitoring reveals such 

an outcome, possible solutions may involve prescribed burning, herbicide treatments, or periodic 

livestock grazing to reduce plant litter and increase the amount of bare soil conditions. 

Fencing of various wetland sites would also remove livestock disturbances and help achieve 

Grasslands Plan objectives for restoring or maintaining these habitats in high ecologic condition. 

The perimeter of springs and wetlands may be or become invaded by smooth brome and Kentucky 

bluegrass, but these species, and Kentucky bluegrass in particular (Sedivec 2006), are not well 

adapted to moderately long intervals of flooding and are less able to establish or spread beyond the 

perimeter of wetland habitats. Wetlands containing high amounts of invasive grass species around 

their perimeters would be less likely to be chosen for fencing due to relatively low ecologic 

conditions. Fencing of developed springs in conjunction with relocating the water tank a short 

distance away could help protect the water collection system and decrease periodic maintenance 

disturbances. A small portion of riparian and woody draw communities would be enhanced if 

included within the fence exclosure, but more extensive adjacent communities would continue to be 

used in accordance with general pasture management unless also fenced. 

Wildlife – Effects to wildlife should be similar to constructing riparian unit above. Most of these 

areas would likely be very small and of minor, if any use to upland nesting species. However, there 

would be potential value for some species that may require typically more complex woody draw or 

riparian habitat conditions.

Soils/Hydrology – Riparian exclosures are recommended for reaches that have a riparian 

functionality rating of FAR-D or NF. Exclosures are recommended where riparian vegetation has 

been overgrazed or trampled by livestock trailing and is currently insufficient to protect banks and 

channels from erosion. Livestock should be excluded until (1) desired riparian cover reaches at 

least 60 percent canopy cover along intermittent reaches; and (2) the geomorphology of the channel 

should show evidence that incision has ceased and channel aggradation has commenced. 

Preferably, prescribed grazing would occur only as an adaptive action once initial objectives have 

been satisfied. The recovery of the riparian area should be prioritized over the condition of upland 

vegetation within riparian exclosures. Monitoring of upland conditions should include assessment 
FEIS Vol. III North Billings County Allotment Management Plan Revision

46 | Appendix D

of accumulation of litter, shifts in plant composition toward invasive grasses (e.g., Kentucky 

bluegrass and smooth brome), or invasion of woody shrubs (e.g., silver sagebrush, rabbitbrush, and 

rose). 

Move winter feeding areas off of National Forest System lands

Range – Currently, on the Medora Ranger District winter feeding and winter grazing is allowed on 

allotments that are issued a grazing association inventory permit. In review of the Medora Grazing 

Association grazing agreement any NFS lands under control of the association may be selected for 

winter grazing by the board of directors with the concurrence of the FS (Grazing Agreement and 

Rules of Management Between Medora Grazing Association and USDA Forest Service 2009). In 

order for this tool to be implemented, a review and possible modification to the grazing agreement 

will need to be made to address the difference in winter grazing versus winter feeding. 

In further review of the application of this tool within the project area, there are years when there 

are open winters and livestock have the opportunity to graze. Due to the nutritional quality of the 

forage being grazed by livestock supplemental feeds are typically used. The source of this 

supplemental feed varies among ranching operations. Since this is a standard practice in southwest 

North Dakota and there were unknowns about the ecological effects of winter grazing, NDSU and 

Hettinger Research and Extension Center initiated a research trial in 2000 to try and answer the 

unknowns. Preliminary results show that from an ecological and land use efficiency perspective 

dormant season grazing that incorporates moderate early summer use combined with winter 

stocking rates utilizing 50 percent of the standing plant biomass was the preferable grazing 

management option (Nelson et al 2006). They also report that this method yielded greater herbage 

production than the other treatments used in the study. Montana Department of Natural Resources 

and Conservation 1999) stresses six areas individuals should be aware of for dormant season 

grazing, as follows: 1) It’s important to maintain ground cover to decrease the amount of soil 

exposed to wind and water erosion. 2) The crown of the plant must remain intact due to the growing 

points and if removed the vigor for spring growth is gone. 3) The amount of plant height and cover 

needed to trap snow and retain moisture. 4) Periods of warm weather may break true dormancy and 

grazing must be managed accordingly. 5) Target grazing use levels which do not exceed 65 percent 

use of current year’s growth and protect deciduous trees and shrubs by limiting access when woody 

species have green leaves at the beginning or end of the dormant period. 6) Place feed and mineral 

sites as far as possible from riparian areas or water courses.

Botany – Most hay is comprised of crested wheatgrass and patches of this species in hay feeding 

sites on unbroken land suggest that hay feeding is contributing to the spread of invasive grasses. 

More aggressive invasive species of sweet clover, smooth brome, Kentucky bluegrass, and annual 

brome have been observed or are likely to be included in hay as these species spread throughout 

hayed land in the project area. High livestock densities in hay feeding areas can result in high levels 

of trampling disturbance that are often compounded by moist soil conditions during the winter and 

spring feeding months. Livestock are observed grazing on rangeland within and around hay feeding 

areas during relatively open winters and can contribute to unplanned or excessive utilization as well 
FEIS Vol. III North Billings County Allotment Management Plan Revision

Appendix D | 47

as premature grazing of native grasses. These factors can contribute to decreased plant vigor of 

native grasses and assist the establishment and spread of invasive grasses. 

Winter grazing does not result in benign effects to the plant community and the potential for 

excessive utilization can equal that of summer grazing (Cook and Child 1971, Peck 1994). 

Insufficient leaf and stem area in the spring increases the dependence on carbohydrate reserves to 

initiate growth, but the loss of plant tissue to winter grazing can impede the ability of plants to 

initiate spring growth and can contribute to decreased vigor and production and increase the 

susceptibility to invasive grass establishment (Frank 1993, Manske 1999). Most hay feeding 

pastures in the project area are not solely used for this practice, so seasonal use combined with 

winter use increases the potential for excessive utilization and decreased plant vigor. Although 

browsing within woody draws is often decreased or concentrated within a few draws during winter 

hay feeding, livestock often seek the shelter of draws for protection from winter wind and 

contribute to high trampling disturbances and decreased conditions. High manure accumulations in 

the draws appear to promote several barnyard weeds such as kochia, pigweed, and ragweed. 

Moving hay feeding off of NFS lands would decrease a vector of invasive grass introductions,

would reduce the spreading and dispersal of invasive grasses due to high stocking densities 

associated with hay feeding sites, and would help improve or maintain plant production and 

composition. 

Wildlife – The physical location of the feeding area is important. If moved to private land but the 

new location is close to the former location, little if anything may be accomplished in regards to 

herbaceous structure. And vice versa, if movement of the feeding area is significant, effects may be 

more pronounced to the structure distribution. 

Due to vegetative compaction and/or consumption from winter use, fall herbaceous structure may 

not be available in the following spring nesting period in the surrounding area, including adjacent 

NFS lands.

Utilize biological controls for noxious weed control in woody draws

Range – See DPG Noxious Weed FEIS and implementation of control measures.

Botany – The primary biological agent of proven consistent efficiency for noxious weeds in the 

project area involves flea beetles (Aphthona spp.) for the control of leafy spurge. Biological 

controls would alleviate collateral impacts from herbicide treatments to desired woody and 

herbaceous species while often achieving equivalent levels of weed control. However, the 

successful establishment of flea beetle populations can be reduced in woody draws due to a high 

degree of shading, high amounts of herbaceous growth and plant litter, and low amounts of bare 

ground. Effective biologic controls do not exist for other noxious weeds on the LMNG. 

Wildlife – Given the typically limited extent of woody draws in many areas and the overall 

contribution of forage within these areas, it is unlikely that control of weeds in woody draws would 

have a significant contribution to upland herbaceous structure. However, woody draws are still 

important to livestock for cover and the limited forage. And, woody draws are important to many 

other species of wildlife. Hence, maintaining the health and vigor of woody draws would be 
 FEIS Vol. III North Billings County Allotment Management Plan Revision 

48 | Appendix D

important for some ground nesting species, such as sharp-tailed grouse that may use woody draws 

for food and cover from the fall through winter months. Though leafy spurge is generally found in 

more mesic sites such as draws, it can also be found in some upland sites. Controlling spurge within 

woodlands could spill over to upland habitat. Control of noxious weeds and invasive plants could 

improve the potential to provide improved levels of ecosystem services than in an invaded state.
Response to Comments for the

Draft Environmental Impact Statement

North Billings County Allotment

Management Plan Revisions

Appendix E

North Billings County Allotment Management Plan Revisions

RANDALL MOSSER

A-1 “The private and fed lands shown on the Headquarters allotment maps for allt. 135 and 

turn-in permit 256 is wrong. There is several hundred acres that were called (null) on old 

maps was not included. Also some fed. land that was intermingled with private land on 

headquarters was not included”. 

The map for Allotment 135 has been updated to include private and National Forest 

System (NFS) lands if they are listed on the current land record for the permit.

A-2 “Mikes Creek only run water when it rains and is not a year around stream that supports 

aquatic veg.” --

It is correct that Mikes Creek is an intermittent stream. The reduced flow period of 

Mikes Creek is one of the factors contributing to the Non-functional status of the 

stream as identified in the SDEIS, Chapter 3 Part 2: 

• The hydrologic connection between the stream and water table (or any alluvial

aquifer) has been lost due to channel incision. 

• Upland hydrology has been altered by overgrazing, which in turn affects

channel hydrology and the seasonal duration of stream flow. 

• Overgrazing has led to poor conservation of rangeland moisture with excessive

runoff and flashy stream-discharge events.

The most relevant Grasslands Plan objectives and guidelines that specifically 

require actions to address degraded riparian conditions, such as those that exist 

along Mikes Creek (see also, USDA Forest Service, 2001, pp.1-2, 1-11) are:

• Move at least 80 percent of riparian areas and woody draws toward selfperpetuating plant and water communities that have desired diversity and 

density of understory and overstory vegetation within site capability. Objective 

• For streams identified as "non-functional" or "functional at risk with a

downward trend,” begin corrective action within 3 years of stream inventories. 

Guideline

A-3 “A lot of the management problems associated with allotment 135 can be attributed to no 

new improvements until this plan was completed. Years have gone by when all attempts 

at range management were stymied because of lack of improvements”. 

The comment acknowledges that range management problems exist within this 

allotment, and that there is a need for action to correct those concerns. This analysis 

proposes a series of different alternatives (see SDEIS, Chapter 2 and Chapter 3 Part 

2) to address range concerns on this and other allotments in the project area.

Response to Comments | 1
North Billings County Allotment Management Plan Revisions

SIERRA CLUB

B-1 “Regarding monitoring, annual VOR readings should be taken for all allotments and 

clipping should be done every three years to help determine utilization, species 

composition, and trend”. 

The SDEIS Chapter 3 Part 2 provides detailed information regarding each 

allotment including the monitoring frequency for each allotment as identified by the 

interdisciplinary team (IDT). The team determined that annual visual obstruction 

readings (VOR) readings were not required for all allotments because some were 

meeting structure objectives. The monitoring plans do not preclude conducting 

monitoring on a more frequent basis, if it is felt the current frequencies are not 

adequate on an allotment. Also, in the third table for each allotment in Chapter 3 

Part 2 of the SDEIS, a monitoring plan is described.

In 2007, a cooperative monitoring effort between the Medora Grazing Association 

(MGA), North Dakota State University (NDSU), and the Forest Service was 

initiated, and data collection began in 2008. This cooperative effort includes 

gathering species composition, forage production, VOR, and the 17 Indicators of 

Rangeland Health in upland sites, and species composition, forage production, 

VOR, and tree/shrub data in green ash woody draw sites. This effort will collect 

data representing each individual allotment beginning in northern Billings County, 

and eventually throughout the MGA. 

NORTH DAKOTA STATE LAND DEPARTMENT

C-1 “Therefore, significant reduction of grazing levels on Forest Service lands may cause a 

reduction in grazing levels on co-mingled school trust lands”. 

Only Alternatives 1 and 4 would result in initial reductions in Federal Authorized 

Use. If the State Land Department believes that the Authorized Use for National 

Forest System (NFS) lands will influence stocking on state lands, the department has 

the option to fence its lands separately from NFS lands and maintain current 

grazing levels. 

C-2 “However, we do not recognize any authority of the Forest Service to assert stocking 

rates on school trust lands. Stocking rates on school trust lands are a matter of leasehold 

rights between the State of North Dakota and our lessees”.

The Forest Service only authorizes use for the NFS lands within each individual 

allotment. These authorizations are not stocking rates, but are initial use values 

that through adaptive management may fluctuate up or down depending on 

monitoring results. The Forest Service through the SDEIS has not proposed a 

change of the associated animal months for State lands within each individual 

allotment under any of the alternatives in the SDEIS. These values can be found in 

the Land Record table on the grazing association grazing permit. 

2 | Response to Comments
North Billings County Allotment Management Plan Revisions

C-3 “The Record of Decision for the Dakota Prairie Grasslands dated July 2002 on page 27 

estimates a reduction of 8.3%. Our estimate was that stocking rates in the Little Missouri 

National Grasslands would be reduced by 25% based on the Final EIS for the Dakota 

Prairie Grasslands to meet the goals and objectives contained there in. Pages 3-52 and 

3-53 of the DEIS confirm the estimates we made in 2002 and propose a much higher 

stocking rate reduction – up to 45%. It is a major concern that the anticipated 9% 

reductions that were proposed by the FEIS for the Dakota Prairie Grasslands has not 

been carried through and applied in the North Billings County Allotment Management 

Plan Revision as originally proposed”. 

The estimated 8.3 percent reduction identified in Table 3 (page 27) of the 2002 

Dakota Prairie Grasslands Record of Decision is an estimated figure used for 

comparison purposes between the different alternatives that were analyzed during 

the Grasslands Plan revision process (Grasslands Plan 2006 ROD, p. 12). The 8.3 

percent is the estimated effect across the entire Dakota Prairie Grasslands. This is a

landscape number which is difficult to compare to the site specific number of the 

North Billings DEIS. The variability associated with the 8.3 percent average ranges 

from a plus 5 percent for the Cedar River National Grassland to a minus 9 percent 

for the Little Missouri National Grassland (LMNG) with a range of variability for 

the LMNG of minus 4 to minus 13 percent (see NPG FEIS, p. B-107, Table B-20). 

The LMNG contains the Medora and McKenzie Ranger Districts. 

The analysis in the Northern Great Plains (NGP) FEIS which produced the average 

8.3 percent reduction also analyzed what reductions would be at the district level. 

That analysis indicated that potential reductions for the Medora Ranger District 

ranged from 8 to 17 percent (Project Record, Supporting Documentation – Range, 

L-2) depending on the structure objective. Site specific analysis of the project area 

under Alternative 4 shows a range of possible reductions in Authorized Use ranging 

from 0 to 44 percent, with an average of about 20 percent reduction (SDEIS, 

Chapter 3 Part 1, Range, Table 3.5) from Preference. 

The NGP FEIS for the Dakota Prairie Grasslands didn’t propose a 9 percent 

reduction, as noted earlier it is an analysis number generated for alternative 

comparison. Neither the 2002 nor the 2006 Grasslands Plan RODs established a 9 

percent reduction. Site specific analysis, under Alternative 4, indicates higher 

reductions in Authorized Use in addition to other actions are needed to address 

resource issues. 

C-4 We are pleased to see the additional data and analysis that has been applied to 

developing the DEIS for the North Billings County Allotment Management Plan. This 

was a major deficiency in the FEIS for the Dakota Prairie Grasslands and did not allow 

for an informed discussion of the potential effects on ranchers in western North Dakota. 

Response to Comments | 3
North Billings County Allotment Management Plan Revisions

It was always the intent of the Forest Service to use data best suited to the analysis 

at hand. This analysis displays the effects of this site-specific project. Thank you for 

your comment.

C-5 “Unfortunately, the additional analysis for the North Billings County Allotment Plan 

confirm our 2002 analysis of Proposed Land and Resource Management Plan and the 

FEIS for the Dakota Prairie Grasslands and the major negative impacts that this plan 

would have on communities and individuals in western North Dakota”. 

The analysis of economic impacts for each alternative shows a range of impacts 

associated with changes in the availability of Federal forage alone and the potential 

impact of eliminating all animals spending at least some time each year eating 

Federal forage in the project area (SDEIS, Chapter 3 Part 1, Economics). The 

economic analysis evaluates and displays a range of expected economic impacts to 

all occupations in the twelve-county area in total, which includes but is not limited 

to direct jobs in ranching and the agricultural service sector. In summary, 

Alternative 1 would reduce the current total contribution to the local economic 

impact area by 20 to 39 part and/or full time jobs and $359,497 to $708,453 dollars 

of labor income annually by 2012; Alternative 2 would cause no impacts; 

Alternatives 3 and 3A would add $47,917 to local Federal expenditures, which 

would add two part and/or full-time jobs and $55,405 of labor income annually 

starting in 2011; Alternative 4 would add $47,917 to local Federal expenditures, but 

given reductions in Authorized Use, it would reduce the current total contribution 

to the local economic impact area by one to four part and/or full-time jobs and 

would change annual labor income within a range of an additional $79 to a loss of 

$53,626 dollars of labor income by 2014 (SDEIS, Chapter 3 Part 1, Economics). 

The economics study provided by Billings County addresses ranch viability or 

impacts to specific operations. Although the analysis of voluminous proprietary 

information for MGA ranchers was not possible because this date was not made 

available, NDSU analyzed ranching viability by exploring debt-servicing capability 

using data from western North Dakota relying on the North Dakota Farm and 

Ranch Business Program. There impacts are broken into three herd sizes in an 

attempt to display what impacts may occur to individual ranches under three herd 

reduction scenarios (10%, 20% and 40%). 

NORTH DAKOTA DEPARTMENT OF HEALTH

D-1 “Care is to be taken during construction activity near any water of the state to minimize 

adverse effects on a water body. This included the minimal disturbance of stream beds 

and banks to prevent excess siltation, and the replacement and revegetation of any 

disturbed area as soon as possible after work has been completed. Caution must also be 

taken to prevent spills of oil and grease that may reach the receiving water from 

equipment maintenance, and/or the handling of fuels on the site. Guidelines for 

minimizing degradation to waterways during construction are attached”. 

4 | Response to Comments
North Billings County Allotment Management Plan Revisions

Proposed activities in riparian zones consists primarily of planting trees, fencing to 

create riparian pastures or riparian exclosures which is mostly hand work; 

therefore, there is little anticipated effect to riparian or water bodies from 

construction activities that would be associated with these activities. Possible 

activities on one allotment do include placing downed woody debris and flow 

deflectors to initiate meandering in a portion of Whitetail Creek. Again, this would 

likely be primarily hand work, however, if equipment were used in such a project 

they would be subject to Forest Service regulations and a hydrologist would also be 

on site during construction activities. Care would be taken during the construction 

activities and Best Management Practices would be applied. 

D-2 “We encourage monitoring of riparian areas and adaptive management to achieve 

functioning systems”. 

Chapter 2, Monitoring of the SDEIS identifies that monitoring of riparian areas via 

Properly Functioning Condition (PFC) surveys will be conducted every five years. 

The responsible official in has decided that, for stream segments rated as Functional 

At Risk or Nonfunctional the monitoring period will be shortened to once every 

three years. The monitoring section for each allotment, found in the SDEIS, 

Chapter 3 Part 2, identifies how riparian monitoring will be conducted.

D-3 “The U.S. Army Corps of Engineers may require a water quality certification from this 

department if the project is subject to their Section 404 permitting process. Any 

additional information which may be required by the U.S. Army Corps of Engineers 

under the process will be considered by this department in our determination regarding 

the issuance of such a certification”.

Proposed actions in one allotment do include placing downed woody debris and flow 

deflectors to initiate meandering in a portion of Whitetail Creek. This is thought to 

be primarily hand work but may involve some use of motorized equipment. 

Regardless, the Corp of Engineers would be contacted to determine if a 404 permit 

would be required. The Forest Service will coordinate with all involved agencies to 

secure needed water quality certification. 

SOCIETY OF RANGE MANAGEMENT

E-1 “Major changes have been made that recognized that the herbaceous seral condition of 

the Little Missouri National Grassland meets the plan goals”. 

Table 3.27 (SDEIS, Chapter 3 Part 1, Seral Stages) identifies that existing seral 

conditions are below early and late seral objectives and exceed moderate seral 

objectives according to analysis of the (2005, 2006-2010) sere plot data for the 

project area. The ecoplot data (1996-1999) indicated that during that time period 

seral conditions were being met. Therefore, the most current data indicates that 

seral stage objectives are not being met. 

Response to Comments | 5
North Billings County Allotment Management Plan Revisions

E-2 “While stocking rate reductions can be an important tool for ecosystem improvement, it 

should also be recognized that improved grazing management strategies (grazing 

rotations that control timing, frequency and intensity of defoliation) coupled with 

stocking rate adjustments, which in some instance may involve stocking rate increases, 

are just as important”.

The SDEIS recognizes the use of various management tools in Alternatives 3, 3A, 

and 4 to address resource concerns. The proposed initial actions in Alternatives 3 

and 3A rely solely on management tools other than reductions in Authorized Use to 

address identified resource issues. Alternative 4 uses many of the same tools 

identified in Alternatives 3 and 3A but includes adjustments in Authorized Use (see 

SDEIS Chapter 3 Part 2). Appendix D of the SDEIS identifies multiple grazing 

management tools to address resource issues. 

The Design Criteria (SDEIS, Chapter 2, Table 2.4) provides an explanation of how 

Animal Month/ Animal Unit Month (AM/AUM) adjustments may occur. The 

SDEIS identifies that temporary increases in Authorized Use may be granted if 

monitoring indicates that resource objectives are being exceeded. 

E-3 “The Billings DEIS recognizes that reducing stocking rates is not a viable method of 

improving riparian habitat and wooded draws. The last cow in a pasture will likely be 

found either in riparian habitat or the wooded draws and so focusing on stocking rate 

reductions would have unacceptable economic impacts. Other management techniques 

recognized in the Billings DEIS are more appropriate and effective for improving these 

areas”.

The SDEIS (Chapter 3 Part 2) recognizes multiple tools to meet or move towards 

Grasslands Plan goals and objectives, of which typically there isn’t any one tool that 

is the sole ‘fix’ for an issue. Usually, the ‘fix’ requires multiple tools that are 

synergistic.

Analysis of Alternative 4 indicated that reduced Authorized Use could be a factor in 

improved woody draw conditions. 

E-4 “It appears that the general proposal to reduce stocking rates up to 45% is fundamentally 

driven by the Plan’s direction to increase visual obstruction readings (V.O.R.). 

Alternative #4 proposes drastic reductions in stocking rates without quantifying how 

those reductions would affect V.O.Rs”. 

The condition of the resources is the fundamental consideration in determining if 

additional management actions are needed to move an impacted resource towards 

desired conditions identified in the Grasslands Plan. See also comment E-7. 

The second part of the comment relates to the relationship between stocking rates 

and VOR. It is difficult to develop a quantifiable relationship between stocking rate 

and Visual Obstruction readings. However, studies have found quantifiable 

relationships between production and VOR (Robel et al 1970 and Benkobi and 

Uresk 2000) and standing residual vegetation and VOR (e.g. Benkobi and Uresk 

6 | Response to Comments
North Billings County Allotment Management Plan Revisions

2000). Also, a relative relationship between stocking rate and upland game bird 

cover does exist. For example, Reece et al (2008) states that “the ability of wildlife 

[i.e. upland game birds] to carryout daily and seasonal activities without being 

observed by predators, declines as stocking rates increase.” See also Duebbert et al 

(1986), Reece et al (2001), and Salo et al (2004) for other examples.

E-5 The Billings D.E.I.S. seems to dismiss Alternative #3 from serious consideration with the 

following statement on page 2-24

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

Alternative 3. If under Alternative 3 monitoring reveals that more aggressive 

measures are required, being able to implement those measures and see 

significant results within the 10 to 15 year timeframe associated with this project 

becomes questionable. 

The DEIS doesn’t dismiss Alternative 3, the purpose of the above cite is to provide 

the reader with additional comparative information showing potential differences 

between Alternatives 3 and 4. 

E-6 In light of this statement it would also be fair to say that if Alternative #4 proved to be 

overly aggressive, then by the time monitoring reveals that less aggressive measures were 

required, it may also be too late to prevent the economic and environmental damage 

already caused by measure #4. 

One of the Design Criteria located in Table 2.4 of the SDEIS identifies that if 

reductions are required that they would be implemented at no more than ten 

percent per annum. Ongoing monitoring for herbaceous structure and composition 

which occurs annually on many of the allotments should reveal in a timely manner if 

actions have been successful. If achieved before the full reduction has been 

implemented further reductions would not occur. This is also a provision of the 

design criteria. 

Reducing stocking levels and implementation of other initial actions under 

Alternative 4 is designed to address resource issues. It is unclear from the 

commentor’s statement how they envision environmental damage occurring from 

this alternative. 

E-7 “The method to determine the initial stocking rates in the Billings DEIS was a paper 

exercise and did not account for the benefits of improved management methods nor did it 

consider the current condition of each allotment. It is well known that even with proper 

stocking rates, one manager can overgraze while another will have an abundance of 

residual vegetation”. 

Therefore, the proper approach where long term management has been in place is to 

 evaluate the current management using proven inventory techniques and through 

 adaptive management based upon the results of a well designed and implemented 

monitoring program, make adjustments to meet the goals. The initial stocking rates 

Response to Comments | 7
North Billings County Allotment Management Plan Revisions

under Alternative #4 do not address the current management conditions but instead uses 

a theoretical approach that does not account for the benefits of improved management 

 that is currently in place or that could be implemented. 

 

The commentor is correct in that the method used to calculate the initial estimated 

carrying capacity did not recognize current conditions or management for an 

allotment. There are assumptions made within the analysis that have been 

identified (SDEIS, Chapter 3 Part 1, Range, Carrying Capacity Analysis). However, 

there are still situations where the allotments are not meeting or moving towards the 

desired conditions outlined in the Grasslands Plan. 

The current condition of each allotment was assessed (SDEIS, Chapter 3 Part 2). 

Based on this assessment the IDT identified what resources were not meeting the 

management direction in the Grasslands Plan and why the management direction 

was not being attained. Based on this analysis, the team identified initial actions to 

move the allotments toward desired conditions (Alternatives 3 and 3A). However, 

the effects analysis displayed (SDEIS, Chapter 3 Part 2) that the initial actions 

would generally not result in improved conditions because they did not address 

grazing intensity or the capacity of the land. 

Alternative 4 was designed by looking at (1) the existing condition (were desired 

conditions being met); (2) the initial actions (would the initial actions move the area 

towards desired conditions). Where those two conditions were met for all resources 

then Alternative 4 did not incorporate a change to Authorized Use. Where the two 

conditions were not met then initial estimated carrying capacity was used as a base 

for setting Federal Authorized Use. 

Alternatives 3, 3A, and 4 apply adaptive management which has a goal to achieve 

site specific desired resource conditions in accordance with the Grasslands Plan 

goals and objectives. A key component of adaptive management is monitoring, as it 

is the driving factor which determines if management actions are accomplishing 

their intended resource goals. In addition, the Design Criteria in Table 2.4 of the 

SDEIS provides an explanation of how AM/AUM adjustments can adjust the annual 

Authorized Use up or down from the initial Authorized Use value adaptively, if 

monitoring shows that Grasslands Plan goals and objectives are being met or 

moving the resource towards Grasslands Plan desired future conditions. 

E-8 The Billings DEIS proposes an average 20.3% reduction in stocking rates (up to 45% in 

some pastures) with no explanation of the effectiveness of this change on V.O.R.s. It is 

suggested that a more reasonable approach, if it is determined that a reduction in 

stocking rate is needed for wildlife management purposes, would be to implement a 

maximum average reduction of 8.3% as identified in the two Records of Decision. Going 

beyond this point at this time would seem to be inconsistent with the adaptive 

management approach and the latest approved Forest Service planning efforts. 

8 | Response to Comments
North Billings County Allotment Management Plan Revisions

The Grasslands Plan Record of Decision estimated there would be a 9 percent 

reduction of livestock grazing across the Grasslands based on the management 

direction in the plan (2002 ROD, page 5). Some allotments could see higher 

reductions, other allotments could see lower. Reducing allotments more than 9 

percent is not inconsistent with the plan because the plan did not establish a limit 

for change. 

For some allotments, Alternative 4 would reduce Authorized Use more than 9 

percent in order to move allotments toward desired conditions. In addition, these 

reductions would occur over time (no more than 10 percent annually). Ongoing 

monitoring for herbaceous structure and composition which occurs annually on 

many of the allotments should reveal in a timely manner if actions have been 

successful. If achieved before the full reduction has been implemented further 

reductions would not occur. This is also a provision of the design criteria (SDEIS 

Table 2.4). 

BADLANDS CONSERVATION ALLIANCE

F-1 Initial Actions in Alternative 3 are almost wholly directed toward supplying additional 

forage opportunities on an already stressed landscape. While grazing rotations and 

more than two dozen new water tanks may provide for cattle, they do not address the 

severe lapses seen in riparian health, woody draws and vegetative composition. And 

perhaps most notably, the desired maintenance of a shifting mosaic expressed in terms of 

vegetative structure is nearly absent and is apt to be further homogenized rather than 

improved. 

Alternative 3 does propose new water tanks and other range developments; 

however, the reason for these stock tanks is not for additional livestock forage 

opportunities. There are many instances where the tank is meant to draw livestock 

away from a riparian area or a woody draw to address identified issues in those 

areas (SDEIS, Chapter 3 Part 2). Also, where applicable, stock tank management 

will be applied where stock tanks will be turned on and off to draw livestock to 

certain areas, thereby rotating the livestock use from area to area. In some cases, a 

proposed new development is replacing an existing development that will be 

rehabilitated. It should also be noted that there are several tools being proposed to 

address the identified resource issues. A goal of proper grazing management is to 

distribute the livestock throughout a location and to not have the livestock use 

focused in any one area. This can be accomplished with a grazing rotation system, 

thereby providing opportunities for vegetation growth and regrowth as the livestock 

rotate through the pastures within the grazing system. Although the grazing system 

and other management tools may appear to give livestock the opportunity to create 

a homogeneous landscape, that is not the intention of the various management tools. 

Response to Comments | 9
North Billings County Allotment Management Plan Revisions

F-2 Adjustment for changes in animal unit forage demands with changes in cow/calf size was 

a recommendation by the Scientific Review Team (SRT Recommendation V-2). It should 

be implemented. 

The commentor is correct in their identification of this SRT recommendation. 

Adjusting for cow size is one of the components of Alternative 4 (SDEIS, Chapter 2, 

Alternatives Considered in Detail).

F-3 We approve of the plan to carry out reductions as needed with no single year decreasing 

AUMs by more than 10%. We would insist on exacting, ongoing monitoring during this 

initial phase, with current baseline data on both structure (Visual Obstruction Readings) 

and vegetative composition and production. 

In Chapter 2, Monitoring the SDEIS identifies the monitoring plan, which among 

other information identifies the types of monitoring that will be completed and 

frequencies. The specific monitoring to be carried out by allotment is identified in 

Chapter 3 Part 2 of the SDEIS. 

F-4 As Alternative 4 stands, there is a range of monitoring frequency. Flexibility must be 

built into this alternative to insure a halt or slowing in reductions should a significant 

upward trend be identified. 

The Forest Service recognized the commentor’s concern and has addressed this in 

the Design Criteria (SDEIS, Chapter 2, Table 2.4). This comment is specifically 

addressed by the following criteria: If monitoring shows that resource objectives are 

being met before full implementation of the AM/AUM reduction has occurred, then 

no further reduction in AUMs will be needed.

F-5 Alternative 4 has the best chance of approaching the Goals and Objectives for 

Management Indicator Species, here the sharp-tailed grouse. Particularly on the Rolling 

Prairie portion of the Project Area, continuing monitoring must take place to determine 

needs for adaptive management. 

Chapter 3 Part 2 identifies the types and frequency of monitoring that is proposed 

for Alternatives 3, 3A, and 4 by allotment. The herbaceous structure monitoring 

would be used to provide habitat condition information for the sharp-tailed grouse. 

Also monitoring of known leks in DPG monitoring block located in the project area 

would be conducted on an annual basis. 

F-6 Efforts to improve season of use on crested wheatgrass are evident. We would suggest 

that similar treatment on pastures showing high percentages of invasive grass (brome, 

Kentucky bluegrass) should be implemented as well, even if some change in 

configuration of these allotments were necessary. This would allow for greater use of 

forage produced (invasives) without further stocking rate reductions, but it may also 

require the permittee to adjust for season of use. 

10 | Response to Comments
North Billings County Allotment Management Plan Revisions

The Botany Report discusses this strategy (Discussion of Results - Seral Stage/Plant 

Composition) as a means to help control invasive grasses and alleviate use of native 

grasses to increase their vigor and predominance in accordance with general 

principles of range science (Project Record, Specialist Reports and Notes). 

Achieving the desired level of high invasive grass utilization over shorter time 

periods would require increasing livestock density. High or maximum levels of use 

based on the existing forage component would therefore be maintained. However, it 

would often not be feasible for a given permittee to increase livestock numbers for a 

variety of reasons, so it could become necessary to add livestock from other 

permittees to an affected allotment until desired results are achieved. Ranch 

logistics for the original permittee would be complicated because other pastures 

would be required for later summer grazing until native grass components are 

sufficiently restored to return to normal grazing schedules. 

F-7 We also note the differing results for seral stage percentages by methodology in Table 3-

16 of the DEIS. The EcoPlot Data from 1997-1998 seems to meet Grasslands Plan 

objectives more than the newer data. We do not find any specific analysis that explains 

the significance of this change and question whether or not this actually reflects a 

downward trend in seral conditions. 

Differences in seral proportions obtained with the ecoplot data versus the NDSU 

and sere plot data were suggestive of an increase in mid seral stages and decrease in 

early and late seral stages, as well as an increase in invasive grasses that would 

represent a trend away from desired conditions. However, this cannot be 

statistically ascertained due to significant differences in sample methodology and 

sample locations. The ecoplot methodology was established to classify and 

inventory plant communities across the LMNG and was not of sufficient rigor for 

precise estimates of plant composition or monitoring of trends (Project Record, 

Specialist Reports and Notes, Botany Report). The ecoplot data was initially utilized 

to augment a limited number of sere plots or other plant composition data, but 

recent data from NDSU plots, additional sere plots, and pace transects has 

decreased the utility of the ecoplot data. 

F-8 BCA was taken aback by the casual and brief discussion under the heading 

Irreversible/Irretrievable (pages 3-182 and3-183). The DEIS states: “Existing invasive 

grasses are having an irretrievable effect on native plant communities.” It goes on to 

say, “Given enough time and the right conditions existing invasive grasses might effect 

native communities to a point their restoration is so difficult that it approaches an 

irreversible loss of native communities.” This is a condition of alarm to differing 

degrees throughout the West, in Dakota Prairie Grasslands’ own Sheyenne National 

Grassland and should be in the Little Missouri. It is a transition that should be stopped 

or slowed on the Little Missouri National Grassland while there is still a chance of 

success. 

See response to comment I-15. 

Response to Comments | 11
North Billings County Allotment Management Plan Revisions

F-9 Adding a forage reserve to the list of options in the Grazing Management Toolbox would 

be significantly helpful in easing the impacts of livestock reductions as seen in the North 

Billings County Project Area, and in preventing repeat occurrences elsewhere in the 

Grassland. 

The idea of a forage reserve has many merits. This idea has been and will continue 

to be explored in another nearby study, i.e. the Grasslands Plan amendment and 

grazing management plan for the Elkhorn Ranchlands. If a forage reserve were to 

be included in the Elkhorn Ranchlands, then it would most likely benefit permittees 

in the North Billings project area, which immediately surrounds the Elkhorn 

Ranchlands, as predicted by the commentor.

The idea of a forage reserve within the North Billings project area runs counter to 

the purpose proposed by Badlands Conservation Alliance. The claim is made that a 

forage reserve “...would be significantly helpful in easing the impacts of livestock 

reductions as seen in the North Billings County Project Area...” To the contrary, 

within the constraints of the project area, the only way to make allotments available 

for a forage reserve is to first cancel or terminate an existing grazing permit within 

that allotment so that it can be reallocated as part of a forage reserve. The 

elimination or termination of an existing grazing permit in an allotment would not 

ease, but rather would add impacts to proposed livestock reductions. 

It is likely that the commentor has confused potential actions of the adjacent 

Elkhorn Ranchlands project with those contemplated in the North Billings project. 

There is no dispute that a forage reserve has merits; however, implementation of 

one within the defined project area would require additional cuts in livestock and 

would cause additional impacts to affected permittees.

F-10 In the discussion on Global Climate Change, it should be pointed out that IF cited 

modeling predictions of increased moisture, temperature and CO2 for the Project Area is 

reliable at all, that precipitation and that temperature increase is expected to come in 

extreme weather events, not necessarily conducive to greater forage production. Indeed, 

in an already stressed system, these extreme events in a landscape like western North 

Dakota may cause adverse conditions including lost moisture infiltration, erosion, etc. 

The Forest Service acknowledges that there are many theories and predictions 

related to climate change. Trying to determine the effects of global climate change 

on the project area is difficult at best. It is possible that extreme weather events may 

occur, and if they do it is reasonable to expect increases in erosion and other adverse 

effects.

F-11 The SRT’s recommendation IV-1: All parties should agree to share detailed (i.e., number 

and size of grazers, on and off dates, etc.) pasture specific records on an annual basis 

seems all the more essential to resolve issues. Ranching families will not last if the 

resource does not last. And, that would be a pity for all. 

12 | Response to Comments
North Billings County Allotment Management Plan Revisions

The Forest Service agrees (Final Response to the SRT Reports, p.12) with the SRT's 

recommendation and concur with the commentor that this information is important 

for managing the allotments. A letter has been sent to the MGA detailing, as per the 

MGA Grazing Agreement, the required actual use information, and the need to 

complete year end reviews with each permittee to verify or amend the Annual 

Operating Instructions (AOIs) to reflect what actually occurred for the past grazing 

season (see Project Record, Correspondence Permittee, actual use letter to MGA 

dated June 28, 2011).

NORTH DAKOTA GAME AND FISH DEPARTMENT

G-1 What should not be neglected, however, is the past work including your Rangeland 

Assessment that has been done in western North Dakota and neighboring areas (see 

short list appended at back). 

Information from the Little Missouri National Grassland Rangeland Assessment 

was used at the landscape scale, as per SRT recommendation, to help determine 

potential resource concerns in the project area.

G-2 The DEIS should identify the tools that will be used to address this issue. In some cases 

such as riparian conditions, very specific tools have been identified. In others such as 

grassland structure the DEIS is silent, or simply lists a possibly all-encompassing, illdefined tool such as “adjust authorized use”. It would seem authorized use may include 

many tools in the grazing management tool box. More specificity is needed on this issue 

in the EIS and the final decision. 

Adjusting Authorized Use is a tool in and of itself and one of many in the grazing 

management toolbox (SDEIS, Chapter 2, Table 2.1). It refers to the number of AMs 

or AUMs, depending on the alternative, which is annually authorized to an 

allotment for livestock grazing. Adjusting Authorized Use can improve conditions 

for several different resource areas. Appendix D of the SDEIS identifies the effects 

of the different tools in the grazing management tool box. As with adjusting 

Authorized Use, one tool may benefit more than one resource. Chapter 3 Part 2 of 

the SDEIS includes an allotment by allotment analysis showing what resource is of 

concern, the initial and adaptive actions by alternative and the effects by resource 

by alternative. 

G-3 Although the DEIS indicates the project area is close to meeting seral stage objectives, it 

still falls short of meeting them. This should be addressed. 

Alternatives 3, 3A, and 4 contain initial actions such as modified rotations, June 

turnout for native species, Authorized Use reductions in the case of Alternative 4, 

etc. These actions among other things would allow plant vigor to increase, allow 

completion of critical plant growth structure, etc. which in turn provides the 

Response to Comments | 13
North Billings County Allotment Management Plan Revisions

opportunity to positively affect species expression and composition. Monitoring will 

determine, on an allotment by allotment basis, if the initial actions are moving 

towards desired conditions at an acceptable rate or if adaptive management needs to 

be initiated to further address resource issues. The SDEIS includes an allotment by 

allotment discussion of seral stages and whether or not the initial actions in each 

alternative are anticipated to improve resource conditions (SDEIS Chapter 3 Part 

2). 

G-4 Prohibiting the use of tame grass hay on native grassland areas is one step that should be 

taken now if it hasn’t been already. 

The Grasslands Plan addresses this concern on page 1-19...”Minimize feed storage 

and routine feeding of domestic livestock on NFS lands” (guideline). Table 2.1 in 

the SDEIS also identified this as a tool “Move winter feeding areas off of National 

Forest System lands”. 

G-5 Regarding Kentucky bluegrass in particular, we believe that controlled research is 

necessary for effective adaptive management and that adaptive management must be 

targeted toward the issue. We also have reservations as to whether the proposed 

decision embraces the flexibility needed to address this issue. 

There is some reluctance to implement early season grazing of pastures with high 

amounts of Kentucky bluegrass mixed with varying amounts of native grasses due 

to the potential for premature use of the native component. In some cases we have 

passed or are nearing a threshold of returning potential dominance to the native 

climax vegetation. Thus, the degree of concern is not justified by existing plant 

composition because loss of native dominance is or is becoming a forgone event. 

However, there is still reason to properly manage invasive dominated pastures 

because their contribution has the potential to decrease livestock reductions 

necessary to maintain existing native dominated communities and otherwise slow 

the spread of invasive species. Some research shows that livestock can become 

accustomed to actively selecting Kentucky bluegrass when it is most palatable 

(Brand, 2006, Sedivec 2006) and this should be actively investigated through close 

monitoring of grazing results under different proportions of invasive-native grasses. 

G-6 In 2009 the Department released an interim report on the collaborative hardwood draw 

monitoring initiated in the 1980s on the Little Missouri National Grassland. This report, 

not the draft which preceded it should be cited (Duxbury 2009). In addition we would like 

to point the earlier collaborative research conducted on hardwood draws using 

exclosures (McKenzie 2004). One of these exclosures and the long-term study exclosures 

installed by Rocky Mountain Research Station (Uresk and Boldt 1986) are actually in the 

project area. 

Information generated by the North Dakota Game and Fish (NDGF) report was 

used and Duxbury is cited in the SDEIS and Botany Report. The report also 

14 | Response to Comments
North Billings County Allotment Management Plan Revisions

supplied additional valuable literature citations. Data from sample cites in the 

project area resulting from the ongoing collaborative woody draw monitoring 

project between the NDGF and Forest Service was used in the assessment of existing 

woody draw conditions and in evaluating trends of these conditions. 

Woody draw exclosures constructed by Uresk and Boldt (1986) that occurred in the 

project area were included in the woody draw analysis ((Project Record, Specialist 

Reports and Notes, Botany Report). One of the sites was Healthy while the second 

was At Risk but bordering on Healthy. Both sites were affected by dense invasive 

grasses of smooth brome and Kentucky bluegrass that likely inhibit improved 

conditions despite the exclusion of livestock. 

The exclosures constructed by McKenzie occurred south and outside of the project 

area and were therefore not used in the analysis. However, observations of these 

sites indicated excellent or Healthy conditions without the burden of dense invasive 

grasses, and to some extent, were used as a reference of potential composition and 

structural condition. 

G-7 However it appears the Forest Service has not addressed both cow and calf size, instead 

having focused on changes in cow size only. We have always emphasized the need to 

address both. Given that the DEIS is a site specific document it would be helpful if cow 

and calf size was addressed on an allotment by allotment basis. In addition, it is unclear 

to us, if stocking rate was based on actual production or potential production; if it 

embraced the concept of structure heterogeneity as detailed in the Grassland Plan; or 

addressed slope as per identified by the NRCS and others. 

In Alternative 4 of the SDEIS the Authorized Use for each allotment is labeled as 

AUMs. An AUM is defined in the glossary as the amount of feed or forage required 

by an Animal-Unit (AU) for one month. Additionally, an AU is considered to be a 

mature 1,000-pound cow, either dry or with a calf up to six months of age, or their 

equivalent based on an average daily forage consumption of 26 pounds dry matter 

per day on an oven-dry basis. Based on this definition, the AUM can be either a cow 

with a calf or a dry cow, therefore as long as the calf is less than or equal to six 

months of age it is not accounted for in the Authorized Use value. 

The carrying capacity analysis used to determine initial Authorized Use values for 

Alternative 4 has several assumptions described in the Carrying Capacity Analysis 

section in Chapter 3 Part 1, Range of the SDEIS. One of those assumptions is that 

forage production values reported for each mapping unit within the soil survey are 

based upon a Reference plant community which essentially is the potential plant 

community for an ecological site. This analysis was conducted based upon 

recommendations I-1 and I-2 from the SRT in accordance with the DPG Final 

Response to the Scientific Review Team Reports, 2006 pp. 3 - 5. 

G-8 Basic Record-keeping Relating to Livestock and Grazing Management is an issue that 

was brought to the forefront by the Scientific Review Team, although it has been a backResponse to Comments | 15
North Billings County Allotment Management Plan Revisions

burner issue for a number of years. As indicated in the past we are fully behind the 

Scientific Review Team on this. It would appear that some permittees are better at 

keeping the Forest Service appraised as to what they are doing on the ground than others 

and that some grazing associations are less concerned with obscuring what is going on 

on-the-ground than others. We do not believe that such basic record keeping and record 

sharing is a discretional activity. 

See response to comment F-11. 

G-9 It has been suggested that monitoring can bridge the lack of such records. We have long 

supported increased monitoring on the Grasslands. Monitoring however should not have 

to bridge fundamental and clearly correctable short-comings relating to record keeping 

on other fronts. This puts the whole onus and burden on monitoring that not only 

challenges your ability to see that it gets done but diminishes the likelihood of success. 

In addition such gaps and lapses in record-keeping undermine the very principles upon 

which adaptive management are founded. 

The Forest Service agrees that record keeping is important (see response to 

comment F-11). However, for this project it is the Forest Service’s belief that the 

best available information will be on the ground monitoring which will indicate if 

Grasslands Plan goals and objectives are being met or resources are moving 

towards Grasslands Plan desired future conditions. 

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 8 

H-1 However, since 50% of perennial streams are already properly functioning we suggest 

you do not constrain project goals and adaptive management strategies to meeting this 

condition. We recommend you include a commitment to continue implementing strategies 

for stream health improvements beyond 80% of perennial streams, as well as improving 

intermittent streams where possible. 

Grasslands Plan Goal 1a (3) identifies an objective of meeting or moving towards 

Proper Functioning Condition (PFC) on at least 80 percent of perennial streams. 

The Forest Service is not treating the 80 percent as the final target; it is the first 

part of this goal. As all the streams in the project area are intermittent, with the 

exception of the Little Missouri River, the different actions proposed in Alternatives 

3, 3A, and 4 to address stream concerns are to improve intermittent stream 

function. 

H-2 EPA is concerned about the lack of water quality data or discussion in the DEIS. Cattle 

grazing has the potential to degrade water quality through increased sedimentation and 

loading of nutrients and pathogens. We recommend the adaptive management plan 

include monitoring for the following: 

 Fecal coliform and total bacteria counts 

 Nutrient concentrations: and 

 Temperature 

16 | Response to Comments
North Billings County Allotment Management Plan Revisions

In response to this comment a section in Chapter 3 Part 1 on water quality has been 

added to the SDEIS. As noted in this analysis the reaches of streams that have a 

riparian functionality rating of Functional at Risk Downward or Nonfunctional are 

likely contributing the majority of fecal coliform due to impacted riparian 

vegetation. In contrast, the riparian vegetation associated with reaches that are 

rated at Proper Functioning Condition (PFC) are likely trapping sediment and 

thereby removing associated contaminants such as fecal coliform. Recent studies 

(Shirmohammadi and Montas, 2003; Pachepsky et. al., 2006; Sullivan et. al., 2007) 

indicate that vegetation filter strips are highly effective in removing nutrients and 

fecal coliform from overland flow and preventing these contaminants from entering 

the stream flow. Actions that increase riparian vegetation will directly decrease 

sediment transport as well as transport of sediment laden contaminants such as 

fecal coliform. 

Based on the correlation between PFC and potential contribution of fecal coliform, 

monitoring will focus on whether At Risk Downward and Nonfunctional stream 

segments are moving towards PFC. 

H-3 However, we recommend that the Forest Service incorporate baseline water quality into 

PFC assessments for future projects. 

As identified in the Water Quality section in Chapter 3 Part 1 of the SDEIS, there 

are no perennial streams in the project area, with the exception of the Little 

Missouri River. 

Part of the PFC assessment method (Prichard et al., 1998, 1999 (modified 2003) 

assesses the condition of riparian vegetation. The strong inverse relation between 

riparian vegetation and water quality (Shirmohammadi and Montas, 2003; 

Pachepsky et al., 2006; Sullivan et al., 2007) indicates that the condition of riparian 

vegetation can serve as a proxy for water quality and therefore minimizes the need 

to monitor water quality directly in streams. 

Some monitoring is proposed for the main stem of the Little Missouri River at the 

confluences of Whitetail and Mikes Creek. See the water quality section located in 

Chapter 3 Part 1 of the SDEIS. 

H-4 The EIS should also include any streams within, or downstream of, the project area that 

are not supporting beneficial uses. Any water body on the Clean Water Act Section 

303(d) list of impaired waters, or on the 303(d) monitoring list, should be identified 

along with the pollutants of concern for that segment. 

There are no water bodies within the project area listed on the Clean Water Act 

Section 303(d) list. All the streams in the project area are identified as Class III 

waters by the North Dakota Department of Health with the exception of the Little 

Missouri River, which is classified as a Class II stream (see North Dakota Century 

Response to Comments | 17
North Billings County Allotment Management Plan Revisions

Code, Chapter 33-16-02.1 Standards of quality for waters of the State, Appendix I). A 

reach of the Little Missouri River in McKenzie County downstream of the project 

area, from the confluence with Beaver Creek to the Highway 85 bridge crossing, has 

been monitored for water quality (North Dakota Department of Health, 2008, p. VI30). This reach is rated as ‘Fully Supporting But Threatened’ for beneficial use 

(listed as recreation), due to levels of fecal coliform (North Dakota Department of 

Health, 2008, p. VI-30). 

H-5 The Little Missouri River has not been assessed for fecal coliform or other pathogens 

from it confluence with Government Creek to its confluence with Beaver Creek. A 

discussion of how the proposed project may impact the Little Missouri River impairment, 

as well as any other impaired or potentially impaired waters, is needed. 

In response to this comment a section on Water Quality has been added to the 

SDEIS. 

H-6 We recommend that a description of the potential impacts, positive and negative, of each 

tool on all the resources of concern be included in the document. Along with this 

information should be a commitment that a tool will not be selected for adaptive 

management use if it will result in negative impact to any resource. 

Appendix D of the SDEIS provides effects analysis of the different tools in the 

grazing management toolbox. 

In the management of a multiple-use landscape, the selection of a tool(s) to address 

one resource concern may have negative impacts on another resource. This is the 

inherent nature of land management within a multiple-use agenda. Under the 

Grasslands Plan some acres are targeted for low vegetative structure, early seral 

plant composition, and emphasis of grazing. Other acres will be prioritized for high 

vegetative structure, late seral plant composition, and emphasis of some wildlife 

species. Across the landscape, tools will have beneficial and adverse effects. For 

example, fencing an area to help develop high vegetative structure will benefit 

wildlife species for which high structure is a critical habitat component to the 

determent of those species which need short vegetation such as prairie dogs. It is the 

degree to which this happens that is important, none of the tools identified in the 

analysis will be applied to an extent that it will have significant negative effects to 

any resource as that would be counterproductive.

H-7 A firm commitment of resources for effectiveness monitoring should be included in the 

EIS. Adaptive management cannot be employed without full implementation of its 

associated monitoring schedule. Consequently, an environmental conservative default 

management plan should be defined in case adequate resources for monitoring cannot be 

secured. 

The success of adaptive management is based on monitoring for without monitoring 

information it is not possible to move forward with adaptive management actions if 

18 | Response to Comments
North Billings County Allotment Management Plan Revisions

called for. The Medora Ranger District and the DPG are committed to carrying out 

or obtaining the needed monitoring information through its own resources or in 

partnership with other entities such as NDSU and the MGA. However, despite the 

best intentions, events do happen which, in the short term, may affect our ability to 

meet the monitoring schedule associated with this project. These events are usually 

fiscal in nature and are at the discretion of the U.S. Congress; therefore, it is not 

possible to say that funding will always be available when needed to complete 

monitoring. Rarely has it happened that no monitoring has been completed, rather 

fiscal impacts have generally meant a reduced amount of monitoring would be 

completed until sufficient fiscal resources become available to establish full 

monitoring. If monitoring funds for this analysis become limited, the funds that are 

available will be concentrated on those allotments of greatest concern while initial 

actions continue to be carried out on the remaining allotments in the project area. 

H-8 The explanation of future decision points that would require NEPA analysis will also be 

beneficial in clarify what is and isn’t considered within the bounds of adaptive 

management. 

Adaptive management for this project is bounded by the tools in the Grazing 

Management Tool box (SDEIS, Chapter 2, Table 2.1). The possibility of new 

management tools is recognized in the following statement from the Alternatives 

Considered in Detail, Alternative 3 section of the SDEIS, “It is possible that new 

rangeland management techniques may be developed during the life of this project. 

New techniques would be incorporated into the toolbox to the extent that their 

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

accompanying Record of Decision”. If effects of a new tool are outside those 

identified in the SDEIS then a new NEPA process would need to be initiated to 

address that tool. 

H-9 We recommend that you remove, or explain more fully, the note that “hitting a trigger 

point doesn’t necessarily mean a change is needed. 

Additional clarification has been added in the Monitoring, Trigger Points section of 

Chapter 2 of the SDEIS.

H-10 We also recommend you include the trigger points in the allotment summary sheets for 

ease of reference and to ensure commitment. 

A copy of the trigger points identified in the Monitoring section of Chapter 2 of the 

SDEIS will be included with each individual Allotment Management Plan when they 

are written. 

H-11 Finally we recommend, as described above under “Water quality that you add water 

quality monitoring as a monitoring item in the Effectiveness Monitoring schedule (pg 2-

20). 

Response to Comments | 19
North Billings County Allotment Management Plan Revisions

Some water quality monitoring is proposed for the main stem of the Little Missouri 

River at the confluences of Whitetail and Mikes Creek. See the Water Quality 

section located in Chapter 3 Part 1 of the SDEIS. Also as noted earlier monitoring of 

PFC will be used as a proxy for monitoring water quality because there is a direct 

correlation of riparian vegetation providing a filter for removing nutrients and fecal 

coliform from overland flow. 

Ha-1 However, two segments of the Little Missouri River upstream of the project area, and two 

segments of the Little Missouri River downstream of the project area are listed as 

threatened and/or impaired for fecal coliform bacteria. The probable sources of 

impairment in the listed segments include livestock grazing or feeding operations, and 

Total Maximum Daily Loads (TMDLs) are needed for these listed segments (see the 

assessment summary table below). 

The TMDL development schedule is established by the State and these four 

segments are listed as ‘Low Priority’ in Table VI-3; 2008 List of Section 303(d) 

TMDL Waters for the Missouri Basin in North Dakota, page VI-30 (North Dakota 

Department of Health, 2008, p. VI-30). 

Ha-2 Due to the lack of assessment data for the area and our perceived need for baseline water 

quality data, we recommend a two-pronged monitoring approach: 

1. Mainstem Little Missouri River, core indicator and regular E. coli 

 monitoring; and 

2. Magpie Creek, E. coli monitoring 

Water quality monitoring is proposed in the main stem of the Little Missouri River 

above and below the confluences with the intermittent streams supporting large 

project area watersheds. The proposed monitoring sites in priority order are 

Whitetail and Mikes Creeks. The watershed area supporting Whitetail Creek, with 

its main tributary Blacktail Creek, overlaps with a majority of the project area and 

therefore has been selected as the highest priority. Water quality monitoring for 

Magpie Creek will be done by monitoring PFCs (see response to comments H-2 and 

H-11). Additional information is located in the Water Quality section of the SDEIS

and in Chapter 2. 

Ha-3 We recommend selecting mainstem [Little Missouri River] monitoring sites where water 

quality and flow data could be collected upstream and downstream of some of the larger 

tributaries. In order to assess potential grazing impacts from USFS allotments, spring 

sampling, when the tributaries may be flowing, may be the best time to collect the 

samples. If a tributary is flowing when the mainstem samples are being collected, then 

water quality and flow data should also be collected at the mouth of the tributary. 

Further, for E. coli, we recommend collecting at least 5 samples during a 30-day period 

to facilitate comparison with ND’s water quality standards. 

20 | Response to Comments
North Billings County Allotment Management Plan Revisions

The Forest Service agrees with the recommendation; please see the monitoring in 

the Water Quality section of Chapter 3 Part 1, and Chapter 2 of the SDEIS for 

further detail. 

Ha-4 Based on information from USFS, it is our understanding that Magpie Creek is a 

perennial stream. Therefore, E. coli water quality sampling should be conducted through 

the full recreational season (i.e., May 1 – Sept 30). 

The upper reaches of Magpie Creek are perennial, but the lower reaches are 

intermittent. See response to comment Ha-2. 

Ha-5 Data needs and a sampling approach should be identified based on ND’s Assessment 

Methodology (AM) with a clear recognition of the critical balance between too much and 

too little data for making beneficial use determinations as described in the AM. This 

information appears in Appendix A of North Dakota’s 2008 Integrated Report, found at: 

http://www.ndhealth.gov/WQ/SW/A_Publications.htm . We recommend developing 

monitoring and data quality objectives in close consultation with Mike Ell, Surface Water 

Program Manager for the North Dakota Department of Health. 

We will develop monitoring and data quality objectives in close consultation with 

Mike Ell, Surface Water Program Manager for the North Dakota Department of 

Health. Data collection personnel will receive training and become certified prior to 

any water quality sampling from Mike Ell and/or his staff. All established ND 

water quality sampling and laboratory testing protocols will be followed.

WESTERN WATERSHED PROJECT

I-1 According to the Scientific Review Team:

[S]tocking rates will still have to be reduced substantially if any appreciable ecological 

recovery of these grasslands is to occur. This is largely because we believe the majority 

of the SNG is substantially overstocked because of insufficient number of pastures to 

optimize graze/rest rotational schedules, extended grazing seasons, and too many and/or 

too large of animals. Utilizing tools such as combining allotments, cross fencing, water 

developments, prescribed burning, etc. will be required to lessen, but not eliminate, the 

need for stocking rate reductions on the SNG. Likewise, stocking rate reductions alone 

will not accomplish ecological restoration. 

LRMP ROD, p. 5. Thus, Alternative 3 is plainly not in compliance with NFMA. 

The above quote is from the 2006 Livestock Grazing Record of Decision for the 

Dakota Prairie National Grasslands (DPG). The quote is in reference to the 

Sheyenne National Grasslands. The proposed project is located on the Little 

Missouri National Grasslands. 

Response to Comments | 21
North Billings County Allotment Management Plan Revisions

The SDEIS evaluates each alternative to determine if it is in compliance with the 

plan (Chapter 3 Part 1). If the project is consistent with the plan then it is 

considered consistent with NFMA. 

 

I-2 In truth, the adjustments need to be in the direction of greater reductions in stocking 

rates than those presented in Alternative 4, due to faulty assumptions used in setting 

stocking rates for that alternative -- such as assumptions of normal rainfall during what 

is clearly a time of increasing draught conditions, the assumptions of good to excellent 

range conditions that are not supported by the evidence, and unrealistic utilization 

factors. 

The Forest Service disclosed the limitations of the data used in the carrying capacity 

analysis, see Chapter 3 Part 1, Range, Carrying Capacity Analysis section of the 

SDEIS. Assumptions associated with the Representative Value are normal growing 

conditions and reference plant community. In very general terms, the assumption 

of “normal” growing conditions could either under or over estimate production 

dependent upon the given climatic conditions for the year. The assumption of 

reference plant community could also under or over estimate production depending 

on the existing plant community for the ecological site. The Forest Service consulted 

with the USDA Agricultural Research Service to assure the initial estimated 

carrying capacity analysis was calculated correctly. 

The analysis of this data provided a starting point for Authorized Use in Alternative 

4. The Design Criteria identified in Table 2.4 Chapter 2 of the SDEIS provides an 

explanation of how AM/AUM adjustments to annual Authorized Use can occur 

from the initial Authorized Use value adaptively, if monitoring shows that 

Grasslands Plan goals and objectives are being met, are moving towards, or not. 

The monitoring for each allotment is described in the third table for each allotment 

in Chapter 3 Part 2 of the SDEIS. If drought occurs in any given year then the 

interim drought management strategy referenced in the Key Issues, Key Issue #6. 

Drought section of the SDEIS or the DPG drought management strategy (when it is 

finalized) would be employed which could result in less Authorized Use. 

I-3 The fact that 36.5% of the riparian areas are non-functioning, and another 5.4% are 

functioning at risk with a downward trend, is frankly obscene. It would appear from this 

deplorable condition that at least 42% of the pastures require indefinite rest! The same 

is true of the Green Ash Hardwood Draws, with nearly 50% showing clear signs of 

intense browse associated with over-grazing. 

The DPG is a unique set of national grasslands in that very little of the lands were 

public domain when the Grasslands where created. The DPG is mainly composed of 

lands that were once privately owned. Prior to coming under Federal ownership 

they were farmed and grazed for decades. The combination of prolonged drought, 

farming and grazing abuses culminated in the dust bowl era of the 1930s. 

Restoration of the lands started in the late 1930s when the lands came under Federal 

ownership. According to Box and Malechek (1987 in Krueger et al 2002), the 

22 | Response to Comments
North Billings County Allotment Management Plan Revisions

rangelands of the great plains have improved in quality from the early part of the 

20th century due to programs to “correct maladjustments in land use” such as was 

authorized under the Bankhead-Jones Farm Tenant Act. The Grasslands Plan was 

developed to ensure the long-term health of the grasslands (Grasslands Plan 2002 

ROD, p 10). 

The Grasslands Plan (p. 1-11) stipulates, “For streams identified as "nonfunctioning" or "functioning at risk with a downward trend," begin corrective 

action within 3 years of stream inventories. Guideline." Chapter 3 Part 2 of the 

SDEIS identifies the proposed restoration treatments under Alternatives 3, 3A, and 

4 for those reaches that are non-functioning or functioning at risk with a downward 

trend. 

Steam conditions are fully disclosed in the SDEIS, and a restoration strategy is 

proposed for each. The following table summarizes restoration strategy by affected 

stream reach.

Table for FAR-D and NF Reaches 

Allot/Pasture # Stream (Reach #) FAR-D 

(Miles)

NF 

(Miles)

Treatment

128-01 Whitetail (6) 1.07 Riparian exclosure

128-01 Whitetail (7) 0.19 Riparian exclosure

129-01 Magpie (5) 0.58 Riparian pasture/exclosure

129-01 Magpie (5) 1.55 Riparian pasture/exclosure

135-08 Mikes (2) 2.79 Riparian exclosures/5 pasture rotation

135-09 Mikes (2) 1.98 Riparian exclosures/5 pasture rotation

135-10 Mikes (1) 1.74 Riparian exclosures/5 pasture rotation

244-02 Whitetail (3) 0.51 Cross fence to develop a riparian pasture

256-02 Blacktail (4) 1.76 Riparian pasture and develop water

256-02 Trib to Blacktail 

(9)

0.45 Riparian pasture and develop water

256-03 Blacktail (4) 1.83 Riparian exclosure

258-01 Ash Coulee (2) 0.32 Riparian exclosure

258-02 Ash Coulee (2) 0.13 Riparian exclosure

277-02 Scairt Woman (2) 0.55 Monitor NF status to determine cause

282-04 Whitetail (11) 0.67 Manage water tanks

282-06 Magpie (6) 0.47 Riparian exclosure

282-06 Magpie (7) 3.84 Riparian exclosure

286-01 Betsy (1) 0.43 Fence woody draw

287-03 Trib to Blacktail 

(9)

0.65 Manage water tanks

289-03 Scairt Woman (2) 0.22 Manage water tanks/Deferred rotation

300-01 Magpie (1b) 0.12 Develop new water

301-01 Magpie (2) 0.14 Deferred rotation

Totals 2.87 19.12

Rest is a valuable tool for improving woody draw health and is proposed for use 

under the action alternatives (SDEIS, Chapter 3 Part 2); however, it is not a 

universal panacea for the woody draws in the project area. Complete removal of 

livestock grazing would have the undesired effect of assisting the further spread and 

Response to Comments | 23
North Billings County Allotment Management Plan Revisions

dominance of invasive grasses (SDEIS, Chapter 3 Part 1, Woody Draws) that can 

impede the regeneration of woody species (Lesica 2009). 

I-4 WWP considers the goal of the LRMP to attain PFC on 80% of streams, while tolerating 

non-functioning hydrologic conditions on 20% of streams, to be a clear violation of 

NFMA.

The Grasslands Plan includes a management objective to meet or move toward PFC 

on at least 80 percent of the perennial streams (Grassland Plan, p 1-2). There is only 

one perennial stream in the project area, the Little Missouri River, which is 

functioning properly. 

There are several reasons why the Grasslands Plan has made an allowance for 

streams that are not at PFC. First, the scientific literature is replete with examples 

of natural, presettlement incision of streams (for a few local examples, see Hamilton, 

1967; Gonzalez 1987, 2001a, 2001b; Biek and Gonzalez, 2001). Natural causes of 

channel incision will continue regardless of land management. Incised channels 

commonly are not at PFC. Second, it is a misconception to believe that all streams 

should always function at PFC. Many desirable riparian species are dependent on 

episodic disturbances. Streams that evolve through episodes of disequilibria 

provide important opportunities for regeneration of cottonwood trees, for episodic 

movement of stored alluvium, and other natural phenomena, none of which is 

inherently bad or. Third, a multiple-use land-management agency must balance 

competing interests. For example, operation of a stock reservoir may fulfill certain 

management objectives, but may cause local impacts to stream reaches downstream 

of stock dams and thereby prevent the downstream reaches from attaining PFC. 

The Grasslands Plan strikes a realistic and fully disclosed balance between 

competing interests within the framework of addressing multiple uses. Fourth, 

some riparian processes and features are relatively responsive to management 

actions; whereas others are not. Highly responsive parts of the system could 

fluctuate from functional at risk to fully functional in a matter of a single year. 

Others, for example the formation of a properly functioning floodplain within an 

incised stream system, could take decades to develop, even with the best landmanagement practices. Some degraded reaches may require years or decades to 

recover even if the affected riparian reach was completely rested. Finally, the DPG 

operates within an intermingled patchwork of land ownerships. Actions on 

neighboring lands can affect conditions on National Forest System lands. The 

Forest Service can strive to improve conditions NFS lands, but it does not control 

land-use activities on surrounding private lands. 

The objective of attaining PFC on 80 percent of streams is realistic given factors 

beyond the control of the Forest Service. In summary, it is a misconception to 

believe that all streams can be and should be at PFC at all places at all times. It is 

incorrect to interpret the Grasslands Plan as "tolerating" non-functioning 

conditions on 20 percent of streams. To the contrary, the Grasslands Plan explicitly 

24 | Response to Comments
North Billings County Allotment Management Plan Revisions

states "For streams identified as "non-functional" or "functional at risk with a 

downward trend,” begin corrective action within 3 years of stream inventories. 

Guideline" (Grasslands Plan p. 1-11). The implementation of restoration plans (see 

SDEIS Chapter 3 Part 2) shows that the DPG is not tolerant of these conditions. 

I-5 Perhaps it is necessary at this late date to remind the Forest Service that under the Clean 

Water Act of 1972, ALL waters of the United States were to be in a fishable/swimmable 

condition by 1979! You are already 30 years late, and it is a violation of federal law to 

sacrifice any streams to private interests, let alone 20% of streams. Where do you find 

the authority to sacrifice water quality and aquatic species in this manner? 

All of the streams in the project area, with the exception of the Little Missouri 

River, are intermittent streams. As such they are neither swimmable or fishable 

because they lack any discharge for extended periods of the year. There are no 

water bodies within the project area listed on the Clean Water Act Section 303(d) 

list for water quality impairment. See also response to comment I-4. The Little 

Missouri River is a perennial stream flowing through approximately 27 miles of the 

project area. This section of the river is both swimmable and fishable and it is not 

listed on the 2008 Section 303(d) list for water quality impairment. 

I-6 What existing conditions clearly demonstrate is that not all of the lands under 

consideration are suitable for grazing livestock. And it is not enough just to be “moving 

toward” PFC in areas that are so chronically degraded. 

The Final Environmental Impact Statement for the Dakota Prairie Grasslands Land 

and Resource Plan (Table B-20) indentifies that 884,730 aces of the Little Missouri 

National Grassland are capable of supporting livestock grazing and that of that 

884,460 acres of the LMNG are suitable for grazing. The proposed project is located 

on the Medora Ranger District one of two ranger districts comprising the LMNG. 

Some of the 270 acres located on the LMNG that are not suitable may be present in 

the project area. However, for all practicable purposes the land in the project area 

is suitable for livestock grazing. 

Chapter 1, Goal 1, Objective 3 of the Grasslands Plan (page 1-2) states that the 

Forest Service is to “Meet or move towards Proper Functioning Condition (PFC) on 

at least 80 percent of perennial streams”. Alternatives 3, 3A, and 4 propose actions 

to move non-PFC streams in the project area towards PFC. Chapter 3 Part 2 of the 

SDEIS describes the rate the allotments may see improvement. Also see response to 

comment I-4. 

I-6a Riparian function and soil productivity are finite resources, and the longer you tolerate 

degraded conditions, the closer you come to irreversible wasting of public resources 

The Forest Service agrees that soil productivity is tied to finite resources. We agree 

that it is not acceptable to tolerate degraded conditions. We agree that to do so 

could irreversibly waste public resources. It is also important to note that these 

Response to Comments | 25
North Billings County Allotment Management Plan Revisions

conditions did not occur overnight and that overall conditions have been improving 

in the grasslands (see response to comment I-8). It is quite evident from the DEIS

and SDEIS, that the existing condition of riparian areas has been thoroughly 

reviewed and presented. Alternatives 3, 3A, and 4 of the SDEIS (Chapter 3 Part 2)

clearly specify, on an allotment-by-allotment basis, the strategies that will be used to 

reverse degraded conditions. Strategies are summarized in response to comment I-3. 

Therefore, it is clear that the Forest Service and the commentor share the same 

desire to fix degraded conditions and to prevent the irreversible wasting of public 

resources. 

The SDEIS (Chapter 1, Issues Eliminated from Detailed Study, Soil Productivity) 

indicates that soil productivity has not been compromised. 

I-7 NFMA requires you to provide for diversity of native plant and animal species, not 

consider them, and not to wait until after you have lost that diversity to consider how to 

recover it. 

All of the action alternatives, over different timeframes, would improve resource 

conditions through a variety of initial management actions (Chapter 3 Part 2). 

These alternatives also provide a back-up plan, including monitoring and additional 

actions (adaptive management), if improvements don't occur at the desired rate. As 

affected resources presumably improve under the alternatives the existing diversity 

of plant and animal communities is assumed to increase. In doing this the project is 

meeting Grasslands Plan standards and guidelines and in so doing is consistent with 

NFMA’s call for a "...diversity of plant and animal communities based on the 

suitability and capability of the specific land area in order to meet overall multipleuse objectives, and within the multiple-use objectives of a land management plan ..." 

(16 USC 1604 (g)(3)(B)).

I-8 What has the cost in terms of diminished biological diversity been from allowing the 

Dakota Prairie Grasslands to be degraded to their present, deplorable state? Which 

species have been hardest hit? 

The DPG is a unique set of national grasslands in that very little of the lands were 

public domain when the Grasslands where created. The DPG is mainly composed of 

lands that were once privately owned. Prior to coming under Federal ownership 

they were farmed and grazed for decades. The combination of prolonged drought, 

farming, and grazing abuses culminated in the dust bowl era of the 1930s. 

Restoration of the lands started in the late 1930s when the lands came under Federal 

ownership. According to Box and Malechek (1987 in Krueger et al 2002), the 

rangelands of the great plains have improved in quality from the early part of the 

20th century (i.e. the Dust Bowl era) due to programs to “correct maladjustments in 

land use” such as was authorized under the Bankhead-Jones Farm Tenant Act. 

Past actions have altered the frequency, intensity and spatial patterns of the 

ecological processes of fire and herbivory that helped shape these communities 

historically. “These relatively recent changes have altered vegetation in this region 

26 | Response to Comments
North Billings County Allotment Management Plan Revisions

and, in turn, have altered the diversity and abundance of many plant and animal 

species (NGP FEIS, page 3-179).” 

Some of the most impacted species include the prairie dog and grassland birds. The 

Grasslands Plan indicates that habitat for these species will be restored and 

managed through active and passive management (e.g. prairie dogs) and 

management of livestock grazing practices for grassland bird habitat. Specific to 

this project, the use of livestock grazing practices, as proposed in Alternatives 3, 3A, 

and 4 will be employed to move the structure distribution towards or meeting the 

objectives of the Grasslands Plan (see Chapter 3 Part 1, Herbaceous Structure). One 

small (<1 ac) prairie dog town occurs within the project area. The town will not be 

actively managed, the prairie dogs will be allowed to expand or contract as 

conditions dictate. See also response to comment I-24 

Invasive grass species of Kentucky and Canada bluegrass, smooth brome, and 

annual brome, are the greatest continuing threat to the maintenance of native 

biological diversity on the LMNG. Several noxious weed species also contribute 

adverse affects, but unlike invasive grasses, noxious weed species are actively 

controlled. The action alternatives (Tables 3.28, 3.29, and 3.30) would positively 

affect plant composition to different degrees. 

I-9 The Most Threatened Birds of Continental America” as the “grassland” birds, including 

the following bird species endemic to or closely associated with grasslands. 

Endemics Secondary (more 

widespread) Species

Secondary (more 

widespread) Species

ferruginous hawk Mississippi kite eastern meadowlark 

mountain plover Swainson’s hawk western meadowlark 

marbled godwit northern harrier dickcissel 

Franklin's gull prairie falcon Savannah sparrow 

Wilson's 

phalarope

greater prairie chicken grasshopper sparrow 

long-billed curlew lesser prairie chicken Henslow’s sparrow 

Sprague’s pipit sharp-tailed grouse clay-colored sparrow 

Cassin’s sparrow upland sandpiper Vesper sparrow

Baird’s sparrow burrowing owl lark sparrow

lark bunting short-eared owl 

chestnut-collared 

longspur

horned lark

Of the endemic grassland bird species that you list, most may occur in the project 

area at times except the mountain plover, Cassin’s sparrow, and McCown’s 

longspur. Among the secondary species listed, Mississippi kite, greater prairie 

chicken, lesser prairie chicken, eastern meadowlark, and Henslow’s sparrow do not 

occur. Dickcissels occur irregularly. The other secondary species may use the 

Response to Comments | 27
North Billings County Allotment Management Plan Revisions

project area. For more information on the avifauna of the LMNG, see: Svingen and 

Martin (2004). 

I-9a Robinson offers the following conservation measures (1) increase the number of prairie 

restoration sites, (2) maintain a network of grassland reserves, (3) remove encroaching 

woody vegetation, (4) maintain some areas that are not grazed or burned for at least 

three years, (5) remove drainage tiles to conserve wetlands, (6) develop grazing practices 

that provide both tall and short grass, (7) minimize early season mowing, (8) minimize 

early season mowing of Conservation Reserve Program lands, (9) aggregate 

Conservation Program lands into large areas, and (10) give special attention to coastal 

wintering grassland areas. Such recommendations for grassland bird conservation 

described by Robinson are not uncommon (see Knopf 1996). Please consider these 

measures in the FEIS, and express the impacts of the proposed alternatives and your 

decision on diversity in relation to the species mentioned [in the previous comment]. . 

Note: your question asks specifically about increasing the diversity of the grassland 

bird species you list. None of the alternatives is likely to increase the diversity of the 

grassland bird species within the project area; i.e. no alternative is expected to 

facilitate establishment/re-establishment of mountain plover, Cassin’s sparrow, 

McCown’s longspur, Mississippi kite, greater prairie chicken, lesser prairie chicken, 

eastern meadowlark, or Henslow’s sparrow. However, this project in the glossary 

of the SDEIS defines diversity as: 

“Diversity refers to the distribution and abundance of different plant and animal 

communities and species within the area covered by land and resource management 

plans. This term is derived from the National Forest Management Act (NFMA). 

This term is not synonymous with biological diversity.” 

This definition includes consideration of both distribution and abundance. 

Therefore our response will consider these factors as well. 

Several of the recommendations you cite, while they may have merit, are not 

relevant to this project. For example, this project does not pertain to previously 

drained wetlands (see above, #5), nor does this project propose management of 

Conservation Reserve Program lands (see above, #8 and #9) or coastal grassland 

areas (see above, #10). The cited recommendations’ that are relevant to this project 

include #1, #2, #3, #4, #6, and #7. 

Recommendation #1, restoration of prairie sites is a part of Alternatives 3, 3A, and 

4. On a small scale, some actions such as interseeding could directly help restore 

some sites by increasing the native species while decreasing the nonnative vegetative 

species. On a larger scale, other management tools propose reducing livestock use, 

which could have a number of positive impacts; restoring fire to the landscape could 

help restore a disturbance factor missing from the development found in true 

mixed-grass prairie; and utilizing grazing systems to alter the species composition to 

28 | Response to Comments
North Billings County Allotment Management Plan Revisions

enhance native plant species, to name a few. Some of these tools may require long 

time frames to achieve objectives.

Recommendation #2, maintaining a network of grassland reserves, would be 

accomplished by all proposed alternatives. The Little Missouri National Grassland 

is a Grassland Reserve (i.e. it is protected from agricultural conversion to cropland 

uses, urban development, etc.). This protection is, and will be, a benefit to all of the 

locally occurring grassland bird species that you have listed above. Several authors 

have pointed out the importance of the National Grasslands to grassland 

conservation, and the Little Missouri National Grassland in particular. For 

example, note that the Little Missouri National Grassland is designated as a 

“globally important bird area” by the American Bird Conservancy. 

Regarding recommendation #3, removing encroaching woody vegetation, no such 

management is proposed under Alternatives 1 and 2. Alternatives 3, 3A, and 4, 

however, do include such provisions. Specifically, these alternatives include 

adaptive management measures such as prescribed burning and mechanical brush 

treatment (see SDEIS, Chapter 3 Part 2). If successful, the reduction in brush, 

shrub, and tree invasion would benefit grassland birds that are particularly 

sensitive to woody establishment (e.g. Sprague’s pipit, Baird’s sparrow and upland 

sandpiper). Conversely, reduction in woody vegetation may lower habitat quality of 

species such as sharp-tailed grouse and savannah and clay-colored sparrows. 

Reduction in tree coverage may also reduce nest and perch sites for species such as 

ferruginous and Swainson’s hawks. 

Recommendation #4, “maintain some areas that are not grazed or burned for at 

least three years,” would occur, in part, under Alternatives 3, 3A, and 4. Those 

alternatives include adaptive management measures such as creation of exclosures, 

implementation of rest-rotation grazing, and multiple-year rest (see SDEIS, Chapter 

3 Part 2). These potential actions would add to those sites within the project area 

that are already excluded from grazing and burning for at least three years. Such 

areas are currently limited to a few small exclosures, typically riparian sites. 

Alternative 1 would exclude livestock grazing entirely from the project area. The 

creation of long-term grazing and burning exclusion areas would be expected to 

increase vegetative litter accumulation; brush, shrub, and tree encroachment; and 

increase the dominance of invasive species such as smooth brome grass and 

Kentucky bluegrass. Of the bird species of interest that occur within the project 

area, none would be expected to benefit from such management long-term (i.e. for 

>10 years). In the shorter-term (1-10 years), species such as Northern harrier and 

short-eared owl would likely increase in distribution and abundance, as these birds 

use areas with thicker grasses and abundant vole populations. Other birds, such as 

Baird’s sparrow and Sprague’s pipit, would benefit until litter accumulation 

exceeded tolerable levels. Conversely, species such as ferruginous hawk, long-billed 

curlew, chestnut-collared longspur, burrowing owl, and horned lark would likely 

see reductions in both distribution and abundance very soon after such a policy was 

adopted. 

Response to Comments | 29
North Billings County Allotment Management Plan Revisions

Recommendation #6, develop grazing practices that provide both tall and short 

grass, would occur under all alternatives, though the relative mix of tall vs. short 

grass would vary considerably. As already explained, Alternative 1 would increase 

availability of tall grass due to the exclusion of livestock grazing. Species such as 

Sprague’s pipit, Baird’s sparrow, northern harrier, sharp-tailed grouse, and shorteared owl would benefit, at least initially. Availability of short grass, however, 

would be expected to decline. The effect on the locally-occurring grassland bird 

preferring short grass, such as ferruginous hawk, long-billed curlew, chestnutcollared longspur, burrowing owl, and horned lark would be adverse. Alternatives 

3, 3A, and 4 both propose managing, utilizing various management tools, for the 

mix of tall vs. short grasses called for in the Grasslands Plan, though the time to 

reach Grasslands Plan objectives could vary considerably. 

Recommendation #7, minimize early season mowing, would be implemented under 

all proposed alternatives. In fact, no mowing would occur under Alternative 1. 

Some mowing might occur under Alternatives 2, 3, 3A, and 4. See, for example, EIS 

Table S.2: “Hay or cut-&-leave crested wheatgrass areas”. The Grasslands Plan, 

however, to which this project tiers, states (p. 1-13): “Delay mowing of grassland 

until July 15 or later to protect ground-nesting birds, including their nests and 

young broods. Project-level analysis will determine the earliest mowing date. 

Guideline”. All ground nesting birds would benefit from this Grasslands Plan 

guideline. Many of the other species on your list would be little affected, due to the 

timing or location of their nests. Burrowing owls, for example, build their nests in 

underground burrows, whereas Swainson’s hawks build their nests in trees. 

Neither site is particularly vulnerable to haying activities. 

I-10 It is not enough to simply point out that local communities depend on cows for their 

livelihood. Privately owned prairie grasslands were converted to agricultural uses long 

ago, to the detriment of native species like prairie dogs and the black-footed ferrets that 

depend on same. We did not create reserves of public lands so that they could be 

similarly converted to private uses -- we created them so that we would not lose species 

like the black-footed ferret, or the sharp-tailed grouse for that matter. If local economies 

are going to be adversely impacted due to managing public wildlands for public wildlife, 

then the blame is not on public lands managers. Nor is this justification for adopting a 

federal lands management policy that can be characterized as an official sanction of the 

tragedy of the commons. 

Under the Multiple Use Sustained Yield Act of 1960 the Forest Service is to manage 

the federal lands under its care for a multitude of different uses. The Grasslands 

Plan was developed to ensure the long-term health of the grasslands; help native 

plants and animals to recover and thrive; and contribute to economic diversity of 

local communities in a sustainable way (Grassland 2002 ROD, p 10-11). This project 

was developed to move the areas towards the goals and objectives in the Grasslands 

Plan. The analysis evaluates the environmental consequences of the proposed action 

and alternatives. Alternative 4 was developed to further reduce adverse effects on 

30 | Response to Comments
North Billings County Allotment Management Plan Revisions

structure. The Economics section located in Chapter 3 Part 1 of the SDEIS provides 

a discussion of the economic effects of the different alternatives. 

I-11 The drought strategies discussed in the DEIS are inadequate and not clearly presented. 

Additional information has been included in the SDEIS (see Chapter 1, Key Issues, 

Key Issue #6. Drought) in response to this comment.

I-12 The Forest Service recently announced that it would begin managing public lands under 

its jurisdiction to maximize carbon sequestration and watershed restoration. Please 

discuss this recent public policy initiative in the FEIS, and provide a thorough analysis of 

the carbon sequestration potential represented by these grasslands in an un-grazed 

versus a grazed condition, and while you are at it you can factor in the reduced 

greenhouse gases that would result if local ranchers were actually forced to reduce their 

herds to levels that their own private ranchlands can support. 

The Forest Service is unsure as to what announcement or policy the commentor is 

referring to in regards to maximizing carbon sequestration. The commentor was 

contacted via e-mail requesting the specific reference for this comment but no

responsewas received. While carbon management is important to the Forest Service 

the Chief of the Forest Service Tom Tidwell in November of 2009 told the Energy 

and Natural Resources Public Lands and Forests Subcommittee that “Carbon will 

not likely be the primarily objective of the Forest Service”. 

The SDEIS (Chapter 3 Part 1, Climate Change) provides discussion of carbon 

storage in an ungrazed situation. This section also provides some discussion on the 

relationship of healthy grasslands and carbon storage in properly stocked and 

managed grasslands. 

The Forest Service agrees that livestock operations on private lands do contribute 

green house gases, however, determining and enforcing livestock carrying capacities 

on private lands is beyond the authority of the Forest Service. 

I-13 Certainly, anything short of dramatically reduced stocking rates on these particular 

allotments would be completely unacceptable. Balancing multiple uses does not 

authorize the Forest Service to sacrifice public uses to private ones. WWP believes that a 

modified Alternative 1 should be the chosen alternative in this case, revoking permits for 

those allotments where chronic degradation has resulted in non-functioning 

streams and potentially irreversible losses of biological diversity. 

The Forest Service agrees that it has no authority to sacrifice public uses for private 

ones, however, as noted in response to comment I-10 it does, however, have a 

responsibility to provide for multiple use of the resources some of which are used by 

private entities such as mineral, timber, and grazing companies. The Grasslands 

Plan 2006 Livestock Grazing ROD, page 9, authorized grazing on the DPG, Chapter 

3 of the SDEIS reveals the effects of different grazing alternatives for the proposed 

Response to Comments | 31
North Billings County Allotment Management Plan Revisions

project. The IDT evaluated existing and identified where resource conditions were 

not at the desired condition in the Grasslands Plan. Based on this the team 

developed corrective actions, as described in Alternatives 3 and 3A. The team 

developed Alternative 4 to provide an additional approach to improving grassland 

conditions while allowing grazing to continue. 

As noted in response to comment I-8, the rangelands of the great plains have 

improved in quality from the early part of the 20th century due to programs to 

“correct maladjustments in land use” such as was authorized under the BankheadJones Farm Tenant Act. All of the streams identified as non-functioning or 

functioning at risk were only for segments of the stream. The areas non-functioning 

or functioning are based on local conditions and circumstances. As noted in the 

SDEIS Riparian section livestock exclosures along Ash Coulee illustrates that 

desired conditions can be met and that removal of livestock grazing from the entire 

allotment is not required to improve conditions. 

I-14 WWP maintains that the DEIS does not represent a hard look at these environmental 

concerns, and is inadequate to comply with NEPA’s full disclosure requirements. Please 

address these inadequacies in the final EIS. WWP is especially concerned over the 

precedent this decision represents in relation to other grassland units of the Dakota 

Prairie Lands. Among the issues that are not thoroughly analyzed in the draft EIS include 

impacts to wildlife diversity and habitat, especially as measured by visual obstruction 

readings, woody draw health, riparian conditions relative to referent conditions (PFC 

methodology), and the cumulative, often irreversible impacts of grazing on the diversity 

of native plant composition, especially with regard to undesirable invasive grasses, 

carbon sequestration impacts and potential (cumulatively across the Dakota Prairie 

Grasslands), and the actual costs associated with particular alternatives – not just the 

potential economic impacts on local private interests. 

The agency is unsure how this project represents a precedent in relation to other 

grassland units. This project analyzed the conditions on these specific allotments, 

and developed alternatives to reduce adverse effects as required by NEPA. Any 

future actions will also go through the NEPA process addressing the conditions and 

concerns specific to that area. 

The DEIS and SDEIS fully disclose the effects of the action on the resources in the 

project area. The SDEIS has been reformatted to more clearly show the effects 

analysis at the project area level (Chapter 3 Part 1) and at the allotment level 

(Chapter 3 Part 2). Chapter 3 of the SDEIS contains the detailed analysis of these 

issues: 

Wildlife diversity and habitat especially as measured by visual obstruction readings:

The SDEIS, the Grasslands Plan, and the NGP FEIS recognize the role of habitat on 

wildlife diversity and habitat diversity, including how it may relate to sensitive 

species (see SDEIS, Chapter 2, Sensitive Species, Management Indicator Species, 

Raptors; and Chapter 3 Part 1, Herbaceous Structure) and sharp-tailed grouse 

32 | Response to Comments
North Billings County Allotment Management Plan Revisions

(SDEIS, Chapter 3 Part 1, Sharp-tailed Grouse). Habitat diversity can be linked to 

species diversity through the visual obstruction readings (ibid.). This link is also 

recognized in the NGP FEIS on pages 3-72, 3-190, 3-240, and 3-480 to 3-493, in 

Appendix H of the NGP FEIS, and in the Grasslands Plan in the objectives and 

desired conditions to achieve those factors conducive to diversity (e.g. pp. 1-13 

through 1-17, 1-19 to 1-20, 2-11 to 2-15, 2-18 to 2-23, etc). The relationship between 

habitat diversity and species diversity is analyzed in the NGP FEIS (see above 

references). Also see response to comment I-24. 

Woody draw health is described in detail by allotment in the Woody Draw section of 

the DEIS and in Chapter 3 Part 2 of the SDEIS.

Riparian conditions relative to referent conditions (PFC methodology): riparian 

condition, PFC ratings are described in detail by allotment in Chapter 3 Part 2 of 

the SDEIS.

Irreversible impacts of grazing on the diversity of native plant composition: - As note 

in the response to comment I-8 grassland conditions are improving; therefore they 

are not irreversible. The DEIS and SDEIS evaluates the effects of the alternatives to 

further move the allotments towards the desired conditions both at the allotment

scale and for the area as a whole. 

Carbon sequestration – is addressed in the DEIS on pages 3-179 and 180 and in the 

SDEIS in the Issues Eliminated from Detailed Study, Climate Change section.

Economics - The marginal costs to the agency associated with improvements in each 

alternative are included in the SDEIS, Chapter 3 Part 1, Economics. Since there are 

other grazing allotments in the District's grazing program, administrative costs are 

not expected to change substantially through implementation of any of the 

alternatives. 

I-15 Regarding invasive grasses, it is not enough for purposes of satisfying NEPA and NFMA 

to simply state that “[t]here is a need to look at ways to reduce/manage invasive 

grasses.” The Forest Service needs to take a hard look at alternative ways to protect 

plant diversity from non-desired invasive species, and incorporate that analysis into this 

decision-making process. Obviously, the most effective means for stemming the flow of 

invasive species is to eliminate the vectors, which in this case is almost assuredly cattle 

grazing. 

As identified in the SDEIS there is a concern that a combination of the expansion of 

invasive grass species and current grazing strategies is adversely affecting the 

desired mosaic of seral stages and maintenance of native plant communities (SDEIS 

Chapter 2). The Forest Service took a hard look at invasive grasses at the broad 

scale (landscape) as well as in each allotment. Alternatives 3, 3A, and 4 propose an 

array of different initial actions to address invasive species. The grazing 

management tool box also contains numerous management tools that can be used to 

Response to Comments | 33
North Billings County Allotment Management Plan Revisions

address invasive species. See the Seral Stage section of Chapter 3 Part 1 of the 

SDEIS for a discussion on initial actions and their effects on invasive species.

Chapter 3 Part 2 of the SDEIS provides an allotment by allotment discussion of the 

effects of the alternatives.

I-16 The Dakota Prairie Grasslands LRMP calls for 5% rest on the landscape. According to 

the ROD, “[p]lan direction will be specifically implemented on individual grazing 

allotments through the development of AMPs...” (p. 9). The proposed decision is not in 

conformance with this approach, instead relegating rest options to the “adaptive 

management” toolbox. Furthermore, WWP believes that it is inappropriate to assume 

you are meeting the 5% standard based on levels of deferred rotation. 

The Grasslands Plan (Glossary, p. 45) defines rest as “To leave an area of rangeland 

ungrazed by livestock or unharvested by mechanical methods for at least one year 

(12 consecutive months).” Pastures, depending upon how many, their size, and 

length of season of use, managed under a two or more pasture rotation do receive 

rest. For example, in a two-pasture deferred rotation in an 8 month season, one 

pasture would be grazed May through August of the first year. In the second year, 

that same pasture would be grazed September through December. Therefore, after 

the grazing period in the first year, the first pasture would have 12 consecutive

months of rest (September through August of the following year). Twice over 

rotations do not have the built-in individual pasture rest and need to be monitored 

to assure rest is being achieved through other means described below. The 

Grasslands Plan rest objective can be met in several different ways. The topography 

of the badlands of the North Billings project does not lend itself to uniform grazing. 

Lack of water also results in nonuse or “rest”. The implementation of the adaptive 

management toolbox will add to the amount of lands being rested from livestock 

grazing. An analysis of pasture rotations by alternative showed Alternative 1 would 

provide 100 percent rest across the landscape with the project area every year after 

year two of implementation. Alternative 2 would provide at least five percent rest 

across the landscape within the project area. Alternatives 3, 3A, and 4 would 

provide at least eight percent rest across the landscape within the project area (see 

Project Record, Supporting Documentation, Range). 

I-17 Since the 2006 Grazing ROD states that all objectives will be met at the allotment level, it 

is inappropriate to evaluate or monitor compliance with objectives at the landscape level. 

Instead, they must be included as enforceable, mandatory terms and conditions in the 

allotment permits themselves. 

The Forest Service believes the commentor is referring to the part of the 2006 ROD 

where it states “[p]lan direction will be specifically implemented on individual 

grazing allotments through the development of AMPs through the Demonstration 

Project. Monitoring and evaluation of allotments will determine if the Grasslands 

Plan desired conditions are being met.”

34 | Response to Comments
North Billings County Allotment Management Plan Revisions

Objectives are concise, time-specific statements of measurable planned steps taken 

to accomplish a goal (Grasslands Plan p. 1-1). While in essence it is true that 

objectives will be considered at an allotment level, some objectives in the Grasslands 

Plan are intended to be measured at a landscape scale. For example composition 

and structure objectives were established for the geographic area scale (see 

Grasslands Plan pages 2-11 through 2-13 for example). So different scales of 

monitoring may be very appropriate even for allotment management plans. 

Differences in allotment size, specific habitat needs in the area, biological capability 

and other factors may determine which objectives should be measured in any given 

allotment.

The Forest Service has also agreed via the Demonstration Project that AMPs will be 

developed at the landscape or multiple allotment level (2006 ROD p. 16). 

The Medora Grazing Association Grazing Agreement (as of October 20, 2009) is the 

document that allows the association to permit allotments within the project area. 

Allotment Management Plans are the tools that provide specific direction for each 

individual allotment on how to address Grasslands Plan goals and objectives, and 

are incorporated as a provision of the grazing agreement/permit. 

I-18 As proposed, the Adaptive Management toolbox is not sufficient to assure compliance 

with all relevant standards and guidelines. An adaptive management approach must 

allow for modification of terms and conditions as better information became available 

through scientific research and operational experience. According to adaptive 

management experts, this approach enables managers to operate in the face of 

uncertainty and to learn by doing, thereby leading to improved understanding and moreeffective management over time.[1] In principle, learning in an adaptive management 

setting involves systematically testing—either operationally, scientifically, or both—

different management alternatives to gain knowledge. The alternatives are developed on 

the basis of the best information available at the time, and, as management proceeds, 

techniques that do not work are modified or replaced by others. 

The SDEIS includes a section under each resource regarding applicable standards 

and guidelines and whether or not they will be met by alternative (SDEIS, Chapter 

3 Part 1). 

The Forest Service agrees in principle that adaptive management should allow for 

modification of management practices as better information becomes available. The 

grazing management tool box provides a host of different management tools that 

may be used to modify management actions if monitoring shows current actions for 

an allotment are not meeting desired results. The grazing management toolbox is 

not all inclusive and the possibility of adding new tools is recognized in the SDEIS

(Chapter 2, Alternatives Considered in Detail, Alternative 3). 

I-19 Adaptive management shares a number of key features with best management practices—

such as those articulated in the Government Performance and Results Act of 1993 and 

the Comptroller General’s 2004 forum on high-performing organizations[2]—including 

Response to Comments | 35
North Billings County Allotment Management Plan Revisions

identifying clearly defined, measurable, and results-oriented management objectives; 

designing and implementing a monitoring plan; making decisions based on management 

objectives; effectively managing partnerships while maintaining accountability to 

Congress and the public; and actively involving key stakeholders over time to engender 

public support. The monitoring you propose is not adequate to serve the purposes of 

adaptive management. Please conform you toolbox to these widely accepted principles. 

The Grasslands Plan, Chapter 1, defines management objectives for the Dakota 

Prairie National Grasslands while Chapters 2 and 3 provided desired conditions for 

Geographic Areas and Management Areas. The Grasslands Plan Direction Specific 

to Project Area section in Chapter 1 of the SDEIS provides a summary of 

Grasslands Plan direction in relation to range resource management. Chapter 3

Part 1 of the SDEIS identifies the desired condition for different resources of 

concern in the project area. Chapter 2 of the SDEIS under the Monitoring section 

identifies the monitoring plan that will be used to monitor results of management 

activities implemented on the different allotments. Also included are trigger points 

which, if reached, result in review and potential additional management 

adjustments. The SDEIS, Chapter 3 Part 2 describes by allotment the type and 

frequency of monitoring in relation to the resource issue(s) for each allotment. 

The Adaptive Management section in Chapter 1 of the SDEIS describes this 

project’s approach to adaptive management and the role monitoring plays in 

adjusting management action if initial management actions are not meeting or 

moving towards desired resource conditions. The grazing management toolbox 

(SDEIS, Table 2.1) identifies available tools for this project plus the option of 

additional new techniques if such become available in the future. Monitoring results 

for this site-specific project will be considered in the wider Grasslands Plan 

monitoring (see Grasslands Plan, Chapter 4). If monitoring shows a need to expand 

the management options for this project beyond the tool box, then another 

assessment and/or decision may be to be initiated with the accompanying public 

involvement. The Forest Service believes that the approach to adaptive 

management presented in the SDEIS is creditable.

I-20 Concerning sharp-tailed grouse, the MIS for this area, please discuss the cumulative 

impacts of grazing on sharp-tailed grouse population trends, utilizing the best scientific 

information available, and discuss the viability of sharp-tailed grouse in the project area 

specifically, and throughout the Dakota Prairie Grasslands are generally. 

The direct and indirect effects of the various alternatives on sharp-tailed grouse and 

their habitat may be found in the SDEIS, Chapter 3 Part 1, Sharp-tailed Grouse

section. The SDEIS evaluates the cumulative effects of past, present and reasonably 

foreseeable actions on sharp-tailed grouse. 

The viability of the sharp-tailed grouse is addressed through the Grasslands Plan.

The Grasslands Plan identifies an objective of “Within 15 years, for threatened, 

endangered, sensitive, and MIS, demonstrate positive trends in population viability, 

habitat availability, habitat quality, and population distribution within the planning 

36 | Response to Comments
North Billings County Allotment Management Plan Revisions

area”. The Grasslands Plan contains no obligation to conduct monitoring or 

surveying within a proposed project area although project data can be used to 

support Grasslands monitoring for threatened, endangered, sensitive, and MIS 

species. The Grasslands is implementing its Grasslands Plan Monitoring Strategy 

which is documented in annual reports incorporated here by reference. The SDEIS 

(Chapters 2 and 3) identifies that the action alternatives, under different 

timeframes, will improve different resources and in so doing help move the LMNG 

towards the above Grasslands Plan objective.

I-21 While Alternative 1 clearly is the most beneficial alternative for sharp-tailed grouse, at 

least under some version of Alternative 4 the Forest Service could maintain that it is 

managing the area for the benefit of its management indicator species, as required by 

law. 

Thank you for the comment. The effects analysis of each alternative on sharp-tailed 

grouse is found in the SDEIS, Chapter 3 Part 1, Sharp-tailed Grouse section. 

Discussion about herbaceous structure (i.e. habitat) is found in the SDEIS, Chapter 

3 Part 1, Herbaceous Structure section. Also see response to comment I-20. 

I-22 Why is there not a biological evaluation for the sharp-tailed grouse included as an 

appendix to the DEIS? 

Forest Service Manual (FSM) 2670.5 states that a “biological evaluation” be 

accomplished for ground disturbing activities for federally threatened, endangered, 

and Forest Service sensitive species – management indicator species are not 

discussed. 

Sharp-tailed grouse is a management indicator species (MIS). FSM 2620.3, 

identifies that the purpose of MIS is “... to address issues, concerns and 

opportunities for plants, wildlife, fish, and sensitive species habitats through all 

planning levels.” Consistent with this direction, the sharp-tailed grouse is addressed 

separately in the DEIS (page 3-152) and the SDEIS, Chapter 3 Part 1, Sharp-tailed 

Grouse section. 

I-23 Also, please include in the FEIS a discussion of the other grassland obligates for which 

the sharp-tailed grouse is an indicator species, and indicate whether the Forest Service 

has any information that would indicate such species are no longer viable. 

The plains sharp-tailed grouse is the management indicator species for the 

biological community associated with grasslands containing scattered shrubs and 

diverse vegetative structure (Grasslands Plan, Appendix H-2). The NGP FEIS, p 3-

261 identified other species that utilize similar habitat for at least part of the year. 

These include but are not limited to American bittern, dickcisssel, LeConte’s 

sparrow, Sprague’s pipit, northern harrier, short-eared owl, mallard (nesting 

habitat), gadwall (nesting habitat), shoveler (nesting habitat), greater prairie 

chicken, prairie vole, Dakota skipper, Powesheik, skipper, Ottoe skipper, and regal 

fritillary butterfly. 

Response to Comments | 37
North Billings County Allotment Management Plan Revisions

Regulations for the establishment of MIS (36 CFR 219.19 and 219.20) do not imply 

that the population dynamics of MIS directly represent the dynamics of other 

species. However, in an effort to help assess the relationship between sharp-tailed 

grouse (MIS) and grassland obligates on the DPG, the Rocky Mountain Bird 

Observatory (RMBO) has monitored grassland birds across the DPG since 2004. 

RMBO has employed the point transect survey methodology within the Grasslands 

Plan long-term sharp-tailed grouse monitoring blocks identified for each unit of the 

DPG (Sparks and Hanni 2008). The 2008 report from this RMBO monitoring effort 

(Sparks and Hanni 2008) finds that certain local grassland birds need attention. 

These include the Baird’s sparrow, Sprague’s pipit, lark bunting, and the 

grasshopper sparrow. The attention is warranted to “reverse significant, long-term 

population declines or sustain vulnerable populations.” However, viability is not 

assessed in Sparks and Hanni (2008). As noted above, the Sprague’s pipit and 

Baird’s sparrow was identified as a species that uses similar habitat that may 

overlap with sharp-tailed grouse habitat. 

Further, the Grasslands Plan identifies an objective of “Within 15 years, for 

threatened, endangered, sensitive, and MIS, demonstrate positive trends in 

population viability, habitat availability, habitat quality, and population 

distribution within the planning area (p. 1-3 Grasslands Plan).” The Grasslands 

Plan contains no obligation to conduct monitoring or surveying within a proposed 

project area, although project data can be used to support Grasslands monitoring 

for threatened, endangered, sensitive, and MIS species. The Grasslands is 

implementing its Grasslands Plan Monitoring Strategy which is documented in 

annual reports incorporated here by reference. The SDEIS (Chapters 2 and 3) 

identifies that the action alternatives will improve different resources, and in so 

doing help move the LMNG towards the above Grasslands Plan objective. 

The RMBO report found lark bunting and the grasshopper sparrow in the Bell 

Lake grouse monitoring block on the extreme western portion of the project area. 

Baird’s sparrow and Sprague’s pipit were not detected in this block. The North 

Billings block has not yet been sampled. However, the Forest Service wildlife 

biologist has observed Sprague’s pipit within the project area in the spring while 

conducting sharp-tailed grouse lek surveys.

I-24 In other words, are all native grassland species still viable in the project area, and if not, 

why not? 

It is the policy of the Forest Service (FSM 2670.32) to avoid or minimize impacts to 

plant and animal species whose viability has been identified as a concern. Consistent 

with Forest Service direction, the Northern Region developed a list of sensitive 

species for each of the units in the region. Sensitive species are defined in FSM 

2670.5. Biological assessments/evaluations were completed for the proposed 

alternatives of this project (see Project Record, Specialist Reports and Notes, 

Wildlife and Botany Reports) and are summarized in the SDEIS, Chapter 2, 

Sensitive Species, Management Indicator Species and Raptors.

Species were typically evaluated on the basis of habitat since few specific surveys 

have been conducted in the project area. The analysis determined that viability of 

38 | Response to Comments
North Billings County Allotment Management Plan Revisions

no species is threatened within its range with the implementation of this project. 

Alternatives 3, 3A, and 4 would be beneficial for some of the grassland obligates, 

over time, especially with actions that would ensure a diversification of grassland 

habitats. 

In addition to the Forest Service sensitive species list, to ensure a full suite of known 

native species where there may be conservation concerns we also referenced the 

“North Dakota Comprehensive Wildlife Conservation Strategy (Hagen et al 2004).” 

From this list and of those species potentially located in the project area, it is 

projected that the project area will be moving towards or meeting Grasslands Plan 

objectives, that none of the species range-wide viability would be adversely impacted 

under the action alternatives (Project Record, Specialist Reports and Notes, Wildlife 

Report, Appendix D; North Dakota Comprehensive Wildlife Conservation Strategy, 

2005). 

Some native grassland species have been lost in the planning area since settlement 

and are no longer present on the LMNG at this time. These include the grizzly bear, 

the wolf, the black-footed ferret, and bison (USDA 2000). The list may include the 

mountain plover as it was noted by T. Roosevelt during his stay in ND in 1885 (NGP 

FEIS Appendix H), but is currently not known to occur in ND. The bear, wolf, and 

bison species were lost early in the 20th century due to hunting pressure and 

predator control. The black-footed ferret and mountain plover were lost to the area 

due to the substantial reduction of black-tailed prairie dog habitat. 

I-24a You note that bison are a native species, and indicate that cows have taken their place, 

but the impacts of bison on soils, plant species, and riparian habitats are far more suited 

to healthy ecosystems than cows. In fact, it is not really feasible to provide for diversity 

of native plant and animal species in the absence of a keystone species like the bison. 

The Forest Service acknowledges that domestic cattle can and have impacted the 

ecosystem differently from bison NGP FEIS (3-234). Archer and Smiens (1991) 

conclude that “while grazing has been an important selection pressure in many 

ecosystems, man has substantially changed its frequency, intensity, extent, and 

magnitude with the introduction of livestock.” See also Towne et al (2005). 

However, it is incorrect to state that a diversity of native plant and animal species 

cannot be provided for without bison. Fuhlendorf and Engle (2001) assert that 

cattle and fire can be used together in an ecosystem approach to restore 

heterogeneity to tall-grass and mixed grass ecosystems. The NGP FEIS (p 2-14) 

determined that “Cattle grazing can adequately achieve the desired future 

vegetation conditions.” Stueter and Hidinger (1999) conclude “that conserving the 

soil, water, and biological resources of the mixed-grass prairie will be accomplished 

with sound grazing management, rather than determined solely by the choice 

between bison and cattle. Whether managing mixed prairie with bison or cattle, the 

stocking rate and grazing management will determine the long-term health of both 

the prairie and grazing animal.” Through the use of various management tools, 

monitoring of resource conditions, and adaptive management decisions, 

improvement of habitat conditions for native and desired non-native species will be 

achieved over time.

Response to Comments | 39
North Billings County Allotment Management Plan Revisions

I-25 Historic records suggest bison were not evenly distributed across the prairie and left 

large areas ungrazed for one to several years. Bison historically moved nomadically in 

response to vegetation changes associated with rainfall and fire. The time lag for return 

movements provided deferment during the regrowth period for which according to both 

historic and archeological records may have ranged from 1 to 8 years (Malainey and 

Sherriff 1996 and others). This interval would have provided a natural “rest” interval 

and is consistent with spatial heterogeneity models that suggest stability in plantherbivore interactions (Coughenour 1991). Today vegetation structure on public 

grasslands has been “homogenized,” with little “short” or “tall” structure exiting. The 

dynamics of herbivory differ between that of wide ranging bison herds and present day 

domestic livestock grazing systems (Hartnett et al. 1997). For a particular area, 

herbivory by wide ranging bison herds was one of high intensity and short duration 

followed by a 2 to 3 year period of rest (Higgins 1986). In contrast, grazing by domestic 

livestock is characterized by high intensity over long duration followed by short lengths 

of rest, depending on the grazing system and management scenario. Grazing in terms of 

spatial extent has exhibited little change in extent with substantial portions of the current 

landscape (about 95%) grazed by domestic cattle. 

WWP would like to see a native ecosystem (or “ecosystem management”) alternative 

added to the FEIS that would allow the public to see how differently the project and 

planning area would function and appear if it were managed for native species instead of 

private livestock. 

The SDEIS (Chapter 2, Alternatives Considered but Dropped from Detailed 

Analysis) considered an “Ecosystem Management” alternative but eliminated it 

from detailed study. It was eliminated for several reasons. First, the state would 

need to fully support and participate in such an alternative, and second, a similar 

response from the mixed-grass prairie can be gained by domestic livestock. 

An alternative to allow for free-roaming bison was also considered, but eliminated 

from detailed study in the Northern Great Plains EIS (see 2003 WO appeal decision, 

starting at page 19). Since this EIS tiers to the Grasslands Plan FEIS there is no 

need to reconsider this alternative for this project (40 CFR 1508.28) 

I-26 The Forest Service should consider re-introduction of bison, at least on a demonstration 

project basis, for those allotments that would be eliminated under a modified Alternative 

1 due to chronic adverse environmental impacts from over-grazing by cattle. 

See response to comment I-25 

As noted before conserving the soil, water, and biological resources of the mixedgrass prairie can be accomplished with sound grazing management, rather than 

determined solely by the choice between bison and cattle; therefore this alternative 

was not considered in detail. The SDEIS identifies specific resource concerns and 

alternative ways to address those concerns through grazing management (SDEIS, 

Chapter 3 Part 2).

40 | Response to Comments
North Billings County Allotment Management Plan Revisions

I-27 Finally, the DEIS does not adequately disclose the costs associated with the proposed 

increases in infrastructure in Alternative 3. Please provide full disclosure on this, as well 

as the costs associated with increased resource damage associated with the excessive 

stocking rates that would result from this alternative.

The Environmental Consequences – Economics, Direct and Indirect Effects section 

in Chapter 3 Part 1 of the SDEIS reveals the total costs of proposed infrastructure 

by alternative as well as other information. Documents in the project record contain 

costs by allotment by alternative. 

The costs associated with the proposed increase in infrastructure for Alternative 3 is 

estimated at $47,917/year and are included on pages 3-253 and 3-254 of the DEIS. 

These costs are also included as expenditures in the agricultural support industry 

for the analysis of impacts to local jobs and labor income. Given that Alternative 3 

would continue existing stocking levels with application of tools to improve range 

conditions there is no reason to expect costs from increased resource damage.

IKE HECKER 

J-1 Another key issue of the woody draws lack of regeneration is the droughts we have had in 

the past years – We may get some rains but as soon as a lot of the young saplings just get 

started to grow we get dry weather and the saplings do not have a chance of continuing 

to grow. With the management of the grazing in the pastures now we do not harvest the 

forages off as much as we did 40 years ago, so the draws are more septable to new 

growth trees. 

It is normal for the vast majority of woody seedlings to perish during their first year 

of growth due to competition with other plants for limited moisture resources. 

However, woody draw communities have persisted under climate extremes of 

drought and late spring freezes for thousands of years and only a small fraction of 

one percent of germinated seedlings are required to survive and advance to later 

growth stages for maintenance of the woody community. Drought occurs at an 

annual frequency of 17 percent (Koch 2003) to 27 percent (Smart and Sedivec, no 

date) in the northern Great Plains and green ash saplings may require ten or more 

years before attaining sufficient root growth and leaf area to become well 

established. Therefore, the majority of all saplings experience periods of drought 

during their initial years of establishment. The occurrence of relatively high sapling 

numbers in sample sites rated as Healthy attests to their ability to tolerate these 

conditions, as does high sapling numbers reported by other researchers from high 

condition or minimally disturbed sites (Project Record, Specialist Reports and 

Notes, Botany Report). 

Lower levels of current grazing compared to past or historic levels identified by the 

commenter are not disputed. Comparison of aerial photographs suggests current 

plant cover in the uplands is greater than it was in 1939 at the end of a severe 

drought period. However, a disproportionate amount of time that livestock spend in 

Response to Comments | 41
North Billings County Allotment Management Plan Revisions

woody draws compared to the total pasture acreage is a factor contributing to the 

low rate of successful woody species recruitment in many sites. A lack of recent tree 

and shrub recruitment and structural complexity was attributed to high levels of 

livestock disturbance as evidenced by direct observations of livestock in the draw, or 

heavily used trails, mechanical damage, and high amounts of manure. Further 

evidence of livestock as the principal cause of low woody species recruitment was 

observed in sites with a range of topographic characteristics that influenced 

livestock accessibility. For instance, steep slopes above the drainage bottom, or 

steeply downcut drainages with minimal evidence of livestock trailing and browsing 

often contained an increased number of seedlings, saplings, and young trees. 

Increased trail networks and mechanical damage along more level areas of the 

drainage contained fewer or no young trees and saplings despite greater soil depths 

and moisture inputs from the surrounding slopes that should contribute to a greater 

density of regeneration.

J-2 We can not afford to take a cut in numbers of cattle- We bought these ranches on a 

Preference number what we believe we can run – and by figuring in so much per animal 

as far as costs and income weather we can make a living with the numbers as we are to 

run. 

The Forest Service recognizes that some ranchers have built their operations on a 

combination of their own private forage and federal forage; however, grazing 

permits convey no right, title, or interest held by the United States in any lands or 

resources (CFR 36 Parts 200-299 Parks, Forests, and Public Property, 223.3 (b)). 

The Forest Service does recognize the contribution that grazing permits make to 

ranch operations and the local economy. The Forest Service also recognizes that 

some resources are not meeting the desired condition described in the Grasslands 

Plan. The Responsible Official has considered the potential effects on the 12-county 

economic impact area and the actions needed to move the resources toward the 

desired condition. 

J-3 Alternative 4 – Allotments 128 page 3-37 The 35 acre proposed enclosure to keep cattle 

out to try and help the head wall cutting will not work to solve the problem. The badlands 

are very fragile and it is a natural occurring process threw the year as freezing – rain 

thawing and gully washers to the frozen chunks of ice coming down the creek at a force 

that would cost a substantial amount of finances to slow the water down and prevent 

head wall cutting. 

The initial action of installing a riparian exclosure will not address the headwalling 

occurring in allotment 128 on Whitetail Creek. I don’t believe that livestock grazing is a 

causal factor for this occurrence. Yet if this exclosure is implemented I’ll lose 

approximately 22 AUMs every year. Finally I don’t feel its economically feasible to 

implement this tool especially if it’s not going to address the issue. 

The establishment of exclosures in other nearby streams (e.g., Ash Coulee) has 

shown that channel morphology and riparian vegetation respond quickly and 

42 | Response to Comments
North Billings County Allotment Management Plan Revisions

desirably when livestock are excluded from riparian areas. The control of all 

riparian disturbances possible and the installation of structures to control stream 

power are specifically intended to halt, retard, and possible reverse channel cutting 

and headwall erosion. 

The commentor may be correct in suggesting that the causal factor for channel 

incision is not related to livestock grazing. However, livestock grazing practices 

need to be managed to address resource concerns. While we may not know the 

cause of incision, the long-term, ongoing erosion, caused by headwall migration, is 

another matter. Livestock access and use of the riparian zone has exacerbated 

resource conditions and contributed to resource damage.

The Grasslands Plan (p. 1-11) provides specific direction to devise strategies to 

address resource concerns on riparian reaches that are rated FAR-D or NF. A 

small exclosure fence is a far more economically feasible tool than the other obvious 

alternative--removal of livestock from the entire pasture. The exclosure directly 

addresses the issue by attempting to restore riparian vegetation, by removing the 

largest threat to vegetation establishment (i.e., livestock), and by eliminating 

livestock trailing and hoof damage to stream banks. 

There is no proposal in the four alternatives to reduce grazing because of the 

installation of a 35-acre exclosure. Proposed Authorized Use reductions in 

Alternative 4 are intended to improve upland conditions and to provide additional 

high vegetative structure for wildlife needs. AUMs for the allotment will be 

adjusted through the AOI to take into consideration the riparian forage removed 

from livestock use due to the exclosure.

J-4 Alternative 3 and 4 – I am totally against combining two herds [cow/calf and two year 

olds] into one herd. In most of the pastures there would NOT be enough water to water 

them all. Also have concerns with implications of rest rotation due to the size of pasture 

128-01. 

The Forest Service agrees that this was overlooked in the development of 

Alternative 3. A meeting was held with the permittee on January 14, 2010 to further 

discuss this comment. The SDEIS Chapter 3 Part 2 has been updated to reflect this 

meeting. In Alternatives 3 and 3A, the initial actions have been changed to continue 

a complementary modified deferred rotation without specifically stating how many 

herds of livestock will be ran.

J-5 I feel in the last 25 years the woody draws have tremendously improved as far as new 

saplings and young formations of trees. Trees are also growing up and out the sides of 

the draws tremendously. 

Based on measurements between 1988 and 1998 from long-term monitoring plots 

across the LMNG, Duxbury (2009) estimated a 29 percent decrease in the density of 

all green ash trees greater than 1-inch dbh, and an almost 50 percent decrease in 

Response to Comments | 43
North Billings County Allotment Management Plan Revisions

trees less than 4 inches dbh (Project Record, Specialist Reports and Notes, Botany 

Report). A subset of thirteen sample sites located in the project area indicated a 

slight but relatively insignificant decrease in the density of trees greater than 1-inch 

dbh between 1993-2008 (SDEIS, Chapter 3 Part 1, Woody Draws, Existing 

Condition, Trends in Woody Draw Structure). The density of saplings less than 1-

inch dbh fluctuated during the four measurement dates, but there was a 63 percent

decrease from a high of 827 saplings/acre in 1993, to 305 saplings/acre in 2008. The 

data therefore conflicts with the perception of appreciably increased tree density or 

woody draw development. Average tree density measurements from Healthy 

sample sites across the project area were considerably less than those reported by 

other researchers from relatively high condition sites (Project Record, Specialist 

Reports and Notes, Botany Report) suggesting that Healthy ratings of the analysis 

were relatively liberal and well below potential conditions. 

Comparison of historic and current aerial photographs did not substantiate the 

perception that woody draw communities are appreciably expanding across the 

landscape (SDEIS, Chapter 3 Part 1, Woody Draws, Existing Condition, Trends in 

Woody Draw Extent and Project Record, Specialist Reports and Notes, Botany 

Report - Appendix D). Although there was field evidence of green ash trees 

expanding into discontinuous shrub patches situated adjacent to some woody draws, 

or expanding slightly up-drainage at the head of woody draws, these sites were not 

sufficiently developed or extensive to support the perception of tremendous woody 

draw expansion. Additionally, the small acreage of these sites does not compensate 

for the occurrence of poor conditions among less than Healthy sites, or apparent 

regression of several sites towards shrub/grass communities. 

The above paragraphs have discussed green ash woody draws. Other woody 

communities relevant to the project area include Rocky Mountain juniper, silver 

sagebrush, and snowberry. The Forest Service acknowledges that Rocky Mountain 

juniper and several woody shrub species are expanding into upland grass 

communities due to wildfire control and livestock grazing induced changes in the 

herbaceous layer (SDEIS, Chapter 3 Part 1, Woody Draws). See also response to 

comment K-55. 

J-6 I also know that a developed spring is more economical than a well as long as the spring 

produces enough water for the herd of cattle. When you have a developed water tank at a 

spring the cattle will have a trail to and from the spring - they may loaf around at the 

spring during the heat of the day but they will not be wallowing around in the creeks and 

muck it all up if they have a spring tank that is cleaned out from occasion to occasion. I 

believe that a developed spring has less impacts than removing the spring development 

and having a natural seep that livestock could access and disturb. 

The Forest Service agrees that a developed spring can be more economical than a 

well as long as the spring produces enough water for the herd of cattle. However, 

the Grasslands Plan does identify the need to maintain and protect riparian areas 

(Grasslands Plan pp. 1-2, 1-9, 1-10, 1-13, 1-19). A meeting was held with the 

44 | Response to Comments
North Billings County Allotment Management Plan Revisions

permittee on January 14, 2010 to further discuss this comment. The SDEIS Chapter 

3 Part 2 has been updated to reflect this meeting. In Alternatives 3, 3A, and 4 the 

above mentioned spring developments will not be removed but will be fenced out. 

This provides a control mechanism for the water development.

J-7 In one of my pastures in section 9 t 143 r 100 the proposal is to fence the spring and put 

a well in up on top to draw the cattle away from the spring. The beavers are full time 

cutting trees down in this area both full grown and in between growth trees. The blame is 

on the cattle from what I see the beaver are doing way more destruction that the cattle 

ever will in this area. In the past years the beaver have clear cut approximately two acres 

and are continuing to do so. Until the beavers are enilated to control the trees will not 

have a chance of regrowth. 

Beaver have been actively harvesting many trees from this site while leaving or 

avoiding tall shrubs such as water birch. Many aspen have been harvested but are 

re-sprouting and potentially improving desirable forage for several wildlife species 

similar to habitat improvement practices that involve aspen cutting to promote 

sapling growth. The degree that beaver are harvesting aspen re-sprouts in the 

affected site is uncertain. However, assuming beaver are adversely affecting woody 

draw habitat, a degree of compensation is conferred through increased riparian 

habitat and a mosaic of habitat types across the landscape. 

Across this particular allotment, 31 percent of woody draws were Healthy while 69 

percent were At Risk. Excluding the site in question would minimally change these 

proportions to 33 percent Healthy and 67 percent At Risk. Assuming that beaver 

are responsible for all site disturbances and changing the condition rating to 

Healthy would increase the proportion of Healthy sites in the allotment to 38 

percent. This is appreciably less than desired conditions and it is evident that 

management actions are needed to increase the proportion of Healthy woody draws. 

With respect to livestock impacts in the affected site, trailing is occurring along the 

drainage and adjacent slopes to and from the developed spring and water tank 

evident livestock browsing of green ash saplings and shrub layers was evident. As 

discussed in the methodology sections of the DEIS, SDEIS, and Botany Report

(Project Record, Specialist Reports and Notes), adverse woody draw impacts 

attributed to livestock were emphasized for condition ratings while ignoring adverse 

affects such as beaver or tree diseases to as great an extent as possible. Another 

woody draw in pasture 5 of the commenter's allotment was rated Healthy despite 

past beaver activity because the site currently meets desired conditions and 

experiences a low degree of livestock disturbance. Woody draws in Allotments 130, 

133, and 134 with numerous beaver-harvested aspen were also rated Healthy 

because livestock related disturbances were relatively light. Other woody draws in 

the project area with beaver activity were rated At Risk because extensive livestock 

browsing of re-sprouting saplings and/or trailing disturbances associated with the 

use of water from beaver ponds was observed. 

Response to Comments | 45
North Billings County Allotment Management Plan Revisions

Fencing the spring in question is an Adaptive Option that would not be initially 

implemented. Additional or recent site observations indicate little potential for 

improved woody draw conditions as a result fencing the spring due to continued 

water availability from several beaver ponds and relatively high rates of overflow 

from the spring (SDEIS, Chapter 3 Part 2, Allotment 126, Effects - Woody Draws). 

Fencing a portion of the upstream woody draw would have a greater potential for 

improving woody draw conditions and riparian habitat along the drainage. Adding 

an upland water tank in the allotment would also contribute to decreased use of the 

site in question, as well as use along Whitetail Creek with additional water a short 

distance downstream of the spring.

J-8 I am in agreement to extend a water pipeline to the edge of pasture in the north east 

section of pasture number 128-01and 02. Up by my corrals. There is a dam in the 01 

pasture but it dries out and then the cattle have to hang out along the creek area of 

whitetail creek. And the cattle in pasture number 02 have to walk approximately a mile to 

the water tank and cause washing as they have to walk threw a draw to get there as a cut 

across. If water would be brought in by an existing pipeline not very far from here it

would help the resources look so much better and distribute the grazing in more pen 

areas where it gets grazed sporadically.

The Forest Service agrees with this comment, however, this action is located in the 

adaptive options in Alternatives 3, 3A, and 4 (SDEIS, Chapter 3 Part 2). Therefore, 

the action would not occur unless monitoring showed that the initial actions aren’t 

meeting or moving the resource towards the Grasslands Plan desired future 

conditions.

J-9 Also in pasture 126-06 [should be 126-04, believed to be typographical error] there is a 

spring that the proposal is to fence it out and bring in a pipling – I would be in favor of 

the proposal as long as they use the existing pipeline I have and not drill another water 

well. Bu I do not favor fencing out the spring. If the water well would go with out water 

for some reason as they have for me in the past the spring would be replacement water 

till u get well up and running again.

The proposed action under Alternative 3 calls for constructing a pipeline-fed water 

tank away from a developed spring adjacent to several woody draws. Use of an 

existing water source would be preferable to the cost of drilling a water well. The 

spring development would be fenced to decrease use of the area and potentially 

improve woody draw conditions, but the development would be retained for 

potential use during emergencies as the commenter describes. Leaving the spring 

unfenced would allow continued livestock use of the site, perpetuating current 

conditions. 

J-10 Also in the magpie pasture in allotment 300 there is a fence enclosure gap going down to 

the magpie creek so the cattle can drink water. I do not see the difference of the cattle as 

the ones outside the enclosure gap that have the full access to the creek and also drink 

water from it. They are doing as much damage if not more but have the full length of the 

46 | Response to Comments
North Billings County Allotment Management Plan Revisions

creek to push dirt in to the water – With water gap u have the cows cosigned to a very 

small area so the damage is not wide spread.

The Forest Service IDT met with the permittee on January 14, 2010 to further 

discuss this concern. It was decided to modify the initial action in Alternative 3 to 

rehabilitate the entrenched livestock trails inside the waterlot, create a water gap in 

the far northeast corner, and harden the watering area to restrict livestock access. 

J-11 A very big concern now is the abundance of noxious weeds taking over since we can not 

graze all the pastures like we used to. Years ago the cattle kept a lot of the noxious weeds 

like burdock and Canada thistle under control by eating it and not letting it go to seed 

and now with the regulations which are suppose to e better the weed issue is getting out 

of complete control.

The Forest Service agrees that a big concern is the abundance of noxious weeds; 

however, the spread of noxious weed species is not solely due to not grazing pastures 

like they use to be grazed. The SDEIS has identified that the increase in oil and gas 

activity, recreation, wildlife, livestock, livestock feeding, etc. have all lead to the 

increase in the number of species and spread of noxious and invasive species on the 

Medora Ranger District (MRD). As pointed out in the Issues Eliminated from 

Detailed Study, Noxious Weeds section in Chapter 1 of the SDEIS, “Noxious weeds 

are a scourge to the prairie ecosystem. They displace and crowd out native plants, 

modify wildlife habitat, reduce livestock forage, adversely impact watersheds and 

riparian areas, and are costly to control. Over the years in the Dakotas, federal 

agencies, state and local governments, county weed boards and local grazing 

associations have expended millions of dollars and countless hours to eradicate or 

control noxious weed populations.” 

The Forest Service is not opposed to using livestock in an integrated pest 

management approach in controlling noxious weeds and invasive species, but this 

management needs to be done in a sustainable way to continue to work towards 

Grasslands Plan goals and objectives (Grasslands Plan, p. 1-20). Further detailed 

management of noxious weeds on the DPG can be found in the Noxious Weed 

Management Project FEIS, 2007.

MEDORA GRAZING ASSOCIATION & BILLINGS COUNTY IDENTICAL

COMMENTS

K-i The Association also incorporates by reference all of the previous comments and appeals 

submitted by MGA as a member of the Heritage Alliance of North Dakota over the last 12 

years.

 

All of the previous comments and appeals submitted by MGA as a member of the 

Heritage Alliance of North Dakota over the last 12 years have been addressed

through the NEPA process in the creation of the Grasslands Plan. The underlying 

Response to Comments | 47
North Billings County Allotment Management Plan Revisions

basis for the Grasslands Plan has been decided, upheld on appeal and affirmed 

through the discretionary review process not only once, but twice (see 2002 ROD, 

2003 WO appeal decision, 2003 Discretionary Review, 2006 ROD, 2007 WO appeal 

decision, 2007 Discretionary Review). 

K-ii Billings County reserves the right to provide supplementary information and further 

incorporates by reference the voluminous comments and appeals submitted by Billings 

County as a member of the Heritage Alliance of North Dakota over the last 12 years. 

All of the previous comments and appeals submitted by Billings County as a 

member of the Heritage Alliance of North Dakota over the last 12 years have been 

addressed through the NEPA process in the creation of the Grasslands Plan. The 

underlying basis for the Grasslands Plan has been decided, upheld on appeal and 

affirmed through the discretionary review process not only once, but twice (see 2002 

ROD, 2003 WO appeal decision, 2003 Discretionary Review, 2006 ROD, 2007 WO 

appeal decision, 2007 Discretionary Review). 

K-1 The North Billings County Allotment Management Plan Draft Environmental Impact 

Statement (AMP DEIS) is only the most recent chapter in the controversy regarding 

management of the Little Missouri National Grasslands. The issues found in the AMP 

DEIS have their genesis in the Dakota Prairie Grasslands Land and Resource 

Management Plan (DPG LRMP) revision started in 1997 with the publication of the 

notice of intent to prepare an EIS. Relevant to these comments, the issues include: (1) 

capability of the LMNG to produce high structure (tall grass) vegetation; (2) rangeland 

resource conditions; (3) whether the high structure vegetation goals will result in 

significant reductions in livestock grazing; (4) the validity of visual obstruction ratings 

(VOR) measured by the Robel Pole as a way to measure range resource conditions and 

as a proxy for biological diversity; (5) impacts of the “so-called larger livestock; and (6) 

the validity of agency data being used to make decisions involving livestock grazing, such 

as proper functioning condition (PFC) assessments for riparian areas; range condition 

assessments, and conditions of woody draws

Commentor is correct in that these issues have been continually brought forward, 

and continually addressed throughout the Northern Great Plains FEIS planning 

process, appeals to the 2002 and 2006 Records of Decision, the Scientific Review 

Team (SRT) report and the Forest Service Response to it, and the Demonstration 

Project creation itself. The SRT itself responded both to some of the original 

questions, plus those brought forward by the commentor (as part of the Heritage 

Alliance of North Dakota). Refer to the 2006 ROD pages 3-6 for a summary of those 

responses. Both the 2002 and the 2006 RODs were upheld on appeal (2003 and 2007 

WO appeal decisions) and affirmed with the Secretary of Agriculture’s 

discretionary reviews (2003 and 2007 Discretionary Reviews). Those project 

records are now incorporated by reference. Thus validated, the Grasslands Plan is 

the guiding document for management of the Little Missouri National Grassland. 

48 | Response to Comments
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K-2 Despite express direction in the Livestock Grazing Record of Decision (Livestock 

Grazing ROD) in December 2006, the AMP DEIS fails to put in place a process to test 

these issues and to avoid livestock grazing reductions.

The commentor misrepresents the direction in the 2006 ROD. As stated on page 8 

of that document “[t]his Demonstration Project will take the LRMP to the ground, 

and implement, monitor, validate, and where necessary, change it. It moves the 

argument away from the hypothetical and esoteric, to practical field application.” 

The Demonstration Project states at page 16 “[s]elected AMPs will be developed and 

implemented, working through the processes described in this document. Goals, 

objectives, standards and guidelines related to livestock grazing will be assessed. If 

adjustments are needed, Grasslands Plan amendments will be proposed.” It goes on 

to say “[G]oals and objectives may also be modified or changed to meet on-theground conditions and/or capabilities. One goal will be to maintain or improve 

current on-the-ground conditions to maintain, to the maximum extent possible, a 

grazing program at current levels and provide sufficient habitat for grassland 

species. Site-specific amendments to the DPG Plan to incorporate these changes will 

be done, as needed.” 

The DEIS and SDEIS evaluated the capability of the area to meet the goals, 

objectives, and standards and guidelines and found the lands were capable of 

meeting the Grasslands Plan direction (SDEIS, Chapter 3 Part 1). 

The Demonstration Project also states at page 17 “[T]here will be no cuts in 

permitted AUMs without monitoring showing that livestock are principally 

responsible for not meeting the desired condition, and that the cuts are the only 

ecologically practicable and economically feasible means available for meeting the 

desired condition. In these situations the Forest Service will work with the grazing 

associations to minimize livestock grazing reductions.” 

The analysis evaluated the existing condition of each allotment and identified those 

resources of concern. The analysis evaluates whether or not livestock grazing was 

principally responsible for not meeting the desired condition (SDEIS, Chapter 3 

Part 2). The EIS evaluated Alternatives 3 and 3A which were developed with the 

grazing association, and Alternative 4 which was developed to further address 

grassland structure. In addition, all the alternatives include a design feature that 

says “if stocking rate adjustments are needed, annual reductions will generally not 

exceed ten percent; and if monitoring shows that resource objectives are being met 

before full implementation of the AM/AUM reduction has occurred then no further 

reduction in AUMs will be needed.” 

Based on the above, the EIS has put in place a process to evaluate the plan direction 

and to minimize livestock grazing reductions either by alternative, or by 

incorporating a phased-in approach to reductions with associated monitoring. 

Response to Comments | 49
North Billings County Allotment Management Plan Revisions

Multiple places in the 2006 ROD discuss minimizing, not avoiding, reductions and 

working to keep a grazing program at current levels and/or at the permitted AUMs, 

but these are all in concert with sufficient habitat for grassland species and other 

multiple uses. In fact, in Alternatives 3 and 3A the Forest Service has already given 

the benefit to the MGA members in this analysis by not implementing the 

recommendation by the SRT to adjust for cow size (see Final Response to the SRT 

Reports, 2006, pp. 14-15) or following the Grasslands Plan guideline I-6 (Grasslands 

Plan, p. 1-19) to adjust for variations in liveweight in some situations. When the 

permitted AUMs are calculated, allotments in the project area are typically over 

their preference number as expressed in AUMs (see Table 3.4 in the SDEIS).

K-3 The AMP process was intended to put in place a process to test the LRMP assumptions, 

goals, objectives, standards and guidelines. Instead the AMP DEIS adopts all of the 

goals, objectives, standards, and guidelines as rigid mandates notwithstanding the 

explicit direction to consider amending the LRMP, if grazing reductions will otherwise 

occur or if appropriate. 

The commentor misstates the 2006 ROD and Demonstration Project language. 

As noted in K-3 the Demonstration Project states at page 16 “Goals, objectives, 

standards and guidelines related to livestock grazing will be assessed. If adjustments 

are needed, Grassland Plan amendments will be proposed.” It goes on to say 

“[G]oals and objectives may also be modified or changed to meet on-the-ground 

conditions and/or capabilities.” 

Commentor also misstates that there is explicit direction to consider amending the 

Grasslands Plan if grazing reductions will otherwise occur or if appropriate. If 

Grasslands Plan amendments are needed, they will be proposed. This is 

independent of any potential reductions. In fact, the language discusses keeping the 

current level of grazing to the maximum extent possible (emphasis added) while 

providing sufficient habitat for grassland species.

Through the North Billings analysis, the specialist considered the capability of the 

land to meet the resource objectives and goals. In other words, the specialists 

looked to see if the land is capable of meeting the Grasslands Plan goals and 

objectives. The analysis determined that yes the land is capable of meeting the goals 

and objectives and that no amendments to the Grasslands Plan were deemed to be 

necessary. 

K-4 Billings County and the Medora Grazing Association (MGA) recommend revision of the 

AMP DEIS, especially Alternative 3 to make it truly an alternative agreed upon by MGA 

and the Forest Service as the preferred alternative. 

The goal of the cooperative effort between the Medora Grazing Association and the 

Forest Service was to produce a proposed action (2006 Grazing ROD, page 17, (7)) 

not a preferred alternative. A proposed action is one way of achieving the purpose 

and need for a project. A proposed action may or may not be a preferred 

50 | Response to Comments
North Billings County Allotment Management Plan Revisions

alternative. As documented in the Project Record and SDEIS (Appendix A), the 

Forest Service worked extensively with the MGA board and individual permittees in 

the development of Alternative 3. 

 The revisions would: 

• Revise adaptive management goals to include the objective of not reducing livestock 

grazing until all other possible alternatives were exhausted; 

Adaptive management doesn’t have goals. It is a process, as described in the 

Adaptive Management section in Chapter 1 of the SDEIS, which allows for 

flexibility in changing management actions if needed to meet or move towards 

desired resource conditions as identified in the Grasslands Plan. In addition, the 

commentor misinterprets the Demonstration Project in this statement. To be 

consistent with the Demonstration Project, the Forest Service will “...maintain or 

improve current on-the-ground conditions to maintain, to the maximum extent 

possible, a grazing program at current levels and provide sufficient habitat for 

grassland species.” (2006 ROD, page 16 provision 4). Exhausting all other possible 

alternatives before reducing livestock grazing may not allow for maintaining or 

improving on-the-ground conditions to provide sufficient habitat for grassland 

species. Analysis on how the alternatives presented in the SDEIS meet multiple use 

Grasslands Plan goals, objectives, standards and guidelines and varied ways of 

using adaptive management to achieve them are found throughout Chapter 3 and in 

the specialists reports (Project Record, Specialist Reports and Notes). 

• Revise the AMP DEIS to test the scientific issues that are still in controversy, including 

but not limited to the capability of the allotments to produce high structure without 

leading to significant grazing reductions, validity of PFC criteria for North Dakota and 

whether they should be altered; historical distribution of woody species and trend and 

the ecological thresholds where woody species encroachment may adversely affect 

habitat for ground nesting birds; and actual carrying capacity calculated following 

NRCS guidelines rather than the theoretical data and modeling in the AMP DEIS, and 

inclusion of all lands in the forage production calculations; 

This suggestion was considered but not given detailed study as an alternative 

(SDEIS, Chapter 2, Alternatives considered but Dropped from Detailed Analysis) 

because the suggestions primarily address how to analyze effects, not how to 

manage livestock grazing. 

However, the SDEIS includes additional discussion regarding these comments. 

Additional discussion regarding the capability of the allotments to provide high 

structure may be found in the Herbaceous Structure, Desired Condition, Capability 

section in Chapter 3 Part 1 of the SDEIS; including discussion of how the level of 

livestock grazing affects structure and that reductions in livestock grazing are the 

only ecological practicable way to increase structure.

Response to Comments | 51
North Billings County Allotment Management Plan Revisions

Additional discussion on the application of PFC criteria for North Dakota may be 

found in the Riparian, Methodology section in Chapter 3 Part 1 of the SDEIS. No 

changes were found to be warranted.

Additional discussion on the historical distribution of woody species and how 

encroachment of woody draws may affect ground nesting birds may be found in the 

Woody Draws, Existing Condition, Trends in Woody Draw Extent section in

Chapter 3 Part 1 of the SDEIS and in the Project Record, Specialist Reports and 

Notes, Botany Report - Appendix D. See also response to comments J-5 and K-55. 

Additional discussion regarding carrying capacity calculations may be found in the 

Range, Methodology, Carrying Capacity Analysis section in Chapter 3 Part 1 of the 

SDEIS. 

• Consider revisions needed in the DPG LRMP to ensure that reducing grazing is the last 

option, rather than the first, and specifically removing the no net increase limit with 

respect to range structures. 

The Grasslands Plan doesn’t specify grazing reductions as a first or last option in 

managing resources on the Dakota Prairie Grasslands nor does it contain any 

direction in regards to no net increase limit with respect to range structures.

Also note grazing reductions were not the first option for managing resources in this 

project area (refer to description of alternatives in Chapter 2 of the SDEIS), and 

that range structures are included in the action alternatives.

The no net increase limit on range structures was in the Draft Grasslands Plan. It 

should be noted that this language was changed between the draft and the final 

Northern Great Plains EIS and has been repeatedly pointed out to the commentor. 

In fact in the April 17, 2007 letter responding to the Heritage Alliance of North 

Dakota (HAND), of which the commentor is a member, appeal of the 2006 Grazing 

ROD, the issue of no net range improvements is again explained with a lengthy list 

of other times that this has been clarified for the commentor (Project Record, 

Supporting Documentation, L-103 (4/17/07 2006 ROD appeal transmittal letter), p. 

7). That decision was upheld by both the Washington Office and a discretionary 

review by the Department of Agriculture.

The Grasslands Plan guideline for range infrastructure is “Use nonstructural range 

management techniques such as water management, herding, ridings, and mineral 

management to achieve desired conditions. If nonstructural management methods 

are not successful, then new structural development may be used to achieve desired 

conditions” (Grasslands Plan, pp. 2-15, 2-22). 

Commentor does acknowledge this change to the no net increase limit in their 

comment number K-33. 

52 | Response to Comments
North Billings County Allotment Management Plan Revisions

K-5 The commentor reserves the right to provide supplemental information following review 

of the Project File made available on October 13, 2009, once the extent of the reductions 

can be estimated and once the data being developed by North Dakota State University is 

compiled. 

The commentor reserves a nonexistent right. Comments are officially accepted per 

the regulations and process outlined in 36 CFR 215.6 (Comments on proposed 

actions). Commenting during this timeframe allows the commentor to appeal a 

decision based on this analysis under 36 CFR 215. However, at the Deciding 

Officer’s discretion comments received after this time frame may be reviewed. If 

received in a timeframe that allows it for this project, additional comments or 

information will be reviewed and will become part of the project record.

K-6 DEIS Incorrectly Characterizes History and Management Mandates of National 

Grasslands, AMP DEIS at 3-8. 

The AMP DEIS omits the statutes and executive orders governing the management of the 

LMNG. The federal lands within the boundaries of the LMNG were acquired or reserved 

for the Little Missouri Land Utilization Project. The Presidential Executive Orders 

reserving the public domain lands stated that these lands for “reserved for use and 

development by the Department of Agriculture for soil erosion control and other land 

utilization activities in connection with the Little Missouri Project, LA-ND 1.” Ex. 

Orders 7673, 7674, 2 Fed. Reg. 1512 (1937). The objectives of the Land Utilization 

Project were: A prevention and control of erosion; conservation and development of 

water resources; demonstration areas of proper livestock grazing; control of destructive 

animal life; and relief of unemployment with conservation project”. The Bankhead-Jones 

Farm Tenant Act (ABJFTA”), 7 U.S.C. ''1010-1013, did not change these objectives but 

rather implemented them, and further stated as its purpose: “To promote more secure 

occupancy of farms and farm homes, to correct the economic instability from some 

present forms of farm tenancy, and for other purposes." 50 Stat. 522 (July 22, 1937). 

These purposes are also set out in the acquisition purposes and complaints of 

condemnation pursuant to which much of the lands within the LMNG were acquired. 

These original statutory objectives define the management parameters for the LMNG. 

Chapter 1 of the SDEIS has been reorganized and updated to show the relevant 

federal laws and regulations that govern the management of livestock grazing on the 

Little Missouri National Grasslands (LMNG). 

Management of the LMNG is governed under the provisions of the Bankhead-Jones 

Farm Tenant Act, the Forest and Range Renewable Resources Planning Act, the 

National Forest Management Act and Forest Service Regulations 36 CFR 213 

(Administration of Lands under Title III of the Bankhead-Jones Farm Tenant Act 

by the Forest Service) and 36 CFR 222 (Range Management) and other laws 

relating to the National Forest System lands. 

Response to Comments | 53
North Billings County Allotment Management Plan Revisions

Specifically, 36 CFR 213 provides the management direction for the administration 

of National Forest System lands under Title III of the Bankhead-Jones Farm Tenant 

Act. 36 CFR §213(b) states “the National Grasslands shall be a part of the National 

Forest system and permanently held by the Department of Agriculture for 

administration under the provisions and purposes of title III of the Bankhead-Jones 

Farm Tenant Act.” Further, the Bankhead-Jones Farm Tenant Act provides:

“The Secretary [of Agriculture] is authorized and directed to develop a program 

of land conservation and land utilization, in order thereby to correct 

maladjustments in land use and thus assist in controlling soil erosion, 

reforestation, preserving natural resources, protecting fish and wildlife, 

developing and protecting recreation facilities, mitigating floods, preventing 

impairment of dams and reservoirs, developing energy resources, conserving 

surface and subsurface moisture, protecting the watershed of navigable 

streams, and protecting the public lands, health, safety, and welfare, but not to 

build industrial parks or establish private industrial or commercial enterprises” 

(Section 31, Title III, Bankhead-Jones Farm Tenant Act of 1937, as amended 

in 1962, 1966, and 1981).” 

Section 213(d) states “the resources shall be managed so as to maintain and improve 

soil and vegetative cover, and to demonstrate sound and practical principles of land 

use for the areas in which they are located.” Section 213.3 addresses protection, 

occupancy, use, administration, and exercise of reservations. This section basically 

states that the rules found in 36 CFR §213 govern the management of these lands. 

Section 213.4 addresses prior rules and regulations. It states “Except as provided in 

§213.3, the rules and regulations heretofore issued for land utilization projects are 

hereby superseded as to all such projects administered by the Forest Service, but 

not as to such projects administered by other agencies.” 

The comment above also states that the DEIS omitted discussing the 1937 Executive 

Orders which the comment claims “define the management purposes of the 

LMNG”. However, the United States Constitution vests Congress with the authority 

over all federal lands. Agencies must administer lands under their jurisdiction 

consistent with those acts of Congress. For the National Grasslands, Congress 

through the Bankhead-Jones Farm Tenant Act and other laws discussed above has 

set for the management purposes and objectives of the federal lands. As such, the 

SDEIS has appropriately set forth those statutes directing management of the 

national grasslands. 

K-7 The Forest Service published the notice of intent to prepare an EIS and sought scoping 

comments for the LRMP revision in 1997. 62 Fed. Reg. 8680 (1997). Public comments 

for the DEIS were filed on or before February 2, 1999. 63 Fed. Reg. 68245 (1998). The 

comments demonstrated that the draft DPG LRMP would reduce livestock numbers from 

29% to 49% with significant economic impacts. See e.g. Comments by the Heritage 

Alliance of North Dakota (HAND) and attached reports (Feb. 2000). 

54 | Response to Comments
North Billings County Allotment Management Plan Revisions

As early as 1996, the LRMP planning team had established as an internal goal of 

reducing livestock grazing by about one-third. The email from the Nebraska National 

Forest Supervisor Mary Peterson responding to projected reductions of 35% stated: "The 

cowboys in ND have big ‘cow chips' on their shoulders. They are still afraid (and 

probably realistically so) their cattle numbers will be reduced." Ex. 1, e-mail to NGPPR 

FEIS Planning team from David Cawrse forwarding email message from Mary H. 

Peterson April 1, 1996. The state and local governments and the affected grazing 

associations objected, raising a number of issues that remain scientifically controversial. 

After the close of the comment period on the DEIS in February, 2000, the Forest Service 

heatedly denied that that such grazing reductions would occur. Between 2000 and the 

present, there have been several efforts to resolve the policy conflicts and scientific 

controversies in order to avoid or reduce the adverse economic and social impacts. The 

first was through roundtable meetings sponsored by the North Dakota Governor. This 

process did not yield any agreement but was the first step in persuading the Forest 

Service that its underlying resource data used to justify the significant reductions in 

livestock grazing, were flawed. 

This comment does not specifically apply to the North Billings project, but rather to 

the Grasslands Plan. However, several errors are contained in the statements above 

that warrant comment. Comments to the livestock grazing portion of the Grasslands 

Plan are found on pages 154 through 184 of the Addendum for the FEIS and 

LRMPs 2001 Revisions. Throughout this section Dr. Lacey is quoted (interestingly 

enough with varying degrees of potential reductions i.e. 30 to 55 percent on p. 159). 

In the responses, the errors in Dr. Lacey’s assumptions are described. Chief of 

which is the assumption that potential reductions in livestock grazing for other 

multiple uses would be an additive rather than a synergistic process where multiple 

resources value can be obtained from a specific piece of land (see Addendum p. 159 

for example).

In the 2002 ROD, the Scientific Review Team process to determine how the grazing 

portion of the plan might be implemented and its effects was created (2002 ROD p. 

5). The group of sample allotments considered in the SRT process closest to the 

project area was Group 6. The average reduction for those allotments, using data 

better utilized at a landscape analysis, was six percent (see undated power point 

slide from SRT report). The SRT points out the data used in the test AMPs, while 

the best available for the study’s purposes, lacked the required level of resolution 

needed to develop, implement, and monitoring of individual pasture AMPs (final 

response to the SRT p. 3). The SRT recommended using NRCS order 2 soil surveys 

and associated ecological site information, which is what was done for this project. 

In summary, the resource data used in both the Grasslands Plan and the North 

Billings process, while different, are appropriate for the scale and kind of analysis 

conducted. The Forest Service, while acknowledging the controversy over various 

estimated reductions, has not agreed that the underlying resource data used was 

flawed, as commentor claims. Nor was the purpose of the Grasslands Plan to reduce 

livestock grazing, rather the analysis focused on the potential impacts of and to 

Response to Comments | 55
North Billings County Allotment Management Plan Revisions

livestock grazing in order to balance multiple uses. The use of the term significant 

reduction in livestock grazing is subjective as used by the commentor. 

K-8 Prior to February 2000 the Forest Service claimed, just as it does in the AMP DEIS, that 

resource conditions on the LMNG were deteriorating due to grazing. Based on the 

public comments on the DEIS and the Governor’s Roundtable, the Forest Service 

significantly revised the EIS, changing the data bases and analytic tools entirely. The 

LRMP nevertheless retained the disputed goals, objectives, standards and guidelines 

despite significant questions about the capability of the LMNG lands to meet those 

objectives. The Forest Service still concluded that grazing would only drop by 9%. 

Most of this comment does not apply to the North Billings site specific project as it is 

in reference to the revision of the Grasslands Plan. The Grasslands Plan is not in 

question here nor is the assumptions behind the analysis at that level (see 2003 and 

2007 Appeal Decisions and 2003 and 2007 Discretionary Reviews). 

The nine percent identified in the comment is correct, however, this was a DPGwide estimate. The Grasslands Plan 2006 ROD, page 12, put this into context. It 

states that “...the Forest Service has estimated an average DPG wide nine percent 

reduction 6 in grazing levels based on the 20 year average authorized use”. The 

footnote states “6

The [NGP] FEIS also explains the estimated AUMs were for 

alternative effects comparisons. Actual stocking levels will be determined in the sitespecific allotment management planning process. (See FEIS, page 3-90 through 3-

91).” See also response to comment C-3. 

K-9 Given the extent of the changes in the FEIS released in July 2001, the Forest Service 

provided a six-month comment period ending on January 31, 2002. Based again on the 

comments by the HAND and the State of North Dakota, the Regional Forester in 

consultation with USDA Under Secretary Mark Rey determined that it was necessary and 

advisable to review the FEIS and LRMP as they apply to livestock grazing. The Regional 

Forester severed the livestock grazing issues from the DPG LRMP and the 2002 Record 

of Decision (ROD) and directed the DPG to form a Scientific Review Team (SRT) to 

address the controversies, particularly to determine if the DPG LRMP could be 

implemented without significant livestock grazing reductions. The documents pertaining 

to the suspension of the LRMP implementation show that the SRT was to "review the 

Forest Service sample design, verification of stocking rate and forage production, 

underlying scientific issues regarding wildlife habitat and vegetation management, 

including consistency with rangeland health and other principles of range management 

and vegetation, and the Plan Revision management objectives, direction, standards and 

guidelines." 

This comment does not specifically apply to the North Billings project, but rather to 

the Grasslands Plan revision process. 

However, several errors are contained in the statements above that warrant 

comment. As noted in the 2002 ROD, the Regional Forester decided to “phase in” 

56 | Response to Comments
North Billings County Allotment Management Plan Revisions

the livestock grazing portion of the Grasslands Plan (see discussion below). This 

was an attempt to stem the controversy over the Grasslands Plan from some sectors

of the public over perceived uncertainty of effects and perceived adverse economic 

effects on local communities (2002 ROD, p. 5). Nowhere does it state this was 

necessary, but was yet another step – in line with the extremely rare step of opening 

the Northern Great Plains FEIS to a six-month extended public comment period 

(2002 ROD, p. 14) – to work with the interested and concerned publics on multiple 

use management. This was after extensive efforts since the beginning of the planning 

process in 1996 (2002 ROD, p. 14). (Also see SRT team process and Demonstration 

Project).

The Regional Forester did not sever the livestock grazing issues from the 2002 

ROD; he identified a “phase in” approach to address the disagreement between 

estimated reductions (Grasslands Plan 2002 ROD, p.5). The commentor is correct in 

stating that the Regional Forester identified that a SRT would be created, however, 

the statement “...to determine if the DPG LRMP could be implemented without 

significant livestock grazing reductions” is incorrect. The Grasslands Plan 2002 

ROD, page 5 states “Completion of these sample allotments will be like taking the 

new plan out for a “test drive. The intent of this “test drive” is to determine if the 

grazing portion of the plan can be implemented and to verify that grazing levels are 

similar to those projected in the Revised Grasslands Plan FEIS”.

The commentor doesn’t identify “The documents pertaining to the suspension of the 

LRMP implementation...” or provide a cite(s) so it is not possible to consider the 

context in which it is made. It’s also important to note that the implementation of 

the Grasslands Plan was not suspended in regards to livestock management, interim 

direction was provided (2002 Grasslands Plan ROD, p. 5) which established the 

SRT process. 

See response to comment K-10 

K-10 The central question was whether the LRMP could be implemented without significant 

livestock grazing reductions. The SRT concluded that given the quality of the data used 

by the Forest Service in the FEIS and LRMP, or the DRAGON Team data used in the 

“test drive” of the AMPs, it was impossible to determine the outcome. SRT at 14. 

The statement that the central question was as stated above is incorrect. Please refer 

to the “Final Response to the Scientific Review Team Reports” dated October 10, 

2006, page 1. The SRT was asked to address two questions: 

1) Can the Grasslands Plan be implemented?

2) Are the grazing levels in the sample AMPs similar to those projected in the 

FEIS?

The SRT agreed the LRMP could be implemented with “...the general qualifier that 

the outcome is uncertain” (2005 SRT Report, p. 32). 

Response to Comments | 57
North Billings County Allotment Management Plan Revisions

The last statement of the comment doesn’t appear on SRT page 14 as stated. This 

statement is also not pertinent to the proposed project as it is in reference to actions 

implemented to address the question regarding if the grazing portion of the 

Grasslands Plan could be implemented.

K-11 The SRT report concluded that it could not answer several key issues due to the lack of 

adequate data and questions about protocol consistency. SRT at 9, 32. This was true 

with respect to assumptions that were said to support grazing reductions, estimates for 

site capability to produce high structure, trend and condition of woody draws, Id. at 10-

11; VOR readings by Robel Pole, Id. at 12-14; and PFC assessments, Id. at 23. While 

the Forest Service’s much-touted "test drive" of the LRMP showed no greater than 9% 

reductions, it relied on the DRAGON team data that the SRT concluded were invalid for 

allotment management decision. Id. at 9. Moreover, the test drive did not address limits 

imposed by the LRMP on range project construction, the amount and timing of rest in a 

grazing system, the lack of accurate vegetation production and condition data, and lack 

of soils data. The Forest Service used 2002 Dragon Team@ data, rather than the data 

used in the FEIS, so the test drive did not fairly assess the impacts of the LRMP goals, 

objectives, standards, and guidelines on livestock grazing levels. Nor could the Forest 

Service support its assumptions of minimal impact on livestock grazing due to the flaws 

in the DRAGON team data and lack of data on actual use that was not provided by the 

Forest Service to the SRT.

This comment is referring to the SRT process that was initiated to determine if the 

Grasslands Plan could be implemented, see response to comment K-10. The 

outcome of this process was a series of issues and recommendations by the SRT. The 

2006 Final Response to the Scientific Review Team Reports identifies the Forest 

Service’s response to those recommendations. This project followed the applicable 

recommendations in accordance with the Forest Service Final Response to the SRT 

Reports, 2006. Appendix C of the SDEIS provides a summary of how each 

recommendation was addressed. 

Again, it is necessary to correct misstatements from the commentor. The SRT did 

not conclude that it could not answer several key question due to lack of adequate 

data and protocol consistency (see SRT report, p. 9 and 32), except to the extent of 

which no pasture specific grazing records with actual use numbers and weights of 

livestock could be provided to them by the Grazing Associations. Different data sets 

are appropriate to be used at different scales of analysis. So the data used to 

analyze the landscape at the Grasslands Plan level may, or may not, be applicable at 

a site-specific level. This does not make the assumptions and analysis in the 

Grasslands Plan invalid, as answered by the SRT when HAND asks the team a 

similar question about data after their report (see 2006 ROD p. 3-6). See also the 

actual statements made, and the Forest Service response to them to address VOR 

and PFC (SRT report and Forest Service response to the SRT report), as 

commentor misunderstand these points as well.

58 | Response to Comments
North Billings County Allotment Management Plan Revisions

Moreover, the commentor misstates what the SRT says about the DRAGON data 

(see SRT report, p. 9). However this is a moot point for this site-specific project as 

the applicable SRT recommendations were followed (see SDEIS, Appendix C). 

Again, refer to the lengthy number of times the commentor has been corrected on 

the no net gain in grazing improvements (Project Record, Supporting 

Documentation, L-103, p. 7). 

Refer to response to comment K-10 regarding the questions the SRT was chartered 

to answer.

Actual use has traditionally been difficult to impossible for Forest Service to obtain 

from its agent, the Medora Grazing Association. As requested by the SRT, which 

would include pasture by pasture numbers, live weight of cattle, class of livestock, 

and actual dates where the livestock were moved, this information is not provided 

by the MGA, possibly because its members have not been asked for this detailed 

information by the MGA. Annual Operating Instructions/Allotment Worksheets, 

which is the general plan for the year before grazing begins, or billing information 

often does not represent the actual on-the-ground data needed from the permittee to 

the Forest Service. This indeed, as noted by the SRT, greatly complicates 

management determinations and activities. 

K-12 The SRT evaluation of grazing management and resource conditions was also frustrated 

by the lack of livestock use and monitoring data on the federal lands. Id. at 16-17. In 

fact, the Forest Service refused to provide the SRT with the actual use data, which it 

received from each grazing association each year. Due to the false statements that there 

were no data, the SRT concluded that it was not possible to determine if the DPG LRMP 

could be implemented without significant livestock grazing reductions. SRT Report at 14. 

The Forest Service agrees with the first sentence in this comment (Final Response to 

the SRT Reports, 2006 pp. 12 and 13). 

Implying that the MGA is indeed providing actual use to the Forest Service is 

incorrect. During the SRT evaluation, the Forest Service supplied the livestock use 

information that was available to them from the grazing associations. On the MRD, 

yearly grazing permits were provided from MGA that show the number and class of 

livestock and their grazing season for the permit year up until the year 2000. AOIs 

were also used to describe livestock use for the SRT evaluation, but until 2001 these 

have been spotty. AOIs are also done early in the year and are just a best guess of 

what the permittee will be running for the given year. Updates provided to the 

Forest Service by the MGA as the season progresses are spotty at best.

Since the SRT made recommendations in their Final Report, 2005 (see SRT Issue 

IV-1, p. 16 and SRT Issue V-1, p. 18) it’s apparent that the SRT believed that the 

information provided them to evaluate livestock use was inadequate for their 

review. The Forest Service did not refuse to provide the SRT with the actual use 

Response to Comments | 59
North Billings County Allotment Management Plan Revisions

data; it supplied what was provided by the MGA, which were total animal months 

per allotment or permit. This doesn’t constitute actual use.

The following information identifies the MGA’s position on actual use. A letter 

dated August 31, 2004 was sent to MGA that requested actual use data which 

consisted of: the date when livestock enter a pasture, the number of livestock, any 

stocking adjustments during the grazing period, and the date when the livestock left 

a pasture. At the September 1, 2004 monthly MGA board of directors meeting the 

issue was discussed, and the minutes reflect the board of directors’ response: “The 

Board is not in agreement that actual use numbers should be provided. They fully 

expect the USFS to use these numbers to institute further reductions on allotments, 

over and above the reductions that are proposed in the new Grasslands Plan. 

Permittees will remember that the USFS used a 20-year average of aum’s to figure 

the “10-15% reduction” included in the new Grasslands Plan. That 20-year average 

used the years of 1980-1999, which contained some very, very dry years.” The MGA 

board of directors meeting minutes of March 2, 2005 identify that the Forest Service

District Ranger again requested actual use numbers for 2004. The MGA responded 

that they had the requested data completed with the exception of one allotment. The 

information provided to the Forest Service was animal months by allotment or 

permit and not what was specified in the August 31, 2004 letter. 

Between the DEIS and the SDEIS the Forest Service conducted a review of MGA 

files for actual use information. The review found the same AOI and grazing 

association permit information that was supplied by MGA and some additional 

information documenting changes to some of the AOIs. There was no evidence of 

the MGA conducting a year end review of their members’ grazing use after 

completion of the grazing season. See response to comment F-11. The 2005 SRT

Report at page 14 did not conclude that it was not possible to determine if the DPG 

LRMP could be implemented without significant livestock grazing reductions. It 

only provided issues and recommendations. See also response to comment K-10. 

K-13 The exclusion of this data means that even now, there has been no correlation between 

livestock numbers, previous management, and current conditions. Nor can the AMP 

DEIS fairly estimate the economic impacts. 

Information regarding actual use would aid in the analysis of past effects of grazing 

systems and whether or not those effects would continue, or not, based on the 

alternatives. This is also described in the NRCS National Range and Pasture 

Handbook (1997) as part of the method to establish an initial estimated stocking 

rate for an operating unit. In addition, actual use would aid in disclosing the 

potential effects of the alternatives to the permittee by comparing actual use to 

preference and/or the Authorized Use under the alternatives. 

In lieu of actual use the interdisciplinary team used the three year (2005-2007) 

average MGA permitted use and/or AOIs to compare to the Authorized Use under 

the different alternatives. The three year average MGA permitted use is 

60 | Response to Comments
North Billings County Allotment Management Plan Revisions

information taken from grazing association grazing permits which are completed 

prior to turn out. The AOIs/Allotment worksheets were used to help describe under 

current management how an allotment is managed as far as rotation and type/class 

of livestock. As noted before, the AOIs and the information they contain are 

completed in the winter or early spring by the permittee before turn-out. They 

represent the permittees “best guess” at that point in time as to the number of 

animals they’ll run, rotations, etc. in the coming grazing season. In lieu of actual 

use, this is the best information available to use in the analysis. 

This information was used in the analysis to evaluate the effects of past grazing 

systems and whether or not trends would likely increase, decrease, or stay the same 

based on the alternatives and the comparison to the three year average MGA 

permitted use from the grazing association grazing permits, as well as preference. It 

is important to note that one of the three years in the average was a drought year in 

which grazing reductions were implemented. This information is provided strictly 

for comparison purposes to more sharply define differences between the alternatives 

(see the Affected Environment – Range, Existing Condition, Actual Use section in 

Chapter 3 Part 1 of the SDEIS). 

Economic analysis is based in part on the information described above not actual 

use, as this was the information provided by the MGA.

K-14 Contrary to the representations made by the Forest Service, the ranger district offices 

had annual reports of livestock use on the National Grasslands. Ex. 3, Schneider Decl. 

&20. The Forest Service does not prescribe any form for such reports but livestock 

numbers on federal lands are provided to the agency. While the format may have varied 

and the compilation would have been time-consuming, the fact remains the data existed 

and the Forest Service chose not to provide it. The AMP DEIS attempts to perpetuate the 

same falsehood by now disparaging the grazing association record keeping as 

“unreliable”. AMP DEIS at 3-15. The thinly concealed accusation of lying needs to be 

excised from the AMP DEIS. 

The Forest Service utilized the data provided by the MGA in its analyses (see the 

Affected Environment – Range, Existing Condition, Actual Use section in Chapter 3 

Part 1 of the SDEIS). However, as noted in response to comments K-12 and K-13 

this data is not actual use. The SDEIS provides a more detailed discussion of 

permits, permitted use, and actual use (Affected Environment – Range, Existing 

Condition, Grazing Permits and Actual Use sections in Chapter 3 Part 1 of the 

SDEIS). 

K-15 Relevant to the AMP DEIS, the SRT concluded that it was not clear whether the sites 

classified for high structure were capable of producing the high structure, Id. at 10, 

whether the VOR measurements were done pursuant to valid and consistent protocols, Id.

12-14, or that high structure necessarily correlated to vegetation condition. Id. at 14. 

Response to Comments | 61
North Billings County Allotment Management Plan Revisions

The commentor appears to be referring to the SRT Report. Analysis completed for 

the North Billings project found these areas were also capable of providing high 

structure (SDEIS, Chapter 3 Part 1, Herbaceous Structure, Desired Condition, 

Capability). The VOR measurements were done based on an approved protocol and 

were completed by the district wildlife biologist and other trained district personnel. 

Note that the Grasslands Plan has standards and guidelines for both high structure 

and seral stages (see examples throughout the Grasslands Plan Ch. 1 through 3). 

High structure and seral stage are not necessarily correlated. Also see response to 

comments K-41 and K-95. 

K-16 The SRT also concluded that the PFC measurements for riparian areas may be ill-suited 

for North Dakota and recommended that the Forest Service revise the criteria for the 

Great Plains soils and climate. Id. at 23. The SRT generally raised questions about 

consistency in the use of protocols and the lack of monitoring data. 

The first statement is incorrect. The SRT did not conclude that PFC measurement 

may be ill-suited for North Dakota. The SRT commented that the PFC assessment 

is potentially inadequate. The SRT recommendation was to determine if PFC rating 

is applicable to North Dakota, to use multidisciplinary teams, and to develop a 

training manual and process. The SRT recommendations do not in any way, 

invalidate the PFC protocol. The DPG responded to these points, first in June 2005 

and again in October 2006. See Dakota Prairie Grasslands, Final Response to 

Scientific Review Team Reports, October 10, 2006, pp. 19-20; available on-line at: 

http://www.fs.fed.us/r1/dakotaprairie/projects/livestock_grazing/corrected_final_srt

_response.pdf. Furthermore, the SRT did not comment on the quality or amount of 

PFC data used in this project as the PFC data used to establish existing conditions 

in the North Billings County project area were collected from 2004 (see Brooks, 

2005) through 2007. The SRT did not review these data and made no judgment of 

these data.

K-17 At the conclusion of the SRT process, it was clear to all that the issues in scientific 

controversy remained very much in contention. Livestock Grazing ROD at 13. In order 

to address these controversies and still move forward, the Forest Service adopted a 

“demonstration pilot project” now called Demonstration Project in the Livestock 

Grazing ROD. Id. This process, which was supported by the grazing associations, called 

for the Forest Service in close cooperation with the grazing associations to develop 

AMPs that would test the validity of the LRMP assumptions, goals, objectives, standards 

and guidelines, and when appropriate revise the plan simultaneously with the AMP. The 

project level development would allow the Forest Service to assess whether the DPG 

LRMP requires or will lead to major grazing reductions and examine ways to avoid 

them. It would also offer the opportunity to test the validity of the scientific assumptions 

in the DPGLRMP 

The SRT states “[i]t is the opinion of the SRT that the perceived problems 

associated with the current FEIS and LRMP stem largely from differences among 

62 | Response to Comments
North Billings County Allotment Management Plan Revisions

affected parties in value systems rather than scientific shortcomings.” (2006 ROD p. 

4) 

Commentor misstates what the Demonstration Project requires. The 

Demonstration Project states “[t]he pre-NEPA process would be completed in 

careful consultation, coordination, and cooperation with the grazing associations 

representing their members working in concert with the Forest Service.” (2006 

ROD p.16) “The purpose of the demonstration project would be to develop and 

implement integrated allotment management plans pursuant to a collaborative 

process with the respective grazing associations that share in the management of 

grazing on the National Grasslands, to determine if Grasslands Plan Goals and 

Objectives are achievable or need modification, and monitor progress towards 

meeting the resource objectives.” (2006 ROD p. 15)

“During this time, selected AMPs will be developed and implemented, working 

through the process described in this document. Goals, objectives, standards and 

guidelines related to livestock grazing in the Grasslands Plan will be assessed. If 

adjustments are needed, Grasslands Plan amendments will be proposed.” (2006 

ROD p. 16). Nowhere in the Demonstration project does it state that AMPs would 

be developed to test the validity of the Grasslands Plan. If plan amendments are 

found to be needed (see discussion in response to comment K-3) then they could be 

proposed simultaneously, however, none were found to be needed for this project 

area.

The Forest Service obligation under the Demonstration Project is to provide “[o]ne 

goal will be to maintain or improve on-the-ground conditions to maintain, to a 

maximum extent possible, a grazing program at current levels and provide 

sufficient habitat for grassland species”. (2006 ROD p. 16, emphasis added). 

The Forest Service does agree that implementing the AMPs, as with all projects, and 

the related monitoring will help assess the on-the-ground conditions as they relate to 

the Grasslands Plan goals and objectives. This may lead to a refinement in 

methodology and goals and objectives over the long term.

K-18 The Livestock Grazing ROD and the Demonstration Project “kicked the can down the 

road” in the sense that the ROD did not resolve the scientific issues first raised in the 

LRMP process and which could not be resolved in the SRT process. Instead, the 

Demonstration Project process is established to test on a project level basis whether the 

goals, objectives, standards and guidelines can be achieved without livestock grazing 

reductions and what additional measures can be instituted maintain grazing levels. 

The underlying basis for the Grasslands Plan has been decided, upheld on appeal 

and affirmed through the discretionary review process not only once, but twice (see 

2002 ROD, 2003 WO appeal decision, 2003 Discretionary Review, 2006 ROD, 2007 

WO appeal decision, 2007 Discretionary Review). As stated by the SRT, the 

perceived problems with the Grasslands Plan and its FEIS stem from differences 

Response to Comments | 63
North Billings County Allotment Management Plan Revisions

over values rather than scientific shortcomings (2006 ROD p. 4). Therefore, the 

first sentence misstates the reason for the creation of the Demonstration Project, 

and again rejects the findings of the SRT.

Commentor misstates the purpose of the Demonstration Project. “The purpose of 

the demonstration project would be to develop and implement integrated allotment 

management plans pursuant to a collaborative process with the respective grazing 

associations that share in the management of grazing on the National Grasslands, to 

determine if Grasslands Plan Goals and Objectives are achievable or need 

modification, and monitor progress towards meeting the resource objectives.” (2006 

ROD p. 15). 

The Forest Service obligation under the demonstration project is to provide “[o]ne 

goal will be to maintain or improve on-the-ground conditions to maintain, to a 

maximum extent possible, a grazing program at current levels and provide 

sufficient habitat for grassland species” (2006 ROD p. 16). 

Given the lack of scientific controversy over the goals, objectives, standards and 

guidelines in the Grasslands Plan, the point of the Demonstration Project is more to 

work cooperatively with our partners to determine how to meet the Grasslands 

Plan.

There actually is no language in the demonstration project that discusses additional 

measures that could be instituted to maintain grazing levels. However, this is 

routinely done in the course of AMP development. Refer to the Alternatives 

Considered in Detail section in Chapter 2 of the SDEIS for a description of how the 

alternatives were developed.

K-19 HAND appealed the Livestock Grazing ROD to secure specific direction that 

economically viable ranching operations be a plan objective and that the Forest Service 

reexamine all of the standards and guidelines, except those clearly mandated by statute, 

such as the Endangered Species Act. While both the Chief and Under Secretary affirmed 

the Livestock Grazing ROD, the Under Secretary gave the Forest Service explicit 

direction that is also relevant to the AMP DEIS. 

| “I am also directing the grasslands supervisor to continue to work with cooperators and 

partners such as the North Dakota grazing associations, North Dakota State University, 

Dickinson State University, the Agriculture Research Service and the Natural Resource 

Conservation Service to refine and supplement the Dakota Prairie Grasslands vegetation 

monitoring techniques”. 

 

This is the correct quote from Undersecretary Rey’s discretionary review letter. 

Ongoing projects are occurring throughout the Dakota Prairie Grasslands to look at 

and refine vegetation monitoring techniques. See also response to comments K-65 

and K-124. 

|

64 | Response to Comments
North Billings County Allotment Management Plan Revisions

 As the Forest Service and its cooperators and partners work to reach agreement how to 

refine and supplement the VOR and other vegetation monitoring techniques to promote 

rangeland health, I direct the supervisor to strongly consider the vegetation monitoring 

techniques suggested by the NRCS. 

This is the correct quote. Refer to the Forest Service Response to the SRT Reports, 

(Project Record, Supporting Documentation, L-97 and SDEIS, Chapter 3 Part 1, 

Range, Methodology, Carrying Capacity Analysis regarding how the NRCS data 

was used in this project.

 I support that approach [DPP] and expect that, should the results of the Demonstration 

Project indicate that modifications are needed, a plan amendment process will be 

initiated as soon as possible. 

 

This is the correct quote from Undersecretary Rey’s discretionary review letter. 

Monitoring completed on implemented AMPs for the North Billings and other AMP 

projects will provide the basis to determine if Grasslands Plan amendments are 

needed (Grasslands Plan 2006 ROD, p. 16, pt 3). However, the analysis completed 

for North Billings determined that the Grasslands Plan goals and objectives are 

achievable; therefore modification to the Grasslands Plan is not needed. Monitoring 

progress towards meeting the resource objectives is an integral component of the 

proposed action.

| 

 The Pilot Project provides for no cuts in the grazing unless monitoring shows the cuts are 

necessary to achieve the goals of the plan, and the Forest Service demonstrates the cuts 

are the only effective means for achieving plan goals. Please keep this office updated on 

a quarterly basis concerning the results of the Demonstration Project.@ Memorandum 

of USDA Under Secretary August 13, 2007. 

 

This is the correct quote from Undersecretary Rey’s discretionary review letter. 

However, it is best understood by adding in the sentence above this quote which is 

“The terms of the Demonstration Pilot Project should be implemented in a fashion 

consistent with the Management Plan and its appendices.” (Mark Rey discretionary 

review of the 2006 Livestock Grazing Decision 8/13/07). 

 

 In fact, Alternative 3 has no initial reductions in Authorized Use, which is the 

proposed action developed in careful consultation, coordination, and cooperation 

with the MGA (see SDEIS Appendix A and Project Record, Permittee 

Correspondence). Alternative 3A which is a modification to the proposed action 

based on MGAs comments also does not include initial reductions in Authorized 

Use. Alternative 4 includes initial reductions in Authorized Use in many of the 

allotments. The Responsible Official will consider the analysis in the SDEIS to 

determine if livestock are principally responsible for not meeting desired conditions, 

and whether or not cuts are the only ecologically practicable and economically 

feasible means available for meeting the desired condition. 

Response to Comments | 65
North Billings County Allotment Management Plan Revisions

K-20 The Medora Ranger District (MRD) started the AMP revision in early 2005 well before 

the conclusion of the SRT process, adoption of the Livestock Grazing ROD and 

Demonstration Project, or the conclusion of the appeal review in August 2007. The 

alternatives were developed in 2006 and revised in 2007. The data appear to have been 

largely based on evaluations done in 1998-1999, 2004 and 2005. 

The Forest Service is unclear on exactly what the commentor means by the start of 

the AMP revision. Field data collection for this project started in 2004 prior to the 

conclusion of the above mentioned processes. The IDT collected field data to 

describe existing condition from 2004 to 2008 (see the Methodology and/or Existing 

Condition sections for each resource in Chapter 3 Part 1 of the SDEIS). The range 

staff held their first round of permittee meetings during the fall of 2005; these were 

followed by meetings in the summer of 2006 (SDEIS, Appendix A). The last round 

of meetings was held in the winter of 2007 (SDEIS, Appendix A). Alternative 

development was initiated in 2006 (Project Record, Process Documentation, IDT 

Meeting Notes, B-12), and was completed sometime after January 2010 (Project 

Record, Process Documentation, IDT Permittee Meeting Notes, B-54). As the 

different processes listed by the commentor were completed, the results were 

adapted into the Forest Service’s planning process for this project.

K-21 Most of the AMP process occurred before notice of intent was published in May 2008, 73 

Fed. Reg. 28098 (May 15, 2008). NEPA requires an agency to integrate the NEPA 

process as early as possible. 40 C.F.R. ''1501.2, 1501.7 (scoping), 1502.7 (EIS 

preparation). Instead, the NEPA notice came more than three and a half years after the 

MRD began the AMP and certainly after most of the major decisions had been made, 

including delineation of the alternatives. The draft of Appendix A is dated February 

2008, showing that the MRD had established all of the alternatives and had its carrying 

capacity calculations completed. 

The Forest Service is not certain what the commentor means by “most of the AMP 

process”; however, Forest Service planning is generally done at two levels, the 

programmatic grassland plan level and the site specific project level. The 

Grasslands Plan establishes Grassland-wide goals, objectives, grassland-wide 

standards and management area standards. Suitable areas were identified for land 

uses across the Forest; these were identified as management areas. Management 

area goals, objectives and standards provide guidance for project level planning and 

decision-making, but are not site-specific enough to fulfill the requirements for 

project level analyses required by the NEPA. 

Project level planning is done in the framework of the Grasslands Plan. It may be 

necessary to conduct field inventory and data collection and analysis before the 

Forest Service proposes an action during scoping. This inventory and data 

collection and interpretation of this data may take months or years. It is not until 

the agency determines that action is needed and takes steps pursuant to the National 

Environmental Policy Act that a proposal exists. The CEQ requires that scoping be 

done as early in the process as practicable and that it would not be appropriate to 

66 | Response to Comments
North Billings County Allotment Management Plan Revisions

conduct scoping until the impacts of a particular action (proposal) are confined to 

specific sites (40 CFR §1501.7. §1502.4; §1508.25). 

The Forest Service is not certain what the commentor means by the statement 

“...the NEPA notice came more than three and a half years after the MRD began the 

AMP and certainly after most of the major decisions had been made,...” but certainly 

no NEPA decision had been made before scoping. Scoping began on May 23, 2008, 

the DEIS was released on July 1, 2009, comment on the DEIS ended October 12th, 

2009. 

Moreover, the “AMP process” the commentor refers to is traditional determinations 

of existing condition versus desired condition needed to develop a proposed action. 

Note the meetings that occurred prior to scoping were with the permittees and the 

Grazing Association, as we said we would do as part of the Demonstration Project 

(see 2006 ROD p. 16-17).

The commentor also misstates the full direction in the NEPA regulations. 40 CFR 

1501.2 says “[a]gencies shall integrate the NEPA process with other planning at the 

earliest possible time to insure that planning and decisions reflect environmental 

values, to avoid delays later in the process and to head off potential conflicts.” To 

have released the proposed action, which was being developed with the MGA 

earlier, would have been premature.

Commentor correctly identifies 40 CFR 1501.7 as scoping, which first requires a 

proposed action (see above). The time taken to evaluate the scope, gather necessary 

background data, and work with the permittee and comply with the SRT 

recommendations are all part of the needed prework described in this section of the 

regulations. 

K-22 Billings County and MGA filed scoping comments that raised the same issues repeated in 

these comments. The major issues, virtually all of which were entirely ignored, in the 

AMP DEIS, are:

Billings County scoping response raised the issues identified below, that are taken 

verbatim from the county’s June 23, 2008 letter. The MGA response to scoping 

dated June 26, 2008 was a series of questions which did not address the comments 

below (Project Record, Scoping Period Comments, D-6, 7, and 9).

+ 

 Integrate Demonstration Project parameters and Under Secretary guidance into the 

AMP and EIS; 

 

As stated elsewhere, this project is in full compliance with the Demonstration 

Project (see response to comments K-25, 26, 27, 28, and 35) as written, and the 

Under Secretary’s guidance (see 2006 ROD, 2007 Discretionary Review and 

response to comments K-19 and K-122). 

+ 

Response to Comments | 67
North Billings County Allotment Management Plan Revisions

 Revise proposed action to reflect genuine collaboration; 

 

The MGA and Billings County seem to have a one sided interpretation of 

collaboration which roughly interpreted is that all their recommendations (see 

response to comments K-127 and K-34) must be included for collaboration to have 

taken place. This is not the Forest Service’s understanding of collaboration; 

however, the proposed action reflects nearly all of the recommendations provided 

by the MGA, see response to comment M. Based on MGA’s comments Alternative 

3A was created for the SDEIS to reflect those specific actions the MGA felt the 

Forest Service should or should not have included – see SDEIS, Appendix A. 

See also response to comments K-26, 27, 28, 35, and L (Schneider 4 and 5). 

+ 

 Revise AMP process to test whether LRMP objectives standards and guidelines are 

achievable; 

 

The Grasslands Plan and its accompanying RODs has twice been appealed and 

upheld and the Regional Forester’s decision was upheld in full by the Washington 

Office ( 2003 and 2007 WO Appeal Decisions) and in the Secretary of Agriculture’s 

discretionary review (2003 and 2007 Discretionary Reviews). There is no direction 

in any of that documentation directing the Forest Service to test whether objectives 

standards and guidelines are achievable nor is there any direction at the site specific 

project level carry out such tests. There are also no recommendations from the SRT 

process to test LRMP objectives standards and guidelines at the project level. 

Also the SDEIS indicates the landscape is capable of reaching Grasslands Plan 

goals, objectives, standards and guidelines (SDEIS, Chapter 3 Part 1). The issue is

how to change management to meet the Grasslands Plan. 

+ 

Revise AMP to identify LRMP amendments; 

 

As previously noted The Grasslands Plan and its accompanying RODs have twice 

been appealed and upheld. The Regional Forester was and is willing to consider 

possible amendments to the Grasslands Plan as the need arises. However, a decision 

has to be made on this project and AMPs written, implemented, monitored and then 

evaluated to determine if additional adjustments to the Grasslands Plan are needed. 

As stated before no adjustments to the plan were noted during this project analysis. 

 

+Disclose and address how to resolve scientific controversies; Scientific controversies 

regarding LRMP assumptions and data not resolved 

 

See response to comments K-11 and K-111 

+ 

 Develop data and protocols to conform to SRT Recommendations; 

+ Failure to develop PFC and Robel Pole protocols; 

+ Correct deficiencies in carrying capacity elements;

68 | Response to Comments
North Billings County Allotment Management Plan Revisions

The protocols for PFC are well established and clearly articulated in Prichard et al., 

1998, and Prichard et al., 1999 (revised 2003). There is no additional need to 

develop additional PFC protocols. The SDEIS provides a thorough discussion of the 

carrying capacity analysis including how it was calculated, whether others use the 

method utilized in this analysis, outcome of peer review, other methodologies that 

are available and why they were or were not used, the SRT recommendations, and a 

discussion of the MGA recommendations (Range, Methodology, Carrying Capacity 

Analysis section of Chapter 3 Part 1 and Appendix A of the SDEIS) 

+ 

 Information Data Quality Act issues; and 

+ Any proposed grazing reductions require quality monitoring data needed to integrate the 

requirements of the Livestock Grazing ROD and the Demonstration Project.

 

The Demonstration Project states that “Monitoring will be needed to establish 

whether or not desired conditions have already been achieved before consideration 

of livestock numbers or AUM adjustments”. The SDEIS describes the existing 

resource conditions based on existing monitoring data collected over the past several 

years at both the geographic and allotment level (see the Methodology and/or 

Existing Condition sections for each resource in Chapter 3 Part 1 and the Existing 

Condition section for each allotment in Chapter 3 Part 2 of the SDEIS. It describes 

whether or not the allotment(s) meets desired conditions based on the monitoring 

data and goes on to describe whether or not livestock grazing was a factor. The 

SDEIS also includes a description of the monitoring to be conducted in the 

Monitoring section of Chapter 2 and by allotment in the third table for each 

allotment in Chapter 3 Part 2 of the SDEIS. 

K-22a The County requested cooperating agency status in June 2008 but the Forest Service has 

done its best to delay to the point where it is less meaningful and also violates NEPA 

rules and guidance. The CEQ governing rules for cooperating agency status define a 

cooperating agency to include a state or local agency or tribe that has jurisdiction or 

special expertise with respect to environmental impacts. 40 C.F.R. '1508.5. The CEQ 

guidance memoranda issued in 1999 and expanded in 2002, which were cited in the 

Billings County cooperating agency request, also apply to requests from non federal 

agencies for cooperating agency status. CEQ Memorandum Designation of Non-Federal 

Agencies To Be Cooperating Agencies in Implementing the Procedural Requirements of 

the National Environmental Policy Act (ANEPA@) July 28, 1999. Billings County 

clearly met the criteria set out in the CEQ rules and explained in the 2002 memorandum 

by CEQ Director James Connaughton entitled Cooperating Agencies in Implementing the 

Procedural Requirements of the National Environmental Policy Act (Jan. 30, 2002). 

Failure to grant the requests or delays in responding contradicts decisions in Wyoming 

federal court setting aside an EIS when the agency failed to act on the cooperating 

agency request, Wyoming v. U.S. Dept. of Agriculture, 570 F. Supp.2d 1309, 1334 1335 

(D. Wyo. 2008); or failed to involve the cooperators in the development of alternatives, 

Intl. Snowmobilers Assn. v. Norton, 340 F. Supp.2d 1249, 1262, (D. Wyo. 2004). In both 

cases, the EIS and the agency decision were set aside for failure to involve cooperating 

agencies. 

Response to Comments | 69
North Billings County Allotment Management Plan Revisions

The actual chronology is as follows: 

• June 23, 2008 – Billings County Commission hand delivers commissions scoping 

comments followed by hard mail copy. Contained in comments is a request for 

cooperating agency status. 

• July 2, 2008 – Letter from Medora Ranger District to Billings County 

Commission stating that commission’s comments were not signed and requesting 

signed copy so Medora Ranger District could consider their cooperating agency 

request.

• August 6, 2008 – Medora Ranger District received a signed copy of Billings 

County Commission comments. 

• January 26, 2009 – Letter from Medora Ranger District responding to request for 

cooperating agency status. 

• March 3, 2009 – Billings County Commission’s responses to 1/26/09 letter. 

• April 13, 2009 – Letter from Medora Ranger District to Billings County 

Commission’s containing draft MOU for commission’s review and comment. The 

letter notes that the County would need to identify a representative who would 

serve as signatory for the County (Part E, number 7 of MOU).

• May 29, 2009 – Medora Ranger District receives draft MOU back from Billings 

County signed by commissioner Arthaud but with Part E, number 7 of MOU 

blank.

• June 9, 2009 – Letter from DPG Supervisor to Billings County Commission noting 

reception of signed draft and transmittal of final MOU for signature. Letter noted 

the need for identification of county contact person, to be filled in block 7, and 

need for that person to meet requirement of paragraph 6 of the MOU.

• July 8, 2009 – Grasslands Supervisory receives signed MOU from Billings County 

Commissioner James Arthaud.

• July 16, 2009 – Letter from DPG Supervisor to Billings County Commission 

noting receipt of the signed MOU by Billings County. It also notes that the person 

identified as the county contact doesn’t meet MOU requirements (Part E numbers 

6 &7) and requests submittal of a different contact person.

• August 20, 2009 – Letter from C.E. Brooks and Associates, P.C. to Horst 

Greczmiel, Associate Director CEQ on failure of Forest Service to grant 

cooperating status to Billings County Commission. 

• September 18, 2009 – Letter from Grasslands Supervisor to Billings County 

Commissioner identified that the Forest Service had not rejected the signed MOU 

and clarified that only thing lacking was identification of a County representative 

without a conflict of interest or appearance thereof.

• October 8, 2009 – Letter from Joan Jurgens (Billings County Representative) to 

Grasslands Supervisor w/ signed copy of MOU. 

• October 29, 2009 – Letter from Grasslands Supervisor to Joan Jurgens 

identifying that the principle contacts are now acceptable to Forest Service, that 

he had signed the MOU which was attached to the letter.

• November 12, 2009 – Letter from Grasslands Supervisor to Joan Jurgens 

identifying meeting between Forest service and County representatives w/ and 

70 | Response to Comments
North Billings County Allotment Management Plan Revisions

attached set of notes for the counties review. Note identify County would supply 

their information to Forest Service by December 23, 2009. 

• December 30, 2009 – Forest Service received an Economic Report from Billings 

County. 

• January 22, 2010 – Forest Service response to Billings County Economic Report 

and cover letter. 

• March 25, 2010 – Meeting between Forest Service and Billings County economist 

to discuss Forest Service and County’s reports. 

• April 2, 2010 - Letter from District Ranger Ron Jablonski to Joan Jurgens. The 

letter transmitted a copy of Forest Service meeting notes, from March 25, 2010 

meeting with Billings County. The letter also requested any edits or additions the 

County may have. 

• April 15, 2010 – Letter District Ranger Ron Jablonski to Joan Jurgens. The letter 

transmitted the latest draft of the Forest Service economic report and a summary 

document, which identified information from the Billings County economic 

report, included in the Forest Service draft. The letter also requested that Billings 

County provide any proposed edits by April 30, 2010. 

• July 22, 2010 – Letter from District Ranger Ron Jablonski to Joan Jurgens 

identifying that he had decided to add Alternative 3A to the North Billings 

analysis. Enclosed with the letter was a copy of the new alternative and a request 

to notify the Forest Service if the new alternative would affect the Billings County 

economic analysis. 

• July 27, 2010 – E-mail from Jeff Adams to Joan Jurgens identifying that District 

Ranger Ron Jablonski had granted Billings County’s request for additional time 

to review Alternative 3A.

• July 30, 2010 – E-mail from Joan Jurgens to Jeff Adams thanking Forest Service 

for granted extension to review Alternative 3A.

• August 13, 2010 – E-mail from Joan Jurgens to Jeff Adams. Dr. Bangsund 

indicates that changes in livestock reductions would change the assessment but 

Alternative 3A doesn’t not appear to change reductions set forth in the DEIS.

• August 27, 2010 - Letter from District Ranger Ron Jablonski to Joan Jurgens 

transmitting copy of Forest Service Final Economic Report.

• September 20, 2010 – Letter from District Ranger Ron Jablonski to Joan Jurgens 

identifying that the carrying capacity analysis for the North Billings project had 

been updated with new NRCS ecological site production information. Enclosed 

with the letter was the updated carrying capacity information. The letter also 

requested an updated copy of the Billings County economic repost if this new 

information changed their report. 

• October 14, 2010 – Letter from District Ranger Ron Jablonski to Joan Jurgens 

identifying that the Forest Service Economic Report had to be updated and 

transmitted a copy of the report. 

• January 24, 2011 - Letter from District Ranger Ron Jablonski to Joan Jurgens 

identifying that some minor editing errors had been discovered in the Forest 

Service economic report. The letter also transmitted a copy of the Final Forest 

Service Economic Report.

Response to Comments | 71
North Billings County Allotment Management Plan Revisions

The agency has complied with 40 CFR 1501.6 

The MRD did not send the first Memorandum of Understanding until after the AMP DEIS 

was released. 

This is an incorrect statement. In a letter dated April 13, 2009 District Range Ron 

W. Jablonski sent a draft Memorandum of Understanding (MOU) to Jim Arthaud, 

Chairman Billings County Commissioners. The DEIS was made available to the 

public on July 1, 2009. 

K-23 Billings County has broad authority to protect the public health and welfare of county 

residents. N.D.C.C. '11-33-02. Assuring access to land for livestock operations and 

ensuring that the land is wisely managed is included in the county mandate and reflected 

in the Billings County Comprehensive Plan. See pp. 4, 7 (ABillings County supports 

maintaining or increasing the level of livestock grazing on federal and state lands, 

protecting water rights, increasing the tourism industry in a manner compatible with 

private property rights and local self-determination, and promoting socially and 

ecologically responsible oil and gas exploration, development, and production.@). 

Protecting the interests of its citizens that depend on the national grasslands for their 

livestock operations and ensuring that the vegetation is well-managed to reduce the risk 

of fire are objectives that are essential to the public welfare of Billings County.

Under North Dakota law Billings County has broad powers to provide for the 

development and zoning of all lands within its boundaries, to provide for a transportation 

system, law enforcement, and other services. N.D.C.C. ''11-33-01, 11-33-03. The county 

implements its authority in numerous ways, including acquisition of real and personal 

property, rights-of-way and easements, land use planning and zoning, approving 

construction within the county, and providing for the maintenance and construction of 

roads within the county, emergency management, development of natural resources 

within the county. N.D.C.C. ''11-11-14; 11-33-01; 11-33-03. Pursuant to its authorities, 

Billings County adopted a Comprehensive Plan. 

http://www.billingscountynd.gov/BillingsCountyComprehensivePlan.htm. The plan 

establishes policies and direction for land management throughout the county. 

Billings County commissioners actively participated in the development of the DPG 

LRMP as well as the related issues pertaining to fire suppression and control, access 

within the LMNG, and energy development projects. These activities reflect the county=s 

obligation Ato serve the health, safety, morals, public convenience, general prosperity, 

and public welfare of the citizens of Billings County.@ Comprehensive Plan at 6.

The Forest Service recognizes that Billings County has prepared the Billings County 

Comprehensive Plan. Billings County Comprehensive plan was considered in the 

development of the Grasslands Plan (Grasslands Plan FEIS p. 3-403). In addition, as 

noted in response to comment K-6 management of the LMNG is governed under the 

provisions of the Bankhead-Jones Farm Tenant Act, the Forest and Range 

Renewable Resources Planning Act, the National Forest Management Act and 

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North Billings County Allotment Management Plan Revisions

Forest Service Regulations 36 CFR 213 (Administration of Lands under Title III of 

the Bankhead-Jones Farm Tenant Act by the Forest Service) and 36 CFR 222 

(Range Management) and other laws relating to the National Forest System lands. 

The United States Constitution vests Congress with the authority over all federal 

lands. Agencies must administer lands under their jurisdiction consistent with those 

acts of Congress. For the National Grasslands, Congress through the BankheadJones Farm Tenant Act and other laws discussed above has set for the management 

purposes and objectives of the federal lands. As such, the SDEIS has appropriately 

set forth those statutes directing management of the national grasslands. 

K-24 Expertise regarding the proposed actions/relationship to the objectives of regional, State 

and local land use plans, policies and controls, 40 C.F.R. ''1501.1(d), 1501.7, 1502.16(c). 

Billings County has land use planning authority and substantial background in national 

grassland management, the Dakota Prairie Grasslands (DPG) Land and Resource 

Management Plan (LRMP), and the related issues pertaining to livestock grazing 

management. Billings County commissioners are knowledgeable about the management 

issues, vegetation and habitat, access rights and needs, and the history and background 

of agriculture in the county. The MGA has played an integral part of this custom and 

culture and the range management issues to be addressed in the EIS. The management of 

the grazing allotments administered by the MGA members has an important role in the 

economy and the custom and culture of Billings County. See Comprehensive Plan at 3, 4 

(ABecause federal lands grazing accounts for over one-half of all livestock grazing in the 

County, continued federal land grazing is of paramount importance to maintain the 

ranching industry and the custom and culture of ranching in Billings County.@), 5 

(A[T]here are no substitutes for the base industries of energy and cattle production. 

Consequently, the current uses of natural resources must be maintained in order to keep 

the custom, culture, and economic stability of Billings County intact.@).

Billings County has the requisite expertise with respect to the resource issues, including 

water, vegetation, land use, zoning, and transportation and with respect to economic and 

social issues to be a cooperating agency. 40 C.F.R. '1506.16. 

Yet the Forest Service has done all that it could to delay action on the county’s request. 

Waiting more than 8 months to respond to a request is not good faith compliance with the 

CEQ guidance regarding cooperating agencies, especially since the MRD was writing 

the EIS while delaying its response to the request. Had Billings County been involved as 

a cooperator, it would have been able to identify the significant costs to the agriculture 

sector and the communities at large, starting with reductions traceable to carrying 

capacity calculations. Previous comments by other range and resource experts 

attributed additional reductions to high structure objectives in the DPG LRMP and 

restrictions on structural range improvements, such as water development. See e.g. 

HAND Comments 1999, 2002, and appeal of 2007 and exhibits. 

Agriculture is an important component of the county economy and culture and this is 

recognized in the Billings County plan. The county participated in and helped to fund the 

HAND economic analysis done in 1999 which displayed the effects of very similar level 

of grazing reductions. HAND Comments 1999, Leistritz 1999. The economic impact 

Response to Comments | 73
North Billings County Allotment Management Plan Revisions

analysis is a much more inclusive analysis of the impacts than what was found in the 

AMP DEIS. 

See response to comment K-23.

K-25 The 2006 Livestock Grazing ROD is part of the DPG LRMP and the proposed North 

Billings AMP Revisions project must be consistent with the planning decisions made by 

the Forest Service in the ROD. 2006 ROD at 2; 16 U.S.C. &1604(I); Neighbors of Cuddy 

-Mtn. v . U.S. Forest Service, 137 F.3d 1372, 1376 (9th Cir. 1998). 

If the AMP DEIS project does not conform to these livestock grazing planning decisions, 

the proposed action may not go forward unless it is modified for consistency, or if the 

DPG LRMP and the ROD are contemporaneously amended. 36 C.F.R. '219.8(e). As 

currently proposed, the AMP Revision project is inconsistent with the livestock grazing 

components set forth in the ROD, and the Forest Service must either modify the proposed 

action to make it consistent with the DPG LRMP, amend the plan to allow for the 

proposed action, or reject the proposed action altogether. Id. 

Commentor is correct in their summarization of 36 CFR 219.8 (e) – that is, a 

selected action must be either consistent with the Grasslands Plan (and other laws 

and regulations) or the Grasslands Plan must be amended to make it consistent. 

Since that rule has been pulled, the National Forest Management Act (NFMA) 

contains the parent language to the cited clause “[r]esource plans and permits, 

contracts, and other instruments for the use and occupancy of National Forest 

System lands shall be consistent with the land management plans. Those resource 

plans and permits, contracts, and other such instruments currently in existence shall 

be revised as soon as practicable to be made consistent with such plans. When land 

management plans are revised, resource plans and permits, contracts, and other 

instruments, when necessary, shall be revised as soon as practicable. Any revision 

in present or future permits, contract, and other instruments made pursuant to this 

section shall be subject to valid existing rights” (U.S.C Title 16, Chapter 36, 

Subchapter I part 1604 (h)(3)(i). 

The 2000 Planning Rule, republished in December 18, 2009 in the Federal Register 

to be in effect until the next planning rule, states in 36 219.10 “ All site-specific 

decisions, including authorized uses of land, must be consistent with the applicable 

plan. If a proposed site specific decision is not consistent with the applicable plan, 

the responsible official may modify the proposed decision to make it consistent with 

the plan, reject the proposal; or amend the plan to authorize the action.”

Alternative 3 meets the standards in the Grasslands Plan. In addition Alternative 3 

is designed to meet the goals and objectives with the initial actions and adaptive 

management measures. However, it may take longer for Alternative 3 to move 

toward the desired conditions in the Grasslands Plan than Alternative 4. 

K-26 The MRD has failed to implement the Demonstration Project format, even though 

required by the Livestock Grazing ROD and disposition of the appeals in August 2007. 

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Instead, the MRD claims that it is implementing the Demonstration Project, AMP DEIS 

at 1-5 - 1-6, although as shown below in these comments, the DEIS misses many of the 

key elements that the Demonstration Project was to consider. 

The following analysis of each Demonstration Project provision shows how the DEIS 

fails in any substantial respect to comply and for that reason, the AMP DEIS needs to be 

entirely revised or a supplement prepared that conforms. 

A. Careful consultation with the Grazing Association 

The Demonstration Project Proposal specifically provides: 

[AMPs] will be developed at the landscape or multiple allotment level. The Pre-NEPA 

process would be completed in careful consultation, coordination, and cooperation with 

the grazing associations representing their members working in concert with the Forest 

Service.

Livestock Grazing ROD at 16. 

The individual allotment AAMPs will be developed from information contained in the 

selected alternative@ of the AMP Revisions project, DEIS at ix-x. In response to the 

requests for additional time to comment, the District Ranger wrote MGA setting out the 

times that the Forest Service discussed the AMP DEIS, a significant number of which 

occurred during the MGA monthly meetings. See e.g. Jablonski Letter of Sept. 17, 2009 

at 2-3. But the quantity of meetings is not a substitute for quality. The DP requires true 

collaboration, not just a meeting where the Forest Service tells the permittee what will be 

done, without regard to the objections and concerns expressed by the MGA members. 

The Forest Service believes that the Demonstration Project has been followed. The 

commentor is correct in stating that the Forest Service agreed to implement the 

Demonstration Project (2006 ROD, p. 10). (NOTE: The Forest Service is unclear as 

to what exactly the commentor means by disposition of the appeals in August 2007, 

but for clarification the Regional Forester’s decision was upheld in full by the 

Washington Office (2007 WO Appeal Decision) and in the Secretary of 

Agriculture’s discretionary review (2007 Discretionary Review). 

The commentor appears to have identified one “key element” from the 

Demonstration Project. The Forest Service fully believes it has implemented careful 

consultation, coordination, and cooperation (Project Record, Process

Documentation, Permittee Meeting Notes, B-51 – B-54; SDEIS, Appendix A; and 

Project Record, Correspondence Permittee, J-23). See also response to comments K27 and K-28. 

The September 17, 2009 letter to the MGA did have many notations that kept the 

board of directors apprised of progress towards the revision of AMPs within the 

project area. It also included notations about the three different sets of permittee 

meetings each of which covered a significant span of time. These meetings included 

the affected permittee, the base property lessor if applicable, their representative 

MGA director, and Forest Service personnel. 

A lot of input was taken from the individual permittees in development of the 

proposed action (Project Record, Process Documentation, Permittee Meeting Notes, 

B-51 – B-54), and ultimately included in the proposed action (see response to

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comment M). In many cases there was compromise back and forth between the 

permittee and the Forest Service. As noted in the permittee meeting notes (Project 

Record, Process Documentation, Permittee Meeting Notes, B-51 – B-54) and on in 

Appendix A of the SDEIS, individual permittees were informed that if they had any 

concerns and/or questions to feel free to call the MRD or their MGA director. The 

Forest Service range personnel were up front with the individual permittees that not 

all of their desired recommendations would be carried forward for a variety of 

reasons. The Forest Service is confident that the meetings were of sufficient quality 

and quantity to adequately consider and discuss MGA members’ objections and 

concerns.

The collaborative approach outlined in the Demonstration Project actually refers to 

the difference between the traditional method of the Forest Service and grazing 

association and individual member (as described above) or an inclusive 

collaborative approach such as Coordinated Resource Management as described in 

the 2006 ROD page 16. See also response to comment K-35. 

K-27 In the pre-NEPA process between 2005 and 2008, the MRD met with the individual MGA 

members on three occasions. Of these three sets of meeting with the members, the Forest 

Service sought input from the permittees during only the first set of meetings. Exhibit 3, 

Declaration of Clint Schneider (Ex. 3, Schneider Decl.) &&3-7. At the first set of 

meetings, the MGA members set out their recommendations for managing each 

allotment, such as flexibility in the operation of a rest or deferred grazing system, 

flexibility for turn on and off dates, development of water or reconstruction of existing 

water development or fences. See Ex. 2, Comparison of MGA Recommendations and 

Alternative 3 of AMP DEIS. 

The Forest Service did meet with the MGA and its members on three occasions 

between 2005 and 2007. The Forest Service disagrees with the statement that “the 

Forest Service sought input from the permittees during only the first set of 

meetings”. The notes taken at the second and third set of permittee meetings 

dispute this statement (Project Record, Process Documentation, Permittee Meeting 

Notes, B-51 – B-54; SDEIS, Appendix A). Furthermore, after reviewing Exhibit 2, it 

was determined that most of the highlighted MGA recommendations were either 

included in the proposed action or dropped for one of several different reasons, see 

response to comment M and SDEIS, Appendix A, Table 3 for further details.

K-28 While the Forest Service promised to seriously consider them, the agency returned 

months later, to say that the MGA recommendations were “unacceptable” to the IDT 

were excluded. No substantive reason was given other than the biologist or the 

archeologist disagreed. A comparison between what was requested and what the Forest 

Service presented as the draft Appendix A for Alternative 3 demonstrates that the Forest 

Service rejected many of the MGA member recommendations, especially those that would 

facilitate distribution away from sensitive resources and would avoid grazing reductions. 

Thus, the objective of collaboration and working together was quickly squelched. Nor 

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was there any change in this attitude after the Livestock Grazing ROD and 

Demonstration Project were adopted. 

 

All permittee requests were seriously considered by the Forest Service and weighed 

against identified issues in each individual allotment. The Forest Service was up 

front with the individual permittees and identified that not all of their requests

would be carried forward for a variety of reasons (Project Record, Process 

Documentation, Permittee Meeting Notes, B-51 – B-54). This is confirmed, as well, 

by Clint Schneider’s Declaration #4 which states “At the end of the first set of 

meetings the Forest Service said they would take these recommendations back to the 

planning team. They were specific that the association members may get what they 

wanted or may not.” During the second set of permittee meetings requests made by 

permittees that were dropped or altered were discussed and explained with the 

individual permittee. Typically, these requests had to be changed because of a 

particular resource need, which was fully explained to the permittee. A review of 

Exhibit 2, revealed that most of the highlighted MGA recommendations were either 

included in the proposed action or dropped for one of several different reasons, see 

response to comment M and SDEIS, Appendix A, Table 3 for further details.

 

The Forest Service disagrees with the statement, “Thus, the objective of 

collaboration and working together was quickly squelched. Nor was there any 

change in this attitude after the Livestock Grazing ROD and Demonstration Project 

were adopted”, see response to comment K-26. 

K-29 As a result, Alternative 3 of the AMP DEIS reflects what the Forest Service wanted, not 

what was recommended and agreed to by MGA members. Ex. 3, Schneider Decl. &&4-5. 

This does not satisfy the ROD which required the Forest Service to develop an alternative 

that was agreed to by both the MGA and the Forest Service nor did this process actually 

achieve consultation and collaboration, as represented in the AMP DEIS. Ex. 3, 

Schneider Decln &&7-8; DEIS at 1-5. 

Forest Service worked extensively with the MGA board and individual permittees in 

the development of Alternative 3 (SDEIS, Appendix A). The proposed action 

reflects nearly all of the recommendations provided by the MGA, see response to 

comment M. Based on MGAs comments Alternative 3A was created for the SDEIS 

to reflect those specific actions the MGA felt the Forest Service should or should not 

have included (see SDEIS, Appendix A). Also see response to comments K-22, 26, 

27, 28, 35, and Schneider 4 and 5.

K-30 The rigid attitude of the Forest Service further made it clear that no changes in 

Alternative 3 would be “acceptable”. By the third permittee meeting, fewer members 

attended since it was clear that their participation would not result in an alternative that 

the MGA members could support. Id. &7. 

The Forest Service disagrees with this comment. The SDEIS, Appendix A

demonstrates that the Forest Service continued to work with the permittees and 

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consistently identified that the Forest Service was willing to continue to entertain 

any concerns, comments, or suggestions. At the second set of meetings the Forest 

Service even offered the opportunity for individual permittees to challenge 

identified issues on their individual allotment (Project Record, Process 

Documentation, Permittee Meeting Notes, B-52). The IDT field reviewed all 

identified challenges. In the case of one allotment the IDT did determine that the 

resource goal was obtained. 

A review of the Forest Service permittee meeting notes reveals that all but six 

permittees attended the third set of meetings (Project Record, Process 

Documentation, Permittee Meeting Notes, B-53). Attendance at the third set of 

meetings did not indicate that “...it was clear that their participation would not 

result in an alternative that the MGA members could support.” The six permittees 

did not attend because of scheduling conflicts, personal health issues, and 

conveyance of two allotments from Federal to private ownership. These missed 

meetings were resolved through telephone conversations, no resource issues were 

identified so third meeting wasn’t truly necessary, and in one situation the third 

meeting was not followed up on.

K-31 A comparison of Alternative 3, Appendix A from the notes of each permittee meetings 

regarding the initial recommendations illustrate the clear fact that the Forest Service did 

not develop an alternative that MGA supported. Requests for water development, 

flexibility for on and off dates, and other structures were omitted entirely. Ex. 2. In 

many cases, the Alternative 3 imposes removal of water developments or fences based on 

“no net increase” in range structures without any agreement by the permittee. 

The Forest Service disagrees with the comment. A review of Exhibit 2, revealed that

most of the highlighted MGA recommendations were either included in the 

proposed action or dropped for one of several different reasons, see response to 

comment M and the SDEIS, Appendix A, Table 3 for further details.

If an initial action proposed to remove a water development, it was either because a 

resource issue was identified or the IDT was following direction from the 

Grasslands Plan. The Grasslands Plan contains no direction related to “...’no net 

increase’ in range structures...” (see response to comment K-4), nor was it used as a 

reason to preclude any range structure.

K-32 The reliance on the no net increase in range structures is also misplaced. It is not 

required by any law or regulation. The Livestock Grazing ROD requires the Forest 

Service to consider amendments and this is one such amendment that should have been 

considered. 

This comment has been previously addressed in response to comment K-4. There is 

no need to consider amending the Grasslands Plan regarding no net increase as it 

does not exist in the Grasslands Plan.

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K-33 The FEIS allows structural improvements when needed to meet the LRMP. DPG LRMP 

FEIS A-33. When this direction is read with more recent direction to take all measures 

to avoid livestock grazing reductions, it is clear that the MRD erred in not accepting all 

of the MGA member recommendations. 

The Forest Service agrees that structural improvements can be used to help manage 

livestock, see response to comment K-4. 

Alternatives 3, 3A, and 4 utilize a variety of nonstructural and structural practices 

(See SDEIS, Table 2.13 and Chapter 3 Part 2) as initial actions. Both are also 

included in the grazing management toolbox (SDEIS Table 2.1) for potential future 

use if needed. 

The Forest Service assumes that the commentor is referring to the 2006 Grazing 

ROD, more specifically the Demonstration Project when referring to “more recent 

direction”. This direct doesn’t say “to take all measures to avoid livestock grazing 

reductions”. Under point 9 of the Demonstration project it states “There will be no 

cuts in permitted AUM’s without monitoring showing that livestock are principally 

responsible for not meeting the desired condition, and that the cuts are the only 

ecologically practicable and economically feasible means available for meeting the 

desired condition”. It should be noted that Alternative 2 has no grazing reductions. 

Alternatives 3 and 3A have no initial grazing reductions. 

It is correct that not all recommendations were carried forward in Alternative 3,

however, there is no requirement to do so. Response to comment M provides 

explanations of why certain recommendations were not carried forward in the 

proposed action. 

It is correct that not all recommendations were carried forward in Alternative 3, 

however, there is no requirement to do so. Response to comment M provides 

explanations of why certain recommendations were not carried forward in the 

proposed action. Additionally, Alternative 3A was added to the SDEIS and it does 

accept all the MGA recommendations.

K-34 The MGA recommendations were not extreme nor would they have adversely affected 

resource conditions. Thus, the summary rejection by the Forest Service is arbitrary and 

capricious and appears to have been a deliberate effort to impose unnecessary reductions 

in livestock grazing. 

The commentor seems to imply that recommendations from the MGA were for the 

most part rejected. This is incorrect, in fact, most comments were incorporated into 

the proposed action. Recommendations not included are addressed in response to 

comment M. 

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Based on MGAs comments Alternative 3A was created for the SDEIS to reflect 

those specific actions the MGA felt the Forest Service should or should not have 

included (see SDEIS, Appendix A). 

The commentor doesn’t provide any information that would allow the Forest 

Service to judge the commentor’s statement that rejected recommendations would 

not adversely affect resource conditions.

This comment is associated with Alternative 3 the proposed action. Under this 

alternative there are no initial reductions in livestock grazing. Adjustments in 

Authorized Use is one of the tools in the grazing management tool box which may be 

implemented if initial actions identified under this alternative do not provide 

acceptable improvement in impaired resource conditions. 

K-35 The AMP DEIS states that MGA expressly agreed to the adaptive management 

alternatives, citing an email from MGA. AMP DEIS at 1-5. In fact, the Forest Service 

gave MGA an up or down choice, coordinated resource management planning (CRMP) 

or Adaptive Management. Ex. 3, Schneider Decl. &10. The Forest Service did not 

present the choice as adaptive management versus the Demonstration Project. Id. The 

AMP DEIS and the District Ranger incorrectly imply that MGA chose not to adopt the 

Demonstration Project methodology. It was never presented as such. Id. Because the 

Demonstration Project is part of the ROD, the Forest Service could not legally evade 

these procedures, even if the AMP process was well along by December 2006, which it 

was not.

The commentor confuses the Demonstration Project options regarding how the 

Forest Service and MGA would develop a Proposed Action i.e Traditional vs. 

Collaborative approaches such as CRM,(see Grasslands Plan 2006 ROD p. 16) with 

using an adaptive management feature in the proposed action. Including adaptive 

management allows for management flexibility in meeting or moving towards 

Grasslands Plan goals and objectives without revisiting NEPA. 

The Forest Service started working on the North Billings project in 2005 and the 

range staff held their first meetings with individual permittees starting in midNovember of 2005. In September of 2006 the Livestock Grazing Record of Decision 

(ROD) for the Dakota Prairie Grasslands was signed. The ROD stated “Either the 

traditional method of the Forest Service and grazing association and individual 

member or an inclusive collaborative approach, such as Coordinated Resource 

Management (CRM) will be used” (Grasslands Plan ROD, 2006 p. 16). The Forest 

Service met with the MGA on December 6, 2006 (Project Record, Supporting 

Documentation – Range, L-23) to review the recently signed ROD and discuss the 

traditional method or a CRM. Up to this point the Forest Service had been working 

with the individual permittee, their respective directors, and the MGA on the North 

Billings project which is the traditional method. 

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The Forest Service discussed with the MGA what a CRM was and also reviewed the 

course it had been following which was a traditional approach. The MGA Board of 

Directors Regular Meeting Minutes December 6, 2006 state “Another approach is 

to continue with the way we are doing things now, which is the Forest Service, 

permittee and Director meeting and discussing the issues for each allotment.” This 

is the traditional approach identified in the 2006 Grasslands Plan ROD on page 16. 

On January 10, 2007 the Forest Service met with the MGA board of directors at 

their regular meeting. At the meeting the MGA declined the CRM and identified 

that they wanted to continue to use the process we had been following in creating 

the proposed action. The Forest Service documented this decision in a letter to the 

MGA dated January 29, 2007. The letter states “At the January 2007 meeting the 

board decided to follow through with the adaptive management alternative as a 

proposed action and to continue on as we have been doing business/process with the 

North Billings Range EIS”. The Forest Service also provided the MGA with the 

opportunity to correct the notes, the MGA did not respond with any corrections. 

The Forest Service believes that at this point the MGA chose the approach in which 

the proposed action would be jointly developed consistent with the Demonstration 

Project (2006 ROD, p. 16). 

On March 5, 2008 (Project Record, Supporting Documentation – Range, L-25; 

Forest Service range staff notes from MGA Meeting March 2008) the Forest Service 

again briefed the MGA on how utilizing at adaptive management approach to the 

NEPA for this project differs from how NEPA has been done in the past in relation

to creation of AMPs. This was done because several of the MGA board of directors 

had changed. They again confirmed that they wanted to continue with the concept 

of adaptive management in the creation of the proposed action. 

On April 3, 2008 the MGA sent an e-mail to the Medora Range staff again agreeing 

with the use of adaptive management. All during this timeframe the Forest Service 

continued to work individually with the MGA members and board of directors in 

the creation of the actions for each allotment that would become the proposed action

(SDEIS, Appendix A and Project Record, Process Documentation – Permittee 

Meeting Notes, B-51 – B-53). 

K-36 Even now, MGA does not object to adaptive management, if actually implemented 

correctly. Alternatives 3 and 4 do not and cannot however implement adaptive 

management, when the controversies regarding the objectives and how to measure 

progress remain unresolved. 

Alternatives 3, 3A and 4 are adaptive management based alternatives; the concept 

of adaptive management is explained in the Adaptive Management section in 

Chapter 1 of the SDEIS. Resource objectives are defined in Chapter 1 of the 

Grasslands Plan. The Final Response to the SRT Reports addresses the Forest 

Service’s response to different methods of measurement. The SDEIS in Chapter 2 

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contains the monitoring plan and Chapter 3 Part 2 identifies the specific monitoring 

and frequencies that will occur for each allotment. 

While there undoubtedly is still controversy over issues that have been decided in 

the Grasslands Plan (see WO appeal resolution letters from 2003 and 2007, and the 

Secretary of Agriculture’s discretionary review letters from 2003 and 2007 which 

uphold the Grasslands Plan decisions), it is not all scientific controversy. In fact, the 

SRT in response to question of adequacy of the data for the Northern Great Plains 

FEIS states “[i]t is the opinion of the SRT that the perceived problems associated 

with the current FEIS and LRMP stem largely from differences among affected 

parties in value systems rather than scientific shortcomings.”

K-37 While the Forest Service does not have adaptive management guidance, the Department 

of the Interior developed guidelines two years ago. Adaptive Management: A Technical 

Guide (DOI 2007). A critical aspect of adaptive management is the need for agreed upon 

and measurable objectives. DOI Guide at 3. Adaptive management is less feasible when 

there is significant disagreement on the objectives and standards. Thus, embracing 

adaptive management is premature at best unless there are adaptive procedures to test 

the scientific controversies and LRMP goals, objectives, standards and guidelines, so that 

all issues are subject to adaptive management.

See response to comment K-36. 

The IDT reviewed the guide cited in this comment. Commentor misstates the DOI 

guide. The statement is “specifying objectives and tradeoffs that capture the values 

of stakeholders” (DOI Guide, p. 3). This is what was done during the Grasslands 

Plan revision process. The MGA chose not to participate in a CRM process which 

would have involved other stakeholders in the public lands. (see response to 

comment K-35). The adaptive management described in the EIS is appropriate for 

the purpose of adaptive grazing management as opposed to adapative management 

in terms of a structured decision making process in lieu of NEPA, as the commenter 

seems to suggest. (DOI Guide).

K-38 In the AMP DEIS, adaptive management assumes that the LRMP objectives, standards 

and guidelines are set in stone and the question is how to achieve them. This ignores the 

fact that the objectives, standards and guidelines are very much in dispute, and the first 

question is whether they can or should be achieved. 

WO appeal resolution letters from 2003 and 2007 and the Secretary of Agriculture’s 

discretionary review letters from 2003 and 2007 uphold the Grasslands Plan 

decisions. Grasslands Plan objectives, standards and guidelines are not in dispute. 

As commentor correctly points out in K-25, the selected alternative must be 

consistent with the Grasslands Plan or the plan must be amended to make it so. The 

SDEIS indicates that the land is capable of meeting the Grasslands Plan, so the 

reasoned approach would be to change management to aid in achieving the multiple 

use objectives. Also see response to comment K-36. 

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K-39 ROD and Demonstration Project Direction Provisions Not Followed 

1. AMPs will be developed and implemented, working through the processes 

described in this document. Goals, objectives, standards and guidelines related to 

livestock grazing in the Grasslands Plan will be assessed. If adjustments are needed, 

Grassland Plan amendments will be proposed. Livestock Grazing ROD at 16. 

As explained above, the Forest Service rejected most of the MGA recommendations 

because IDT members for biology or archeology did not agree or they were not 

consistent with the LRMP. As a result, the AMP DEIS does not assess the achievability 

of the goals, objectives or standards and guidelines or whether they should be revised to 

avoid livestock grazing reductions. Thus, there is no determination as to the need for 

adjustments in the goals, objectives, standards and guidelines. This is a material and 

fatal omission. 

The Forest Service disagrees with the statement that most of the MGA 

recommendations were rejected, see response to comment M and SDEIS, Appendix 

A. 

The SDEIS includes Alternative 3A which includes all of the MGA’s 

recommendations. The SDEIS also addresses the consistency of the different 

alternatives with Grasslands Plan direction (SDEIS, Chapter 3 Part 1). The SDEIS 

indicates that the land is capable of meeting the Grasslands Plan so there is no need 

to adjust Grasslands Plan goals, objectives, standards and guidelines. 

K-40 The AMP DEIS assumes erroneously that the DPG LRMP is to be implemented as it was 

written in 2002, thereby ignoring the 2006 Livestock Grazing ROD and the incorporation 

of the SRT recommendations and the Demonstration Project. This assumption excises 

the SRT process, the reports, and the Livestock Grazing ROD adoption of the 

Demonstration Project system. Because the AMP DEIS omitted this critical step and 

must be significantly revised.

Appendix C of the SDEIS identifies how the SRT recommendations were used in 

this analysis. Detailed discussion and documentation of the consultation and work 

done with the MGA to develop the proposed action (Alternative 3) is found in the 

DEIS at 3-10 and 3-11 and SDEIS in Appendix A. Chapter 3 Part 1 of the SDEIS 

addresses the provisions of the Demonstration Project. 

K-41 The consequences of not providing for reconsideration of the goals, objectives, standards 

and guidelines are manifest. The AMP DEIS states that the high structure VORs are not 

met in most cases. See e.g. DEIS App. A-49-53, 47, 49 -71, 73-90. Only three of the 41 

allotments are said to meet the high structure objectives. There is, however, no process 

to determine whether the land can produce the vegetation structure to meet the assigned 

VOR. 

Six allotments were determined to be meeting herbaceous structure conditions: 

132A, 239, 241, 243, 248, and 282. 

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Long term monitoring of the LMNG has determined that the identified habitat 

types are biologically capable of producing High structure. See SDEIS, Chapter 3 

Part 1, Herbaceous Structure, Desired Condition. 

K-42 Nor do we have confidence in the conclusion that the allotments fail to meet high or even 

moderate structure objectives since much of the underlying work was done before the 

SRT concluded that the VOR data were suspect. 

SRT did not review the VOR data specific to this project nor did they determined 

that it was “suspect”. The SRT did not conclude that the VOR data for the SRT 

process was “suspect.” Instead, they asked the DPG to analyze data by stations 

versus using the transect average: SRT Recommendation II-2 (Final Response to the 

SRT Reports, p 14): “Robel pole data should be summarized by frequencies of 

readings rather than by averaging readings”. The DEIS incorporates SRT 

Recommendation II-2 on pages 3-134 and 3-135. The SDEIS incorporates SRT 

Recommendation II-2 (SDEIS, Chapter 3 Part 1, Wildlife and SDEIS, Chapter 3 

Part 2). Transect and station analyses are provided in this document.

K-43 The same deficiency applies to the PFC readings of the riparian areas. The AMP DEIS 

concludes that the riparian areas are functioning at risk (FAR) or non-functioning (NF). 

But the AMP DEIS never considered adjusting the PFC criteria or redoing the readings 

after developing a process and training to ensure consistency in the readings. SRT also 

criticized the use of one person rather than review of the data by an IDT. Id. at 23. 

The DEIS (p. 3-57) identifies that intermittent and perennial streams in the project 

area range from PFC to non-functional, it does not conclude that all the riparian 

areas are either FAR or NF. The Affected Environment – Riparian, Existing 

Condition section of Chapter 3 Part 1 of the SDEIS clarifies that all the streams in 

the project area are intermittent with the exception of the Little Missouri River. 

Tables 3.9 and 3.10 in the SDEIS summarize the miles of stream by PFC rating and 

provide the individual PFC rating by allotment.

The methods used to collect PFC data for the SDEIS conform to the written 

protocols (see Prichard et al., 1998, 1999 (revised 2003)) and comply with the 

recommendations that the SRT made in 2005. The comments (i.e. "deficiency"), 

made by the SRT in 2005, were made in reference to some data that were collected 

in 1997 and 1998. Those comments did not apply to the data used in this project. 

The SRT never criticized the data collected for this project. The SRT criticized the 

manner in which some PFC data were collected in 1997/98 for the Little Missouri 

Rangeland Assessment, which was a separate endeavor conducted more than a 

decade ago by other personnel. All the PFC data used to determine existing 

condition in the North Billings project were collected with interdisciplinary teams 

(See Brooks, 2005, p. ix and individual PFC checklists in the Project Record, 

Supporting Documentation – Riparian, L-26). 

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K-44 The AMP DEIS instead assumes that the only impediment to achieving the VOR structure 

and PFC is livestock grazing and does not address site capability or the need to revise 

the plan 

The DEIS and SDEIS do not assume that the only impediment to achieving the 

structure objectives is livestock grazing. The DEIS on page 3-128 and the SDEIS 

(Chapter 3 Part 1, Herbaceous Structure, Introduction) recognizes other factors, 

however, livestock grazing is the most significant and wide-spread management 

activity that affects grassland structure (NGP FEIS, p. 3-239). Site capability is 

previously addressed in response to comment K-41. 

This allegation is also not correct in relation to PFC. The DEIS and SDEIS clearly 

states situations where degraded riparian conditions are related, in part, to factors 

other than grazing, (e.g. in the DEIS Allotment 135, p. 3-62; Allotment 282, Fantail 

Creek, p. 3-67; Allotment 282, Whitetail Creek, p. 3-68; Allotment 289, p. 3-69), 

(SDEIS, Chapter 3 Part 2). Where livestock are the sole or principal cause of 

degradation, that fact is either explicitly stated or deduced from discussion. The 

PFC checklists, part of the Project Record, provide additional details documenting 

livestock impacts to riparian areas. The allegation regarding site potential is 

incorrect. All riparian segments are evaluated with respect to site potential as a 

standard part of the PFC protocol. There is no indication that a revision to the 

Grasslands Plan is needed for evaluating riparian health. The Dakota Prairie 

Grasslands has already addressed the recommendations of the SRT regarding PFC 

(see Dakota Prairie Grasslands, Final Response to Scientific Review Team Reports, 

October 10, 2006, pp. 19-20; available on-line at: 

http://www.fs.fed.us/r1/dakotaprairie/projects/livestock_grazing/corrected_final_srt

_response.pdf.) The DEIS and SDEIS fully considered the recommendations of the 

SRT to the degree that any of these recommendations apply to the North Billings 

project.

K-45 Nor does the AMP DEIS consider the other recommendations by the SRT. 

Appendix C of the SDEIS details how the applicable SRT recommendations were 

used in this analysis. 

K-46 One goal will be to maintain or improve current on the ground conditions to maintain, to 

the maximum extent possible, a grazing program at current levels and provide sufficient 

habitat for grassland species. Site specific amendments to the DPG Plan to incorporate 

these changes will be done, as needed. Id at 16. 

The AMP DEIS omits this goal entirely. Nor does the AMP DEIS propose an amendment 

to the LRMP to adopt this goal and objective. Ironically, the AMP DEIS, which effects a 

reductions from 13% and most between 25 and 45% based solely on a new calculation of 

stocking rates, proves the accuracy of the HAND comments made more than 10 years 

ago. AMP DEIS 3-36 to 3-51. 

The commentor correctly cites this portion of the Demonstration Project. This goal, 

by virtue of being in the 2006 ROD, is a goal of the project. So the project does not 

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need to specifically adopt this goal. Since Alternatives 3 (the proposed action) and 

3A have no initial reductions in Authorized Use, these alternatives do discuss and 

disclose how the project balances keeping the grazing program near current levels 

while maintaining or improving on-the-ground conditions and providing sufficient 

grassland species habitat. Even under Alternative 4, reductions are gradually 

staged in, no more than 10 percent a year (DEIS Table 2.3, SDEIS Table 2.4), and 

monitoring occurs to validate these decisions and resource conditions throughout 

Alternatives 3, 3A, and 4. 

The DEIS on pages 3-52 and 3-54 identifies that under Alternative 4 reductions 

would range from 0 to 45 percent of preference with an average of about 20 percent 

excluding those allotments with no reductions. Note the 20 percent was a typo in the 

DEIS which should have been stated as “about 23 percent”.

After the DEIS was published new NRCS production information became available. 

Initial estimated carrying capacity was recalculated using the updated information. 

Under Alternative 4 reductions in Authorized Use ranged from 0 to 44 percent with 

an average reduction of 20 percent (SDEIS Table 3.5). The table below summarizes 

the information from Table 3.5. 

Percent 

Reduction

Number of 

Allotments

0-10 11

11-20 15

21-30 8

31-40 7

41-44 1

K-47 The AMP DEIS reductions are solely due to recalculation of the carrying capacity and do 

not consider additional reductions for compliance with LRMP goals, objectives 

standards and guidelines, including high structure, VOR readings, PFC, maintenance of 

woody draws, or retention of a natural setting. 

Alternative 4 sets Authorized Use based on initial estimated carrying capacity. The 

alternative is built on the premise that reductions in Authorized Use in combination 

with other initial actions (see SDEIS, Chapter 3 Part 2) will meet or move impacted 

resources towards Grasslands Plan goals and objectives. Monitoring will be 

conducted to determine if suitable progress is being made. If adjustments are 

needed, the Design Criteria (SDEIS, Table 2.4) provides an explanation of how 

AM/AUM adjustments may occur. At that time all of the tools in the tool box are 

available to address the concern, further reductions is only one of many tools. 

Also see response to comment K-7, where Lacey’s additive math error is discussed 

in terms of the Grasslands Plan.

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K-48 The AMP DEIS also foregoes structural range improvements in favor of livestock grazing 

reductions. The AMP DEIS reliance on the Tool Box does not address this issue. 

Alternatives 3 and 3A do not utilize grazing reductions as an initial action to 

address impacted resources. Grazing adjustments are one of the adaptive tools in 

the toolbox that may be used if other identified actions don’t move impacted 

resources towards Grasslands Plan desired future conditions. Alternative 4 utilizes 

the initial estimated carrying capacity to establish Authorized Use along with 

various other range improvements to address identified resource issues (see SDEIS, 

Chapter 3 Part 2).

The grazing management tool box is a repository of management tools that can be 

used to address resource issues (see SDEIS, Chapter 1, Adaptive Management) if 

monitoring shows initial management actions aren’t meeting or moving impacted 

resources towards Grasslands Plan desired future conditions.

K-49 Scientific Review Team (SRT) recommendations will be incorporated into and 

implemented through the Final ROD and the livestock grazing allotment management 

planning process Id at 16. 

The SRT process yielded a number of recommendations, which are not a part of the AMP 

DEIS. The AMP DEIS does not discuss the SRT recommendations in detail nor does it 

adopt the recommendations explicitly. 

The Forest Service adopted the SRT recommendations as described in the Forest 

Service Final Response to the SRT. How the team met the applicable 

recommendations are detailed in the SDEIS Appendix C.

K-50 The Forest Service has stated that it is implementing the SRT recommendations. AMP 

DEIS at 1-4 to I-5; I-10. The adoption of SRT recommendations is selective at best, such 

as the claimed use of NRCS methodology to calculate carrying capacity and dropping the 

floristic quality index.

See SDEIS, Appendix C. 

K-51 SRT recommended that the Forest Service reconsider the criteria for what is PFC in 

North Dakota. SRT at 22-23 (A Determine if PFC rating is applicable to North Dakota, 

use multi-disciplinary team to conduct PFC ratings, and develop a training manual and 

process.) The SRT also questioned the PFC data used by the Forest Service since it was 

not clearly developed using a team approach. Id. The SRT recommended that the Forest 

Service use interdisciplinary teams and extensive training. Id.

The PFC ratings are based on the local site potential and capability (Prichard et al., 

1998, pp. 6-7). Therefore, even though the protocol is standardized, the evaluation 

of individual attributes is made by an interdisciplinary team with knowledge of local 

site potential and capability. The PFC method has been used across the United 

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States and internationally. Its universal applicability is possible because evaluations 

are made relative to the potential of each locality. 

The use of interdisciplinary teams is a standard part of the PFC protocol (see 

Prichard et al., 1998, p. 1; Prichard et al., 1999 (revised 2003), p. 1). The DEIS used 

data collected by interdisciplinary teams, including that of Brooks (2005, p. ix), and 

Forest Service personnel in the summers of 2006 and 2007 (see PFC field checklists, 

Project Record, Supporting Documentation – Riparian, L-26) to determine existing 

condition. 

The PFC method has already developed standard manuals (Technical Reference 

1737 series issued by the Bureau of Land Management). Also, states in the western 

United States have training cadres already developed to provide local training 

assistance. The Montana/Dakota training cadre is the local training cadre. Two of 

the members of the MT/ND training cadre (Kurt Hansen and Mark Gonzalez) are 

current or past members of the Dakota Prairie Grasslands with decades of 

experience studying local streams and rangelands. The necessary training resources 

are already well established for North Dakota. 

See also response to comment K-43. 

K-52 The AMP DEIS continues to use the same PFC criteria and data without revision for 

North Dakota riparian areas and uses the earlier data without regard to questions about 

its reliability and consistency. See e.g. App. A-7 (citing to 1998-99 and 2004 readings), 

A-11, A-14. Notwithstanding the SRT recommendations, the AMP DEIS does not 

consider revision of PFC to reflect the Great Plains. This has significant consequences 

since the AMP DEIS concludes about 47% of the riparian areas are functioning at risk or 

not functioning. 

See response to comments K-16, K-43, and K-51. The 2004 PFC surveys were 

conducted with an interdisciplinary team (Brooks, 2005, p. ix). The 2004, 2006, and 

2007 field investigations were used to define existing conditions. All these surveys 

were completed with interdisciplinary teams. Some 1997-98 data were cited in the 

DEIS to indicate trend in riparian conditions. The 1997-1998 data were not used to 

establish existing condition in the project area. 

The PFC surveys are based on knowledge of local site potential and conditions, 

therefore the PFC surveys follow the protocol. A revision of the PFC protocol for 

the Northern Great Plains is not indicated. The PFC is a valid means of 

documenting and assessing existing conditions on the Great Plains and has been 

used in Montana, North Dakota, South Dakota, Nebraska, and Wyoming all of 

which are part of the Northern Great Plains.

K-53 The AMP DEIS also ignores the criticism of the scientific validity of the PFC data due to 

variable protocols used by Forest Service employees and the lack of credible data. The 

allotment summaries make scant effort to document that livestock grazing is principally 

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responsible for the non-functioning or at risk classification. The premise appears to be 

that livestock grazing is always the causal factor, even though the AMP DEIS does not 

even mention let alone analyze the impacts of big game use or energy development. The 

allotment summaries refer to roads but impose the burden of correction on the livestock 

grazing program. 

The first sentence of this comment is unclear regarding which criticism is being 

ignored and also fails to specify the nature of any deficient data. The PFC protocol 

is a qualitative assessment that is based on quantitative science (Prichard et al., 

1998, p. 1). See response to comments K-43 and K-51, 

The allotment summaries are not intended to assign "blame" or responsibility for 

riparian degradation. The detailed description of livestock impacts to individual 

stream reaches is included in individual PFC checklists (see Project Record, 

Supporting Documentation – Riparian, L-26). The DEIS (pp. 3-57 through 3-70) 

and the Watershed Report (Project Record, Specialist Reports and Notes) also 

document livestock impacts in detail in an allotment-by-allotment fashion. 

Numerous photographs in the Project Record also document impacts that are 

clearly attributable to livestock, such as cattle trailing, hoof shear, pedestalling, and 

browsing. Also, see memoranda in the Project Record Gonzalez, May 17, 2006; 

Gonzalez, June 2, 2006; Gonzalez, July 26, 2006; and Gonzalez, August 2008. 

Chapter 3 Part 2 of the SDEIS also identifies where livestock are principally 

responsible for stream conditions.

The statement that livestock grazing is always the casual factor is incorrect. 

Individual PFC checklists (see Project Record, Supporting Documentation – 

Riparian, L-26) discuss impacts from livestock and other factors. Please see 

response to comment K-44 above. Big game use is discussed on page 3-96 of the 

DEIS and energy development on page 3-84. See also response to comments K-57 

and K-99. 

K-54 The SRT recommended removal or reduction in brush encroachment which was harming 

sharp-tailed grouse and other ground nesting bird habitat, once the Forest Service 

established monitoring protocols and objectives. SRT at 31. 

The context of the SRT report concerning woody expansion (2005 SRT, Appendix 

B, p.47) occurs outside the project area on the Sheyenne RD where it is recognized 

that woody expansion may be affecting prairie chickens. Whereas, on page 16 of the 

2005 SRT Report, the SRT panel states “sharp-tailed grouse are fairly tolerant of 

expanding woody plant communities” and Appendix H of the Grasslands Plan 

describes the sharp-tailed grouse as the management indicator species “for the 

biological community associated with grasslands containing scattered shrubs and 

diverse vegetative structure.” At this time, woody expansion is not recognized as a 

limiting (or controlling) factor in regards to habitat quality for sharp-tailed grouse 

and other ground nesting avian species on the LMNG. The DPG Response to the 

SRT Recommendation III-2 (Final response to the SRT Reports, p. 11) states that 

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prairie grouse are most responsive to changes in residual herbaceous vegetation 

then woody vegetation (Vodehnal et al 2007). 

K-55 The AMP DEIS does not address the SRT recommendation that the Forest Service 

document historical distribution of woody species, the trend, and set clear objectives. 

SRT at 21. The SRT concluded that the Forest Service did not have good information 

regarding trends and dominance of woody species. Id. It also found that the expansion 

of woody species could degrade habitat for ground nesting birds, including sharp-tailed 

grouse, when the woody species reach a specific ecological threshold. Id. 

Of the different types of woody draw communities in the project area the condition 

of green ash (American elm) / chokecherry woody draws was of concern. Other 

woody communities listed by the SRT that are most relevant to the project area 

include Rocky Mountain juniper, silver sagebrush, and snowberry. Ponderosa pine 

and bur oak listed by SRT do not occur in the project area, while quaking aspen, 

cottonwood, and willow are of limited extent, are not identified as distinct resource 

issues, or are adequately covered as inclusions among woody draw and riparian 

habitat conditions. 

The SDEIS discusses woody draw trend (Chapter 3 Part 1, Woody Draws, Existing 

Condition, Trends in Woody Draw Extent) noting an estimated 5 percent expansion 

of green ash woody draws across the project area landscape. Field observations 

indicated that green ash trees were expanding up-drainage in some communities, or 

establishing within outlying shrub patches situated away from the primary woody 

draw community. 

The Woody Draws, Desired Condition section in Chapter 3 Part 1 of th SDEIS 

identifies the desired condition for woody draws.

See response to comment K-54 for discussion on woody draw expansion and effects 

on ground nesting birds. 

K-56 The AMP DEIS fails to address this issue entirely and instead concludes that the woody 

species in draws throughout the project area are deteriorating due entirely to livestock 

grazing. AMP DEIS at 3-95. In several cases, MGA members proposed removal of 

brush species and these were omitted and rebuffed. App. A-11, 24, 36. The AMP DEIS 

also promotes increasing woody species without regard to ecological threshold issue. 

The DEIS at 3-95 (SDEIS, Chapter 3 Part 1, Woody Draws, Factors Affecting 

Existing Condition of Woody Draws) identifies several factors such as fires, disease, 

climatic effects, and wildlife other than livestock use which affect woody draw 

condition. 

A review of the MGA comments in Exhibit 2 and Forest Service permittee meeting 

notes in regards to App. A-11, 24, 36 revealed that the permittees did not propose 

removal of brush species.

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The SDEIS does not promote increasing woody species. Desired conditions of the 

woody draws on the Little Missouri National Grassland are identified in the Woody 

Draws, Desired Condition section in Chapter 3 Part 2 of the SDEIS. Appendix D of 

the SDEIS identifies grazing management tools that may be used to reduce woody 

species such as prescribed burns or mechanical and also identifies the effects these 

tools may have on livestock grazing, etc. 

K-57 Given the lack of historical distribution and trend data, it is equally reasonable that other 

factors affect the woody tree species, including big game grazing. The AMP DEIS 

ignores the role of big game throughout the DEIS by not addressing the extent of game 

foraging on woody species and in riparian areas. For example, the AMP DEIS 

concludes that deer have less impact since five deer are equal in weight to one cow. 

AMP DEIS at 3-96. But there is no information about the number of deer and elk 

compared to livestock nor when they are in the allotment. 

Historical trend is addressed in response to comment K-55. 

The Forest Service agrees with the commentor that factors other than livestock use 

have an effect on woody draw condition. These other factors were addressed in the 

DEIS on pages 3-96 and 3-97. The commentor has misquoted the referenced cite

from the DEIS, below is the complete text. 

Wildlife such as deer and beaver can adversely affect woody draw conditions but 

the affects are generally not as severe as occurring with livestock due to lower 

animal numbers, smaller size, and less forage intake. In terms of carrying capacity, 

approximately 5 mule deer are equivalent to one mature cow in the amount of 

forage consumed (NRCS, 2009). Gubanyi et al. (2008) found whitetail deer densities 

of about 70 deer per square mile caused adverse impacts to vegetation structure and 

species composition of woodland communities in southeast Nebraska, but mule deer 

densities have averaged only 6.6 deer per square mile in portions of the project area 

during 1991-2007 (NDGF, 2008). In contrast, livestock stocking in the project area is 

generally on the order of 200-300 head per square mile, with each head harvesting 

the equivalent of approximately five deer.

The SDEIS (Chapter 3 Part 1, Woody Draws, Factors Affecting Existing Conditions 

of Woody Draws) has included additional information regarding big game effects on 

woody draws.

K-58 The carrying capacity issue was not disclosed to MGA until virtually three years after the 

commencement of the AMP revision process in February of 2008. Ex. 3, Schneider Decl. 

&14. The AMP DEIS concludes that the project area is overstocked, AMP DEIS at 3-12-

3-13, but fails to disclose and analyze how the carrying capacity calculations will 

translate into grazing reductions. Ordinarily, a conclusion that an allotment is 

overstocked means an immediate reduction. 

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The Forest Service disagrees with the commentor’s contention that carrying 

capacities were not disclosed to the MGA until three years after the commencement 

of the AMP revision process. The MGA should be well aware that the grazing 

agreement between the MGA and the Forest Service specifically states, “The AMP 

will contain, as a minimum, the following: ...Estimated livestock carrying capacity 

for the allotment...” (Grazing Agreement and Rules of Management between 

Medora Grazing Association and United States Department of Agriculture Forest 

Service, 2009, II. F. 2. c.) which although is in a different location in the 2009 

grazing agreement, has been in previous agreements as well. In the summer of 2006, 

during at least nine of the permittee meetings in the second round, the Forest 

Service shared that a carrying capacity analysis would be conducted (Project 

Record, Process Documentation, Permittee Meeting Notes, B-52). The MGA Board 

of Directors Regular Meeting minutes dated January 10, 2007 and October 3, 2007 

document that the Forest Service had informed the MGA board of directors that a 

carrying capacity analysis would be conducted. At the third round of permittee 

meetings held during the winter of 2007 an informational sheet was provided to 

each individual member that summarized by pasture and land ownership the initial 

estimated carrying capacity of the allotment (Project Record, Process 

Documentation, Permittee Meeting Notes, B-53). The Forest Service explained to 

each individual permittee and their representative MGA director how the analysis 

was completed. 

The DEIS at pages 3-14 through 3-19 does not have any language that concludes 

that the project area is overstocked. 

Even though the initial estimated carrying capacity information was provided to the 

permittees as noted above, it was not used in the creation of the proposed action 

(Alternative 3). The initial estimated carrying capacity was used in Alternative 4 to 

determine a starting point for Authorized Use along with other proposed initial 

actions to address identified resource issues. Table 3.5 in the SDEIS identifies the 

percent reduction in Authorized Use under Alternative 4. 

K-59 Nor does the AMP DEIS explore alternative actions to avoid such reductions. Vague 

references to toolbox and adaptive management pertains to achieving LRMP goals, 

objectives, standards, and guidelines rather than increasing carrying capacity. 

The DEIS in Chapter 2 identifies two alternatives which do not use reductions. 

Alternative 2 maintains stocking at preference levels. Under Alternative 3 initial 

actions maintain stocking at preference. The SDEIS has added another Alternative 

i.e. 3A whose initial actions do not include reductions in Authorized Use. The 

purpose of adaptive management is clearly identified in Chapter 1 of the DEIS at 

pp. 1-10 and 1-13 through 1-15. The toolbox and its role is identified on pages 2-14 

and 2-15 of the DEIS. The function of an adaptive management approach is provide 

a flexible approach to meet or move towards Grasslands Plan goals, objectives, 

standards, and guidelines. There is no direction in the Grasslands Plan to increase 

carrying capacity. However, it should be noted that by moving impacted resources 

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to Grasslands Plan desired condition forage production would likely increase thus 

potentially providing additional forage for a variety of different uses including 

grazing. 

K-60 The capacity of the LMNG to produce forage and maintain high structure has been an 

issue from the very beginning of the DPG LRMP. The solution recommended by SRT and 

adopted in the Livestock Grazing ROD and Demonstration Project was to avoid grazing 

reductions and to develop sound data. The LRMP assumption of insignificant or less 

than 9% reductions was based on nonexistent or flawed data. The test drive during the 

SRT review was equally flawed and showed even less of a reduction. 

The Forest Service agrees that the capacity of the LMNG to produce high structure 

has been an issue, however, a review of the SRT report did not produce any cites 

where the SRT recommended avoiding grazing reductions or to develop sound data.

The Livestock Grazing ROD (which includes the “Demo Project”; 2006) does not 

state “avoid” grazing reductions. Contextually, the ROD states, for example: to 

“maintaining sustainable grazing operations (p. 7)”; to “...maintaining, to the 

maximum extent possible...current AUM levels (p. 9)”; to “minimize livestock 

reductions (p. 9)”; “The AMP process...will be the basis for any adjustments to 

livestock numbers (p. 11).”“maintain, to the maximum extent possible, a grazing 

program at current levels...(p. 16;” and “There will be no cuts in permitted AUMs 

without monitoring...p. 17)” 

The ROD thus aims to minimize reductions through the use of other tools and 

strategies that may be employed (but does not eliminate the stocking tool) to also 

meet resource objectives. The DEIS and SDEIS recognizes this, and in Alternatives 

3, 3A, and 4 employs monitoring and adaptive management to minimize the 

potential effects of Grasslands Plan implementation on the potential need for AUM 

adjustments.

The Grasslands Plan projection of an average 9 percent reduction across the DPG 

was based on a 20 year average authorized use (2006 ROD page 12). 

Note the SRT report does not state the “test drive” was flawed. Commentor 

misquotes the SRT and the 2006 ROD in their statement. 

See response to comment K-112. 

K-61 The AMP DEIS instead shows significant reductions due solely to carrying capacity 

calculations that are very similar to the estimates grazing reductions made by HAND 

experts more than 10 years ago. 

The initial estimated carrying capacity was used in Alternative 4 to determine a 

starting point for Authorized Use along with other proposed initial actions to 

address identified resource issues. The DEIS on pages 3-52 and 3-54 identifies that 

under Alternative 4 reductions would range from 0 to 45 percent of preference with 

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an average of about 20 percent excluding those allotments with no reductions. Note 

the 20 percent was a typo in the DEIS which should have been stated “about 23 

percent”.

After the DEIS was published new NRCS production information became available. 

Initial estimated carrying capacity was recalculated using the updated information. 

Under Alternative 4, reductions in Authorized Use ranged from 0 to 44 percent with 

an average reduction of 20 percent (SDEIS Table 3.5). The table below summarizes 

the information from Table 3.5. 

Percent 

Reduction

Number of 

Allotments

0-10 11

11-20 15

21-30 8

31-40 7

41-44 1

K-62 Given the fact that the Forest Service adamantly denied that the DPG LRMP goals, 

objectives, standards and guidelines would result in significant livestock grazing 

reductions, the MRD should have immediately re-examined the procedures it used to 

reach carrying capacity. 

The Grasslands Plan level analysis considered changes or potential reductions at the 

unit-wide level (hence why the data used was appropriate for the level of analysis.) 

Site specific analysis may reveal the need for different levels of adjustments. Note in 

the DEIS that the carrying capacity methodology and results were peer reviewed. 

(see DEIS 3-13 and SDEIS, Chapter 3 Part 1, Range, Methodology, Carrying 

Capacity Analysis). There is no need to either amend the plan or modify the site 

specific analysis to approximate the estimated average reduction across the entire 

DPG.

See also response to comment C-3. 

K-63 As shown below, there are several sound reasons to conclude that the MRD made 

significant errors that, if corrected, would show much higher carrying capacities. The 

AMP DEIS must redo the carrying capacity calculations to conform to NRCS guidelines, 

because they were not followed. 

For response to the first sentence of this comment, see response to comments K-64 

through K-72. 

The Forest Service does not need to redo the carrying capacity calculations. The 

SRT did not recommend using NRCS guidelines, it did recommend using the NRCS 

Order 2 soil surveys (Final Response to the SRT Reports, 2006, p. 3), which the 

Forest Service did utilize in the carrying capacity analysis (DEIS pp. 3-12, 3-13). 

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The DEIS did not claim that the Forest Service used NRCS guidelines and 

methodologies. 

K-64 Commentors are unclear exactly what carrying capacity assumptions were used in the 

calculations. Ex. 1, Lacey Letter of October 11, 2009. The brief explanation in the AMP 

DEIS, 3-12 to 3-13, is insufficient to document this very important step in an AMP. It is, 

however, clear that the Forest Service did not follow the preferred protocol of clipping 

and weighing key areas of the land base in order to assign carrying capacity. 

The Forest Service believes that the carrying capacity assumptions are clearly 

identified on page 3-13 DEIS. The Forest Service agrees that additional descriptive 

information could be added to the carrying capacity analysis section of the DEIS, 

the SDEIS has been updated to include this information (SDEIS, Chapter 3 Part 1, 

Range, Methodology, Carrying Capacity Analysis). 

The Forest Service assumes that the commentor is referring to method one from the 

NRCS National Range & Pasture Handbook to calculate stocking rates as “the 

preferred protocol”; however, as stated in the Lacey letter of October 11, 2009 it is 

identified as “often the best method”. Many variables go into determining the 

methdology to use for analyzing carrying capacity. The SDEIS describes the 

methodoloy and rationale for the carrying capacity analysis used (SDEIS, Chapter 3 

Part 1, Range, Methodology, Carrying Capacity Analysis). 

The DEIS does not claim that the Forest Service used NRCS guidelines and 

methodologies. The SRT made a recommendation to use the NRCS Order 2 soil 

surveys in the development, implementation, monitoring, and refinement of pasture 

or allotment-level management plans (Final Response to the SRT Reports, 2006 

SRT Recommendation I-1), which the carrying capacity analysis did utilize. 

K-65 The production data developed by North Dakota State University (NDSU) should provide 

some basis for comparison. MGA in cooperation with the Forest Service, has been 

working with NDSU to evaluate range production, capability and trends. The report will 

be submitted as soon as the evaluation and compilation is finished in the next few months. 

The Forest Service agrees the production data collected cooperatively with NDSU, 

MGA, and the Forest Service will be of value in evaluating carrying capacity. It’s 

important to note that this data collection effort will only serve as a baseline. 

Trends cannot be evaluated until additional data collection efforts occur. 

The Forest Service reviewed NDSU’s 2008 preliminary data. In the review of the 

first year of data NDSU pointed out that production values (Biomass) were 

displayed incorrectly and would need to be corrected. After the correction was 

made in the 2008 preliminary data the Forest Service reviewed the data again and 

found errors in biomass calculations on crested wheatgrass, smooth brome grass, 

and Kentucky bluegrass. It was estimated that the above mentioned errors would be 

corrected and the information provided sometime in the spring of 2010. 

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In the summer of 2010 the Forest Service received the 2008 and 2009 data and 

reviewed it. This data is addressed in the Range, Methodology, Cooperative 

Monitoring Data section in Chapter 3 Part of the SDEIS.

K-66 The AMP DEIS does not say but the explanation implies that the AMP DEIS does not use 

actual site data from the allotments in question. The AMP DEIS should also identify and 

document the basis for the assumptions used in reaching carrying capacity. Only then 

can the public evaluate whether the assumptions and methodology conform to NRCS 

guidelines and whether they are a valid substitute for actual site data. Thus, the AMP 

DEIS must be able to justify the accuracy and validity of the process used. The two pages 

in the AMP DEIS are technically inadequate. 

The Forest Service believes it is quite clear on pages 3-12 through 3-13 of the DEIS 

that the forage production values used in the calculation of the initial estimated 

carrying capacity were provided by the NRCS. Also, the assumptions used in the 

calculation are clearly stated on page 3-13 of the DEIS. NRCS methodology was not 

used to determine carrying capacity (see response to comment K-63). The Forest 

Service agrees that additional descriptive information could be added to the 

carrying capacity analysis section of the DEIS, the SDEIS has been updated to 

include this information (SDEIS, Chapter 3 Part 1, Range, Methodology, Carrying 

Capacity Analysis). 

The Forest Service sought out peer review (SDEIS, Chapter 3 Part 1, Range, 

Methodology, Carrying Capacity Analysis), “To help assure that the carrying 

capacity analysis was calculated correctly the Medora Ranger District Range staff 

had the analysis, methodology, and calculations reviewed by the USDA’s 

Agricultural Research Service”. The peer review determined and made the 

following recommendations. The formulas and process used were accurate. A 

recommendation to coordinate with the NRCS to rerun the data set with updated 

production values was made because the initial production data downloaded from 

the Soil Data Mart in 2005 was inaccurate. They also recommended to ground truth 

some of the allotments where there were large discrepancies between the Preference 

AUMs and the Carrying Capacity AUMs &/or on allotments that had several 

significant issues. Finally, they recommended updating data sets as production 

values were updated (Project Record, Inter & Intra-agency Memos, Conversations 

& Agreements, I-7). All of these recommendations have been considered and 

implemented by the Forest Service. 

While the Forest Service agrees that actual site data would further build upon the 

carrying capacity analysis conducted, the best available information was used at the 

time. Monitoring described in the third table for each allotment in Chapter 3 Part 2 

will confirm or provide a better estimation of carrying capacity for each allotment. 

Additionally, the Forest Service has reviewed the 2008 and 2009 cooperative 

monitoring data (see SDEIS, Chapter 3 Part 1, Range, Methodology, Cooperative 

Monitoring Data).

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K-67 As Dr. Lacey writes:The NRCS National Range and Pasture Handbook (NRPH, 

September, 1997) describes four methods of calculating stocking rates: 1) "often the 

best method for establishing the initial stocking rate is to assist the client in making a 

trend study and utilization check on the key grazing area of the management units. A 

recording of current stocking rate along with an evaluation of trend or health of the plant 

community and percent used of the key species can provide an insight to the correct 

stocking rate for the grazing period." (ironically, this is the approach that the permittees 

and you advocated for years). 2) Another method of establishing the initial stocking rate 

is based on production data and growth curves developed locally as a part of the field 

office technical guide. An estimate of forage supply can be estimated for each month and 

totaled for the annual production for each management unit. 3) The "usable production 

method" is based on measuring or estimating the total amount of forage (standing crop) 

per acre and converting green weight to air dry weights and into AUMs. 4) The forage 

value rating method is a utilitarian classification indicating the grazing value of 

important plant species for specific kinds of livestock or wildlife. The classification is 

based on palatability or preference of the animal for a species in relation to other 

species. It is important to note that none of the four approaches outlined in the 

Handbook resembles the FS method that is described in the DEIS. 

The AMP DEIS explanation does not describe one of the four methodologies listed above. 

Instead, the AMP DEIS states that the Forest Service used NRCS ecological site data. As 

Lacey notes, there is no mention of clipping data that would be correlated to site data. 

See response to comments K-63, K-64, and K-66. 

K-68 The AMP DEIS states that the Forest Service assumed Aweighed average figure was 

based upon the ecological site reference plant community production (Representative 

Value) for each ecological site within the soil mapping unit." AMP DEIS 3-13. The 

AMP DEIS does not say how it reached a weighed average, was it clipping data or was it 

another estimate. The missing information could significantly affect the actual 

calculations. 

The answer to the commentor’s question in regards to whether the weighted 

average was based on clipping data or another estimate is contained within the 

commentor’s quote from the DEIS. The weighted average production value is based 

on the ecological site reference plant community production value that was provided 

by the NRCS. 

The Forest Service reminds the commentor that the carrying capacity analysis was 

peer reviewed; see response to comment K-66. 

K-69 The AMP DEIS also included other assumptions, "some assumptions to consider about 

the Representative Value are as follows: 1) season long grazing, 2) normal growing 

conditions, and 3) reference plant community." AMP DEIS 3-13. Lacey notes that these 

assumptions would have affected calculations also but the limited explanation fails to 

disclose how they affected carrying capacities disclosed in the DEIS. Ex. 1, Lacey p.2.

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The AMP DEIS also does not explain how it adjusted for those allotments that do not use 

season long grazing. Most of the allotments in the AMP DEIS use rest-rotation or 

deferred grazing systems, rather than season long. 

The Forest Service provided the assumptions stated in the DEIS on page 3-13 to give 

the reader a better understanding of how the production value came about for a 

particular Representative Value. 

The Forest Service used the best available information at the time the initial 

estimated carrying capacity calculations were made. 

Commentor is correct in that each of the Representative Values and the rationale 

behind them have an effect on the initial estimated carrying capacity. In very 

general terms, season long grazing would weigh the formula towards a lighter 

carrying capacity; “normal” growing conditions could both under and over estimate 

production dependent upon the year; and the reference plant community could both 

under and over estimate production depending on the site. This general discussion 

has been included in the SDEIS (Chapter 3 Part 1, Range, Methodology, Carrying 

Capacity Analysis) to help the reader better understand the rationale, but the 

bottom line is these are a conservative set of assumptions.

K-70 In the absence of any documentation of clipping and weighing, Lacey notes that if the 

MRD relied on similarity indices that are linked to ecological sites which use a historic 

climax plant community, then the calculations could have omitted significant forage. As 

Lacey explains:

If the FS did somehow estimate production by species and compared it directly to the 

ecological site guides, they would be calculating similarity indices. According to the 

National Range and Pasture Handbook, similarity indices are calculated by comparing 

clipping data (i.e., #lbs of production by species) on an ecological site to the historic 

climax plant community that is defined on the respective ecological site guide. If the FS 

did this, they would have a "similarity index" for each ecological site. However, the 

similarity indices are not representative of the stocking rate. For example, 2,000 lbs/acre 

of smooth bromegrass may be produced on a loamy site, but it would not contribute 

toward the IS because smooth brome (an introduced species) would not be listed on the 

Historic Climax Plant Community loamy ecological site guide. Likewise, if the FS did 

have a list of species growing on an ecological site, and the respective production of 

each, an inexperienced observer may note that smooth brome did not occur on the 

historic climax plant community, and thus, smooth brome would not given any credit for 

forage value on the site. 

See response to comment K-71. 

K-71 If the AMP DEIS carrying capacity calculations used plant communities based on the 

historic climax plant communities list, then the AMP DEIS would have excluded many 

forage species, including smooth brome grass and crested wheatgrass. Thus the 

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carrying capacity calculations may well have excluded forage used by livestock and 

wildlife alike.

The Forest Service did not calculate similarity indices. The Forest Service assumes 

that the commentor is referring to reference plant communities when they talk 

about historic climax plant communities. Reference plant community is one of the 

assumptions given in the carrying capacity analysis explanation. There is 

disagreement within the body of literature that introduced/tame/exotic/invasive 

graminoid species increase stocking rates and increase overall net primary 

production compared to native graminoid species (Williams and Post’s 1945, 

Smoliak and Slen 1973, Smoliak et al. 1981, Hart et al 1988, Hofmann et al. 1993, 

Willms et al. 2009). 

The SRT recommendation identifies (Final Response to the SRT Reports, 2006, p. 

16) that if crested wheatgrass cannot be separated out from native grasslands, 

grazing should not occur before the 3.5 leaf stage of the management plant species 

or June 1, thereby managing the pasture as native. The Grasslands Plan also has 

direction to manage those pastures that have greater than 70 percent crested 

wheatgrass as a crested wheatgrass pasture and those not meeting this definition as 

native pastures (Grasslands Plan, p. 1-19). 

The monitoring for plant composition will give the Forest Service a better 

representation of what forage is within the project area. The carrying capacity 

analysis can then be reviewed, but adjustments to Authorized Use will continue to 

be resource issue driven as the Forest Service seeks to meet or move towards 

Grasslands Plan goals and objectives. 

K-72 The AMP DEIS methodology also does not clearly account for soils and related plant 

variability. Assuming that the MRD does not have “shovel-specific” soil sites and 

instead relied only on the Web Soil Survey, then it would have omitted important 

productive sites on the allotments, particularly coulee, outflow areas, and small 

drainages. Ex. 1, Lacey p.3. These sites may be very productive as well. 

Other included soils and miscellaneous areas, however, have properties and behavior 

divergent enough to affect use and or require different management. These are called 

contrasting inclusions. They generally are in small areas and could not be mapped 

separately because of the scale used. In my experience, most of the soil surveys 

conducted in western states are done at a scale that precludes the mapping of small 

drainages and coulees (overflow sites) that often contribute significantly to the carrying 

capacity of an area that is comprised of a mapping unit. Therefore, the carrying capacity 

of the soil mapping unit is often under estimated when this approach is used. The 

magnitude of this discrepancy varies with the topography, mapping scale, and 

capabilities of the soil scientist that did the mapping. 

The Forest Service description of the carrying capacity analysis on page 3-12 of the 

DEIS is consistent with the recommendation of the SRT in using the Order 2 soil 

survey and associated ecological site information. Additional information regarding 

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the carrying capacity analysis has been included in the SDEIS in Chapter 3 Part 1, 

Range, Methodology, Carrying Capacity Analysis. The Forest Service utilized the 

weighted average of production of the ecological sites described within a soil map 

unit, such as 69F. The weighted average accounts for contrasting inclusions of both 

high production sites (such as overflow areas), as well as, low production sites (such 

as clay out crops/badlands). The weighted average for any map unit will account 

for the high and low production of the contrasting inclusions and miscellaneous 

areas.

K-73 Regardless of how the AMP DEIS reached its carrying capacity calculations, the 

explanation leaves key issues unanswered. It is however apparent that the AMP DEIS 

does not follow the NRCS guidelines. It is impossible to delineate the assumptions made 

or the procedures followed from the brief description in the AMP DEIS. Nevertheless, if 

the AMP DEIS used only web-based information, as implied, then the AMP DEIS 

underestimates the carrying capacity both with respect to usable forage that is not 

considered “historic climax plant community” and by omitting small but very productive 

areas in the allotments. 

See response to comments K-63, K-64, and K-66 through K-72. 

K-74 It is likely that there are other significant issues but until commentors have access to the 

Project File and can compare it with the actual data that has been developed over three 

years, we cannot make final conclusions. 

Commentors did go through the Freedom of Information Act and have acquired the 

draft project file. It is not the commentor’s job to make a final conclusion as part of 

the NEPA process. (see 36 CFR 215 section on comment requirements). Also see 

response to comment K-5. 

K-75 Even without the Project File data, it is likely that the AMP DEIS carrying capacity 

calculations understate productivity significantly and cannot be a valid basis to institute 

reductions. The carrying capacity calculations must either be deleted or redone. 

The commentor provides no data or literature in their comment to support the 

claim that carrying capacity calculations understate productivity significantly and 

therefore carrying capacity calculations must be redone. 

For the reasons stated below (response to comments K-76 through K-79), the Forest 

Service disagrees with the commentor’s statement that the carrying capacity 

calculations must be deleted or redone. See response to comments K-63 and K-68 

through K-72. 

The Forest Service did not base reductions on the carrying capacity analysis. 

Adjustments to Authorized Use were one of the proposed initial actions to address 

identified resource issues in Alternative 4. The initial estimated carrying capacity 

was utilized as a starting point for Authorized Use in Alternative 4.

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K-76 Another factor in the carrying capacity calculations could be the exclusion of lands 

producing less than 300 pounds per acre. The AMP DEIS does not indicate that it 

follows the SRT recommendations to include in the carrying capacity calculations land 

that produces less than 300 pounds per acre. The Forest Service Response to the SRT 

indicated that it still disagreed. Forest Service Response to SRT at 4-5. The SRT 

recommended that the Forest Service include these lands in carrying capacity estimates. 

SRT at 10 (“Recommendation I 2: AMP’s herbage production estimates should be 

estimates for all sites. If adjustments in livestock carrying capacities are necessary 

because of unsuitable terrain (i.e., unsuitable sites), adjustments should be made directly 

(i.e., no allowable forage) rather than indirectly (i.e., no herbage produced).”). The 

AMP DEIS did not implement this recommendation, even though the ROD states that the 

Forest Service will implement the SRT recommendations. Livestock Grazing ROD at 6. 

The recommendations of the SRT were taken into consideration and all lands were 

used in calculating the initial estimated carrying capacity. (see Project Record, 

Supporting Documentation – Range, L-1 and L-8 and SDEIS, Appendix C) 

K-77 The Forest Service objection to including the areas producing less than 300 pounds per 

acre misunderstands the difference between a land use suitability determination and 

calculation of available forage. These are entirely different concepts and make entirely 

different conclusions. By excluding these lands, the Forest Service is simply not 

following the accepted protocols and deliberately skewing the data. 

See response to comment K-76. 

K-78 The LRMP FEIS assumed a 50% increase in livestock size while the SRT found data 

showing that the increase was more like 20% increase in weight with between 7 and 14% 

increase in forage demand. SRT at 18. The SRT did not recommend reductions to reflect 

the large cow size, but did recommend recalculation of AUMs and evaluation of whether 

management has adjusted to accommodate the larger cattle. SRT at 19. This has not 

been done in the AMP DEIS. 

The NGP FEIS at page 3-84 actually states, “The increase in stocking levels and the 

increase in cow size have had a combined effect of up to 50 percent increase in 

grazing use on some units”. The Report of the SRT, 2005 at page 18 actually shows 

a 20 to 35 percent increase in slaughter weights based on the “preference” numbers 

being based on a 1,000 pound cow, with or without her calf up to six months of age. 

The 7 to 14 percent increase in forage demand is incorrectly linked with the 

commentor’s statement regarding the 20 percent increase in weight. The 7 to 14 

percent values refer specifically to an example of a 1,100 and a 1,200 pound cow, 

respectively. The SRT is identifying that there is an increase in nutritional demand 

as body size incrementally increases.

 

The commentor is misrepresenting the SRT’s recommendation on page 19 (Report 

of the SRT, 2005) by combining part of the SRT’s identified issue into their 

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recommendation. The recommendation states, “Redefine the animal unit to reflect 

current cow size along with older, larger calves and recalculate the corresponding 

authorized livestock numbers on allotments”. This recommendation was 

implemented in Alternative 4 by authorizing use by the AUM which by definition 

accounts for the size of the cow. Adjustments for cows larger than 1,000 pounds will 

be necessary in the management of the allotment. The Glossary of the SDEIS 

identifies the differences between AM, AUM, AU, and Animal Unit Equivalent 

(AUE). 

K-79 MGA experience shows that livestock may be about 300 pounds larger than they were in 

the mid to late 1930s when stocking rates were originally set. But when stocking rates 

were first established on the LMNG and the preference allocated to MGA members, the 

grasslands had only begun to heal from devastating drought, storms, and years of 

attempted cultivation. Since that time, the grasslands have been restored to productivity, 

and wildlife and big game numbers have greatly increased. Thus, just because 

preference numbers have not changed and livestock are larger does not mean that the 

allotments are overstocked. Range productivity has also increased. Many MGA members 

also employ supplemental feeding techniques to maintain livestock health and 

productivity. Thus, any increase in livestock size does not result in direct pressure on 

forage resources due to availability of supplemental feed. 

The Forest Service is unable to comment in regards to the statement, “MGA 

experience shows that livestock may be about 300 pounds larger than they were in 

the mid to late 1930s when stocking rates were originally set”, because the 

commentor does not provide any data or literature citations to support the claim. 

The Forest Service’s review of literature (see SDEIS, Appendix D) indicates the 

average cow size has increased 545 pounds. 

The Forest Service agrees, anecdotally, that the grassland’s productivity has been 

restored since the mid to late 1930s and that wildlife numbers may have increased. 

However, the commentor does not provide any productivity data to define to what 

degree productivity has been restored in relation to the increase in cow size through 

the years. 

The commentor has not provided any data or literature to substantiate their 

statement, “Thus, just because preference numbers have not changed and livestock 

are larger does not mean that the allotments are overstocked. Range productivity 

has also increased.” The SRT states, “The bottom line is obvious. There are more 

“Animal Units” on the DPG than “preference” numbers originally indicated was an 

appropriate stocking rate. All future management plans must acknowledge the 

increase in cow and calf size and the subsequent forage demands of larger, higherproducing cows and older, larger calves.” (Report of the Scientific Review Team, 

2005, p. 19). 

The Forest Service acknowledges that many MGA members do utilize supplemental 

feeding on the grasslands, but not all members do. Supplemental feeding could 

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offset to some degree the increase in livestock size. However, some supplemental 

feeds targeted at correcting nutrient deficiencies can stimulate intake, digestion, 

and/or utilization of forage (Huston J.E. and W.E. Pinchak in: Heitschmidt and 

Stuth 1991. Grazing Management: an ecological perspective, Chapter 2, p. 57, 

Supplemental Nutrition Management), thereby increased livestock size with 

supplemental feeding could equate to increased forage utilization. 

K-80 If the Forest Service were following the Demonstration Project principles, it would have 

returned to MGA to discuss changes in the LRMP or additional management measures to 

avoid the apparent reductions. This did not occur, the Forest Service only informed 

MGA in February 2008 that it was overstocked. At no point, has there been any 

discussion of how the reductions will be imposed and significantly, the AMP DEIS does 

not address this crucial fact or how much the additional reductions will be to meet the 

LRMP objectives, standards and guidelines as proposed in Alternatives 3 and 4.

 

As identified for each resource in Chapter 3 Part 1 of the SDEIS, the land is capable 

of achieving Grasslands Plan goals, objectives, standards, and guidelines therefore 

no changes to the Grasslands Plan are needed. The design criteria located in 

Chapter 2 of the SDEIS (Table 2.4) identify how reductions are to be phased in i.e. 

10 percent per annum. There are no additional reductions contemplated to meet 

Grasslands Plan objectives, standards and guidelines. The action alternatives are 

designed to meet or move impacted resources toward desire conditions. Monitoring 

will determine if additional adjustments area needed to reach desired conditions. 

K-81 If the carrying capacity or forage production is significantly less than the grazing 

preference, the AMP DEIS also needs to determine whether the DPG LRMP high 

structure assignments are correct as well.

 

See response to comment K-1. 

K-82 The AMP DEIS carrying capacity was a desk top process, as opposed to a physical site 

review. The review process would require confirmation of soil types, vegetation, density 

and weight, a process requiring several years. 

 

See response to comment E-7. 

K-83 The same review would also determine site capability for high structure. The high 

structure assignments found in the LRMP direction were based on data now determined 

to have been invalid for site specific management decisions. The AMP DEIS does not 

acknowledge this data gap and inconsistency with the LRMP direction. 

Commentor misunderstands the use of data for Grasslands Plan level planning 

versus site-specific project planning. The goals, objectives, standards and guidelines 

for the Grasslands Plan have been decided and upheld through appeals (2003 and 

2007 WO appeal decisions and 2003 and 2007 Discretionary reviews). Therefore, 

without solid valid data as to why the project area could not meet the goals, 

objectives, standards and guidelines, these are determined to be valid.

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The commentor repeatedly requests the Forest Service follow the SRT 

recommendations. The Forest Service has done so for this project (see SDEIS, 

Appendix C). In the 2006 Forest Service Final Response to the SRT, it is stated high 

structure will only be required of biologically capable areas (2006 Final Response to 

the SRT Reports p. 5). It goes on to define the habitat types that are considered 

biologically capable for the Little Missouri National Grassland (2006 final response 

to the SRT p. 5). The DEIS is not inconsistent with the SRT or Grasslands Plan 

direction. Again it should be noted the validity of the data used at the level it was 

used at was appropriate (see response to comment K-7). 

K-84 The SRT also criticized the VOR data based on highly variable protocols and results. 

SRT at 10. The AMP DEIS ignores the peer critique of the Forest Service data and 

concludes that most allotments fail to meet the high structure objectives on the data. See 

e.g. App. A-49-53, 47, 59-71, 73-90. 

The AMP DEIS does not reassess the capability of the sites, and instead assumes that the 

allotments would meet the objectives but for livestock grazing. AMP DEIS at 3-57, 3-72. 

The SRT discussion at 10 is addressing a recommendation to use NRCS Order 2 soil 

survey information in the development of AMPs which the analysis did and the 

definition and use of “biologically capable”. 

 

Contrary to the allegation, the LMNG VOR protocol is not highly variable but is 

well documented. Essentially, the same protocol has been in use since the LMNG 

began using the VOR methodology in 1996 (DEIS p. 3-129 to 3-130; Project Record, 

Specialist Reports and Notes, Wildlife Report, Appendix B; Schenbeck 1996; and 

NGP FEIS, Appendix B). The only item of any significance is the stratification 

process but since the transect staring points are geo-referenced, cross-walking with 

any stratification is possible. The protocol is also reasonably consistent with Kohn’s 

(1976) study of grouse habitat on the LMNG

It is possible that the SRT is confused with the use of the method when considering 

all of the studies concerning use of the VOR method such as found in Benkobi and 

Uresk (2000) versus what the objective was in Kirby and Grosz (1995) or Reece et al 

(2001). Standardizing across all studies is not an objective of the SDEIS.

The SRT did not review VOR data for this project, see response to comment K-42. 

The commentor is correct in stating that allotments not meeting high structure 

objectives are identified in Appendix A of the DEIS. 

There is no need to reassess site capability see response to comment K-41. The DEIS 

at 3-57, 3-72 is addressing riparian condition and effects. The only reference to 

structure is the statement “However, of concern is the low amount of high structure 

in the project area which has the potential to effect the integrity of ephemeral 

drainages....” 

K-86 The working groups’ or Forest Service and the grazing associations and their members’ 

proposals would be carried forward in the National Environmental Policy Act (NEPA) 

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process as the Forest Service’s proposed action for the AMP and any related LRMP 

amendments, provided they are consistent with existing law. Id at 17. 

This is a correct quote from the Demonstration Project (2006 ROD, p. 17). 

K-87 The DEIS does not include many, if not most of, the Association recommendations 

because the IDT rejected them. This contradicts the criteria for the Demonstration 

Project which were adopted in the 2006 Livestock Grazing ROD. 

The Forest Service believes this part of the Demonstration Project has been met, see 

response to comment M. The Association recommendations have been added to an 

additional alternative, 3A, so the decision maker and the public can view the 

differences in the alternatives.

K-88 The Livestock ROD requires that the A proposed action be the approach agreed to by the 

grazing associations and the Forest Service.@ ROD at 17. MGA and affected livestock 

grazing permittees never in fact agreed to Alternative 3 as stated in the AMP DEIS. 

AMP DEIS at xvi. While MGA and its members were willing to support adaptive 

management as a concept, the Forest Service excluded them from the detailed 

development of Alternative 3 in the AMP DEIS, and there was no agreement as to project 

specifics, as discussed supra at 15. 

See response to comments K-26, 27, 28, 35, Schneider 4 and 5, comment M, and 

SDEIS, Appendix A.

On January 10, 2007 the Forest Service met with the MGA board of directors at 

their regular meeting. At the meeting the MGA declined the CRM and identified 

that they wanted to continue to use the process we had been following in creating 

the proposed action. The Forest Service documented this decision in a letter to the 

MGA dated January 29, 2007. The letter states “At the January 2007 meeting the 

board decided to follow through with the adaptive management alternative as a 

proposed action and to continue on as we have been doing business/process with the 

North Billings Range EIS”. The Forest Service also provided the MGA with the 

opportunity to correct the notes, the MGA did not respond with any corrections. 

K-89 Certainly MGA members did not agree to a 20% cut in numbers or the more accurate 

45% reductions anticipated once other restrictions are applied. Ex. 3, Schneider Decl. at 

&&15-16. 

The Forest Service agrees with this statement. Authorized Use reductions would 

occur under Alternative 4 and would range from 0 to 45 percent with a 20 percent 

average reduction from preference (DEIS at p. 3-52). Note the 20 percent reduction 

is a typo the average reduction would be about 23 percent. 

After the DEIS was published new NRCS production information became available. 

Initial estimated carrying capacity was recalculated using the updated information. 

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Under Alternative 4, reductions in Authorized Use ranged from 0 to 44 percent with 

an average reduction of 20 percent when excluding the 2 allotments with no 

reductions (SDEIS Table 3.5). See also response to comment K-61. 

Alternative 4 is a Forest Service created alternative, and as such didn’t require the 

concurrence of the MGA. 

K-90 Because MGA members did not agree to Alternative 3, as represented in the AMP DEIS, 

claims that MGA members were in full agreement are misleading. 

 

See response to comments K-29 and K-35. 

K-91 There will be no cuts in permitted AUMs without monitoring showing that livestock are 

principally responsible for not meeting the desired condition, and that the cuts are the 

only ecologically practicable and economically feasible means available for meeting the 

desired condition. In these circumstances, the Forest Service will work with the grazing 

associations to minimize livestock grazing reductions. Livestock Grazing ROD, App. A, 

at 17. 

The SRT criticized the Forest Service for its lack of monitoring data. SRT at 32-34. The 

recent review of range conditions embodied in the Range Assessment does not constitute 

monitoring data, because the AMP DEIS does not use repeatable data that measured 

change in vegetation over time. A one-time assessment which includes two years of 

drought fails to meet the decision criteria of monitoring data that would support a 

reduction in livestock grazing levels.

The Range Assessment i.e. Dragon information was not used as monitoring data, see 

also response to comment G-1. 

The DEIS (Chapter 3) and the SDEIS, Chapter 3 Part 2 identify where livestock are 

principally responsible for not meeting the desired condition,

The DEIS, under the methodology sections in Chapter 3, identified the different 

types of resource information collected and how and when it was collected. These 

methodologies are repeatable and are carried into the Monitoring section of 

Chapter 2 of the DEIS as well as the Allotment Summary Sheets in Appendix A. 

Assessments need to include data taken in drought as drought is a normal process 

on grassland prairie ecosystems. Holechek notes (DEIS, p. 2-3), that drought has 

occurred on the Northern Great Plains 21 percent of the time since 1940 (Holechek 

et al, 1991). The data used included one year of drought not two. Within the last ten 

year period drought has occurred on the Little Missouri National Grasslands four 

times (SDEIS, Chapter 1, Key Issues, Key Issue #1. Drought). To exclude data 

collected during drought would present skewed results. Allotments need to be 

properly stocked to withstand periods of drought, as well as normal and above 

normal periods of precipitation. 

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In addition, the Forest Service used NRCS order 2 soil mapping and the ecological 

site information/production information included to help determine the initial 

estimated carrying capacity. This information, which the SRT suggested 

considering, reports production data that is based on the combination of expertise of 

many professionals from various agencies and field data through the years where 

available. 

K-92 The AMP DEIS does not document the development of the “monitoring data” used. In 

the mid 1990's the Forest Service prepared reports on the National Grasslands that 

described as monitoring data. See Custer National Forest Monitoring Reports. These 

reports were later quietly discarded by the DPG perhaps because they concluded that the 

LMNG was in good to excellent ecological condition. Unlike the data used from 1995 to 

2005, the Custer National Forest Monitoring Reports used seral stages and ecological 

condition ratings of the LMNG. 

Commentor confuses Grasslands Plan level monitoring data with project level 

monitoring data. Some portions of the 2002 Grasslands Plan have only just started 

being monitored in part because the Livestock Grazing portion of the plan was 

“phased in” and so underwent review by the SRT, was confirmed in the 2006 ROD, 

but has actually only been implemented on the ground through the Allotment 

Management Planning processes in a few areas. The starting point that should be 

used is the analysis in the Northern Great Plains FEIS and field work done 

specifically for this project. Project monitoring protocol is described in the DEIS 

starting on page 2-18 and in Appendix A and in the SDEIS in the Monitoring section 

in Chapter 2 and in the third table for each allotment in Chapter 3 Part 2. Seral 

stage conditions are described starting on page 3-144. Ecological condition rating 

information from the Little Missouri Rangeland Assessment report identified 

concerns with herbaceous structure and green ash woody draws. 

K-93 The SRT Report noted that the Forest Service did not present monitoring data after 1995, 

SRT at 32, so we assume there is no monitoring data from 1995 to 2005. The AMP DEIS 

purports to use data that it characterizes as monitoring data even though the data sets 

were not started until three years ago. Because two of the years were drought, it is 

reasonable to assume this is not the monitoring data that the SRT or the range industry 

would expect as a basis to make rangeland management decisions. 

The DEIS, under the methodology sections in Chapter 3, (SDEIS, Chapter 3 Part 1) 

identifies the different types of resource information collected and how and when it 

was collected. The collected information was used to establish existing condition 

which was compared to desired condition to establish a need for action. It will also 

serve as a baseline for future monitoring to determine if initial actions are meeting 

or moving towards Grasslands Plan goals and objectives. Monitoring becomes 

significant after a decision is made, and management actions are implemented. 

DEIS, Chapter 2 identifies the monitoring plan and DEIS, Appendix A identifies the 

specific monitoring and frequency of accomplishment by allotment (SDEIS Chapter 

2, Monitoring and third table for each allotment in Chapter 3 Part 2). The Forest 

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Service is unaware of any reference in the DEIS to the collected data being referred 

to as monitoring data and the commentor doesn’t present a specific reference to 

support their statement. See also response to comment K-91. 

K-94 The lack of consistent monitoring data is even more problematic in the evaluation of the 

riparian areas. The SRT found a number of technical flaws in previous PFC 

assessments. It appears that the AMP DEIS uses many of the same flawed data sets to 

classified riparian area conditions. 

The Forest Service is unaware of any technical flaws, other than the completion of 

some surveys, more than 10 years ago, by an individual, rather than by an 

interdisciplinary team. And those data from the late 1990s were not used in this 

project to define existing conditions. Instead some of those data from the 1990s 

were used to establish trends in riparian conditions. The existing condition reported 

in the DEIS is based on data collected by interdisciplinary teams in 2004, 2006, and 

2007. The SRT did not identify any other technical flaws, contrary to the assertion 

by the commentor. See also response to comments K-16, 43, 51, and 52. 

K-95 This is also true for Robel Pole readings, which the SRT concluded could not be used 

reliably due to the lack of documented protocols. SRT at 34 (A3. The protocol for using 

the Robel pole to assess structure is flawed. Suggestions for improving the methodology 

are located in Section II, Issues II 1 to 4.@). The SRT generally found the data used for 

the LRMP inadequate in virtually every aspect for AMP and specific grazing 

management decisions. SRT at14, 32-34. This was due to the lack of actual use data on 

the part of the Forest Service, lack of monitoring data, and lack of information with 

respect to woody species historical distribution and trends in particular. SRT at 17 (A 

The lack of information on how vegetation responds to changes in grazing practices has 

hampered the SRT in its evaluation, and no doubt hampers the FS in carrying out its 

mission. The SRT recognizes that resources for monitoring are limited, but proposes that 

carefully designed protocols can be implemented without major additional costs.@); at 

13 (A Standardized protocols should be adopted and training provided for consistency 

among years and observers using the Robel pole method.@); 32-34. 

The commentor is confusing the SRT and Grasslands Plan revision effects with this 

project. The Grasslands Plan was upheld through appeals and discretionary 

reviews.Applicable SRT recommendations, in accordance with the DPG Final 

Response to the SRT Reports have been incorporated into the analysis of this 

project, (see Appendix C).

The Forest Service agrees that monitoring is important, and this is brought forth 

through the Monitoring section of the DEIS and in Chapter 2 of the SDEIS and in 

the specific monitoring associated with each allotment identified in the SDEIS, 

Chapter 3, Part 2. 

The same VOR protocol has been in use since the LMNG began using the VOR 

methodology in 1996 (SDEIS, Chapter 3 Part 1, Herbaceous Structure, 

Methodology; Project Record, Specialist Reports and Notes, Wildlife Report, 

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Appendix B; Schenbeck 1996; NGP FEIS, Appendix B). The only item of any 

potential significance is the stratification process but since the transect starting 

points are geo-referenced using GPS and GIS technologies, cross-walking with any 

stratification is possible. Lastly, the VOR protocol is reasonably consistent with 

Kohn (1976) and Mattise (1978) studies of grouse habitat on the LMNG. The SRT 

may have confused the entirety of VOR literature with what has essentially been the 

standard protocol on the LMNG since 1996. 

K-96 The Forest Service continues to ignore actual use data that it declined to provide to the 

SRT, erroneously telling the SRT that no such data existed. The DEIS perpetuates the 

incorrect information where it suggests that the Association reporting data are untrue or 

“unreliable” DEIS 3-14. 

See response to comment K-12. 

K-97 MGA data show that use levels vary from year to year but that the data exist and are 

reported to the Forest Service. Ex. 3, Schneider Decln. &20. Apparently the MRD 

claims that even an early removal of a few head must be reported to the Forest Service as 

nonuse. This is not consistent with Forest Service policy which permits delegation of 

authority to approve nonuse to the association. FSH 2209.13, ch. 20 '23.1, &2. The 

policy for direct grazing permits, which does not apply to grazing agreements, defines 

nonuse as more than 10% of permitted use. FSM 2231.62a, 2231.7. Moreover, MGA 

monitors use to ensure that if a member is not grazing in any given year, the authorized 

AUMs can be awarded to a member who can use the AUMs. 

The Forest Service agrees that use levels may vary from year to year. But the Forest 

Service disagrees that the actual use levels are reported to the Forest Service. See 

response to comment K-12. 

The Forest Service has reviewed the above FSH and FSM citations, and believes 

that the comments do not pertain to the proposed project. However, the Forest 

Service would like to point out that the Allotment Worksheet/AOI does include the 

following statements, “If the permittee desires to change the grazing schedule as set 

forth below, the permittee will notify the Pasture Director within 5 days, who in 

turn, will notify the Medora Grazing Association office as soon as possible. The 

MGA will notify the US Forest Service within 10 days of the requested change and 

the basis for it. The Forest Service will be notified by the Association via telephone 

call with written confirmation to follow.” Early removal of livestock would be a 

change in the grazing schedule, which would require notification to the Forest 

Service. Typically, this would be the kind of information the Forest Service would 

expect to receive as actual use information.

 

If the MGA monitors its members use or lack thereof, the Forest Service has not 

received any reports of this nature.

K-98 The AMP DEIS states that MGA did not take drought reductions in the last two years. 

AMP DEIS 3-10. This is inaccurate. In 2008, MGA members resisted the MRD demand 

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that everyone take a 35% reduction and instead members took reductions based upon the 

conditions in each pasture. Ex. 3, Schneider Decln. &23. 

The SDEIS has included the drought reductions taken in 2008. See response to 

comment N-18 regarding reductions taken during the 2008 drought.

K-99 Notwithstanding conclusions that the Forest Service lacked necessary data or reliable 

data, the AMP DEIS proposes significant reductions without monitoring data. The AMP 

DEIS provides scant documentation supporting the conclusion that livestock grazing is 

“principally responsible” for the failure to meet the LRMP goals, objectives, standards 

or guidelines. The summary sheets found in Appendices A and C do not describe the 

monitoring data nor document conclusions regarding causation for failure to meet the 

assigned vegetation structure or PFC standards. 

These sheets primarily refer to evidence of livestock use but rarely if ever distinguish 

between energy development and livestock and omit the impacts of big game use entirely. 

The commentor’s statement that the Forest Service lacked necessary data or 

reliable data, is assumed to be in reference to the SRT process whose function it was 

to determine if the Grasslands Plan could be implemented (see response to comment 

K-10), however, it doesn’t pertain to this project. 

See response to comment K-89 in regards to the commentor’s statement concerning 

the DEIS proposing significant reductions. However, the effects of cattle on the 

different resources are identified in Chapter 3 of the DEIS, in Chapter 3 Part 2 of 

the SDEIS, and in the respective specialist reports (Project Record, Specialist 

Reports and Notes). 

In regards to the commentor’s statement that the summary sheets do not describe 

monitoring data. Appendix A in the DEIS does in fact provide a summary of what 

was found from the field data under the heading of Existing Condition. The field 

data itself is located in the Project Record. More detailed information is included 

under the various resource sections in Chapter 3 of the SDEIS and in the respective 

specialist reports (Project Record, Specialist Reports and Notes). See also response 

to comment K-93. 

The DEIS and SDEIS in Chapter 1 identifies Grasslands Plan direction, existing 

condition, and a need for action when the existing condition varies from desired 

condition. Chapter 3 and Appendix A of the DEIS and Chapter 3 Part 2 of the 

SDEIS provide a summary of existing conditions by allotment, based on field data, 

and a need for action to meet or move resources towards the desired resource 

conditions identified in Chapter 3 of the DEIS and Chapter 3 Part 1 of the SDEIS.

The effects of oil and gas development use are identified on pages 3-7, 3-59, 3-84,3-

96, 3-97 3-141, 3-150, and 3-158 of the DEIS and Chapter 3 Parts 1 and 2 of the 

SDEIS. The impacts of wildlife and oil and gas development have been previously 

addressed in response to comment K-57. 

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K-100 The AMP DEIS fails to make any finding that reductions are the only “ecologically 

practicable and economically feasible” solution. The AMP DEIS also assumes that, in 

many cases, range structures cannot be added to the allotments, and thus livestock 

grazing reductions are the primary and only tools (DEIS Appendix D) rather than other 

methods that would involve structures to improve distribution and reduce use of sensitive 

areas. The limit on range structures is not required by law and the ROD requires the 

Forest Service to reconsider this criteria. 

The Forest Service believes both Alternative 3 and Alternative 4 meet this test. 

Balancing the ecologically practicable and economically feasible can be done on a 

sliding scale. A combination of both potential reductions and other practices to meet 

the ecological and economic goal to maintain a grazing program to the extent 

possible and provide sufficient habitat for grassland species is inherent in both 

alternatives. Alternative 3 has no initial livestock reductions, other techniques i.e. 

range infrastructure, water development, grazing rotation adjustments etc. were 

used as initial actions to address resource concerns. Alternative 4, uses the initial 

estimated carrying capacity to establish initial Authorized Use in AUMs, and in 

concert with other tools (i.e. Range infrastructure, etc.), results in no change in 

Authorized Use for some allotments (see SDEIS, Table 3.5). For the other 

allotments the resource needs (ecologically practicable) drive including reductions 

as an initial tool to meet or move towards Grasslands Plan goals and objectives. 

The Forest Service disagrees with the statement that “The AMP DEIS also assumes 

that, in many cases, range structures cannot be added to the allotments, and thus 

livestock grazing reductions are the primary and only tools..” The DEIS doesn’t 

assume or state such an accusation nor does the commentor present a specific 

reference to support this statement. The proposed action is built on use of tools and 

range methodologies other than livestock reductions as initial actions to address 

resource issues. DEIS Table 2.11 summarizes structures proposed by alternative. 

The misconception concerning range structures is further addressed in response to 

comments K-4 and K-33. 

K-101 The DEIS states that the Forest Service has not identified a preferred alternative because 

the agency “would like to hear what the public has to say about the project and its 

alternatives before selecting a course of action”.@ DEIS at I. CEQ regulations require 

the section of the EIS on alternatives to "identify the agency's preferred alternative if one 

or more exists, in the draft statement, and identify such alternative in the final 

statement.@ 40 C.F.R. '1502.14(e). CEQ has further clarified that this means that if the 

agency has a preferred alternative at the Draft EIS stage, that alternative must be labeled 

or identified as such in the Draft EIS.@ Forty Most Asked Questions Concerning CEQ's 

National Environmental Policy Act Regulations, 46 Fed. Reg. 18026, 18027 (March 23, 

1981). 

Commentor correctly quotes this section of the DEIS. The responsible official in 

this case had no preferred alternative at the time the DEIS was released. A 

preferred alternative is identified in the SDEIS.

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The requirement is “[i]dentify the agencies preferred alternative or alternatives, if 

one or more exists, in the draft statement and identify such alternative in the final 

statement unless another law prohibits the expression of such a preference”. 40 

C.F.R. '1502.14(e) 

Commentor also cites the Forty Most Asked Questions... This quote is:

4b. Does the "preferred alternative" have to be identified in the Draft EIS and the 

Final EIS or just in the Final EIS? 

A. Section 1502.14(e) requires the section of the EIS on alternatives to "identify the 

agency's preferred alternative if one or more exists, in the draft statement, and 

identify such alternative in the final statement . . ." This means that if the agency 

has a preferred alternative at the Draft EIS stage, that alternative must be 

labeled or identified as such in the Draft EIS. If the responsible federal official in 

fact has no preferred alternative at the Draft EIS stage, a preferred alternative 

need not be identified there. By the time the Final EIS is filed, Section 1502.14(e) 

presumes the existence of a preferred alternative and requires its identification 

in the Final EIS "unless another law prohibits the expression of such a 

preference." 

The DEIS was consistent with both the regulation and the guidance.

K-102 The Forest Service rationale for not disclosing its preferred alternative is also 

disingenuous. Only Alternatives 3 or 4 are likely to be considered. Given the MRD 

modification of Alternative 3 to “conform to the LRMP” or objections by the IDT, it is 

clear that the Forest Service prefers Alternative 4. Thus, the Forest Service cannot hide 

its preference and is required to disclose it. 

The Responsible Official has a range of alternatives to consider; he may select any 

one of the five alternatives or take parts of any of the alternatives and create a 

modified alternative. There is a range of implications associated with the selection

of any of the alternatives, which will be fully disclosed in the Record of Decision. 

The Forest Service is unclear on the commentor’s rationale about why the changes 

to Alternative 3 would imply that Alternative 4 would be the preferred alternative, 

when in fact there were very few changes made to MGA recommendations, see 

response to comment M. The Responsible Official discloses his lack of a preferred 

alternative on page i of the DEIS Abstract. The Forest Service is in compliance with 

the CEQ guidance on this issue.

K-103 The Forest Service’s rationale for not identifying a preferred alternative contravenes the 

NEPA policy, which requires a preferred alternative in an EIS. FSM 1950.41, &6. The 

agency should first subjectively identify its preferred alternative and then respond 

accordingly to public comment. Thus, if the Forest Service currently favors one of the 

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identified alternatives, it must identify it as the preferred alternative, regardless of what 

the public has to say, and reopen the DEIS for meaningful public comment. 

Commentor misinterprets the FSM. The FSM 1950.41 (6) reads, “[f]or each Forest 

Service proposal the responsible official shall coordinate and integrate NEPA review 

and relevant environmental documents with agency decision making as follows: (6) 

Identify the preferred alternative in an environmental impact statement (EIS) (40 

CFR 1502.14).” See response to comment to K-101 for the 40 CFR 1502.14 

language. 

It is unclear where the commentor draws the “subjectively identify its preferred 

alternative” conclusion. The Forest Service finds no NEPA process flaws after 

considering this comment against the DEIS. 

K-104 The alternatives are the heart of the EIS, 40 C.F.R. '1502.14(a). Because the 

requirements for a proposed action or preferred alternative are essential to the integrity 

of the NEPA process, the DEIS must be rewritten and put out for public comment a 

second time.

If the alternatives fully considered are substantially changed, a supplemental or a 

new draft EIS may be warranted. Refer to response to comments K-102 and 103 

above on the discussions on a preferred alternative. Commentor does correctly 

state the need for a proposed action in the NEPA process, and as documented in the 

project record and the DEIS, a proposed action was scoped and analyzed, giving the 

public and the commentor two opportunities to comment on the proposal. Because 

of these opportunities (including an extended comment period), and the extensive 

prework that was done with the permittee to develop the proposed action, it is felt 

that the DEIS does not need to be rewritten. 

As point of clarification, the commentor does correctly quote the alternatives is the 

heart of the EIS, but incorrectly cites the reference. This is actually found in the 

paragraph between the main heading of 40 CFR 1502.14 and 40 CFR 1502.14 (a). 

K-105 The AMP DEIS calls Alternative 3 the proposed action even though it is not the proposed 

action of MGA. The Livestock Grazing ROD provides that the Forest Service and the 

grazing association will agree on the “proposed action alternative”. Livestock Grazing 

ROD, App. A at 17, supra at 26. But Alternative 3 is not fairly described as the 

“proposed action,” given the changes that the Forest Service made, notwithstanding the 

objections of MGA members. Ex. 3, Schneider Decl. at &14. 

The commentor misquotes the Livestock Grazing ROD, App. A at 17, which states: 

“The range of alternatives might include, but are not limited to: 1) The proposed 

action, which would be the approach agreed to by the grazing associations and the 

Forest Service...”. 

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Forest Service worked extensively with the MGA board and individual permittees in 

the development of Alternative 3 (SDEIS, Appendix A). The proposed action 

reflects nearly all of the recommendations provided by the MGA, see response to 

comment M. Based on MGAs comments, Alternative 3A was created for the SDEIS 

to reflect those specific actions the MGA felt the Forest Service should or should not 

have included (SDEIS, Appendix A). 

This comment is addressed in response to comments K-29 and M. 

K-106 In accordance with Livestock Grazing ROD and Demonstration Project , the AMP DEIS 

may, but is not required to, consider a “no grazing” alternative. Livestock Grazing ROD 

at 17; FSH 2209.13, Ch.92.31. In these circumstances, NEPA does not contemplate the 

detailed analysis of a “no grazing” alternative in the DEIS, because the LRMP already 

made the decision to have livestock grazing on these lands. Livestock Grazing ROD at 

13 incorporating by reference decisions made in the 2002 DPG LRMP ROD. 

The EIS is required to consider the No action alternative as directed by The Council 

on Environmental Quality (CEQ) regulations at 40 Code of Federal Regulations 

(CFR) 1502.14 (d). “Include the alternative of no action”. 1502.15 continues with 

this direction related to alternative evaluation: (a) Rigorously explore and 

objectively evaluate all reasonable alternatives, and for alternatives which were 

eliminated from detailed study, briefly discuss the reasons for their having been 

eliminated. (b) Devote substantial treatment to each alternative considered in detail 

including the proposed action so that reviewers may evaluate their comparative 

merits.

Forest Service Handbook 2209.13_90 WO Amendment 2005-10, page 11 states that 

“In addition to the proposed action, the “no action” alternative shall always be fully 

developed and analyzed in detail. “No action” is synonymous with “no grazing” and 

means that livestock grazing would not be authorized within the project area.”

The Livestock Grazing ROD at 17 (7) provides examples of a range of alternatives 

that might be included in an alternative array. This specifically includes both a “no 

grazing” and a current management alternative, which is included in this analysis.

The Livestock Grazing ROD at 9 states “This decision authorizes grazing on the 

Dakota Prairie Grasslands through the issuance of grazing agreements and/or 

grazing permits, which will comply with the provisions of the Dakota Prairie 

Grasslands Plan as finalized by this ROD”. In other words the ROD identifies that 

grazing is a valid use of the DPG and where allowed shall be accomplished through 

issuance of a grazing agreement and/or grazing permits in accordance with the 

provisions of the Grasslands Plan. This does not negate the need to consider a no 

action alternative. 

K-107 The “no grazing alternative” should not be confused with the no action alternative 

required in NEPA. These lands have been grazed since the 1890s, and livestock grazing 

is a matter of vital economic and social interest to the local communities. NEPA requires 

that the Forest Service consider reasonable alternatives, and in this case, a no grazing 

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alternative is not only unreasonable, but contrary to the purpose and need of the DEIS, 

statutory objectives for the LMNG and the issues driving the LRMP, including avoiding 

reductions in livestock grazing. 

In a factually similar context, the court in Natural Resources Defense Council v. Hodel, 

624 F. Supp. 1045 (D. Nev. 1985), aff’d 819 F.2d 927 (9th Cir. 1987) held as much: 

First, it is an indisputable fact that livestock grazing has been going on in the Reno 

planning area, on public lands, for more than a century. . . For better or worse, 

production of forage for livestock use is at least an important priority in the overall 

resource picture of this area. . . Second, the mandate of Congress in PRIA was that 

livestock use was to continue as an important use of public lands; they should be 

managed to maximize productivity for livestock and other specified uses. 43 U.S.C. ' 

1903. Third, NEPA does not require examination of alternatives that are so speculative, 

contrary to law, or economically catastrophic as to be beyond the realm of feasibility. 

Kilroy v. Ruckelshaus, 738 F.2d 1448, 1454 (9th Cir.1985); California v. Block, 690 F.2d 

753, 767 (9th Cir.1982). The complete abandonment of grazing in the Reno planning 

area is practically unthinkable as a policy choice; it would involve monetary losses to the 

ranching community alone of nearly 4 million dollars and 290 jobs. . . not to mention 

unquantifiable social impacts. . . Eliminating all grazing would have extreme impacts on 

this small community. A Ano grazing@ policy is simply not a Areasonable alternative@ 

for this particular area. Citizens For A Better Henderson v. Hodel, 768 F.2d 1051, 1057 

(9th Cir.1985). Id. at 1054. 

See response to comment K-106. 

K-108 As was true in NRDC v. Hodel, the Northern Great Plains have been grazed for at least 

several centuries, first by buffalo and other game, and later by domestic livestock. The 

AMP DEIS admits as much when it states that the ACongressional intent to allow grazing 

on suitable lands@ and that there is a Aneed for continued livestock grazing to support 

local families and communities.@ DEIS at x. In fact: A no grazing alternative was 

considered but eliminated at the [DPG LRMP] FEIS level because the Great Plains 

(including the DPG) evolved with several natural ecological disturbance processes, 

including herbivory (grazing). Grazing is an important process in achieving desired 

vegetation and habitat conditions to address rangeland and forest health and other 

issues.@ Livestock Grazing ROD at 9. 

A “no grazing alternative” would also contradict the legal objectives which govern 

management of the National Grasslands. These lands were acquired and reserved from 

the public domain to support the rural economy and provide demonstration projects for 

grassland agriculture, or livestock grazing. Ex. Orders 7374, 7375. The National 

Grasslands were established during the Great Depression, when the small farms allowed 

under the Homestead Acts reeled from triple calamities of drought, dust storms, and 

falling commodity prices. Congress adopted a solution in the Emergency Appropriation 

Acts and Executive Orders to purchase the farms, relocate the farmers to more arable 

land, and to return these former farms to grassland agriculture to be managed by the 

remaining ranchers. Howard E. The National Grasslands, 78 N.D.L.Rev. 409, 420-421 

(). Thus, the no action alternative or the status quo is Alternative 2, continued livestock 

grazing that preserves rural agriculture economy. No grazing is a significant departure 

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from the status quo, does not conform to the LRMP decisions nor does it meet the 

Purpose and Need of the proposed action. 

The commentor is incorrect in stating that “...no grazing alternative was considered 

but eliminated at the [DPG LRMP] FEIS level...” The no action alternative is 

identified in the DPG FEIS and carried through the analysis in Chapter 3 of the 

FEIS.

See response to comment K-106 in relation to the definition of no action. 

K-109 Even if the Forest Service were to analyze a no grazing alternative, it needs to 

acknowledge that such an alternative is not consistent with Presidential and statutory 

direction, the history of the National Grasslands, is inconsistent with the current land use 

plan, and does not meet the purpose and need of the action. Thus, any consideration of 

‘no grazing’ as an alternative should only respond to public comments showing a 

substantive reason that ‘no grazing’ is a viable alternative. There is no indication in the 

record that this is the case here. 

The ROD for this project will provide the deciding officials reasoning for his 

decision including why other alternatives were not selected. 

K-110 Under NEPA, agencies must ensure professional and scientific integrity and accuracy of 

analyses. 40 C.F.R. ''1500.1, 1502.24. The Forest Service, therefore, must identify areas 

of scientific controversy and respond to adverse opinions held by respected scientists. 

Public Lands Council v. U.S. Department of the Interior, 929 F. Supp. 1436 (D. Wyo. 

1996), aff’d in part, rev’d in part, 167 F.3d 1287 (10th Cir. 1999), aff’d 529 U.S. 728 

(2000). 

By the Forest Services’ own admission, there are several unresolved scientific 

controversies. Livestock Grazing ROD at 13. Rather than addressing the Forest 

Service’s own scientific assumptions, which are admittedly controversial, the AMP DEIS 

appears to use the original 2002 LRMP assumptions. See Seattle Audubon Society v. 

Mosely, 798 F. Supp 1473, 1482 (W.D. Wash. 1992) (setting aside EIS which did not give 

reasoned analysis and response to scientific report which disputed agency findings); 

Sierra Club v. Eubanks, 335 F. Supp.2d 1070, 1079 (E.D. Calif. 2004) (NEPA 

specifically requires BLM “to objectively evaluate and disclose credible scientific 

evidence that contradicts its proposed course of action”). 

In reviewing page 13 of the 2006 ROD, it is difficult to find any language that would 

suggest “several unresolved scientific controversies” (see 2006 ROD, p. 13). 

Discussion about modifying and strengthening Grasslands Plan monitoring does 

occur, which is only reasonable and prudent as additional studies are done and valid 

data collected. Again, the SRT report discusses continuing controversy, but not 

over the scientific points, but rather over the values held by a diverse group of the 

American public, and the need to balance uses to meet multiple public land 

management goals and objectives driven by a multitude of factors (see 2006 ROD p. 

4-5).

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The information provided by the commentors is considered and evaluated in the 

Range section of Chapter 3 Part 1 of the SDEIS and in this response to comments. 

Also, refer to the Range, Methodology, Carrying Capacity Analysis section in 

Chapter 3 Part 1 of the SDEIS and the project record where the Forest Service 

specialists have done peer review with other Federal agencies on the methodology 

and best available background information used as far as current ecological sites 

and soil mapping. 

The opinion the commentor relies upon to support their claim of scientific 

controversy also commented on the Grasslands Plan (Dr. Lacey). Please note 

throughout the Addendum for the Final Environmental Impact Statement and 

Land and Resource Management Plans in Comments and Responses (for example p. 

160-161) where the same scientist (Dr. Lacey) made basic errors in assumptions of 

land management planning creating misleading conclusions. The scientist used also 

fails to explain there are several different acceptable methodologies that can be used 

to reach an estimated initial stocking rate, and also fails to use all of the criteria 

suggested by the SRT committee to reach his conclusions (for example, the use of 

adjusting for cow size and older, larger calves, see SRT report, p. 19). In fact, his 

report does not discuss why, or why not, this important criteria was ignored, in 

contrast to the Forest Service specialists who discuss that this would be a step 

evaluated as part of adaptive management (see DEIS 1-13 through 1-15, and 

Appendix D). Regardless, this scientist’s work was duly evaluated, considered and 

discussed in the SDEIS, which meets the requirement the commentor purports to 

claim from Public Lands Council v. USDI.

K-111 The DEIS fails to address scientific controversies which the Forest Service admitted 

remain unresolved after more than 10 years of NEPA process and debate in the DPG 

LRMP. Livestock Grazing ROD at 1. These include (1) recommendations regarding 

woody draw management and encroachment, (2) whether the soil, precipitation and 

weather will support high structure vegetation and VORs assigned in the DPG LRMP, (3) 

whether VORs provide a valid measurement to manage vegetation for biological 

diversity, resource health, and livestock grazing, (4) whether it is appropriate in 

calculating carrying capacity to exclude lands producing less than 300 pounds per acre; 

(5) whether the PFC criteria developed by the Forest Service should apply to riparian 

areas or be adjusted to reflect the northern Great Plain; and (6) the validity of the Forest 

Service data to date, especially the consistency of protocols for VOR readings, PFC 

assessments, and assumptions regarding range condition and carrying capacities. 

Review of page 1 of either the 2002 or 2006 Grasslands Plan ROD did not reveal any 

unresolved scientific controversies. Page 1 of the 2006 ROD does state that “Due to 

uncertainty and considerable controversy regarding assumptions, standards, and 

guidelines and projected effects of the LRMP, the 2002 established a “phase in” or 

“interim” approach to implementing the Plan’s livestock grazing direction and 

guidance”. It further states that “It has been four years since the initial Record of 

Decision was signed and 11 years since the beginning of the Northern Great Plains 

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planning process.” The additional points identified in the comment are not on page 

1 as implied by the commentor.

However, the points were addressed by the SRT and recommendations provided to 

the Forest Service who responded in the DPG Final Response to the Scientific 

Review Team Reports. The DEIS addressed the applicable recommendations 

consistent with the DPG’s Final Response to the SRT reports, see Appendix C of the 

SDEIS. 

This statement has been responded to through the Forest Service’s 2006 Final 

Response to the Scientific Review Team Reports. See also response to comment K11. 

K-112 The Demonstration Project was designed to address the above issues at the project level. 

Id. at 15 (“Based on the SRT’s findings and recommendations, the continuing 

controversy over the livestock grazing portion of the DPG Plan, and the national 

grassland mandate to demonstrate sound and practical principles of multiple use 

management that includes grassland agriculture, a pilot demonstration project is being 

proposed.”). The AMP DEIS design does not address these issues nor does it adopt 

procedures to do so. Most importantly, the AMP DEIS assumes that the 2002 LRMP 

objectives, standards and guidelines are set in concrete and does not consider 

amendments to the DPG LRMP, even though the DPP was intended to explore necessary 

changes to avoid livestock grazing reductions. Not only does the DEIS not try to avoid 

reductions but Alternative 4 embraces reductions as the principal management tool in its 

tool box. Appendix A-91-135. 

Commentor correctly quotes part of the purpose of the Demonstration Project. 

While that statement does capture some of the rationale behind the creation of the 

Demonstration Project, the very next sentence of that paragraph goes on to say 

“[t]he purpose of the demonstration project would be to develop and implement 

integrated allotment management plans pursuant to a collaborative process with the 

respective grazing associations that share in the management of grazing on the 

National Grasslands, to determine if Plan Goals and Objectives are achieveable or 

need modification, and monitor progress towards meeting the resource objectives.” 

What the Forest Service agreed to do with the SRT report (see the list provided by 

the commentor in K-111), are addressed in the Final Response to the SRT report. 

So the Demonstration Project was not designed to address the SRT issues listed in 

K-111 at the project level. The Applicable SRT recommendations were addressed

in the analysis (SDEIS, Appendix C). Also see response to comment K-116. 

The SDEIS analysis didn’t reveal the need for amendments to the Grasslands Plan 

so none are proposed. As cited elsewhere in this response, the Forest Service best 

available science and knowledge of the area shows the land is capable of achieving 

the Grasslands Plan goals and objectives (see Capability section for each resource in 

Chapter 3 Part 1 of the SDEIS). Monitoring, described in the Monitoring Section in 

Chapter 2 and in the third table for each allotment in Chapter 3 Part 2 of the 

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SDEIS, will determine if adjustments are needed in either the Grasslands Plan or 

the management of the allotments.

Nowhere in the Demonstration Project does it suggest that the Grasslands Plan 

should be amended so as to keep resource conditions as they currently are across the 

Dakota Prairie Grasslands, nor that no changes in management should occur until a 

perfect monitoring and data gathering system universally agreed to by all users for 

all possible grassland resources should be developed. Rather, the purpose would 

seem to be to move forward with the permittees in balancing needed changes in 

management in a cooperative manner to meet Grasslands Plan goals and objectives 

and to minimize permitted AUM reductions in the proposals (refer to the 

Demonstration Project Proposal Strategy section on p. 16 and 17 of the 2006 ROD).

Commentor incorrectly makes the assumption that alternatives must avoid 

reductions. It would be a violation of 40 CFR 1502.14, when taken in total to not 

explore reasonable alternatives, such as Alternative 4. 

Not only does the DEIS not try to avoid reductions but Alternative 4 embraces reductions 

as the principal management tool in its tool box. Appendix A-91-135. 

This is an incorrect statement. Alternative 2 has no Authorized Use (DEIS p. 2-14, 

3-52) reductions. There are no initial reductions in Authorized Use in Alternatives 3 

or 3A, which were designed using a variety of tools (SDEIS, Appendix A) excluding 

initial adjustments to Authorized Use (DEIS 2-15). Alternatives 3 and 3A under the 

SDEIS don’t consider Authorized Use adjustments unless monitoring reveals the 

need for a management adjustment, and then it is one of many tools that can be 

selected to address a resource concern. 

K-113 Similarly, despite the disclosure that initial reductions will be an average of 26%, the 

MRD makes no effort to avoid such reductions or to address the SRT recommendations. 

The commentor is referring to Alternative 4 when referring to an average 26 

percent reduction. The DEIS on page 3-52 identifies that under Alternative 4 for 

those allotments receiving an adjustment in Authorized Use range from 0 to 45 

percent with an average reduction of about 20 percent from preference. Note the 20 

percent was a typo in the DEIS should have been about 23 percent. 

See comments K-4, K-48, K-100, and K-112 in regards to the MRD lack of effort 

concerning reductions and Appendix C in the SDEIS regarding SRT 

recommendations. 

K-114 Also the AMP DEIS does not disclose how the Forest Service resolved the data issues 

raised by the SRT. 

How the issues brought forward by the SRT will be dealt with across the DPG are 

discussed in the Final Response to the Scientific Review Team Reports (Oct. 10, 

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2006). How they are dealt with in this project can be found in Appendix C of the 

SDEIS. Note not all of the SRT recommendations can be dealt with in a project by 

project basis, as some are more administrative in nature, such as “[m]aintain and 

share detailed, pasture-specific grazing records by Grazing Association and Forest 

Service personnel.”

K-115 In many cases, the PFC readings appear to have been done prior to the final SRT report, 

thus raising questions about the validity of the determinations that the areas fail to meet 

PFC. For example, 244 allotment was originally classified as meeting PFC and now is 

shown at risk, although livestock numbers did not change. App. A-74. 

The PFC data used to establish existing conditions in the North Billings County 

project area were collected from 2004 (see Brooks, 2005) through 2007. It is unclear 

to the Forest Service how collecting PFC field data prior to the final SRT report 

would affect the validity of the PFC determinations made from that field data. 

Additionally the SRT report dealt with the Grasslands Plan not this site specific 

project. The SRT did not review the PFC data for this project and made no 

judgment of the data. 

The evaluation of a riparian area provides a snapshot of conditions. The rating is 

not permanent. Surveys are routinely repeated to establish trends and to detect 

problems with current management or to document successful restoration of 

degraded areas. The two surveys in question are 6 to 7 years apart. The results of 

the survey indicate that in a matter of a few years, riparian conditions can degrade. 

In contrast, there are cases where rest or small changes in management can restore 

riparian conditions in one or two years. 

K-116 It is also clear that the AMP DEIS does not adopt most of the SRT recommendations, 

with the exception of dropping the floristic quality index and not using the DRAGON 

team data. Otherwise the criticisms levied by the SRT and its recommendations are 

ignored. 

This is an incorrect statement, applicable SRT recommendations were addressed in 

each resource area of the DEIS. However, every SRT recommendation and how it 

was addressed has been compiled into one section in the SDEIS (see Appendix C of

the SDEIS). 

K-117 Ordinarily, DEIS, therefore, would be revised to respond to the credible but 

contradictory scientific evidence provided. While the Forest Service ultimately has the 

discretion to decide what science to choose, the best available science “is not just 

whatever the Forest Service finds on the shelf. . . it still must be good science-that is 

reliable, peer-reviewed, or otherwise complying with valid scientific methods.” Ecology 

Center, Inc. v. U.S. Forest Service, 451 F.3d 1183, 1193, 1194 n.4 (10th Cir. 2006). In 

this case, the Livestock Grazing ROD acknowledges the scientific issues are still in 

controversy and requires each AMP to develop procedures to address them. Livestock 

Grazing ROD at 11 (“Based on the continuing controversy over the livestock grazing 

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North Billings County Allotment Management Plan Revisions

portion of the DPG Plan, and the national grassland mandate to demonstrate sound and 

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

Demonstration.”). When it appears there will be reductions, the Forest Service must also 

consider amending the LRMP to avoid reductions or to test the underlying assumptions 

in the plan. Id. Because the SRT concluded that several of the DPG LRMP and other 

Forest Service assumptions lacked credible scientific support, the data to be used in the 

AMP DEIS must conform to the SRT recommendations. The AMP DEIS does not 

incorporate the recommendations and thus is fundamentally flawed.

The Forest Service used the applicable SRT recommendations (see SDEIS, 

Appendix C), and used peer review to check methodology. See response to comment 

K-112 for response to the contentions on scientific controversy, the purposes of the 

Demonstration Project, and whether there is a need to amend the Grasslands Plan 

to avoid reductions. 

The Demonstration Project states “Goals, objectives, standards and guidelines 

related to livestock grazing in the Grasslands Plan will be assessed. If adjustments 

are needed, Grasslands Plan amendments will be proposed.” The analysis 

completed for the North Billings project determined that the Grasslands Plan goals 

and objectives are achievable; therefore, modification to the Grasslands Plan is not 

needed and has not been incorporated. However, monitoring progress towards 

meeting the resource objectives is an integral component of the proposed action. 

The analysis in the DEIS and SDEIS meet the requirements of the Demonstration 

Project and appropriately followed the Final Response to the SRT report. 

K-118 The AMP DEIS also omits the impacts of other grazing animals. The populations of 

deer, elk and big horn sheep have grown significantly since the establishment of the 

LMNG. Hunting is a major sport in North Dakota and population objectives of NDGF 

reflect its popularity. Nevertheless, these game animals affect rangeland resources and 

the AMP DEIS fails to address the interaction and the impacts. This is especially 

important with respect to woody species, since deer and elk will graze woody species in 

the spring before livestock are turned out. 

Elk and deer herds have increased significantly, but the DEIS fails to address the 

differences between cattle and big game use or even if the data make the distinction. This 

omission is significant, and suggests that the data do not support the premise in the DEIS 

that all reported resource concerns or unsatisfactory conditions are due to livestock 

grazing needs to be reexamined. See e.g. Appendix C summary of conditions by 

allotment; DEIS App. C-41.

See response to comment K-57. 

K-119 The SRT also criticized the Forest Service data for failing to document causation, 

especially as to PFC assessments. The same flaws are found throughout the AMP DEIS, 

where the PFC notes fail to identify any cause. See e.g. Appendix A-77, A-118.

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The DEIS on pages 3-60 thru 3-70 identified livestock and other impacts to stream 

reaches. The PFC field notes (Project Record, Supporting Documentation - 

Riparian, L-36) contain notations regarding the presence of livestock, tracks in the 

creeks, grazed vegetation, cattle manure in the streams. See also response to 

comments K-44 and K-53. 

K-120 Noxious Weed Infestations Due to Many Factors Omitted in AMP DEIS 

The AMP DEIS assumes that noxious weed infestations are largely due to livestock use, 

livestock trailing, and grazing. AMP DEIS at 3-54 (equating less livestock with fewer 

noxious weeds). This is only partly correct. Noxious weeds are carried by all grazing 

animals, including big game, birds, wildlife, as well as the wind. Wildlife, birds, and 

wind play a significant role in the dispersal of noxious weeds. Sakai, et al., The 

Population Biology of Invasive Species, ANNU. REV. ECOL. SYST. 2001. 32:305B32 at 

312. The need to conduct noxious weed control in wilderness areas where there is no 

livestock use is further evidence that livestock are by no means the sole or even the 

primary vector for noxious weeds. 74 Fed. Reg. 40809 (2009); 71 Fed. Reg. 64509 

(2006). It is also well-established that surface disturbance from energy development will 

facilitate new noxious weed sites. The AMP DEIS ignores these significant impacts 

entirely.

The DEIS does not assume that noxious weed infestations are largely due to 

livestock. The DEIS at 3-54 identifies that under Alternative 4 fewer livestock might 

have a positive effect because there would be fewer cows, therefore, fewer vectors to 

spread noxious weed seed. The same would be true if there were less car and truck

traffic, fewer hikers, less ground disturbance, etc. 

The Forest Service agrees that big game, wind, birds etc. also have a role in 

dispersal of noxious weed seed. The DEIS doesn’t single out livestock as the only or 

primary vector effecting livestock. The DEIS (pp. 3-6, 3-7, 3-16, 3-85, 3-127, 3-150, 

3-151) and Botany Report (Project Record, Specialist Reports and Notes) identify 

many other vectors that can spread noxious weeds. 

K-121 Energy development has been occurring on the National Grasslands for almost 60 years 

and that development also has significant impacts on vegetation, soils, and sediment. It 

would appear that in most cases the data relied upon in the AMP DEIS do not make a 

distinction between livestock uses and other land uses, such as energy development, 

especially in riparian areas. See e.g. AMP DEIS C-4, C-29, C-32, C-41 (roads cause 

noxious weeds and crested wheatgrass). There are a few notes about roads but nothing 

about well sites, pipelines and transmission line construction or other development. 

These are actions occurring at the same time and place and need to be addressed in the 

AMP DEIS as similar and cumulative actions. 40 C.F.R. '1508.25(a). 

The effects of oil and gas development use are identified on pages 3-7, 3-59, 3-84,3-

96, 3-97 3-141, 3-150, and 3-158 of the DEIS and Chapter 3 Parts 1 and 2 of the 

SDEIS.

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The individual PFC field checklists (see Project Record, Supporting Documentation 

– Riparian, L-26 and L-36) note impacts to riparian areas from various activities, 

livestock grazing and other activities. The PFC protocol is specifically designed to 

examine riparian areas. Well sites are never located in riparian areas on National 

Forest System lands of the Dakota Prairie Grasslands. Pipelines and transmission 

lines are buried. Road crossings, by Grasslands Plan direction, are perpendicular to 

streams (see Grasslands Plan, p. 1-9, 1-10, 1-11). The fact that there are few notes 

about roads, pipelines, and transmission lines reflects that this infrastructure has 

been generally installed well and located properly so as to have little to no long-term 

impacts to riparian areas. Pipelines are generally bored under riparian areas as are 

transmission lines to minimize disturbance. 

Additional information regarding oil and gas development has been added to the 

Past, Present, and Reasonably Foreseeable and Cumulative Effects sections in 

Chapter 3 Part 1 of the SDEIS.

K-122 Recommendations 

A. Revise Purpose & Need to Reflect Livestock Grazing ROD, Rey Direction 

and DP Objectives

1. Include Avoiding Livestock Grazing Reductions 

As found in both the Livestock Grazing ROD, Demonstration Project, and the Under 

Secretary direction, the AMP DEIS must show significant efforts to maintain livestock 

grazing levels. The AMP DEIS does just the opposite and needs to be revised to adopt 

the full range of techniques to avoid reductions. Reductions should occur only after 

monitoring data demonstrate a need and other techniques have not succeeded. 

The 2006 Grazing ROD (page 16) states that “ One goal will be to maintain or 

improve current on-the-ground conditions and/or condition to maintain, to the 

maximum extent possible, a grazing program at current levels and provide 

sufficient habitat for grasslands species”. There is no requirement to show 

significant efforts to maintain livestock grazing levels. 

The DEIS and SDEIS provide an array of alternatives to address resource concerns. 

Alternative 2 has no Authorized Use reductions (DEIS p. 2-14). Alternatives 3 and 

3A (SDEIS) have no initial reductions in Authorized Use, and cannot entertain 

reductions unless monitoring shows resource objectives aren’t being met. 

Alternatives 3 and 3A both utilize a full range of different techniques (see DEIS 

Appendix A, SDEIS Chapter 3 Part 2) to address resource concerns. The toolbox 

(DEIS p. 2-15) is comprised of all the different tools used to address resource 

concerns. The commentor doesn’t provide other techniques to consider. Alternative 

4 uses a combination of grazing reductions and other range management techniques 

K-123 The AMP DEIS needs to include LRMP amendments that will include deletion of the ‘no 

net’ increase in range structures, revision of high structure and VOR standards to reflect 

site capability and maintaining grazing levels, revision of PFC criteria designed for 

western North Dakota, and revision of woody draw standards to reflect historical 

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distribution and trend data, recalculate AUMs and evaluate whether larger livestock 

affect forage health and vigor adversely, and include all lands in calculation of carrying 

capacity.

The IDT considered these comments in a new alternative. However, that alternative 

was dismissed from detailed study. See the Alternatives Considered But Dropped 

from Detailed Analysis section in Chapter 2 of the SDEIS for a detailed discussion 

of why the alternative was dropped. 

K-124. Recalculate Carrying Capacity with Actual Data 

Incorporate MGA program with NDSU which will have three years of ecological site 

condition and production data. More than three years ago, MGA contracted with NDSU 

to develop range condition data, which will be compiled and evaluated within two 

months. 

The cooperative monitoring effort between NDSU, MGA, and the Forest Service

began on the ground data collection in 2008. The Forest Service has reviewed the 

2008 and 2009 cooperative monitoring data (see SDEIS, Chapter 3 Part 1, Range, 

Cooperative Monitoring Data). See response to comment K-65. 

K-125 Revise Data or Acknowledge Missing Data to Conform to SRT Recommendations 

The AMP DEIS puts in place significant grazing reductions in many cases without 

correcting the data deficiencies identified by the SRT. The AMP should be the point 

where management is not changed without sound data. If the data were flawed or 

questionable due to varying protocols, lack of training, or the need to revise criteria, then 

it cannot be fairly used to justify grazing reductions. The cost is too high to the members 

and to the community to impose cuts that are not needed just because the readings were 

inaccurate. 

See response to comment K-114. 

K-126 Put in Place Process to Develop Data Through Joint Monitoring 

If adaptive management is going to work, there needs to be a process to develop good 

information. The AMP is that opportunity and the information development needs to 

mirror the recommendations of the SRT regarding VORs, vegetation structure, PFC and 

woody draws in particular.

The Monitoring Plan starting at page 2-18 of the DEIS and the Allotment Summary 

Sheets (Appendix A) identify the process and what will be monitored and frequency 

of monitoring by allotment. The monitoring regime for each allotment has been 

updated in the SDEIS (see Chapter 3 Part 2). Information that will be collected 

does mirror SRT recommendations in accordance with the DPG’s Final Response to 

the Scientific Review Team Reports. The MGA as the Forest Service’s agent has a 

role in the collection of monitoring information in conjunction with Forest Service 

data collection efforts. 

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See also response to comment K-112. 

K-127 Revise Alternative 3 to Reflect All of the MGA Recommendations

The MGA stands ready to engage in good faith negotiations to develop a joint 

alternative. The AMP DEIS cannot conform to the Livestock Grazing ROD and 

Demonstration Project until this occurs. 

A review of Exhibit 2, revealed that most of the highlighted MGA recommendations 

were either included in the proposed action or dropped for one of several different 

reasons, see response to comment M for further details. Based on MGA’s comments 

Alternative 3A was created for the SDEIS to reflect those specific recommendations 

the MGA felt the Forest Service should or should not have included in Alternative 3

(SDEIS, Appendix A). 

K-128 Revise Alternative 3 to Include Monitoring Program Designed to Test Issues in 

Controversy 

In light of the fact that there may not be sufficient data and the questions about the 

carrying capacity calculations, it is apparent that adaptive management or stock and 

monitor system avoids reductions and yet allows credible data to be developed. This 

system will only work if the AMP also acknowledges the need to put in place a process to 

evaluate the merit and ability to meet LRMP goals, objectives, standards and guidelines. 

No additional processes are needed to evaluate the merit of the Grasslands Plan 

goals, objectives, standards, and guidelines (refer to the 2003 and 2007 Grasslands 

Plan Washington Office appeal decisions and the associated Discretionary Reviews, 

the SRT report, and the Final Response to the SRT report). The SDEIS identifies 

that the ground is capable of meeting The Grasslands Plan goals, objectives, 

standards and guidelines. Project implementation, monitoring and review will 

determine if any adjustments are needed to the Grasslands Plan in accordance with 

point 3 (2006 ROD, page 16) of the Demonstration Project.

Also see response to comment K-22. 

K-129 Avoid Livestock Grazing Reductions

The AMP DEIS fails to include the requirement that grazing levels be maintained. 

This needs to be central to the decision and AMP.

The Demonstration project states “One goal will be to maintain or improve current 

on-the-ground conditions to maintain, to the maximum extent possible, a grazing 

program at current levels and provide sufficient habitat for grassland species. (2006 

ROD, p. 16). This is not a requirement to maintain current grazing levels, and as 

such is not incorporated into the DEIS or SDEIS.

Throughout the 2006 ROD, including the Demonstration Project, implementing the 

Grasslands Plan and providing for the suite of multiple uses is discussed. The 

Forest Service has formally agreed to the practice it has often employed on the 

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Dakota Prairie Grasslands, which is to try to minimize livestock reductions while 

providing for sufficient habitat for grassland species, multiple uses, and complying 

with all applicable federal laws, regulations, and executive orders. 

EXHIBIT 1. LETTER OF JOHN LACEY, PHD. OCTOBER 11, 2009 

L-1 Based on my review of the selected material, I believe that the FS methodologies did not 

correctly follow the NRCS guidelines. Based on the FS description of their 

methodologies, I do not know how they generated their estimated carrying capacities. 

The commentor is correct in that the Forest Service did not follow NRCS guidelines 

for estimating carrying capacity (see response to comments K-63 and K-64). 

The Forest Service acknowledges that additional descriptive information could be 

added to the carrying capacity analysis section of the DEIS, the SDEIS has been 

updated to include this information (SDEIS, Chapter 3 Part 1, Range, Methodology, 

Carrying Capacity Analysis). 

L-2 It is important to realize that the FS decision to use a quasi-NRCS approach to carrying 

capacities should be criticized.

See response to comments K-63 and K-64. 

L-3 It is important to note that none of the four approaches outlined in the Handbook 

resembles the FS method that is described in the DEIS. 

The commentor is correct in that none of the four approaches outlined in the NRCS 

National Range and Pasture Handbook were used to estimate carrying capacity. See 

response to comments K-63 and K-64. 

L-4 I think that your clients deserve to know--- How did the FS obtain their production data 

(did they clip plots and weigh each species)?

See response to comments K-66 and K-68. 

L-5 The FS claim that the “weighed average figure was based upon the ecological site 

reference plant community production (Representative Value) for each ecological site 

within the soil mapping unit.” This seems to suggest that the carrying capacity was 

somehow estimated by comparing “something” to ecological site guides? 

The commentor is incorrect in suggesting that the carrying capacity was estimated 

by comparing “something” to ecological site guides. In the Range, Methodology, 

Carrying Capacity Analysis section in Chapter 3 Part 1 of the SDEIS, the Forest 

Service identifies that forage production values for each mapping unit within the 

soil survey were calculated by using a weighted average of the listed ecological sites 

within that mapping unit. Each listed ecological site within a mapping unit has a 

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reported Representative Value that is the expected production for the reference 

plant community under normal growing conditions for that ecological site. 

L-6 The FS further writes “some assumptions to consider about the Representive Value are 

as follows: 1) seasonlong grazing, 2) normal growing conditions, and 3) reference plant 

community.” To me, this suggest that these considerations somehow influenced the 

estimated carrying capacities. If so, how did they influence the calculations? 

See response to comment K-69. 

L-7 If the FS did somehow estimate production by species and compared it directly to the 

ecological site guides, they would be calculating similarity indices. According to the 

National Range and Pasture Handbook, similarity indices are calculated by comparing 

clipping data (i.e., #lbs of production by species) on an ecological site to the historic 

climax plant community that is defined on the respective ecological site guide. If the FS 

did this, they would have a “similarity index” for each ecological site. However, the 

similarity indices are not representative of the stocking rate. For example, 2,000 lbs/acre 

of smooth bromegrass may be produced on a loamy site, but it would not contribute 

toward the DI because smooth brome (an introduced species) would not be listed on the 

historic Climax Plant Community loamy ecological site guide. Likewise, if the FS did 

have a list of species growing on an ecological site, and the respective production of 

each, an inexperienced observer may note that smooth brome did not occur on the 

historic climax plant community, and thus, smooth brome would not be given any credit 

for forage value on the site.

See response to comments K-70 and K-71. 

L-8 The FS needs to clarify their description of the methodology, and be required to 

specifically describe how the production of crested wheatgrass, smooth bromegrass, 

Kentucky bluegrass, etc, entered into their carrying capacity calculations. Or were they 

omitted because they were not listed as a species on the Historic Climax. Plant 

Community (and thus significantly lower forage production)?

See response to comment K-71. 

L-9 In my experience, most of the soil surveys conducted in western states are done at a scale 

that precludes the mapping of small drainages and coulees (overflow sites) that often 

contribute significantly to the carrying capacity of an area that is comprised of a 

mapping unit. Therefore, the carrying capacity of the soil mapping unit is often underestimated when this approach is used. The magnitude of this discrepancy varies with the 

topography, mapping scale, and capabilities of the soil scientist that did the mapping. 

See response to comment K-72. 

L-10 The FS may have been logical (if they had clipping data) when they calculated forage 

production values for each mapping unit within the soil survey by using a "weighed 

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average" of the ecological sites within that mapping unit. This suggests to me that if a 

mapping unit was comprised by 70% shallow and 30% clayey ecological sites, then the 

weighted forage production for the unit would consider the number of acres of each, and 

the respective forage production that characterizes them. However, this "weighted 

average" could not be compared to the ecological site guides. Furthermore, the 

"weighted average" would not have included the "contrasting inclusions". 

See response to comments K-66, K-68, K-71, and K-72. 

L-11 The FS used a harvest efficiency of 25%. This value may not be appropriate for all 

allotments. According to the NRCS Handbook, harvest efficiency is the percentage of 

forage actually ingested by the animals from the total amount of forage produced. 

Harvest efficiency increases as the number of animals increases in an area and they 

consume plant material before it senesces, transfers to litter, or otherwise leaves the 

area. Because of differences in stock density, vegetative types, livestock distribution, 

grazing system, etc, it is logical to expect that harvest efficiency would not be identical 

for all allotments. In many areas, a harvest efficiency of 35% is probably attained.

The SDEIS in Chapter 3 Part 1, Range, Methodology, Carrying Capacity Analysis 

describes the formula used to calculate the carrying capacity analysis and gives an 

explanation of why 25 percent was used as the harvest efficiency value. The Forest 

Service agrees that every individual operator is different, but generalities need to be 

made when doing an analysis across many acres of land. 

L-12 The NRCS Handbook defines an animal unit (AU) as one mature cow of approximately 

1,000 pounds and a calf as old as 6 months or their equivalent. An AUM is the amount of 

forage required by an animal unit for one month. According to the Handbook, the NRCS 

has "elected to use 26 pounds of oven-dry weight or 30 lbs air-dry weight (as-fed) of 

forage per day as the standard forage demand for a 1,000 pound cow (one animal unit). 

Therefore, their "913" pounds of forage (air dried) required to maintain a cow for one 

month appears to be consistent with NRCS methodology. Although I did not find the FS 

description, they probably multiplied the 913 lbs of forage by 1.2 to estimate the forage 

required to maintain a 1,200lb cow? (If they did, it should be pointed out that the 

relationship between the consumption of a 1000 and 1200 lb cow, is not linear. But as 

argued by the SRT, a big cow eats more than a little one).

If the Forest Service adjusts for the average size of a cow being greater than the 

definition of an animal unit, the process for this is described in the SDEIS in 

Chapter 3 Part 1, Range, Methodology, Livestock Weight Adjustment and in 

Appendix D. This would be done outside of the carrying capacity analysis.

L-13 As you know, adjusting stocking rates simply on the basis of cow size is not logical 

without additional supporting data. Unfortunately, some land administrators now use 

cow size as a tool to reduce livestock use on rangelands.

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The commentor is incorrect that the Forest Service is using cow size as a tool to 

reduce livestock use on rangelands. Alternatives 3, 3A, and 4 were created to 

address various resource issues in light of Grasslands Plan goals and objectives. 

These alternatives propose initial actions which include several grazing 

management tools. 

EXHIBIT 2. TABLE COMPARING MEDORA GRAZING ASSOCIATION 

RECOMMENDATIONS WITH ALTERNATIVE 3 OF THE DEIS

M-1 See SDEIS, Appendix A which documents how Exhibit 2 of the Medora Grazing 

Association’s and Billings County’s comments was considered. Alternative 3A was 

developed based on the review of this exhibit. 

EXHIBIT 3. DECLARATION OF CLINT SCHNEIDER, MEDORA GRAZING 

ASSOCIATION

N-1 3. The Forest Service held individual meetings with each permittee or permittees for the 

in-common pastures to discuss management of the allotments. The first set of meetings 

involved about half an hour with each member when the member could recommend 

changes in management, as well as structural and non-structural range improvements. 

The Forest Service took detailed notes. Throughout the meetings, the Forest Service 

personnel talked about achieving the objectives in the Dakota Prairie Grasslands Land & 

Resource Management Plan (Plan). The Forest Service employees were particularly 

focused on meeting the structure objectives or the VOR readings specified in the plan.

In review of the MGA letters sent out to the individual permittees and base property 

owners an hour was scheduled for each individual allotment for the first set of 

meetings (Project Record, Supporting Documentation – Range, L-22 – October 11, 

2005 and November 9, 2005; Project Record, Process Documentation, Permittee 

Meeting Notes, B-51). Enclosed within the letters was information from the Forest 

Service concerning these meetings and the Allotment Management Plan revisions. 

MGA also instructed the permittees to review the information before their 

individual meeting. The actual length of the meeting varied among allotments. 

There were allotments that only took a half hour, and others took an hour or more.

A review of the notes taken, the information enclosed in the MGA letters (Project 

Record, Correspondence Permittee, J-4), and the SDEIS, Appendix A shows that 

Forest Service personnel did discuss the Grasslands Plan goals and objectives and 

also pointed out in the meetings what potential issues may occur on the allotment. 

However, Forest Service personnel made it clear that site specific issues were not 

identified at this time. Structure objectives were one of several goals and objectives 

discussed at the first set of permittee meetings. 

N-2 4. At the end of the first set of meetings the Forest Service said they would take these 

recommendations back to the planning team. They were specific that the association 

members may get what they wanted or may not. 

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The Forest Service agrees that permittee requests, comments, and concerns were 

brought back to the Forest Service IDT after the first set of permittee meetings. A 

review of the notes taken at the first set of permittee meetings indicates that the 

Forest Service did specify that they would take the information back to the IDT, and 

permittees would be kept in the loop (Project Record, Process Documentation, 

Permittee Meeting Notes, B-51). Forest Service personnel indicated that requests 

could be considered especially if they addressed identified resource issues and didn’t 

cause any additional resource issues.

N-3 5. In 2006, the Forest Service scheduled a second set of meetings. This consisted of an 

explanation of why the Forest Service did not take what the member wanted. If the 

member did not get what he recommended it was put into the “toolbox.” The Forest 

Service instead proposed trying different techniques to achieve or make progress toward 

achieving the LRMP objectives. Nothing was concrete but the Forest Service told the 

members what would be done, and did not give the members the chance to suggest 

something else. In many cases the Forest Service just said the biologist or archeologist 

on the IDT could not accept the member’s recommendations. 

See response to comments K-27 and K-28. 

N-4 6. There was no timetable given between trying different techniques and figuring out 

what would and would not work. 

The monitoring section of each Allotment Summary Sheet in Appendix A of the 

DEIS describes timetables for implementation monitoring. The SDEIS has included 

a Trigger Points section under Monitoring in Chapter 2, and monitoring frequencies 

for each allotment have been updated in the third table for each allotment in 

Chapter 3 Part 2. 

N-5 8. In response to questions regarding the length of time the Forest Service has taken, we 

were told that the AMP DEIS has been delayed to work on the grazing agreement 

renewal.

While the Forest Service has repeatedly provided information on timetables and 

deadlines for the North Billings project that has been backed up, at no time has the 

Forest Service said that the work was delayed to work on the grazing agreement 

renewal. Work on each project has been concurrent with different representatives 

heading up the individual projects.

N-6 9. The DEIS states that the Board agreed to adaptive management. DEIS 1-5. This is 

misrepresented. There was one short meeting where the Forest Service gave MGA 

members an up or down choice between coordinated resource management planning 

(CRMP) or adaptive management. MGA was not told what it would involve but members 

were aware of a continuing CRMP process that has not gone smoothly. Based solely on 

130 | Response to Comments
North Billings County Allotment Management Plan Revisions

that up or down choice, we expressed a preference for adaptive management based on 

what the Forest Service explained and no additional information. 

 

See response to comment K-35.

N-7 10. Adaptive management was not presented as precluding or excluding the 

Demonstration Project that the association supported. Nor was it presented as waiving 

the resolution opportunities raised by the Scientific Review Team (SRT).

See response to comment K-35.

N-8 11. Even now we are not opposed to adaptive management if it were properly structured 

with agreed upon objectives. The dilemma we face is that the Plan objectives 

particularly the structure and woody draw are the subject of a major scientific 

controversy. So adaptive management as set out in the DEIS is not able to test the 

validity of the objectives in the first place.

 

See response to comment K-36.

N-9 13. There was no discussion of how to test whether the sites are capable of producing the 

structure objectives and VOR measurements set out in the LRMP. On many occasions 

the members told the Forest Service that the allotment could not to meet the objectives 

due to limits on the site capability. These comments were ignored. 

 

See response to comments K-15 and K-41. 

Comments on site capability were not ignored. The Forest Service took the 

opportunity at permittee meetings to describe what they considered “biologically 

capable” visually on a map. In fact, at the second set of meetings the Forest Service

offered the opportunity for individual permittees to challenge identified issues on 

their individual allotment. The IDT field reviewed all identified challenges (Project 

Record, Process Documentation, Permittee Meeting Notes, B-52).

N-10 14. At no time during this process were we told that the Forest Service calculations of the 

carrying capacity showed that we were overstocked. The first I heard of it was when the 

Forest Service presented the stocking rates in relation to Appendix A, Alternative 3. 

More importantly, the Forest Service has never disclosed to MGA that there would be 

any reductions. In fact the Forest Service repeatedly represented that there would not be 

reductions until the tools in the toolbox were explored. Now however it is clear that both 

Alternatives 3 and 4 call for immediate cuts without regard to the separate task of 

meeting or maintaining the LRMP objectives.

See response to comment K-58. 

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N-11 15. These cuts are much higher than the 10 years of Forest Service representations to the 

Governor, the public and to the SRT that reductions would be only an average of 9% if 

that. Instead, the cuts are as much as 40% and average 29%.

 

See response to comments K-46 and K-89. 

N-12 17. The Forest Service did tell MGA that all lands deemed to produce less than 300 

pounds per acre are classified as unsuitable and are not counted in the carrying 

capacity.

 

The Forest Service disagrees with this statement. See response to comment K-76. 

N-13 18. I have read the Scientific Review Team Report on several occasions. The SRT team 

expressly recommended that the Forest Service include the lands that produce less than 

300 pounds per acre. While the Forest Service has told us that they are implementing the 

SRT recommendations, it is clear to me that they are not. 

 

See response to comment K-76. 

N-14 19. We did provide the Forest Service with permitted use data for the years 2005 through 

2007, even though 2005 was a severe drought. The Forest Service claims that it would 

‘take that into consideration’ but we have not seen any explanation as to how the Forest 

Service weighted those numbers. Previously, the Association provides the Forest Service 

with actual use data when asked for the reports. 

MGAs permitted use data for the years 2005 through 2007 was used to describe an 

average permitted use for current management. No “weight” was given to any one 

year, be it a drought or above-average precipitation year. This information was used 

in the analysis to evaluate the effects of past grazing systems and whether or not 

trends would likely increase, decrease, or stay the same based on the alternatives 

and comparison to the three-year average MGA permitted use, as well as 

Preference. This information is provided strictly for comparison purposes to more 

sharply define differences between the alternatives (SDEIS, Chapter 3 Part 1, 

Affected Environment – Range, Actual Use and Tables 3.4 and 3.5).

See also response to comment K-12. 

N-15 20. I have read page 3-15 of the DEIS where the Forest Service implies that MGA is 

misrepresenting the actual use numbers. The Forest Service is flatly incorrect and 

should know that. First, MGA has always provided actual use numbers when requested 

by the Forest Service and this conforms to our grazing agreement. Our reports do not 

differ significantly from that of direct permittees, who also reach agreement on numbers 

at the beginning of the season, pay the grazing bill and report when they have left federal 

land. The suggestion that the information is flawed or false reflects hostility on the part 

of this Ranger District office.

See response to comments K-12 and K-14. 

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N-16 21. It is true that many operators, if conditions change, might sell livestock early. This is 

not a violation of the permit nor is it a violation of Forest Service policy. 

The Forest Service agrees that operators may sell their livestock early and that this 

does not violate the permit. However, this again represents why the data the MGA 

provides from the Allotment Worksheets/AOIs does not reflect actual use. 

N-17 22. It is not true as implied in the DEIS, 3-14 that MGA members are grazing more than 

what is reported by MGA. Both the association structure and the resource would quickly 

reveal if someone were grazing above his preference.

See response to comment K-14. 

N-18 23. The DEIS is also incorrect when it states that MGA members did not take reductions 

due to drought in recent years. There are two types of reductions, one is mandatory and 

ordered by the Forest Service and a second is voluntary and undertaken by members 

when lack of rain supports a decision to leave federal lands early. In 2004, there was a 

mandatory reduction. In 2005, the MGA members agreed to voluntary reductions and 

understocked in response to the drought. While we had good precipitation in 2007, in 

2008 the Forest Service ordered a mandatory 35% reduction. MGA objected to the 

across-the-board reduction due to the variability of conditions. As a result the reductions 

were voluntarily done by allotment, ranging from 15% to 40%. 

The SDEIS has included the drought reductions taken in 2008. However, some 

clarification is required to address the commentor’s statements on what kind of 

reductions were taken in recent years. The commentor is correct that in 2004 a 

mandatory reduction was put in place. However, a mandatory, not voluntary, 

reduction was implemented in 2005 (Project Record, Supporting Documentation, 

Range, L-21 - November 10, 2004). The reduction in 2008 was also a mandatory 

reduction that considered individual allotments on a site-by-site basis. Field reviews 

were conducted by Forest Service personnel and applicable pasture directors with 

determinations made on the ground of what the 2008 reduction would be.

Response to Comments | 133

FEIS Vol. III North Billings County Allotment Management Plan Revision

Index

FEIS Vol. III North Billings County Allotment Management Plan Revision

Index | 1

Index

A

adaptive management, 1, 2

AMs, 3

Animal Months

AMs, 3

animal unit equivalent, 2

animal unit equivalents, 2

AUEs, 2

AUE, 2

AUEs, 3

AUM, 3

AUMs, 2, 3, 82, 83

C

carrying capacity, 2

cow size, 2

E

erosion, 53

G

grazing association, 2, 3

H

herbaceous structure, 1

I

issues, 1

P

preference, 3

S

scoping, 2

SRT, 2