Final Comprehensive Conservation Plan 

and Environmental Impact Statement

Charles M. Russell National Wildlife Refuge

UL Bend National Wildlife Refuge

Volume 2—Comments and Responses for the Draft Plan 

and Environmental Impact Statement

Montana

April 2012

Prepared by 

U.S. Fish and Wildlife Service

Charles M. Russell National Wildlife Refuge

Airport Road

Lewistown, Montana 59457

406 /538 8706

and

Region 6, Mountain–Prairie Region

Division of Refuge Planning

134 Union Boulevard, Suite 300

Lakewood, Colorado 80228

303 / 236 8145

CITATION

U.S. Fish and Wildlife Service. 2012. Final comprehensive conservation plan and environmental impact statement: Charles M. 

Russell National Wildlife Refuge, UL Bend National Wildlife Refuge. Volume 2—Comments and responses for the draft plan and 

environmental impact statement. Lakewood, Colorado: U.S. Department of the Interior, Fish and Wildlife Service, Mountain–Prairie 

Region. 458 p.

Contents

Abbreviations ................................................................................. V

CHAPTER 1—Introduction .................................................................... 1

CHAPTER 2—Comments from Agencies and Organizations ..................................... 3

CHAPTER 3—Comments from Individuals ...................................................... 303

How to Find Responses to Individual Comments .................................................. 303

Most Common Concerns or Issues ............................................................. 303

Summary of Form Letters ..................................................................... 313

Responses to Individual Comments ............................................................ 315

1000—Purpose and Need .................................................................. 315

2000—Refuge History, Vision, and Goals .................................................... 316

3000—Alternatives and Objectives .......................................................... 316

4000—Affected Environment and Environmental Consequences. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 328

5000—Planning and NEPA Processes and the Draft CCP and EIS ............................. 333

CHAPTER 4—Public Hearing Testimony ....................................................... 335

Billings; September 28, 2010 ................................................................... 336

Bozeman; September 29, 2010 ................................................................. 354

Great Falls; September 30, 2010 ................................................................ 370

Lewistown; October 12, 2010 .................................................................. 381

Jordan; October 13, 2010 ..................................................................... 395

Glasgow; October 14, 2010 .................................................................... 413

Malta; October 14, 2010 ....................................................................... 427

Bibliography .................................................................................. 439

Table 1. Number of individual comments by grouped comment codes and comment descriptions ......... 303

Abbreviations

ADA Americans with Disabilities Act

APF American Prairie Foundation

AUM animal unit month

BLM Bureau of Land Management

CCP comprehensive conservation plan

CFR Code of Federal Regulations

DEIS draft environmental impact statement

DNRC Montana Department of Natural Resources and Conservation

DOI U.S. Department of the Interior

EIS environmental impact statement

Enhancement Act Title VIII of the Water Resources Development Act of 2000

FEIS final environmental impact statement

FWP Montana Department of Fish, Wildlife and Parks

FWS U.S. Fish and Wildlife Service

GIS Geographic Information System

GPS global positioning system

GS General Schedule (employment type)

HDP height-density plot

HMP habitat management plan

IMPLAN Impact Analysis for Planning

Improvement Act National Wildlife Refuge System Improvement Act of 1997

MDEQ Montana Department of Environmental Quality

MFWP Montana Department of Fish, Wildlife and Parks

MOA memorandum of agreement

NEPA National Environmental Policy Act

NGO nongovernmental organization

NRCS Natural Resources Conservation Service

NWR national wildlife refuge

PILT payment in lieu of taxes

PWA proposed wilderness area

Refuge System National Wildlife Refuge System

Region 6 Mountain–Prairie Region of the U.S. Fish and Wildlife Service

RLGIS Refuge Land Geographic Information System

SDHU Silver Dollar Habitat Unit

Service U.S. Fish and Wildlife Service

TEA–21 1998 Transportation Equity Act for the 21st Century
VI Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

TES threatened and endangered species

TMDL total maximum daily load

USACE U.S. Army Corps of Engineers

U.S.C. United States Code

USDA U.S. Department of Agriculture

USDA–APHIS USDA–Animal and Plant Health Inspection Service

USFS USDA Forest Service

USGS U.S. Geological Survey

WG wage grade (employment type)

WSA wilderness study area
CHAPTER 1—Introduction

The U.S. Fish and Wildlife Service (Service) has 

developed this volume 2 of the final comprehensive 

conservation plan and environmental impact statement (FEIS) for the Charles M. Russell National 

Wildlife Refuge and the UL Bend National Wildlife Refuge. This companion document for the FEIS 

includes the following components:

■ copies of comment letters from Federal, State, 

and local government agencies and organizations 

with Service responses

■ comments from individuals with Service 

responses

■ summaries of form letters received

■ copies of the transcripts from seven public hearings

The draft comprehensive conservation plan 

and environmental impact statement (DEIS) was 

released to the public for review and comment on 

September 7, 2010. A 60-day comment period for the 

document closed on November 16, 2010, and was extended through December 10, 2010. In addition, the 

Service held seven public hearings in fall 2010.

Throughout the comment period, the Service 

received more than 1,700 comments from 919 individuals (primarily emails, letters, and oral comments 

during public meetings), 53 letters from Federal, 

State, and local government agencies and organizations, and 19,627 form letters. 

The purpose of this volume is to address the substantive comments received on the draft CCP and 

EIS. As defined by National Environmental Policy 

Act (NEPA) compliance guidelines, comments are 

considered substantive if they:

■ question, with reasonable basis, the accuracy of 

the information in the document;

■■ question, with reasonable basis, the adequacy of 

the environmental analysis;

■■ present reasonable alternatives other than those 

presented in the environmental impact statement;

■■ cause changes or revisions in the proposal.

This volume contains the Service’s responses to 

substantive comments on the DEIS. Comments, 

with responses, are divided into two chapters. Chapter 2 has copies of the comments made by Federal, 

State, and local government agencies and organizations that qualify as tax-exempt, nonprofit entities. 

Chapter 3 summarizes the comments made by the 

public or other entities.

In compliance with the spirit of the Privacy Act 

of 1974, it is the policy of the U.S. Fish and Wildlife 

Service, Mountain–Prairie Region, to not publish the 

names, addresses, or other personal information of 

individuals (agencies, business, and organizations are 

excluded). Rather than print every letter from individuals and redact (black out) all personal information, and because many of the comments are similar 

in nature, the Service has summarized the general 

nature of the comments received and tracked the 

number of individuals that expressed each general 

comment. This is also consistent with the Paperwork 

Reduction Act of 1995.

The Service responded to each substantive comment. Where appropriate, the text of the FEIS has 

been revised to address comments. Some of the 

comments do not meet the definition of “substantive” (as defined previously), and those are shown 

as “comment noted.” In some instances, the Service 

has opted to respond to specific nonsubstantive comments where the public displayed a strong interest. 

CHAPTER 2—Comments from Agencies 

and Organizations

The Service received formal comments from the following Federal, State, and local government agencies and organizations:

1. U.S. Army Corps of Engineers (USACE), 

page 4

2. Bureau of Land Management, Malta, p. 8

3. Bureau of Land Management, Miles City, p. 10

4. U.S. Environmental Protection Agency, p. 14

5. National Park Service, p. 31

6. Fort Peck Tribes, p. 33

7. Montana Fish, Wildlife and Parks, p. 34

8. Montana State Historical Preservation 

Society, p. 38

9. Fallon County Commissioners, p. 39

10. Fergus County Commissioners, p. 40

11. McCone County Commissioners, p. 57

12.Petroleum County Commissioners, p. 63

13.Phillips County Commissioners, p. 65

14.Powder River Commissioners, p. 78

15. Missouri River Council of Conservation 

Districts, p. 79

16. Garfield County Conservation Districts, p. 93

17. McCone County Conservation Districts, p. 97

18.Phillips County Conservation Districts, p. 103

19.Valley County Conservation Districts, p. 105

20.American Prairie Foundation, p. 108

21. Backcountry Hunters and Anglers, p. 110

22. Blue Goose Alliance, p. 114

23. Central Montana Wildlands Association, p. 118

24.Defenders of Wildlife, p. 138

25. Gallatin Wildlife Association, p. 146

26. Helena Hunters and Anglers, p. 148

27. Hellgate Hunters and Anglers, p. 150

28. Lund Law (represents counties), p. 152

29. Maryland Ornithological Society, p. 179

30. Missouri River Stewards, p. 184

31. Montana Association of Oil, Gas, & Coal 

Counties, Inc., p. 187

32. Montana Audubon, p. 188

33. Montana Farm Bureau, p. 193

34. Montana Mountain Bike Alliance, p. 197

35. Montana Petroleum Association, p. 199

36. Montana Pilots Association, p. 202

37. Montana Seaplane Pilots Association, p. 203

38. Montana Stockgrowers Association, p. 204

39. Montana Wilderness Association, p. 207

40. Montana Wildlife Federation, p. 216

41. Mosby Musselshell Watershed Group, p. 221

42. National Wildlife Federation, p. 223

43. National Wildlife Refuge Association, p. 236

44.Phillips County Livestock Association, p. 246

45.South and North Phillips County Cooperative 

State Grazing District, p. 251

46.The Nature Conservancy, p. 252

47.The Wilderness Society, p. 256

48.Western Watersheds Project, p. 270

49.Wildlife Conservation Society, p. 290

50.World Wildlife Fund, p. 292

51.Yellowstone Buffalo Foundation, p. 299

52.Yellowstone Safari Company, p. 300

53.Yellowstone Valley Audubon Society, p. 301

Letters from these agencies and organizations 

are shown in the following pages. Beside each reproduced letter is the Service’s response, numbered to 

correspond to specific comments in the letter. The 

Service reviewed all supporting attachments; however, such attachments are not included in this volume.
Comment 

Number Response Comment number Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana

44 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana 1–1. the habi- Service and comments. The for your Thank you 1–1. tat and wildlife it protects for the American public benefits from our relationship and how we manage public lands. We acknowledge your expectation that management of the refuge should provide quality opportunities and experiences than generally available on other public lands managed for multiple use purposes.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 5

Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana

1–2.

1–3.

1–4.

It is unfortunate USACE staff were unable to participate 

-

cause it resulted in substantial changes in big game objectives from an earlier draft of the DEIS. Based on public comment and a reevaluation, we revised the big game objectives in the FEIS to meet or exceed objectives in established Montana 

game 

management plans. In cooperation with all partners, we will 

-

tat management plans tailored to local habitat conditions and 

- There was an error in the DEIS and the objective for big

bighorn 

and 

Comment noted. 1–2. 

1–3. at the August 2010 meeting with cooperating agencies be

Parks (MFWP) big ildlife, of Fish, W Department 

develop specific abundance and composition objectives in habi

for objective D4 The DEIS wording for 

. There was no intent to limit the 

-

years old. 

potentials.

1–4. horn sheep was supposed to state a minimum average age of 6.5 sheep (page 89) is also in errortotal population on the refuge to around 225, but rather to set a population objective of around 225 for the currently occupied sheep habitat in hunting district 622. The FEIS clarifies that additional bighorn sheep may be established in suitable habitat. See also response 1–3.
Comment 

Number Response

6 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana 1–5.

-

The FEIS clarifies the objectives and connects the imSer

other 

the 

enhance 

a place 

of mission “The 

the refuge is 

than 

and protect, 

important 

them. 

conserve, 

with 

to others 

, biomass, or cover of many species 

species 

with 

bird 

fish, wildlife, and plants and their habitats for the continuing 

American people.” Thus, 

more not are populations 

working 

portant benefit of the that supports a variety of plant life as well as habitat for fish and wildlife. Habitats are an essential necessity for wildlife. 

plant 

is 

1–5. vice Sentinel plant species, but they do provide an early warning indicator of habitat degradation for other plants and for wildlife. 

There are several hundred species of plants on the refuge. 

, frequency

focal 

Thus, the densityis immeasurable. Also, changes in population numbers would not be readily detectable due to the tiny numbers and vast 

e will measure demographic information at sampling needed. W

randomly selected remnant sites to determine if the plants are 

. This can be accomplished and would be doing well or poorly

immediately useful for adaptive management. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 7

Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana

1–6.1–7.

1–8.

-

We made several changes to the proposed wilderness 1–6. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

Comment noted.

Comment noted; see also responses for 1–3, 1–4, and 1–5. 

-

-

1–7. 1–8. We plan to emphasize habitat as the essential necessity of di

ildlife includes thou

and invertebrate animal species. Plants are 

verse and abundant wildlife populations. Wsands of vertebrate equally important and are the foundation of vibrant habitat. We revised the FEIS to better connect the important focal species, particularly bird species, with the habitat objectives.
Comment 

Number Response

8 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #2: Bureau of Land Management, Malta, Montana Specific monitoring protocol for upland sentinel species is 2–1. 

being developed (DEIS page 191). In the development of those

does use the historical plant monitoring efforts, the Service 

community information in the Natural Resources Conservations Service (NRCS) ecological site descriptions and manyother sources of information (strategies for upland objectives

e principally employ this information D1–9 DEIS page 68). W

in sentinel species designation and management rather thansimilarity indexes.

We believe that effective communication can bridge some 2–2. 

of the differences between how our agencies approach riparian

, given that we have different mis- health monitoring. However

sions; monitoring protocols will not be the same.

2–1.2–2.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 9

Letter #2: Bureau of Land Management, Malta, Montana

2–3.2–4.

The developing monitoring standards for the refuge will 2–3. 

incorporate many of the same methods and considerations outlined in TR 1734–6 including current plant community versus desired or potential, overall plant cover and distribution. We use the historical plant community information in the NRCS ecological site descriptions and many other sources of informaThe riparian health assessment has a well established tion. 2–4. monitoring effort in place (DEIS pages 196–197). By using consistent and well-established trend data, the refuge can track effects of management changes on riparian habitats. The detailed descriptions of the studies are provided through the citations in the bibliography (the papers by Paul Hansen, DEIS page 441).
Comment 

Number Response

10 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #3: Bureau of Land Management, Miles City, Montana 3–1. - threat

-

that 

e do not propose realignment of any BLM fences. A 

boundary

wildfire 

order 

any 

ens to burn off the refuge, and there is not a goal or objective 

- to allow any fire to burn off of the refuge and affect neigh

boring land. Reference DEIS pages 80–82 and note several 

Fur-

- inuse 

would 

lands. 

would 

that 

to neighboring 

tensive suppression strategies where perimeter areas are threatening to burn of the refuge.” Refer to DEIS page 82 

, 

areas 

Service “The 

delineate to 

be appropriate for various fire management options. See re

executive 

suppresses 

impacts 

states, 

actively 

81 page 

cooperators 

mitigating 

with 

references to 

DEIS 

working 

thermore, about sponse 3–4 about predator control.

the be constructed on 

Service 

W

may 

The 3–1. 

3–2. fence but no alterations are planned or can be made to existing BLM fences and their locations. There would be no effect to BLM lands. Refer to the responses that follow for other detailed responses to your comments.

3–2.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 11

Letter #3: Bureau of Land Management, Miles City, Montana

3–3.3–4.3–5.3–5.3–5.3–5.3–5.3–6.3–7.3–8.3–9.

There appears to be confusion with the take of coyotes 

as part of an established hunting season versus the action of 

-

-

predator control. Along with a signed compatibility determination, a refuge must have an approved hunting season for 

ildlife Refuge System 

Act of 1997. (Improvement Act) established six 

core wildlife-dependent recreational activities, one of which is hunting. An established hunting season on coyotes is in line with that legislation. Predator control simply for the reduction of populations is not compatible with the mission of the Service because all predators are a vital part of a functioning ecosystem. Specific control measures may be carried out on a caseThese appear to be comments on the discussion about 

our strategic plan for climate change, which was finalized in 2010, and not on specific actions in the DEIS. Although the 

no 

-

Comment noted. 3–3. 

3–4. the take of coyotes. The National WImprovement by-case basis if wolves enter the landscape (DEIS page 99). 

effects, 

so there is 

cumulative 

sentence first cited the was cited, we 

3–5. paragraph confusion where the statement came from. 

be could there that correct are ou Y 3–6. 

but the reality is that cumulative impacts would be negligible. 

. While wildlife can migrate 

Nonetheless, we have addressed this in the FEIS.

’s scoping comments The Service disagrees. The EPA 3–7. 

suggested we identify the analysis area, and they did not take issue with it in their comments on the DEIS. The primary purpose of the analysis area was to identify the primary areas where we looked for foreseeable activities outside the decision area and where any direct, indirect, or cumulative impacts con

, most effects would occur within the 

nected to our actions would occuroutside the boundaryanalysis area.
Comment 

Number Response

12 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #3: Bureau of Land Management, Miles City, Montana 3–8. The provision for livestock grazing under Executive 

- Order 7509 specifically states that it can only occur if it re

mains compatible with the primary purposes of the refuge. As outlined by the establishing legislation, the primary purpose 

and 

-

-

grouse 

, the natural 

of sharp-tailed 

depend 

a maximum number 

pronghorn and secondary non predatory species in such numbers as to maintain a balanced wildlife population. Subsequent 

priority of wildlife on national 

and Fish 

species. 

(U.S. 

the on 

policy integrity 

would 

reinforced the 

biological 

efforts 

The 

recovery 

s habitat.

legislation has 

refuges. 

sustain to 

ildlife Service [FWS] 2001), which resulted from the pas

Additional 

is wildlife Wsage of Improvement Act, directs that livestock grazing on refuges is permissible only when prescribed in plans to meet wildlife or habitat management objectives and only when more natural methods, such as fire or grazing by native herbivores, cannot meet refuge goals and objectives. Generallyprocesses of fire and grazing by native herbivores meets the management objectives for wildlife and habitat on the refuge.3–9. A primary objective in the CCP is to increase the resiliency of the refuge’
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 13

Letter #3: Bureau of Land Management, Miles City, Montana

3–10.

3–11.

3–12.

3–13.

3–14.3–15.3–16.

species (particularly threatened 

- and endangered) are a priority on the refuge. Any paleontolog

-

ers on the refuge would have to consider and mitigate potential impacts to achieving the primary refuge purposes and would 

There 

-

tool that can 

for the various 

-

states, 

-

research

-

-

and 

years.” 

universities 

a 

15 

listed current and 

by done 

and plant 

work 

All wildlife 

archaeological 

be outlined during the permitting process.

“over read 

and grazing is 

to 

were disclosed 

FEIS 

targeted 

grazing 

the e updated 

objective 

livestock of 

We updated the FEIS to read “over 15 years.”

W

or 

The DEIS made no statements that any specific ar

3–10. ical 3–11. 3–12. has not been a comprehensive bird monitoring program on the refuge. Information about lek locations for sharp-tailed grouse, greater sage-grouse, and other species is detailed in chapter 4.3–13. eas would not be grazed outside of any exclusion areas. If an 

Grazing”) 

is 

be used (in this case, improving and maintaining prairie dog habitat), then grazing could be implemented by prescription. 

effects The 

alternatives in the DEIS (“Chapter 5—Environmental Conse

“Livestock under DEIS (page 264 

quences,” page 269).

The 3–14. 

“With defined habitat objectives, livestock grazing can stimulate new plant growth and increase the vigor of plant communities.” The FEIS has more discussion about the benefits of prescriptive grazing.

See response 3–4.

The list provided is an example of current conservation 

and 

3–15. 3–16. organizations that may seek a partnership on land conserva

While we projects. management 

identifiable tion likely partnerships, there certainly could be others.
Comment 

Number Response

14 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–1. 4–1. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 15

Letter #4: Environmental Protection Agency, Helena, Montana

4–2.4–3.4–4.4–5.4–6.4–7.

The Service notes your concern about open roads and 

motorized use. Based on those comments and others we have revised alternative D in the FEIS to include additional seasonal closures to improve hunting opportunities and to provide 

-

to assess any water quality impairments that may be related to refuge land management practices as part of an effort to 

Montana 

-

e added discussion in the FEIS on water quality im

pairments on some of the drainages mentioned in your letter. There is an extensive list of objectives and strategies that would improve the health of riparian areas on the refuge. In 

- addition to the list in the DEIS (pages 73–74), we have pri

oritized some of the restoration work and added a strategy 

with comply would activities fire 

W

4–2. additional security habitat on the refuge.4–3. improve riparian health on the refuge. 

prescribed All 

smoke management regulations. In the FEIS, we added this requirement to the elements common to all alternatives (DEIS page 32).

We made several changes to the proposed wilderness 

4–4. 4–5. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

The modifications made for the FEIS should address 4–6. 

many of your concerns.

Comments noted. 4–7. 
Comment 

Number Response

16 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–8. Thank you for your comments. 4–8. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 17

Letter #4: Environmental Protection Agency, Helena, Montana
Comment 

Number Response

18 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana

4–9.

Road management for the Charles M. Russell Refuge 4–9. 

received considerable public comment, as referenced in the DEIS. We considered all perspectives in preparing the FEIS and final CCP and the balance for vehicular access was a hybrid version of road management that incorporated elements 

- from each alternative. In the FEIS, we made some modifica

tions to the preferred alternative to address displacement of wildlife off some key ridges during hunting season.

We recognize the effects of roads and motorized uses and 

concur that there are increasing demands for recreational 

iewing Area or 

, most of the roads are lightly 

TVs on refuge roads or using 

. Nonetheless, we 

use in some areas on the refuge like the Elk V

winter

popular fishing sites. Howeverused outside of hunting season and much of the refuge remains inaccessible during the winter months or during wet periods. In addition, there has historically been good compliance with our regulations for operating A

in the to access the lake snowmobiles 

recognize that more data is needed to assess transportation management and its impacts on refuge resources and that a transportation plan should be developed before making any substantial new recommendations about road closures. Closing a road in one place can result in unintended impacts and consequences elsewhere.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 19

Letter #4: Environmental Protection Agency, Helena, Montana

4–10. e actively 

are TVs, 

-created routes. W

including A vehicles, 

There are no additional user

All travel. off-road illegal 

4–10. enforce required to stay on numbered routes. Overall, there is good compliance by users on the refuge.
Comment 

Number Response

20 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–11. ater Quality We made a number of changes in the FEIS, which should 4–11. address your comments and questions by adding a section in “Chapter 4—Affected Environment” under “W impaired surface waters men- to elaborate on the Monitoring” tioned and referenced the MDEQ website as a source for more information. There are currently no known abandoned mine sites located within the refuge boundaries. Livestock grazing is not permitted in most riparian areas found on refuge lands.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 21

Letter #4: Environmental Protection Agency, Helena, Montana
Comment 

Number Response

22 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–13.

- e have included an assessment of current water qual

s boundaries that are within our control (FEIS chapter 

quality 

e plan to 

-

. A properly functioning riparian 

. 

s 

etland Research Program, Ecological Solutions 

. Paul Hanson were contracted to inventory and 

-

-

water 

alteration in 

cover

the 

high vegetative 

quality by reducing 

See response 4–4 about the use of smoke management 

e have noted or added the literature that 

A, 

anessa Hinkle concurred with our 

.

of Much 

maintaining 

Monitoring”). Quality ater 

help improve water 

and 

, Ms. V

W

W

4–12. ity impairments, likely causes, and percent of area within the refuge’

“4.2 4, 

impairments originate upstream, off the refuge. Wcontinue to work with our neighbors and within our boundaries to improve water qualityarea will streamside vegetation The FEIS includes an extensive discussion of riparian health on the refuge. From 1995 to 1997, the University of Montana’Riparian and WGroup, and Drassess riparian health. In 2009, the assessment was repeated and it was determined that riparian health improved greatly since 1995. (A more indepth analysis of the findings is in chapter 4, “4.3 Livestock Grazing and Riparian Monitoring”). The Service plans to coordinate with the MDEQ on any impoundment removals to assure consistency with total maximum daily loads and water quality restoration plans. 

4–13. plans on all fires. Wyou reference into the FEIS. In discussions we had with EPRegion 8 in Denverassessment that the smoke management plan addresses your concern, and a visibility analysis is not necessary

4–12.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 23

Letter #4: Environmental Protection Agency, Helena, Montana

4–14.

In the FEIS, we have additional notations about smoke 

management in chapter 3 (“3.2 Elements Common to All Alternatives”) which should address your concerns. Additional 

the in added was quality air to impacts potential 

4–14. 

discussion of 

FEIS.

The Service is a member of the Montana/Idaho Airshed 

Group. The air shed group is composed of State, Federal, tribal, and private member organizations who are dedicated to the preservation of air quality in Montana and Idaho. These agencies work cooperatively to prevent negative smoke effects 

objectives. management land to accomplish fire using while 

Each member who conducts a prescribed burn in Montana is required to have a burning permit issued by MDEQ. Under 

the refuge will all alternatives, the use of prescribed fire on 

continue to follow protocol and guidelines established in the Montana/Idaho Airshed Operating Guide (MIAG 2010).

Critical smoke concerns are addressed in each individual 

prescribed burn plan. These plans are very thorough and discuss specific smoke issues, measures to reduce impacts, downwind receptors, and smoke vector maps. The Service obtains clearance from the Montana/Idaho Airshed Group before conducting any prescribed fire. An air shed coordinator and meteorologist evaluate each prescribed fire information air shed by air shed to anticipate cumulative smoke effects. Key 

type direction, 

other 

and 

any 

speed wind elevation, burn 

of burn, proximity to smoke-sensitive features, anticipated 

pertinent 

be cannot effects 

and burners, 

conducted if negative 

nonmember 

information made available at the time of the decision. A 

not is 

include 

burn 

from 

factors impacts prescribed mitigated. 
Comment 

Number Response

24 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–15. See response 4–5.

We added your recommendations for best management 

4–15. 

4–16. practices in the FEIS.

4–16.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 25

Letter #4: Environmental Protection Agency, Helena, Montana
Comment 

Number Response

26 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–17. We already employ many of the suggestions for reducing 4–17. transportation of weeds onto the refuge, but have added some of your suggestions to the discussion in the FEIS.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 27

Letter #4: Environmental Protection Agency, Helena, Montana

4–18. - We added the suggestion of increasing more riparian ar

, funding and 

4–18. eas to proper functioning condition. Unfortunatelylegal rights to historic flows drives our ability to fully restore some of these areas.

Climate change is a major area of emphasis for the Ser- 4–19. 

vice. (DEIS page 7).

4–19.
Comment 

Number Response

28 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana 4–20. The FEIS has more information about our sentinel plant 4–20. work, including additional monitoring data and references e are in the process of working with ecologists, to reports. W statisticians, and experts in other scientific disciplines (DEIS page 67) to develop monitoring protocols. In the FEIS, we clarified that monitoring protocols would be peer reviewed in accordance with our quality guidelines. Monitoring data will be described and tribes the with relationship available on request. our value e W 4–21. 

our consultation efforts including what we learned from our discussions with them (DEIS pages 239 and 354). We have reached out several times to the tribes during the process and heard from one tribe during the comment period for the DEIS (letter #6).

4–21.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 29

Letter #4: Environmental Protection Agency, Helena, Montana

4–22. None of the actions in the DEIS will cause an adverse 

e discussed the 

327) and 

access. 

DEIS (page 

or low-income populapublic impact on 

in the 

which regulates harvest and 

e have incorporated this response 

to livestock permittees 

little would have 

Montana, 

road closures 

the State of 

4–22. effect on human health and the environment. Wimpacts expanded the discussion in the FEIS. While there are certainly families within the analysis area that are low income or even poverty level, our habitat and wildlife management actions will not disproportionately impact minorities tions. For example, we do not charge for public use activities, and We discussed the factors that could determine the impact of livestock production on the refuge (DEIS page 326). 

While the tribes would like to see increased opportunities 

for tribal hunting, those are issues that have to be addressed through licensing (DEIS page 239). Winto the discussion of the effects on environmental justice in the FEIS.
Comment 

Number Response

30 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #4: Environmental Protection Agency, Helena, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 31

Letter #5: National Park Service–Intermountain Region, Denver, Colorado

5–1.

5–2. -

Thank you for your comment.

The Service agrees that there should be careful consider

5–1. 

5–2. ation of visual and audible impacts near the Lewis and Clark 

rail. We have added more description about National Historic T

the siting of any energy facilities and have included a picture of the existing turbine at the Lewistown headquarters building depicting its small footprint (FEIS chapter 4).
Comment 

Number Response

32 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #5: National Park Service–Intermountain Region, Denver, Colorado 5–3. The trail name was corrected to its full name in the FEIS. Thank you for your comments. 5–3. 5–4. 5–4.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 33

Letter #6: Fort Peck Tribes, Poplar, Montana

6–1. Thank you for your comments. The Service appreciates 6–1. 

the input by the Fort Peck Tribes. 
Comment 

Number Response

34 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana s input in developing the ratios for The Service appreciates MFWP’ DEIS and agree that the objectives in the DEIS and FEIS are 

productivity

male-to-female achievable. For the last 10–20 years, 

both mule deer and elk have averaged substantially above the 

Several comments were received about big game 

management for natural and diverse age structures to 

support quality big game hunting, viewing experiences, and to be consistent with the natural ecological processes theme of alternative D. Many commenters expressed that hunters 

generally 

Public 

and , 

, hunting 

not refuge 

Montana. 

the on 

eastern 

experience 

in 

conditions, 

levels proposed in the DEIS.

lands on other public 

expect found comments questioned why the big game objectives proposed in the DEIS were lower standards than have been achieved in the past, and in some cases, lower than objectives in approved MFWP plans. In response to public and agency comments on the DEIS, big game objectives were adjusted in the FEIS to assure that big game management on the refuge meets or exceeds objectives in approved State conservation plans.

In accordance with national policy striving to the extent 

practicable to achieve consistency with State management objectives and regulations, refuge-specific abundance and population composition objectives may be established through stepdown habitat management plans and will be 

habitat 

quality unique, 

to regional 

a 

7–1. tailored other considerations. Those objectives will consider naturally functioning ecosystem processes, biological integrityopportunities, and quality of recreational experiences. 

7–1.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 35

Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana

generalization 

- that a shorter mule deer hunting season on portions of the ref

uge has been the cause of increased hunting pressure. Based 

s hunter survey information, patterns in the number 

of mule deer hunters in the Missouri Breaks and surrounding areas have been variable. The number of mule deer hunters has steadily increased throughout the Missouri Breaks and surrounding areas since the late 1990s, as has the mule deer 

A requirements, the CCP planning process 

e note that MFWP 

-

-

ated effects of management with an emphasis on providing for public and economic uses and less on wildlife. Comment letters from many individuals, nongovernmental organizations, and 

-

e agree with MFWP that hunter harvest is generally 

the primary factor affecting the abundance of mature males in 

296) 

, but overall the impact on hunting 

-

other agencies supported the objectives and management ap

, no take 

-

oppose the big game objectives in alternative B, but it explores and evaluates an emphasis focused on abundant wildlife populations and less on public or economic uses. Similarly, 

-

objectives proposed under alternative C explored and evalu

and 

(page 

levels, 

e look to existing State regulations on which 

e agree with 

DEIS 

the 

the 

harvest 

support 

in 

not 

comment 

does data 

but 

available 

on MFWP’population.proaches in alternative B. 

populations, 

The 

must explore a range of alternatives. W

trends, and 

the 

status population 

o satisfy NEP T

W

game 

s concerns on mountain lion monitoring and expect the 

7–2. 7–4. 

Federal law prohibits take of all wildlife on national wild

7–3. big was taken out of context, which stated that limiting harvest rates could be necessarywould be negligible. 7–5. life refuges, unless specifically authorized. Currentlyof furbearers or mountain lions is permitted on the refuge. To open those species for public harvest, preparation and approval of a new hunting package is required. After internal review and approval of a proposal, public input is solicited before a final decision is made. Each new hunt package must include justification, monitoring. Whunt packages are developed for consideration. WMFWP’results of ongoing research, and future collaborations, will lead to a joint management and conservation of mountain lions.

7–2.

7–3.

7–4.

7–5.

7–6.

7–7.
Comment 

Number Response

36 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana have to would refuge on the wolves public take of Any 7–6. follow the same development and approval of a new hunt pack- e clarified this in the 

-

age, as referenced in response 7–5. WFEIS. In addition, we recognize the role MFWP has in manag

, we also have a responsibility ing resident wildlife. However

for managing wildlife within the refuge and will work with MFWP in on this issue.

Greater sage-grouse has been identified as a focal species 7–7. 

in the FEIS and will be monitored. When the draft CCP and EIS was written, the determination on the sage-grouse listing had just been published. The guidance that the National Wildlife Refuge System (Refuge System) received from the Service’s national sage-grouse coordinator about the public harvest of sage-grouse is that hunting is not an issue provided that habitat remains in good condition and populations are healthy. In areas where populations have declined, it may be sensible to close the season. Conditions could vary across 

- national wildlife refuges. On the refuge, sage-grouse popula

. Harvest levels likely 

, influence on population dynamics. In the 

tions are generally robust and healthyhave limited, if anyabsence of new information, we will adopt State-recommended harvest management strategies for sage-grouse. This was updated in the FEIS. 

Access is open to all hunting recreationists in proposed 7–8. 

wilderness areas, along with everywhere else on the refuge except the 1,200 acre elk viewing area and a small administraildlife Station. In compli-

, motorized ilderness Act and national policy

tive area around the Sand Creek Wance with the Waccess is not allowed within proposed wilderness areas. We are unaware of any data showing road or proposed wilderness area management on the refuge has caused greater elk depredation on private lands or overbrowsing of important shrub species and would be interested in reviewing the data used to support 

Charles M. Russell Refuge 

that generalization. 

Road management on the 

received considerable public comment, as referenced in the DEIS. Many expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open additional 

7–8.7–9.

7–10.7–11.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 37

roads, primarily for hunting access and game retrieval. Others 

e considered all felt that any closure was unacceptable. W

perspectives on road management in finalizing the preferred alternative and the balance for vehicular access was a hybrid version that incorporated elements from each alternative.

We made several changes to the proposed wilderness 

alternatives after considerable review from the public and others. Slight changes were made to the acreage under 

DEIS. In in the errors to mapping D due B and alternative 

addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness 

Comments noted.

We look forward to continued collaborative and cooperaarea. 7–9. 7–10. 

tive work on aquatic species.7–11. Thank you for your comments.

Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana
Comment 

Number Response

38 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #8: Montana Historical Preservation Society, Helena, Montana 8–1. Thank you for your comments. The Service will continue 8–1. to consult on undertakings found in Section 106 of the National Historic Preservation Act and will consult on the proposed sensitivity model. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 39

Letter #9: Fallon County Supervisors, Baker, Montana

9–1.

-

The Service disagrees that the DEIS should be with- 9–1. 

drawn for further analysis. In the FEIS, we have clarified that only the U.S. Congress can make a withdrawal order permanent, but we see no impact on the human environment 

The refuge. by advocating for a permanent withdrawal on the 

benefits of such a withdrawal on the biological resources and special areas designations are referenced in the FEIS chapter 5 and further clarified in chapters 3 and 4), specifically about the extension of the 20-year withdrawal. Also, we are not aware of any active mining or exploration that has occurred on the refuge; therefore, we do not believe there is direct, indirect, or cumulative impact on the socioeconomic environment 

locatable withdrawal for a permanent of seeking a result as 

minerals on a national wildlife refuge. The primary purpose of the refuge is to protect wildlife values. Seeking a permanent 

- withdrawal is consistent with the mission of the Refuge Sys

tem and the primary purposes of the refuge. 
Comment 

Number Response

40 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 41

Letter #10: Fergus County Commissioners, Fergus County, Montana

This plan lacks significant scientific data. You are basing your decisions on a single study instead of researching 

additional studies that might have opposing findings.

The counties can’t support Strategies For Partnerships C1 – C4 & D1 – D5 – Develop management procedures 

that will benefit livestock operations and select wildlife species because the 

manage

ment you 

have in this plan in no way is going to benefit livestock permittees. The counties would support 

partnerships on Alt A1 – A3.

Pg. 419 J. Neher Duffield – socioecono

mic impacts of Valley and Phillips counties prepared for the

Prairie Foundation by Bioeconomics inc.

Economic data is not complete. The data prepared for the Prairie Foundation was used but the counties were not 

consulted.

The six counties 

met with USGS once. At that meeting they stated that they would come to the individual 

counties and talk with the county commissioners to gain better knowledge of the economics of the counties. That never happened.

The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet 

four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.

Private Land

Pg. 191 No mention of private lands under the “State and Private Lands” caption.MFWP has indicated that less than 50 percent of the wildlife habitat is within the CMR boundary. There are 

areas on the south side of the river which the CMR has less than 15 percent of the habitat. With 

wildlife numbers at their current levels and if permitted to expand, the majority of these gameani

mals are going to be impacting private lands.

Any change to grazing allotments with private lands within them would greatly affect the private landowner and 

their private property rights.

Minerals

Mineral development should be included in both Alternatives B and D on a case-by-case basis, taking into consideration accessibility, type of mineral extraction, opportunity for 

revenue to offset the cost of refuge management to the taxpayers, amount of disturbance or lack thereof to the habitat and/or wildlife, etc. Research into each development proposed 

must be accurate as to actual disturbance and not politically acceptable “science”.

10–1.

10–2.

10–3.10–4.10–5.

10–6.

10–7.10–8.10–9.

The comment does not provide information as to the 

, what data was not scientific, or offer examples 

-

-

-

e 

e did not receive further communication or 

-

, the 

-

-

10–1. page, the studyof other studies that should have been reviewed. 

It is not clear the exact reasoning for the opposition to 

alternatives C and D. When the plan is carried out, livestock permittees who can adjust their operations and work with the refuge in achieving habitat objectives would benefit.

The U.S. Geological Survey (USGS) consulted numer 10–3. 

ous sources in conducting the socioeconomic analysis. Several observations from the counties were cited in the DEIS (page 251). In July 2011, we provided the counties with emails and data sources used by USGS in the economic analysis and offered a willingness to expand further discussions of the affected environment if there was data that was left out. Wgave the counties until August 15, 2011, to provide us with additional data. Wdata on this topic. The sources USGS used were cited extensively in the document including data from Federal, State, and local agencies, as well as private landowners. Additionallysocioeconomic analysis went through extensive peer review before the release of the DEIS.

Although individual meetings with the county commis

local community meetings. attend all staff did USGS 

10–4. sioners did not occur following the initial meeting with the six counties, The information gained from these meetings, combined with additional background data and research, provided a strong foundation for the socioeconomic analysis. One of the most respected economists on livestock grazing from the University 

aylor, wrote the section on the livestock 

s policy for meeting the Data 

. D. T yoming, Dr

10–2. of Wgrazing analysis.

In a review of the Service’ 10–5. 

Quality Act (Information Quality Guidelines, FWS 2011a), the guidelines affirm the importance of disseminating and present

e consider all requests to correct 

information following its guidelines and work with the author of the material in question. Of interest in the comment is the 

the Data Quality violates in DEIS 

ing quality information. W

that the data implication 
Comment 

Number Response

42 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Act and is not supported by credible science; the guidelines state that the burden is on the requester to show what infor- mation needs correction as well as to the type of modification being sought. It is also up to the requestor to show supporting et, there is no specificity in the implication made , no explanation of why the information is incorrect, or how it should be corrected. For clarification, integrity refers to the security and protection of 

-

information as opposed to how it is used in a scientific sense. 

e inadvertently left out the acreage for private lands in 

the DEIS (page 191) and modified the title in the FEIS. How-

, we did identify the acreage of private lands elsewhere in 

and 168–169, 

acknowledged the impacts that could occur for some permittees (DEIS pages 319 and 326–329). This discussion has been expanded further in the FEIS. None of the actions in the CCP and EIS prevent access to existing inholdings within the 

It is unclear what the statement, “less than 50% of the 

,” means. All land 

- charac

e suspect the 

(about 40,000 acres), pages 

reference meant the refuge comprises a relatively small and 

-

. Those hunting districts contain 

evidence. Yhere. There is no page number

W 10–6. 

everthe DEIS on page 26 refuge.10–7. can variable proportion of administrative hunting district boundarcontinuous wildlife habitat on and adjacent to the refuge. We 

density. 

Over time, these factors would be variable as native ungulates 

, seasons, 

and a variety of other factors. Managing lands within the refuge primarily for native wildlife should result in fewer 

In the DEIS upland objective D4 (page 66) there is 

a provision to work with permittees in developing habitat management plans so they can make adjustments in their 

toward 

its 

or 

on 

wildlife habitat is within the CMR boundary

depending habitat, wildlife considered 

teristics and management use by humans. W

distribution wildlife 

ies as established by MFWP

on 

clarified this in the FEIS. 

data no offers letter The 

are mobile and respond to habitat conditions, weather

moving that impact the 

impacts to adjacent lands. 

e acknowledged 

10–8. operations. W

be 

Letter #10: Fergus County Commissioners, Fergus County, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 43

a greater reliance on prescriptive grazing could have a major effect on some permittees (DEIS pages 326–331). However, as noted in the compatibility determination (DEIS page 372), for grazing to be considered a compatible activity on the refuge, it needs to be a comprehensive prescriptive program. 

We are pursuing an extension of the mineral withdrawal 10–9. 

for Charles M. Russell Refuge on the locatable minerals (UL Bend Refuge has a permanent withdrawal) and would advocate for a permanent withdrawal of minerals. Only the U.S. Congress can designate a permanent withdrawal. We have 

- clarified the information in the FEIS about mineral develop

ment.

Letter #10: Fergus County Commissioners, Fergus County, Montana
Comment 

Number Response

44 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana Grazing Pg 330 All of the alternatives would likely result in negligible to minor cumulative benefits to local communities by increasing income, jobs and (under B&D) additional opportunities for recreation and tourism. Pg 333 There would be some increases in the level of visitation, particularly in C&D but they would be minor to moderate differences over existing conditions. Pg.330 Alt D would generate $2

million 

more in local output, 25 additional jobs and $569.6 thousand 

more in labor income compared to Alt A (excluding grazing operations)

Pg. 324 proposed staff for Alt D includes all current staff positions and seven additional positionsConsidering that they are saying that there will be some increases in visitation the only economic increase would be the seven additional positions for the CMR. They are not looking at impacts from grazing operations.Pg. 330 Under existing conditions (Alt A) at 34% of the refuge would be prescriptive grazed and this 

would not change unless units become available through the sale to a third party, or when

habitat conditions dictated a change.

Pg. 64 & 65 Upland C3- continuing the practice of holding grazing permits as ranches sell their land to 

outside parties.

Pg. 33 Sum

mary Alt A (current)– There would be gradual 

move to prescriptive grazing only when units 

beca

me available or habitat evaluations are co

mpleted and when prescriptive grazing is identified 

as necessary to meet wildlife or habitat objections.

There already is an option to move to prescriptive grazing as necessary to 

meet wildlife and habitat objections.

The counties object to pushing to have 75% of the Refuge under prescriptive grazing with no data to back it?

Pg. 190 Livestock numbers on the Refuge are currently lower than any ti

me in the past century.

740,000 acres potential grazing, 409,849 (annual), 252,706 (prescriptive), 77,475 (non-grazed)

The document should have scientific data that proves that non-grazed and prescriptive grazing is any better condition than the grazed allotments. There is no scientific data shown in this document that you will 

meet your 

objectives by re

moving cattle or going to prescriptive grazing. There is no documentation of the differences 

between grazed units that have recovered verses non-grazed or prescriptive grazed units.Pg. 39 Summary of Alt B – within 4-7 years a prescriptive livestock grazing plan would be developed 

for 50-75% of the refuge.

Pg. 63 Rationale for Alt B – the service esti

mate that only 75% of the refuge would convert to 

prescriptive grazing.

Pg. 52 Summary of Alt D – Generational transfer of permits would continue; however, grazing would 

be on a prescriptive basis.

Pg. 67 Rationale for Alt D – This alternative calls strongly for the return of the evolutionary forces of 

fire and herbivory (grazing by wildlife) that shaped this landscape during the past 6,000 years.

10–10.

The economic analysis considered impacts from grazing 10–10. 

operations and direct and secondary effects (DEIS table 35, page 317). Economic increases would occur from more refuge jobs and increased visitation (DEIS page 326). There would also be increased spending by the additional refuge employees as well as increased spending by nonlocal visitors. As prescriptive grazing is implemented across 50–75 percent of the refuge, the level of grazing could be reduced from the current level, but it could increase for short periods. Operators who could change their operations to help the refuge meet its wildlife objectives would benefit. Changes to refuge grazing would not 

, but it could affect in- be significant for the six-county economy

dividual ranches with refuge grazing permits (DEIS page 326). 

Though the no-action alternative enabled us to progress 

-

10–11. 

toward improving forage resources, particularly where grazing 

is absent, the annual grazing program does not meet Service policies, nor is it a comprehensive wildlife management program. In addition continued implementation would not achieve many of the goals set for the project (DEIS page 322). The 

a resource to be was meant noted that it specifically 1986 EIS 

management plan and not a comprehensive management plan. There are both legal mandates and substantial literature ree 

-

garding the compatibility and use of prescriptive grazing. W

added more information to the FEIS on these topics.

The direction cited in the Improvement Act instructs 10–12. 

us that if we are going to use livestock grazing, it needs to be 

(FWS resources wildlife of benefit the prescriptively for done 

2000a, FWS 2001). The data describing differences between annual grazing and ungrazed conditions is described in the DEIS (pages 191–193). In the FEIS, we clarified and added information on our legal mandates and data collected on various 

-

sites on the refuge as well as more information about how pregrazing of prescriptive use The work. would scriptive grazing under this plan would differ depending on the wildlife species, weed species, native plant species, or specific habitat condition the prescription is designed to affect. Rest would also be a condition that is prescribed to benefit wildlife, and the CCP would facilitate these kinds of prescriptions. 

10–11.10–12.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 45

Letter #10: Fergus County Commissioners, Fergus County, Montana

Total ungulate effects and fire effects on plant communities would be measured with diagnostic species (sentinel species).When declining trends are found or when competition for resources results in habitat damage, livestock numbers would be reduced or eliminated before wild ungulates. The Service esti

mates 

it could convert about 75% of the refuge to prescriptive grazing due to the need to add or eli

minate fences. If funding and resources per

mitted, more of the refuge could convert to 

prescriptive grazing over 15 years.

This plan is aimed at making it non beneficial for permittees to graze cattle within the CMR boundary. You are 

going to a system that has not been proven for any length of time (agreed to by Barron Crawford October 12,2010) and are setting goals that will be unattainable. You are going experiment to see if your plan will work at the per

mittees expense. You will never be able to get the amount of some forbs back that you plan considers 

successful implementation of objectives.You already have the option to change to prescriptive grazing when habitat conditions dictated a change?

Pg. 329 If per

mittees no longer desired to retain their grazing per

mits, the Service would work with

DNRC to assu

me permits, providing funding exists.

Pg. 187 The reduction in population of (palatable forbs) is likely due to constant selective grazing fire 

suppression and competition from less palatable native species or invasive species. Palatable forb 

populations historically benefitted from fire and periods of less grazing pressure.• The document states that econo

mic uses would be limited when they are injurious to 

ecological process.

Any wording that says likely due or the possibility of is not based on scientific data. The counties object that

your are speculating on what might happen.Pg. 373 Grazing monitoring cost: refuge personnel currently spend approximately 25 to 35 percent of 

their ti

me issuing permits, monitoring for trespass livestock and habitat conditions.

Pg. 373 No monitoring costs for recreational huntingPg. 373 No monitoring cost for campingPg. 371 ATV and snowmobiles – The cost of monitoring the use of the refuge is the most expensive cost 

we incur.

The counties question the accuracy of this. There is no way that 25-35 percent of the entire CMR staff’s ti

me is 

spent on grazing allotments with ATV and snowmobiles most expensive and no time on hunters or campers. We request documentation of the accuracy of this state

ment be implemented in the 

plan or sent to the counties.

Pg. 331 However, considering that the refuge currently supplies less than 1% of all AUM’s in the region, the regional cu

mulative effect of the refuge 

management actions, when combined with the economic effects of 

other land management changes would be negligible.

MFWP has indicated that less than 50 percent of the wildlife habitat is within the CMR boundary. There are 

areas on the south side of the river which the CMR has less than 15 percent of the habitat. With wildlife numbers at their current levels and if permitted to expand, the majority of these gameanimals are going to be on private and BLM lands. The land they occupy have substantially higher AUM’s than CMR lands. This would indicate that the 

management on both private and 

BLM lands is adequately 

maintaining range and habitat conditions without prescriptive grazing.

10–13.10–14.10–15.10–16.

12, 

taken 

-

October 

were 

from transcripts public the of 

Barron Crawford’s remarks 

a review In 

it appears that 

10–13. 

2010, 

out of context (Lewistown transcript pages 38–40). Mr. Crawford stated, “the sentinel plant concept is not a new concept.” The concept is new for this refuge, and he emphasized that the Service is supposed to manage for wildlife habitat and not range. The intention is not to return to historical condi-

, and , heterogeneity tions, but to promote biological diversity

resilience.

The plan is not aimed to make it not beneficial for 

permittees to graze on the refuge (DEIS upland objective D4, page 66). It would bring the refuge into compliance with the Improvement Act, our compatibility policy, and 

is used grazing that by ensuring policy integrity biological 

to accomplish habitat and wildlife objectives. There is considerable science on the use of prescriptive grazing. In the FEIS, we added more information and citations in the upland habitat section. Refer to comment 10–11 about the use of 

A document is a 

common practice in describing what impact could occur in the 

, projections are 

- based on a combination of professional opinions made by read

ings of scientific literature, past experiences, and from field observations. The observation made in the DEIS (page 187) is 

professional the and 

The compatibility determination in the DEIS (page 

entire refuge staff spends 

25–35 percent of their time on these activities, but the field personnel who are directly responsible for managing these operations spend about that much time. Administrative staff, 

, and others also 

-

prescriptive grazing in alternative A.

The use of the word “likely” in a NEP 10–14. 

future. While there is not absolute certainty

refuge the on work 

opinions of several biologists (DEIS page 350).

infer that the 

field 

mean to 

, the deputy project leader

direct on based 

10–15. 373) did not the project leaderspend considerable time in administering the grazing program. This is clarified in the FEIS.

See response 10–7. 10–16. 
Comment 

Number Response

46 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana Pg. 14 You say that AUM’s will not be addressed, however throughout this document everything is being blamed on livestock grazing and justifies the reduction of AUM’s. Throughout the entire document you refer to grazing continually. Therefore the counties believe that grazing should be included in the Pg. 11 1.8 Significant issues to address. Pg. 68 Strategies for Upland D1-D9 - If sentinel plants populations continue to decline after elimination of livestock grazing, explore opportunities to promote periods of rest or abandonment for sensitive areas. If sentinels continue to decline due to herbivory pressure, work with MFWP to reduce the numbers of large ungulates throughout the Missouri River Breaks to levels lower than objectives in MFWP’s management plans. Counties oppose your Alt B & D and support Alt C Pg. 64 C-1 – includes fencing for better livestock distribution, water development, rotational grazing, and other management techniques designed to improve range condition. C-2 – support surveys and scientific data to measure residual cover. C C-4 – support using fire where physical features allow for efficient use of fire as 

management tool.

C-5 – support because coordination will occur with local ranchers and federal agencies.

C-6 – support evaluating process of prescriptive grazing and measuring success through a 

co

mprehensive monitoring program. This will provide scientific data to develop adaptive management changes 

if sentinel plants continue to decline.

Under Alternatives B, C and D, there is much discussion about prescriptive grazing. What is not understood by the Service is that this action would generate a negative economic benefit to 

per

mittees and counties. Per

mittees require a stable grazing allotment on which they can depend 

from year to year. 

Without that insurance, their operations will not be sustainable and they will 

have to sell part or their entire herd. This situation would become markedly critical during years 

of drought. As a result, counties also, are impacted negatively through loss in taxable revenue and potentially, population.

- We included livestock grazing as part of the larger sig

page (DEIS and wildlife management habitat issue of 

10–17. nificant 11, first bullet under habitat and wildlife management). This 

the same as 

strategy is used for meeting habitat objectives. 

Upland objective D5 is 

326–330) acknowledged the negative 

-

Comment noted. 10–18. 

upland objective C–6. 

The DEIS (pages 

arrange in their operations for future grazing needs. can 

10–19. effects increased prescriptive grazing would have on some permittees (DEIS page 326), and we added to this in the FEIS. 

e would work with permittees (DEIS page 66) during the W

development of the habitat management plans to see where they Every effort will be made during that process to give ranchers time to plan for their operations. Livestock operators who are willing to work with us in achieving the wildlife and habitat goals and objectives will benefit.

10–17.10–18.10–19.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 47

Letter #10: Fergus County Commissioners, Fergus County, Montana

Weeds

• In regard to the management of noxious and invasive species under Alternative B, it is stated 

that the Service would collaborate with others to co

mbat invasive plants on the shorelines. It 

must be noted that for many years travelers through lands managed by the Service have observed first-hand that there are 

many species of noxious weeds recognized as such by 

various Montana departments and agencies, as well as the Bureau of Land Manage

ment that 

occur in many parts of the Refuge other than just the shorelines.

• It has also been the case that observations of the after-effects of fires, appearing in the first 

new re-growth have been an abundance of noxious weeds. This should be considered and weighed carefully when any 

management decision is made using prescribed fire and should 

be taken into consideration in Alternatives B and D.

• The Service, historically, has been notorious for allowing invasive species (noxious weeds)

to flourish on CMR managed lands. This has beco

me a serious reverse economic i

mpact to 

counties and adjacent landowners. Nowhere in the CCP has this reverse econo

mic impact 

been measured or noted.

• One of the most serious examples of inattention on the part of the Service has been the 

unchecked proliferation of Canada Thistle. This noxious weed has spread withoutrecognition by the Service of the devastation it causes to rangeland for both the wildlife and 

livestock.

Pg. 83 Continue to work with the Service’s invasive species strike team, county weed boards, neighbors and conservation organizations to maintain and update mapping of weed infestation.

• 

Pg. 83 Continue to work with the Service’s invasive species strike team, county weed boards, neighbors 

and conservation organizations to maintain and update mapping of weed infestation.

We would like the word continue removed. Nothing has been done to work with the county’s weed boards on invasive species. Should read work with.

10–20.10–21.10–22.10–23.10–24.

The DEIS (pages 199–200) references what is known 

about invasive species and the efforts to reduce their spread. 

- In all of the action alternatives (B, C, and D), we would in

crease our efforts to combat invasive and noxious weed spe-

- e agree that any management decision to use pre

. In the first regrowth 

after fire, noxious weeds do not occur unless the land has a history of overgrazing by livestock or other disturbance resulting in high populations of weeds already present. For example, Japanese brome (a noxious weed), is replaced by a healthy 

- a pre

species 

after 

the 

years few of plants a native collection 

W

diverse 

10–20. cies. 10–21. and scribed fire. It is not possible to generalize on the response of 

on 

scribed fire should be weighed carefully

depends It fire. or prescribed wildfire to weeds 

of weed, the species of native plants present, the soil, moisture conditions before and after the fire, the time of year the fire 

-

occurs, the intensity of the fire, and more. 

See response 10–20 about action alternatives. Saltcedar 10–22. 

has been pointed out as the primary invasive species of concern during the planning process. It flourishes below the high water mark along the shoreline of Fort Peck (DEIS page 200). 

- spe invasive other disturbance, been has there where areas In 

cies have also flourished. In other disturbance areas, invasive 

, the refuge has been on 

-

been 

-

species have also flourished. Furtherthe receiving end of invasive species from adjacent lands. 

outbreaks of Canada thistle occur in dis

has not extent the shoreline. Their 

of the Most 

areas along 

10–23. turbed mapped (DEIS page 199).

Invasive species control projects continue to be ac 10–24. 

complished around the refuge. The Service has worked with county extension agents, the Mussellshell River Working Group, USACE, BLM, and others (DEIS page 200).
Comment 

Number Response

48 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana Water Pg. xvii Wildlife populations, both on and off the Refuge, are affected by water quality and access to water. Livestock grazing has degraded habitat, particularly near water sources. wildlife are also using the water sources. Again you blame livestock grazing for all the degrading of the habitat on the Refuge. The counties support more water resources to disperse cattle and wild ungulates to mitigate the damages of habitat near water sources. Most of the wildlife and habitat are off the Refuge, which is outside your jurisdiction. The plan lists no scientific data on the water resources that have been damaged outside the CMR boundary. This document needs to show monitoring data of water sources off the refuge. Pg. 72 Riparian Area and 

Wetland B2 (same as D) – Over 15 years remove all reservoir and stock 

ponds that do not support species of concern and adhering to any permit require

ments, initiate 

restoration of the natural hydrology of the drainage. Determine if additional stock ponds are needed to meet requirements of target species.

Oppose removing all reservoirs and stock ponds that do not support species of concern. Wildlife would be 

concentrated on the river causing damage to the habitat and hunter conflicts. The counties support more water resources to disperse cattle and wild ungulates to mitigate the damages of 

habitat near water sources. It must be noted that stock ponds notably benefit migratory waterfowl.

Support C-2 Riparian Area and 

Wetland.

Pg 40 &57 Water quality is 

mentioned throughout on grazing in summary of Alt B & D water quality is 

specifically bla

med on grazing? The plan needs to show data on the effects that prescriptive 

grazing and burning (natural and prescriptive) have on water quality.

There is no information presented as to what water 

of effects 

.

. See response 10–7.

the noted 

We note the counties’ opposition to any stock pond 

-

ildlife does not require human-made impounde 

-

Wfound. 

prescrip

been normally have 

beneficial 

not would 

Comment noted. 

we 

that 

FEIS, 

numbers 

the In 

10–25. resources have been damaged from refuge management. Most of the water resources on the refuge are downstream of the refuge boundary10–26. removal. Looking at potential impacts to migratory waterfowl, we reviewed the national hydrology data set on the number of waterbodies that exist outside the refuge but within the scope of analysis. There are more than 1,200 water bodies (averaging 18 acres) and the overall effect would be negligible for waterfowl. Removal of constructed reservoirs and stock ponds within the refuge will not concentrate wildlife on the Missouri River to any great degree. Once artificial impoundments are removed, prairie stream functions would be restored along with corresponding riparian areas. As riparian areas develop, beaver would naturally return and beaver ponds would become reestablished. Wments (Krausman 2006), and any benefits are often outweighed by the adverse effects caused by concentrating wildlife in areas 

at and 

added information to the FEIS on this topic. 10–27. 10–28. tive grazing on water quality and clarified information about the use of prescribed fire and water quality

10–25.10–26.10–27.10–28.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 49

Letter #10: Fergus County Commissioners, Fergus County, Montana

Roads

Pg. 334 MFWP would like to see the Service reopen a number of refuge roads that have been closed in 

the past, including those within proposed wilderness units.

Pg. 334 The counties are also concerned about a number of issues related to roads and particularly about 

recognizing rights of way under RS 2477 or where they believe they have a valid county petitioned right of way.

While the CCP advises that deter

mining the legal validity of roads within the CMR is outside of the scope of the

CCP and that the Service has no control over determining legality, the Service appears overzealous in discussing the closure of 106 miles of road under Alternative B and 23 miles of road under Alternative D.There are legal procedures involved in closing legally petitioned county roads, which the Service has chosen to ignore. Montana Road Law has been ignored. Before any roads are closed, the six counties insist that Montana Road Law be included in the decisions.The total number of miles closed prior to the CCP should be acknowledged.

The counties are opposed to permanently closing road 315 in Petroleum county. It is presently seasonally closed 

which accomplishes wildlife protection needs.

Pg. 119 The counties support Access C1 – C4, D3 & D4The counties are requesting that language be put in this document that e

mergency services are allowed to use 

closed roads to rescue lost, injured or incapacitated hunters, hikers, bird watchers or others who may be 

miles from an open road.

The counties support additional access for elderly and disabled.

Wildlife/Bison

The Department of Interior Bison Conservation Initiative, October 28, 2008, states Charles M. Russell National wildlife refuge is in the early stages of considering devoting part of the refuge to bison habitat with adjoining 

landowners including the BLM.This document contradicts everything that the CMR has stated about introducing bison on the refuge.Pg. 63 Rationale for Alt B is the only mention of bison is that Murie identified evidence of earlier 

occupation of bison.

Pg. 92 The International Union for Conservation of Nature established the Bison Specialist group that 

was charged in 2005 with developing a “North American strategy for Bison Conservation”. That comprehensive plan is expected to be released in the near future and will provide scientifically 

based guidelines for proponents interested in restoring bison at an ecologically functional scale.

The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet 

four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.

Reintroduction of Big Horn Sheep has been discussed under Alternatives B, C, and D, with the addition of “promoting private conservation easements and conservation incentives to benefit species diversity or restore extirpated species and cooperating with MWFP to consider other species reintroductions or expansion of species when there is adequate habitat to support the species” included in Alternative D. In plain language, the latter is interpreted to include the

Wildlife/Bison cont.

10–29.10–30.

10–31.

10–32.10–33.

10–34.

10–35.

are that 

W

should be 

roads 

. policy

the identify to is CCP 

necessary for habitat and wildlife management and public 

- uses. This is consistent with the guidance found in the Im

agree e planning Service’s 

that old rights-of-way disputes are important issues, but the 

e work with local 

governments to address rights-of-way as we did in Petroleum County (DEIS page 231). Given there is substantial variance 

by the six counties, these issues 

e have incorporated in the FEIS and CCP a number of 

suggestions that the counties made. For example, we included winter access for ice fishing and improvements to the Knox 

.

In defining the no-action alternative (alternative A), we 

reviewed the existing guide map (last revised 2002), earlier guide maps, old files, wilderness studies, and other information we could find on refuge roads. In doing so, we have not found any inconsistencies in our interpretation of the no-action alternative as it is portrayed in the DEIS. Past road closures, some dating back more than 30 years, are not relevant to the 

ith 670 miles of roads open on the 

, there are few 

to changed 

its wildlife 

838 is road 

accomplish 

with 

e can 

junction 

W

the 

the of 

and 

role 

Act 

315 from its 

The 

CCP is not the tool for resolving them. W

records kept 

provement in the addressed at the county level. 

Road 

10–29. 

W

Ridge road, as suggested by Fergus Countyno-action alternative. Wrefuge and boat access from the lake and riverplaces on the refuge that cannot be accessed within a mile of existing access. 10–30. a seasonal closure in the FEIS. objectives through a seasonal closure while allowing seasonal 

Through communication and cooperation, whatever 

access. 10–31. actions are needed to rescue a visitor will be accommodated. Under all alternatives, the Service will carry out management actions through cooperation and collaboration with Federal, State and local governments. Existing facilities should be universally accessible and conform to accessibility standards; however, as noted in the DEIS (page 232), there are hundreds of miles of open refuge roads that are available for hunters of all abilities in addition to the accessible hunting blind.
Comment 

Number Response

50 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana been bison 

-

and 

The 

-

-

have 

in play 

habitat 

there 

should 

for 

process 

consider 

, the refuge is not in 

refuge 

planning 

the 

bison 

role 

Comment noted.

the 

what 

early From 

management. Many citizens and stakeholder groups have expressed a desire for bison restoration, and this was identi

to 

wolf reintroduction. or 

issues significant 

olves and bison are specifically dis

in 

about conversations 

the of 

. We clarified the discussion in the FEIS under this 

one fied 

the lead role in any bison restoration proposal. This message 

extends to include 

10–32. any stage of devoting considerable refuge habitat to bison, although there is one permittee on the south side of the refuge that has grazed bison for years.10–34. The comment makes no reference to any specific data.

We disagree that this summary statement in the DEIS 

58) 

10–33. 

as 

wildlife. Since the Service began drafting alternatives, with county representatives participating in those discussions, we have been consistent in our message that the State should play did not change in the DEIS. Currently10–35. (page statement refers to conservation efforts at a landscape level through partnerships. Wcussed in the DEIS (pages 92–94 and 99). There are no proposals to reintroduce wolves, but it is possible they may arrive naturally and refuge management needs to prepare for that possibilitysection. See also response 10–33 about bison.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 51

Letter #10: Fergus County Commissioners, Fergus County, Montana

reintroduction of free-ranging bison and/or wolves and a serious threat to the continuation of the agricultural economic base of the entire plains counties of Montana. An in-depth economic

study of the impact of introducing free-ranging bison and/or wolves on the CMR must be completed prior to any such action.Even though the MFWP and others have invested time and effort trying to produce brucellosis free bison herd as stock to establish herds managed for conservation and ecological purposes elsewhere, the counties would request that bison are brucellosis free beyond a reasonable doubt.

Pg. 93 The Service would cooperate with MF

WP, BLM, DNRC, conservation organizations and others

to conduct the necessary biological, social and econo

mic research to deter

mine the feasibility of 

such a proposal. (Bison restoration)

It is inappropriate to name partners such as the World Wildlife Fund, the American Prairie Foundation, and the International Union for Conservation of Nature, whose vast ability to amass funds extends to many other countries other than the United States. It is estimated that

80% of the members of such organizations are not citizens of the U.S. Because the Refuge is owned and maintained by United States taxpayers under the federal estate, world-wide plans for the future of our refuge to include free-ranging bison must not be based on outside (residents from other countries) objectives. Therefore the counties oppose the wording oflisting individual conservation groups and referring to the counties and neighboring landowners as others.

We oppose bison on the CMR. Bison are not currently considered a wildlife species outside of Yellowstone

Park and therefore should not be addresses as such.

Phillips county passed a resolution 2010-08 that states all buffalo in Phillips County will be considered 

domestic livestock, regardless of origin.During public meetings orchestrated by the MFWP, vast numbers of residents of the six counties within which the CMR exists, attended to voice their adamant opposition to the idea of freeranging bison because of their concerns that their livelihood would be negatively impacted.

Pg. 88 Rationale for Alt B reference to Murie’s observations from 1935 – 75 years ago when he 

believed that the west end of the refuge could support 2,000 -2,500 elk and he predicted that mule deer would continue to flourish in the pine uplands.

Things change in 75 years and this is another reason this plan is setting unattainable goals. The plans places a 

lot of emphasis on one person’s observations to do this. Murie’s observations were based on beliefs and not scientific data.

Pg. 88 Cooperation with landowners and wildlife 

managers is necessary to ensure that big game

populations are healthy to support wildlife dependent recreational activities.

They want the landowners to cooperate for the benefit of wildlife but are making it non beneficial for livestock 

per

mittees to graze on the CMR.

Counties support mountain lion hunting on the CMR

e collaborate with a wide array See response 10–33. W 10–36. 

of national and international partners to protect wildlife. For example, the DEIS (page 6) describes international partnerships to protect birds. The purpose of the reference in the DEIS (page 92) was to provide context for the interest in bison 

Comments noted.

restoration.

None of the alternatives rely solely on Murie’s observa10–37. 10–38. 

tions and report. It is true that many things have changed during the last 75 years, many of them to the benefit of wildlife and wildlife habitat. Much of his report focused on big game species and most are now more widespread and abundant than the conservative estimates and distribution he envisioned during his assessment, which he made during the bleak times just after the Great Depression and Dust Bowl era of the “dirty thirties.” Olaus Murie was an accomplished naturalist and pioneer in the field of wildlife biology who did ground-breaking 

e used his report, field research on a variety of mammals. W

based on site visits throughout the refuge and conversations with numerous residents, as an expert reference of the time. 

Comment noted. Comment noted. 

10–39. 10–40. 

10–36.10–37.10–38.

10–39.10–40.
Comment 

Number Response

52 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana Fire Pg. 333 Alt C would not promote fires natural role while B & D would. All alternatives would protect private property. Considering the geographic size and shape of the CMR. Fires have a significant chance of leaving the CMR and burning adjoining lands. Pg. 329 Under all alternatives the Service would extend agreements that are already in place for aggressive fire suppression activities on DNRC lands. Should state aggressive fire suppression on private lands. Pg. 331 The use of prescribed fire would improve plant vigor and health, but there could be so

me temporary losses of soil. Major wildfires could lead to severe soil erosion.

The plan needs to show data on the effects that burning (natural and prescriptive) have on water quality.Pg. 39 Alt B – Wildfire would be used to protect, maintain and enhance resources and where 

possible, be allowed to function in its natural ecological role.

Pg. 57 Alt D – The service would restore the natural fire regime through increased use of prescribed 

fire to increase the viability of fire dependent plant species.

Pg. 81 Wildfire C-2 support but add when the potential exists to threaten state or private properties.

With federal budgets being strained how can you have a plan that will greatly increase the 

manage

ment costs 

by implementing prescribed fires? It is not fiscally responsible to implement a plan that can’t be carried out because of budget restraints.

Executive Order 13514 signed by President Obama in Section 9. Recommendations for greenhouse gas 

accounting and reporting subsection (iii) consider and account for sequestration and emissions of greenhouse gases resulting from Federal land management practices. Contrary to what was stated by Barron Crawford, there is no evidence that carbon from prescribed fires is sequestered in the ground. The study by TH DeLuca was paid by a biased group and does not meet the criteria.

The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS

meet four ele

ments: a.) quality; b) utility (referring to the usefulness of the data for its 

intended purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.

This was added to the discussion of unavoidable adverse 10–41. 

effects in the FEIS.

We agree and have clarified this information in the 10–42. 

FEIS. The goal for fire management specifically states we will 

-

protect values at risk (DEIS page 30).

More information was added about fires and water qual 10–43. 

ity in the FEIS. 

It is not unusual for an action alternative to require 10–44. 

substantial additional money to implement, and this was noted 

is funding All 1). (page DEIS the in and cover inside 

In the FEIS, our policy for adhering to Executive Orthe on based on annual appropriations. 10–45. 

der 13514 (565FW1) was added to the section under climate change in the DEIS (pages 84–85 and in appendix D). All of the 

consistent are 84–85) (pages DEIS the identified in suggestions 

with the new Executive Order. We note Fergus county’s opposition to the study by DeLuca, but we stand by the study. Under all alternatives, we would be required to adhere to Executive Order 13514. Carrying out any specific action in the alternatives will negligibly affect climate change, and all alterfor carbon sequestration natives will provide many benefits due to the large amount of vegetated land the refuge provides. It is not clear from the comment as to why you see the DeLuca and Aplet study as biased or not meeting the criteria under the 

e note that the DeLuca and Aplet study Data Quality Act. W

Fergus County refers to was part of a larger discussion under the rationale for climate change (DEIS page 86). None of the actions were specifically derived from that study, nor was it used in the analysis under “Environmental Consequences” in chapter 5. See response 10–5 about the Data Quality Act. 

10–41.10–42.10–43.10–44.10–45.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 53

Letter #10: Fergus County Commissioners, Fergus County, Montana

Wolves/Predators

Pg xxiii Predators would be managed to benefit the ecological integrity of the refuge.

The counties support a year round coyote hunting season.

Pg. 99 Alt B & D We oppose no hunting season for wolves on the Refuge. You should work with the 

FWP in setting a season. Again you not taking into account how the decision you make on the refuge is going to affect the adjoining landowners and the economies of the counties. No hunting of wolves will also negatively affect the wildlife on and off the refuge.An in-depth economic study of the impact of allowing wolves on the CMR must be 

completed prior to any such action.We oppose wolves on the CMR.Phillips County passed a resolution 2003-03 stating that “wolves are deemed an unacceptable species” and prohibit the presence, introduction or reintroduction of wolves within the boundaries of Phillips County.Phillips County passed resolution #2003-02 “unacceptable species” prohibiting the presence, introduction or reintroduction of any animals which pose a threat to public, health, safety and livelihood within the boundaries of Phillips County and shall take any and all actions necessary to protect its citizens.

Fergus County passed resolution #6-2003 deeming wolves an unacceptable species

Climate Change

Pg. 84 the Great Plains is projected to experience increases in temperature, evaporation, and drought 

frequency. The average temperature is expected to increase 2-4 degrees F by the year 2020 in the plains. The final CCP will be in place in 2020.

A great deal of the CCP is devoted to researching the CMR’s response to climate change. The scientific community has become increasingly divided on this issue. While we agree 

that climate change is taking place, just as the sun comes up every morning, it is our contention that not enough valid scientific data exists to preclude that during the fifteen year projected lifespan of this CCP, anyone is going to observe any great change in the habitat or subsistence of any of the wildlife currently populating the CMR. Less emphasis should be put on researching climate change.

All of the climate objectives came from the one publisher, U.S. Global Change ResearchProgram (Karl et al 2009).

Executive Order 13514 signed by President Obama in Section 9. Recommendations for greenhouse gas 

accounting and reporting subsection (iii) consider and account for sequestration and emissions of greenhouse gases resulting from Federal land management practices.

10–46.10–47.10–48.10–49.10–50.

-

sys s ecological of the refuge’ resilience 

Comment noted.

s role.

We have modified the language in the FEIS to reflect 

10–46. 

10–47. the State’

We do not have plans to reintroduce wolves. 

As noted in the DEIS (page 7), response to climate 

10–48. 10–49. change is a top priority for the Department of Interior and the Service. The objectives reflect this priority (DEIS pages 

- 84–86). Improving the 

tems (DEIS page 66) is key to managing the refuge in a changing climate. The focus would be on research, monitoring, and management of the following: carbon sinks and sources; black 

-

-

carbon; climate sentinel plants; dependent animals; and ecological processes and the food web that uses them, beginning with pollinators (DEIS page 86). 

We added the new Executive Order in the FEIS. The 10–50. 

U.S. Global Change Research Program coordinates and integrates Federal research on changes in the global environment. It was mandated by the U.S. Congress in the Global Change Research Act of 1990 (Public Law 101–606), which called for 

- pro research States United integrated and “comprehensive a 

gram, which will assist the Nation and the world to understand, assess, predict, and respond to human-induced natural processes of global change.” 
Comment 

Number Response

54 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana Environmental Consequences Pg. xxiv The degree of effect was quantified using known numeric or 

modeled esti

mates or where 

extensive monitoring or research provided the information. Where sufficient numeric information was not available, qualitative or relative assessments were 

made using scientific 

literature or professional field experience.

This plan should not be based on estimates or literature that is based on scientific data from areas outside of the

CMR.

The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet 

four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.

Wilderness

We support Alternative A - There would be no additions or subtractions to the acreages of the proposed 

wilderness units.

We oppose expanding wilderness boundaries to the edges of open roads or the CMR boundary. This would 

negative impact on the counties economies.

Public comment has indicated the solitude of the area. By expanding wilderness to the edge of the road it will 

take away from the current solitude.

-

The language in the DEIS is consistent with NEPA, 10–51. 

U.S. Department of the Interior (DOI) regulations, the Improvement Act, and our planning policy in using available science when other data does not exist. The comment does 

- inac information is scientific what about specifics provide not 

curate or how it should be corrected. See response 10–5. 

The small expansions of the wilderness boundary would 10–52. 

have negligible effects on access, solitude or the economies of 

e made several changes to the proposed wilder- the counties. W

ness alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

10–51.10–52.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 55

Letter #10: Fergus County Commissioners, Fergus County, Montana

Economics

Pg. 317 Alternative A – one job for every 1,350 AUM’s of livestock grazing

Current level of AUM’s actually used on refuge would generate 14 jobs in local economy(6 counties – Table 35)AUM’s

% Jobs $775,500 of Production $1.5 million total econ output

Fergus 359 1.9 .27 $14,735 $28,500Garfield 6,839 36.2 5.1 $280,731 $543,000Petroleum 468 2.5 .35 $19,387 $37,500Phillips 4,849 25.7 3.6 $199,303 $385,500McCone 2,726 14.4 2. $111,672 $216,000Valley 3,631 19.2 2.7 $148,896 $288,000If you look at the figures straight from the CMR, there are definitely more than negligible effects on the counties if the AUM’s were lost.Pg. xxiv While the overall economic effects of any alternative would be positive, implementation of new 

grazing and habitat 

manage

ment approaches in Alt B and D would result in impacts to individual 

livestock permitees.

As stated above the impacts would affect more than just the individual per

mittees. 

Overall i

mpacts of any 

alternatives would not be positive.

Pg. 12 This draft CCP and EIS addresses the following aspects of the socioeconomic issue: Range of 

alternatives and effects of those alternatives on the local economy and community.

From the state

ments in the CCP it is obvious that the actual impacts to the economy and communities is not 

truly understood. Economic data is not complete. The data prepared for the Prairie Foundation was used but the counties were not consulted.

The six counties 

met with USGS once. At that meeting they stated that they would come to the individual 

counties and talk with the county commissioners to gain better knowledge of the economics of the counties. That never happened.

Under Alternatives B, C and D, there is much discussion about prescriptive grazing. What is not understood by 

the Service is that this action would generate a negative economic benefit to per

mittees and counties.

Per

mittees require a stable grazing allotment on which they can depend from year to year. 

Without that 

insurance, their operations will not be sustainable and they will have to sell part or their entire herd. This 

situation would become markedly critical during years of drought. As a result, counties also, are impacted negatively through loss in taxable revenue and potentially, population.The data on visitor numbers is questionable. It is 

mathe

matically impossible to have the number of visitors that 

you are referencing in the docu

ment.

10–53.10–54.10–55.

10–56.

See response 10–4. The USGS social scientists met with 

-

the 

-

to related 

Representa

issues 

2008. 

economic 

4, June on 

and 

not available through State and 

See response 10–10. 

social their 

headquarters refuge 

discuss 

the 

more information 

10–53. 

10–54. several of the local county commissioners and representa

to 

at 

tives CCP tives from Phillips and McCone Counties provided copies of fact sheets and suggestions for local contacts at the meeting. The USGS followed up with the local contacts in an attempt to gather national data sources. Krystal Steinmetz from the Bear Paw Development Corporation provided demographic information about Phillips County and the communities of Malta, Saco, and Dodson, but the data were all from existing national and State data sources. Anne Boothe from the Phillips County Economic Growth Council was not exactly sure what she had that was not generated through census materials. The USGS was able to locate additional socioeconomic profiles for the local counties completed by Headwater Economics, Economic Profile System. Databases used for the Economic Profile System county profiles are from national sources: Bureau of the Census including County Business Patterns; Bureau of Labor Statistics; and the Regional Economic Information System of the Bureau of Economic Analysis, U.S. Department of Commerce. To use consistent and the most up-to-date data across the counties, the USGS pulled the most recent demographic and economic county-level data directly from the national and State sources. These data sources were the same as those used in the reports provided by the counties but were more up to date. In July 2011, we provided the counties with emails and data sources 

- used by USGS in the economic analysis and offered a willing

ness to expand further discussions of the affected environment 

until 

e did not 

counties the gave e Wout. left was that data was there 

The DEIS acknowledges the moderate to major impacts 

if August 15, 2011, to provide us with additional data. Wreceive further communication or data on this topic.10–55. to some permittees as greater reliance on prescriptive grazing occurs (pages 326–33). 
Comment 

Number Response

56 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #10: Fergus County Commissioners, Fergus County, Montana

j

seilstadt emai

Laurie Shannon, Planning Team LeaderU.S. Fish and Wildlife Service134 Union BoulevardLakewood, CO 80228ph: (303) 236-4317fax: (303) 236-4792"Life isn't about how to survive the storm, but how to dance in the rain" --Unknown----- Forwarded by Laurie Shannon/R6/FWS/DOI on 08/01/2011 06:51 AM -----

"Carl Seilstad"

<cseilstad@co.fergus.mt.us>

12/01/2010 03:41 PM

To <Laurie_Shannon@fws.gov>

cc <commissioners@co.phillips.mt.gov>

Subject

Laurie,I am sending you these additional comments per our phone conversation on the 24th of November.

As I mentioned to you I do not believe the counties concerns were addressed in the planning process for the CCP.We have opposed the aggressive approach to prescriptive grazing in Alternative D. As it currently stands you have that ability to go towards prescriptive grazing in Alternative A, Pg 330. We outlined this under our comments under Grazing. What we did not put in our comments was that our permittee would be putting cattle in a new pasture without the cattle or their owners knowing where the water sources are. Anyone that raises cattle will tell you until if a cow is not accustomed to their environment their calves will wean at a lighter weight. Having to transport cattle beyond what the permittee is doing now would also be an economic factor. Once these producers gather there their cattle what kind of facilities will there be for loading and transporting them home? If they move into a new pasture is the CMR going to assure the permittee that the fences will hold their cattle, or are you going to make them fence every pasture you force them into. All of these concerns will make economically unfeasible to graze the CMR. If you stayed with Alternative A at least there would be sound science to back prescriptive gazing. We also feel that your economic analysis is incorrect if you take the aggressive approach to prescriptive grazing.The counties met with the USGS at one of the planning meeting and we were told they would get with each individual county to gain better knowledge of the economics of the counties. However you used economic data from the Prairie Foundation the Counties were never consulted.I also suggested that before a final document is released that the cooperating agencies have a final meeting with the CMR CCO planning team.These are just a couple of the issues we brought up in our comments. I would suggest you look closely at not only our comments but the comments submitted by Lund Law as this firm is representing the six counties. We will look to see at that time if our comments were actually used. Thank you Carl Seilstad

s estimates of current visitation figures 

come from a variety of sources including traffic counters, physical counts, and hunter permits. The estimates of increased visitation over 15 years are modest numbers (see previous responses 28–49), and the rationale behind those numbers was explained (DEIS pages 105–107 and 112–114). The comment does not provide facts as to why the data is inaccurate. In the FEIS, we have clarified the information in the DEIS (page 

consistent 

to 

is 

227) about how we estimated visitation numbers.

In the FEIS, we added more discussion about the use 

of prescriptive grazing throughout the document. We acknowl-

- edge there could be important considerations for some opera

tors who are used to turning their cattle out at the beginning of the grazing season. Even under alternative A, we would 

For 

which 

of increased fees 

this. of example 

grazing 

in spite 

good 

prescriptive 

with our legal mandates. It would likely exceed 50 percent 

transport their cattle frequently 

implementing 

ithin the Refuge System, there are many examples of 

operators who 

new pastures based on the requirements of a prescriptive grazing program. These operators find it is worth their while 

refuge 

a 

wildlife 

The refuge’

within 15 years, given the Service has progressed from 0–34 

provides 

percent in 20 years. 

national 

Ranch 

on a 

and transportation costs. In northeastern Montana, many 

Matador 

10–56. 10–57. continue 

W

livestock 

graze to 

livestock operators transport their cattle to other grazing some operators, these would not be insurmountable issues, and some of the concerns raised could be worked out during development of the habitat management plans. 

See response 10–4. 10–58. 

10–59. Thank you for your comments.areas. 

10–57.10–58.10–59.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 57

Letter #11: McCone County Commissioners, McCone County, Montana

Thank you for your comments. The Service has valued 

- toward prescrip

-

s contributions in the CCP.

transition greater 

11–1. McCone County’

We recognize that a 11–2. 

tive grazing from current conditions (34 percent) could negatively affect some permittees (DEIS page 326–331). Even under alternative A, the amount of prescriptive grazing is likely to be closer to 50 percent or greater for more than 15 years, depending on ranch sales or other factors. As stated in 

- the DEIS (page 66), we would communicate with the permit

tees in developing the habitat management plans so ranchers 

grazing needs. The habitat future can make arrangements for 

management plans are where specific prescriptions for a given habitat management unit would be developed.

All of the action alternatives would result in increased 11–3. 

efforts toward reducing invasive and noxious weeds. We will continue to work with cooperators to limit the introduction and spread of invasive and noxious weeds in the refuge, including nearby lands. 

11–1.11–2.11–3.
Comment 

Number Response

58 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #11: McCone County Commissioners, McCone County, Montana

-

e agree that any management decision to use pre-

, but do not agree that

- there is an abundance of noxious weeds in the first new re

growth after a fire, unless the land has a history of overgrazingby livestock resulting in high populations of weeds alreadypresent. Japanese brome, for example, decreases for a fewyears after fire on most sites when a healthy and diverse native collection of plants occurs on the site. It is not possible togeneralize on the response of weeds to wildfire or prescribedfire. It depends on the species of weed and native plants thatare present; soil types; moisture conditions before and after the

fire; time of year the fire occurs; and the intensity of the fire.

e agree that the proliferation of invasive species is an 

important issue, but we disagree that the refuge bears sole re

, which has been pointed 

of concern 

species invasive 

an issue 

scribed fire should be weighed carefullysponsibility for its causation. Saltcedar

many of the local communities as 

has flourished below the high watermark along the shoreline of Fort Peck, but we do not control water levels on the lake 

(DEIS 

-

man-

-

-

mapped 

areas, 

been not has extent 

disturbance 

s ecological systems is key to 

other 

Its 

In 200). 

W

W

page 

11–4. 11–5. out by (DEIS have also flourished.

Most Canada thistle outbreaks occur in disturbed areas 

shoreline. the 

page 199).11–7. Comment noted and acknowledged (DEIS page 220). 

Response to climate change is a top priority for the De

11–6. along 

11–8. partment of the Interior and the Service (DEIS page 7). The objectives reflect this priority (DEIS pages 84–86). Improving the resilience of the refuge’aging the refuge in a changing climate (DEIS page 66). 

We note the counties’ opposition to any stock pond re 11–9. 

moval. There are more than 1,200 water bodies (averaging 18 acres) within the scope of analysis and the overall effect of stock pond removal would be negligible for waterfowl. Removal of human-made reservoirs and stock ponds within the refuge would not concentrate wildlife on the Missouri River to 

11–4.11–5.11–6.11–7.11–8.11–9.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 59

Letter #11: McCone County Commissioners, McCone County, Montana

any great extent. Once artificial impoundments are removed, prairie stream functions would be restored along with corresponding riparian areas. As riparian areas develop, beaver 

-

-

e 

-

-

-

rebecome 

ildlife does not require human-made impound

ments (Krausman 2006) and any benefits are often outweighed by the adverse effects caused by concentrating wildlife in areas 

Wfound. 

There are no plans to introduce wolves or bison onto the 

See response 11–10. From early in the planning process 

there have been conversations about what role the refuge 

-

-

-

stake

address

and 

would 

been 

ponds 

normally 

and beaver 

have not 

naturally return 

would that 

would established. W

numbers at and 

have added information to the FEIS on this topic. 

citizens Many management. bison in play 

11–10. 

refuge. 

11–11. should holder groups have expressed a desire for bison restoration; this was identified as one of the significant issues to consider under habitat and wildlife. Since we began drafting alternatives, we have been consistent in our message that the State should play a lead role in any bison restoration proposal that goes forward. This message did not change in the DEIS. Currently, the refuge is not devoting considerable refuge habitat to bison, although there is one permittee on the south side of 

e cooperate and partner with a wide array of national 

e agree that they are important is

the refuge that has grazed bison for years. and international partners to protect wildlife (DEIS page 6, describes international partnerships to protect birds). The discussion in the DEIS (page 92) provides the context behind the interest in bison conservation.

Comment noted. 

The role of the CCP is to identify roads that are neces

11–12. 11–13. 

11–14. sary for habitat and wildlife management and public uses. This is consistent with the guidance found in the Improvement Act and our planning policy. Wsues, but the CCP is not the proper tool to resolve them. For 

in County Petroleum with worked have we 

W

example, 

11–10.11–11.11–12.11–13.11–14.
Comment 

Number Response

60 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #11: McCone County Commissioners, McCone County, Montana ing rights-of-way (DEIS page 231). Given there is substantial variance in the records kept by the six counties, these issues o the extent that the counties have provided suggestions about what is needed for habitat, wildlife, and public uses, we have incorporated their suggestions in the CCP and EIS. For example, we included allowing seasonal access for ice fishing as suggested by Fergus County and improvements to the Knox Ridge road. Road 315 in Petroleum County will remain open as a seasonally are several examples with the counties for , as noted in the DEIS (page 232), there are hundreds of miles of open refuge roads that are available for hunters of all abilities in addition to the accessible hunting blind. The small expansions of wilderness areas would have a negligible effect on access, solitude, or the economies of the 

-

road maintenance, and those arrangements would continue.

Through communication and cooperation, whatever 

actions are needed to rescue a visitor will be accommodated. Under all alternatives, the Service will carry out management actions through cooperation and collaboration with Federal, State and local governments. Existing facilities should be universally accessible and conform to accessibility standards; 

The economic impacts of revenue sharing were dis

e currently buy inholdings 

-

should be addressed at the county level.

T

opened road in alternative D. There 

about agreements in the DEIS 

Comment noted.

discussed 11–15. however11–16. 11–17. counties.11–18. cussed in the DEIS (page 313). Wfrom willing sellers and this would not change under any al

e have clarified this in the FEIS. The location ternative. W

and timing of future land acquisitions are based on unforeseen opportunities and market conditions. Therefore, changes in 

-

-

property tax revenue and revenue sharing payments of poten

tial future land acquisitions would be speculative at this time. For refuge lands, there is a refuge revenue sharing payment. 

T) do not apply to refuge lands 

- con counties’ the 

Payments in lieu of taxes (PIL

e understand W313). and 14 pages (DEIS 

cerns on the amount of these payments in recent years. Our records show McCone County was paid $1606 in fiscal year 2001. 

11–15.

11–16.

11–17.

11–18.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 61

Letter #11: McCone County Commissioners, McCone County, Montana

-

-

We are pursuing an extension of the mineral with 11–19. 

drawal for locatable minerals on the Charles M. Russell Refuge (UL Bend Refuge has a permanent withdrawal). Under several alternatives we will advocate for a permanent witha permanent can designate Only the U.S. Congress 

e have clarified the information in the FEIS 

drawal. withdrawal. Wabout mineral development and its potential. 

We cooperate with several national and international 

-

in interest the context behind the provides (page 92) 

11–20. partners to protect wildlife (DEIS page 6, describes international partnerships to protect birds). The discussion in the DEIS bison restoration.

11–21. Thank you for your comments.

11–19.11–20.11–21.
Comment 

Number Response

62 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #11: McCone County Commissioners, McCone County, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 63

Letter #12: Petroleum County Commissioners, Petroleum County, Montana

12–1.12–2.12–3.12–4.12–5.12–6.

The mineral estate for locatable minerals was withdrawn 

for 20 years on Charles M. Russell Refuge and permanently on 

e are seeking another 

20-year mineral withdrawal on the Charles M. Russell Refuge and further clarified this in the FEIS. Although we are seeking a permanent withdrawal, only the U.S. Congress can make this 

In the FEIS, we changed road 315 to a seasonally closed 

road from the junction of road 838 to its end. This will improve late summer and winter wildlife habitat and at the same time 

- popu

-

within, 

e have 

, the 

a 

future 

cannot 

of 

to 

CCP 

, we refuge boundary

inholdings from willing sellers when there is available funding. 

. This would 

access 

currently buy 

in revenue 

willing sellers 

deficit 

and 

the UL Bend Refuge (DEIS page 173). W

the road for vehicle 

ater Resources Development Act of 

2000 (Enhancement Act) (Public law 106–541) gives the Ser

timing and 

any 

FEIS 

from 

location 

make up 

of 

lar fishing area along the shore.

The 

to 

Comment noted.Comment noted.Comment noted.

use 

ithin the authorized 

itle VIII of the W

for 

acquire lands to 

refuge using funds derived from the sale of 

authorized 

determination. land acquisitions are based on unforeseen opportunities and 

The 

W

be the same regardless of the alternative selected. W

payment. 

FEIS. 

e understand the concerns of the counties 

seasonal 

authority 

the in this 

for 

scheduled 

the 

or adjacent to, the cabin sites within the executive order boundarymarket conditions. Wabout declining revenue-sharing payments. Ultimately

is Congress 

12–1. 12–2. 12–3. 12–4. 

12–5. allow 12–6. Also, Tvice clarified U.S. payments between the amount available in the fund and the amount make a commitment to dispose of Federal land elsewhere. 
Comment 

Number Response

64 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #12: Petroleum County Commissioners, Petroleum County, Montana 12–7. - The Service appreciates Petroleum County’s contribu 12–7. tions to the planning process.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 65

Letter #13: Phillips County Commissioners, Malta, Montana

13–1.13–2.13–3.13–4.13–5.

The comment provides no information as to the page, the 

, why it is not scientific, or what other studies should have 

It is not clear the exact reasoning for the opposition to 

alternative C and D. When the plan is carried out, livestock permittees who can adjust their operations and work with the 

- The USGS consulted multiple sources for the socioeco

nomic analysis. The wide variety of data, which were cited extensively in the document, included sources from other FedThe USGS social scientists met with several of the local county commissioners and representatives to discuss their social and economic issues related to the CCP at the refuge headquarters 

McCone 

Counties provided copies of fact sheets and suggestions for 

the 

not 

-

the 

-

-

most up-

-

from 

and 

refuge in achieving the habitat objectives could benefit.

landowners. 

with 

and 

up 

information 

County 

Phillips 

followed 

private 

more 

Phillips 

and local agencies, and 

from 

USGS 

gather 

Representatives 

about 

The 

o use consistent and the 

meeting. 

to 

county-level data directly 

attempt 

the 

an 

information 

and economic 

2008. 

at 

in 

State, 

June 4, 

contacts 

contacts 

demographic 

13–1. 

studybeen reviewed. 13–2. 13–3. eral, on local local available through State and national data sources. Krystal Steinmetz from the Bear Paw Development Corporation provided communities of Malta, Saco, and Dodson, but the data were all from existing national and State data sources. Anne Boothe from the Phillips County Economic Growth Council was not exactly sure what she had that was not generated through census materials. The USGS was able to locate other socioeconomic profiles for the local counties completed by Headwater Economics, Economic Profile System. Databases used for the Economic Profile System county profiles are from national sources: Bureau of the Census including County Business Patterns; Bureau of Labor Statistics; and the Regional Economic Information System of the Bureau of Economic Analysis, U.S. Department of Commerce. Tto-date data across the counties, the USGS pulled the most recent demographic the national and State sources. These data sources were the same as those used in the reports provided by the counties but were more up-to-date. In addition, the socioeconomic analysis 
Comment 

Number Response

66 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response went through extensive peer review before to the release of the DEIS. In July 2011, we provided the counties with emails and data sources used by USGS in the economic analysis and offered a willingness to expand further discussions of the af- fected environment if there was data that was left out. We gave the counties until August 15, 2011, to provide us with e did not receive further communication or 

-

-

Although individual meetings with the county commis

sioners were not feasible, USGS staff attended all the local 

these 

of increased visita

(DEIS 

clarified 

from 

explained 

have 

gained information 

meetings, combined with more background data and research, provided a strong foundation for the socioeconomic analysis. Furthermore, a respected economist on livestock grazing from 

-

was 

, wrote the analysis aylor

FEIS, we 

. D. T

s estimates of current visitation figures come 

additional data. Wfor the livestock grazing.

The refuge’ 13–5. 

from a variety of sources including traffic counters, physical 

The estimates 

yoming, Dr

permits. hunter and counts, 

tion over 15 years are modest numbers (see response 28–49) 

numbers 

The 

those 

112–114). In the 

meetings. 

the University of W

the rationale behind 

data on this topic.13–4. community and pages 105–107 and the information about visitation versus visits and how we estimated visitation numbers (DEIS page 227).

Letter #13: Phillips County Commissioners, Malta, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 67

Letter #13: Phillips County Commissioners, Malta, Montana

13–6.13–7.13–8.13–9.

13–10.

withdrawal mineral of the 

for Charles M. Russell Refuge on the locatable minerals (ULBend Refuge has a permanent withdrawal) and would advocate

-

, 

DEIS 

further 

.”

-

-

-

-

relatively small and

-

U.S. Con

e have clarified

contain

e have

the 

, seasons,

in 

correct that

later 

expanded 

districts 

Only the 

commenter is 

of minerals. 

lands 

e suspect the commenter in

gress can designate a permanent withdrawal. Wthe information in the FEIS about mineral development.

e inadvertently left out the acreage for private lands in 

the DEIS (page 191) and was corrected in the FEIS. However

been 

a 

hunting 

extension 

private 

discussion has 

refuge includes 

Those 

an are pursuing 

a permanent withdrawal 

of 

the 

MFWP. 

The 

acreage 

This 

that 

by 

the 

the refuge. 

326–329). 

e W

W

identify 

depiction of private lands ( DEIS pages 168–169), and acknowl

319, 

13–6. 

did 

for 13–7. we (page 26, which references about 40,000 acres), provided a edged the impacts that could occur for some permittees (DEIS pages in the FEIS. None of the actions in the CCP prevent access to existing inholdings within the refuge.

It is unclear what the commenter means by saying “less 13–8. 

than 50% of the wildlife habitat is within the CMR boundaryAll land can be considered “wildlife habitat” depending on its

, and refuge personnel during winter 2005–2006).

characteristics and management. W

suggest to tended 

variable proportion of administrative hunting district boundar

as established 

continuous wildlife habitat on and next to the refuge. Wland contained within the refuge boundary for each hunting disare mobile and respond to habitat conditions, weatherand a variety of other factors. Managing lands within the refugeprimarily for native wildlife should result in fewer impacts toadjacent lands as native ungulates would increase the time

spend on 

ies updated information in the FEIS showing the percentage oftrict, for elk habitat (as described by MFWP), and estimates ofthe number of elk found on the refuge (based on aerial observations by MFWP

Wildlife distribution is variable over time as native ungulates

they more animal unit months (AUMs) per unit area are grazed bylivestock on lands next to the refuge, which may be a factorcontributing to the relatively high proportion of elk found onthe refuge compared to the relatively small proportion of thetotal elk habitat on the refuge.
Comment 

Number Response

68 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #13: Phillips County Commissioners, Malta, Montana 13–11.

- pre

13–9. 

jobs and increased visitation (DEIS page 326). There would 

added refuge employees, 

Comment noted.

Comment noted.

Economic increases would occur from additional refuge 

as 

As visitors. nonlocal by 

13–10. 13–11. also be increased spending by the 

spending increased the as well 

scriptive grazing is carried out across 50–75 percent of the 

, 

refuge, the level of grazing could be reduced from current levels, but may also increase for short periods. Changes to refuge grazing would not be significant for the six-county economybut it could affect individual ranches with refuge grazing permits. The only effect in alternative A is the direct production of refuge AUMs (DEIS page 326). 

Although the no-action alternative has enabled us to

toward improvement of forage resources,

13–12. make some progress particularly where grazing is absent, the annual grazing program is not a comprehensive wildlife management program and

-

continued implementation of it would not achieve many of thegoals set for the project (DEIS page 322). The 1986 EIS notesthat it was meant to be a resource management plan and not

-

-

manlegal both are There plan. management a comprehensive 

dates and literature about the compatibility and use of prescrip

e added more of this information to the FEIS. tive grazing. W

The direction provided by the Improvement Act and 13–13. 

our policies is that livestock grazing needs to be done prescriptively for the benefit of wildlife resources (FWS 2000a, FWS 2001). The data describing the differences between annual grazing and ungrazed conditions is described in the DEIS (pages 191–193). In the FEIS, we clarified and added more information on legal mandates and data collected on various sites on the refuge, as well as information about how prescripof prescriptive grazing in use work. The would grazing tive this plan would differ depending on the wildlife species, weed species, native plant species, or specific habitat condition the 

- prescription is designed to affect. Rest would also be a condi

tion that is prescribed to benefit wildlife and the CCP would facilitate these kinds of prescriptions. 

13–12.13–13.13–14.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 69

In a review of the public transcripts from October 12, 

s remarks were taken 

- . Craw

-

Mr38–40). 

13–14. 2010, it appears that Barron Crawford’

transcript pages (Lewistown context of out 

ford stated that “the sentinel plant concept is not a new concept.” The concept is new for this refuge and he emphasized that we are to manage for wildlife habitat and not the range. The intention is not to return to historical conditions, but to 

, and resilience. , heterogeneity promote biological diversity

The plan is not aimed at making it not beneficial for 

permittees to graze on the refuge (DEIS page 66, “Upland Objective D4.” It would bring the refuge into compliance with the Improvement Act, our compatibility policy and biological integrity policy by ensuring that grazing is used to accomplish habitat and wildlife objectives. There is considerable science on the use of prescriptive grazing. In the FEIS, we added more information and citations in the upland habitat section. Refer 

of prescriptive grazing under to comment 13–12 about the use 

alternative A.

Letter #13: Phillips County Commissioners, Malta, Montana
Comment 

Number Response

70 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #13: Phillips County Commissioners, Malta, Montana 13–15. 13–16. 13–17. 13–18. 13–19.

13–20.13–21.

Money is based on annual appropriations so we cannot 13–15. 

guarantee that it will assume permits (DEIS page 329).

A document is a The use of the word “likely” in a NEP 13–16. 

common practice in describing what changes could occur in the 

A documents by their nature attempt to predict future. NEP

future outcomes. While there is not absolute certainty, projections are based on a combination of professional opinions made by reading scientific literature, past experiences, and from field observations. The observation made in DEIS (page 187) is based on direct field work on the refuge and the professional opinion of several biologists (DEIS page 350).

The compatibility determination in the DEIS (page 373) 13–17. 

did not mean to suggest that the entire refuge staff spends 25–35 percent of their time on these activities, but the field personnel who are directly responsible for managing these operations spend about that much time. Administrative staff, 

, and others spend 

-

, deputy project leader the project leader

e considerable time in administering the grazing program. W

clarified this in the FEIS.

The economic effect of refuge grazing is considered 13–18. 

negligible compared to overall grazing in the six counties. 

a be necessarily not would grazing prescriptive 

See response 13–7. 

Furthermore, “loss” of grazing. 

We included livestock grazing as part of the larger 

13–19. 13–20. significant issue of habitat and wildlife management (DEIS page 11, first bullet under habitat and wildlife management). Furthermore, we disagree that it should be a standalone issue outside of habitat and wildlife management. On national wildlife refuges, livestock grazing is a strategy used for meeting habitat objectives. 

Comment noted. 13–21. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 71

Letter #13: Phillips County Commissioners, Malta, Montana

negative 

impacts that increased prescriptive grazing would have on 

e will work 

of 

-

- will

goals 

-

combat 

-

-

brome 

species 

-

-

development 

spe

the 

who are 

habitat 

to 

acknowledged 

some permittees and we added this in the FEIS. W

the 

efforts 

operators 

and 

Japanese 

invasive 

weed, 

66) during the 

other 

wildlife 

our 

. In the first regrowth 

example, 

of 

the 

species 

Livestock 

increase 

326–330) 

For 

in achieving 

the 

disturbance, 

page 

(pages 

(DEIS 

their operations. 

would we 

present. 

on 

been 

depends 

Comment noted.

has 

D) 

there 

DEIS The 

permittees 

the habitat management plans to see where they can make arrangements in their operations for future grazing needs. Every effort would be made during that process to give ranchers time 

us with 

for 

and objectives could benefit.

The DEIS (pages 199–200) discussed what is known 

The comment provides little information as to what to add to the discussion (DEIS pages 199–200). In all of the action alter

It 

C, 

fire. 

work 

about invasive weeds and the efforts to reduce their spread. 

and (B, natives 

invasive and noxious weed species. 

e agree that any management decision to use pre W

13–24. (a noxious weed), is replaced by a healthy and diverse native collection of plans a few years after a prescribed fire. It is not possible to generalize on the response of weeds to wildfire or 

where 

prescribed 

See response 13–24 about action alternatives. Saltcedar 

13–22. to plan scribed fire should be weighed carefullyafter fire, noxious weeds do not occur unless the land has a history of overgrazing by livestock resulting in high popula

of weeds already 

13–23. 

to ing 

tions of native plants present, the soil, moisture conditions before and after the fire, the time of year the fire occurs, the intensity of the fire, and more.13–26. has been pointed out as the primary invasive species of concern during the planning process. It flourishes below the high water mark along the shoreline of Fort Peck (DEIS page 200). 

areas 

with 13–25. In cies have also flourished. In other disturbance areas, invasive species have also flourished. 

13–22.13–23.

13–24.13–25.13–26.13–27.13–28.
Comment 

Number Response

72 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #13: Phillips County Commissioners, Malta, Montana 13–29. 13–30. 13–31. 13–32.

13–33.

been 

in dis-

-

outbreaks of Canada thistle occur 

has not 

Invasive species control projects continue to be ac

e have worked with county 

orking Group, USACE, 

There is no information presented as to what water 

resources have been damaged from refuge management. Most of the water resources on the refuge are downstream of the 

- s opposition to any stock pond re

moval. There are more than 1,200 waterbodies (averaging 18 acres) within the scope of analysis and the effect of stock pond 

- ild

life does not require human-made impoundments (Krausman 2006), and any benefits are often outweighed by the adverse effects caused by concentrating wildlife in areas and at numbers 

-

removal would be negligible for waterfowl. Removal of constructed reservoirs and stock ponds within the refuge would not concentrate wildlife on the Missouri River to any great degree. Once artificial impoundments are removed, prairie stream functions would be restored along with corresponding riparian areas. As riparian areas develop, beaver naturally 

-

return and beaver ponds would become reestablished. W

e added informa

prescripof 

economies of 

, 

that would not have normally been found. W

effects 

extent the shoreline. Their 

beneficial the 

extension agents, Mussellshell River Wtive grazing on water quality and clarified information about the use of prescribed fire and water quality.

noted 

The small expansions of the wilderness boundary would 

access, solitude, or on the 

internal review comment and on public 

of the 

. See response 13–8. 

areas along 

mapped (DEIS page 199).

Comment noted.

we FEIS, 

Most 

e note the county’

the In 

turbed 

W

negligible effects 

13–27. 13–28. complished around the refuge. WBLM, and others (DEIS page 200).13–29. refuge boundary13–30. tion to the FEIS on this topic. 13–31. 13–32. 13–33. have the counties. Based changes were made to the proposed wilderness areas in the FEIS.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 73

Letter #13: Phillips County Commissioners, Malta, Montana

13–34.13–35.

13–36.13–37.

13–38.13–39.

The role of the CCP is to identify the roads that are 

public uses. management and 

This is consistent with the guidance found in the Improvement 

e agree that these are important 

them. 

-

-

-

-

one is 

resolve 

there 

to tool 

although 

the 

bison, 

not 

and wildlife 

is CCP 

for habitat 

Act and our planning policy. W

the but 

, we have worked with Petroleum County in address

ing rights-of-way (DEIS page 231). Given there is substantial variance in the records kept by the six counties, these issues should be addressed at the county level. 

o the extent that the counties have provided suggestions 

about what is needed for habitat, wildlife, and public uses, we have incorporated several suggestions in the FEIS and the actions are needed to rescue a visitor will be accommodated. Under all alternatives, the Service will carry out management actions through cooperation and collaboration with Federal, 

, as noted in the DEIS (page 232), there are hundreds 

of miles of open refuge roads that are available for hunters of all abilities in addition to the accessible hunting blind.conversations about what role the refuge should play in bison management. Many citizens and stakeholder groups have expressed a desire for bison restoration, and this was identified as one of the significant issues to consider for habitat and wildlife. Since we began drafting alternatives, with county representatives taking part in those discussions, we have been consistent in our message that the State should play a lead role in any bison restoration proposal. This message did not change 

, the refuge is not in any stage of devot

to habitat 

Comment noted.

Through communication and cooperation, whatever 

State and local governments. Existing facilities should be universally accessible and conform to accessibility standards; 

From early in the planning process there have been 

in the DEIS. Currently

refuge 

solve, 

13–34. However

.

considerable 

necessary 

to issues 

T

CCP13–35. 13–36. however13–37. ing permittee on the south side of the refuge that has grazed bison for years.
Comment 

Number Response

74 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #13: Phillips County Commissioners, Malta, Montana In a review of our policy for meeting the Data Quality Act (Information Quality Guidelines), the guidelines affirm the 

-

-

importance of disseminating and presenting quality information. The comment suggests the data in DEIS violates the Data Quality Act and is not supported by sound science. The guidelines state that the burden is on the requester to identify 

-

as the type of be corrected, as well 

correction being sought. It is also up to the requestor to show supporting evidence. There is no specificity in the implication 

e disagree that this summary statement in the DEIS 

The 

als to reintroduce wolves, but it is possible they may arrive naturally and refuge management will need to prepare for that 

response 

-

reintroduction. 

several na

s observa

also 

wolf or 

statement refers to conservation efforts at a landscape level 

olves and bison are specifically discussed in the DEIS (pages 91–91 and 99). There are no propos

See FEIS. 

bison 

the in 

e collaborate with 

what information needs to 

to include 

this clarified 

58) extends 

through partnerships. W

e W. 

W

See response 13–37. W

tional and international partners to protect wildlife (DEIS (page 6). The discussion in the DEIS (page 92) also provides the context for the interest in bison restoration.

Comments noted.

None of the alternatives rely solely on Murie’

tions and report. It is true that many things have changed during the last 75 years, many of them to the benefit of wildlife 

, we use his report, based on site and wildlife habitat. However

visits throughout the refuge and conversations with many residents, as an expert reference.

Comment noted.

13–38. made. 13–39. (page possibility10–37.13–40. 13–41. 13–42. 13–43. 

13–40.13–41.13–42.13–43.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 75

Letter #13: Phillips County Commissioners, Malta, Montana

13–44.13–45.13–46.13–47.13–48.13–49.13–50.

This was added to the discussion of unavoidable adverse 

e agree and added this information in the FEIS. 

consistent DEIS 

o carry out any specific action . T

W

More information was added about fires and water qualComment noted.

It is not unusual for an alternative to require more 

money to carry out an action, and this was noted on the inside cover and in the DEIS (page 1). All funding is based on annual 

In the FEIS, our policy for adhering to Executive Order 13514 (565FW1) was added to the section under climate 

change in DEIS (pages 84–85) and in appendix D. All of the 

are 84–85) (pages the identified in 

with the new Executive Orderin the alternatives will negligibly affect climate change, and all 

- alternatives will provide many benefits for carbon sequestra

tion due to the large amount of vegetated land the refuge provides. It is not clear what the relevance to the Data Quality 

e note Phillips counties’ opposition to the study 

.

by DeLuca, but we stand by it.

See response to comment

13–44. 

effects in the FEIS.

13–45. 13–46. 

ity in the FEIS.

13–47. 

13–48. appropriations.13–49. suggestions Act refers to. W13–50. 
Comment 

Number Response

76 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #13: Phillips County Commissioners, Malta, Montana 13–51. 13–52. 13–53. 13–54.

13–55.

e have modified the language in the FEIS to reflect 

s role. As with mountain lion or any new species that 

could be harvested on the refuge, a hunt plan and package 

sys

would have to be developed and approved by the Washington office before any regulation that allowed for a hunt could be 

The U.S. Global Change Research Program coordinates 

- and integrates Federal research on changes in the global envi

the Global 

e do not have plans to reintroduce wolves. 

As noted in the DEIS (page 7), response to climate 

change is a top priority for the Department of the Interior and the Service. The objectives reflect this priority (DEIS pages 

- s ecological of the refuge’ resilience 

tems (DEIS pages 66 and 86) is key to managing the refuge in 

by the U.S. Congress in It was mandated 

Change Research Act of 1990 (Public Law 101–606), which called for a “comprehensive and integrated United States research program which will assist the Nation and the world 

to human-induced respond and predict, 

Comment noted.

W

13–51. 

13–52. carried out.13–54. 84–86). Improving the 

assess, 

the State’

W 13–53. 

a changing climate. 13–55. ronment. to understand, natural processes of global change.” 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 77

Letter #13: Phillips County Commissioners, Malta, Montana

As stated in alternative D (DEIS page 326), moving 13–56. 

toward prescriptive grazing over 50–75 percent of the refuge 

could but economy, six-county the for significant be not would 

affect individual ranches with refuge grazing permits. Even under alternative A, given that prescriptive grazing accounts for 34 percent of the refuge grazing, it will likely be closer to 50 percent over 15 years. 

See response 13–1. 13–57. 

13–58. See response 13–23. Thank you for your comments.

13–56.13–57.13–58.
Comment 

Number Response

78 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #14: Powder River Commissioners 14–1 14–1. Thank you for your comments. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 79

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–1.15–2.15–3.

. The Service received the attachment from Dr. Lacey

Conservation Districts 

. Lacey Dr

comment 

2010). 

the 

(May 

during 

e issues in table 1 in 

document 

us to 

review 

comments 

internal 

similar 

the assess 

submitted 

Many of the comments contained in this letter are identi-

-

-

15–1. Thank you for your comments.

15–2. His services were contracted by the to also period, and we responded to his substantivchapter 3. 15–3. cal to letters 10, 11, 12, 13, and especially 28. Where the comments are identical, a reference is made to the same response in letter 28. Where the comments are unique, a separate response is provided. For example, the comment made in 15–3 is identical to 28–2. Refer to the response in 28–2.
Comment 

Number Response

80 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–4. 15–5. 15–6. 15–7. 15–8. 15–9. 15–10. 15–11. 15–12.

15–13.15–14.15–15.

-

See responses 28–4 through 28–14. 15–4 through 15–14. 

It is not clear how we will evaluate the “Traditional 

-

15–15. Ecological Knowledge” held by indigenous cultures or multigenerational families into the document, as no specific examples were given. Practices held by indigenous cultures are not necessarily the same as those used by ranchers of today. For example, Native Americans used prescribed fire (DEIS page 187) and were highly mobile (DEIS pages 233–234) as they followed the migration patterns of game. Furthermore, bison were central to their culture, which remains the same today 

- e agree that ranchers are very knowledge (DEIS page 239). W

able about the land and can provide valuable insight as the plan is carried out. There will be many opportunities to work with local ranchers (DEIS page 66) as habitat management plans are developed. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 81

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–16.15–17.15–18.

15–19.

15–20.15–21.15–22.

See responses 28–17 through 28–24.

See response 28–15. 15–16. 

15–17 through 15–24. 

15–23.15–24.
Comment 

Number Response

82 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–25. 15–26. 15–27. 15–28. 15–29.

15–30.15–31.

15–32.

The Missouri River Council of Conservation Districts 

-

See response 28–25. 15–25. 

15–26. represented the conservation districts as a cooperating agency throughout the planning process (DEIS pages 354–355 and up

e have incorporated many of the conser- dated in the FEIS). W

vation districts’ suggestions and concerns into the document. Invasive species control projects continue to be accomplished 

e have worked with county extension 

orking Group, USACE, BLM, and 

around the refuge. Wagents, Mussellshell River Wothers (DEIS page 200). 

See response 28–40.

Grazing is not a goal of the Refuge System. As outlined 

, prescriptive grazing may be 

e support working with permittees in 

United States 

-

s water needs, 

15–27. 15–28. in our biological integrity policyused to benefit wildlife. Worder to meet or exceed wildlife habitat objectives.

the (page 174), DEIS in the As 15–29. 

holds Federal reserved water rights on the Charles M. Russell Refuge and UL Bend Refuge. The United States is in the process of quantifying these reserved rights with the Montana 

ater Rights Compact Commission. As stated in the 

DEIS (page 175), the United States anticipates the compact will protect existing private rights, the refuge’

, BLM. 

stated 

and that of its sister agency

See response 28–41.See response 28–15.See response 28–43.

Reserved W15–30. 15–31. 15–32. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 83

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–33.15–34.15–35.15–36.15–37.15–38.15–39.15–40. -

-

The analysis evaluated both direct and secondary eco

a

-

-

of 

See responses 28–46 thru 28–51. 

year the of out 

e acknowledge the

months 4 for 

See response 28–44.

accounts refuge the 

15–33. 15–34 through 15–39. 

15–40. nomic impacts (DEIS page 317, table 35). Furthermore, graz

on ing 

ranch operation. The analysis did not look at the overall ranchoperation, the market value of the ranch, or the economic viability of the ranch. Implementation of prescriptive grazingwill occur under all alternatives and we modified the discussion in the FEIS to provide more detail. Wimpacts for some permittees. In the FEIS, we expanded thisdiscussion. 
Comment 

Number Response

84 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–41. 15–42. 15–43. 15–44. 15–45. 15–46.

15–47.15–48.15–49.

-

See response 28–53.See response 28–55.

See response 28–57. Palatable shrub species are eaten 

15–41. 15–42. 

15–43. by livestock and wild ungulates. The effects of the total population of wild and domestic on palatable shrubs are cumulative. Wild ungulates have priority on national wildlife refuges.

A document is a NEP

See response 28–59. See response 28–60.

the word “likely” in use of The 

15–44. 15–45. 15–46. a common practice in estimating what might happen in the future. Any monitoring protocol will be peer reviewed in acs Quality Information Guidelines and 

See responses 28–63 thru 28–65.

cordance with the Service’this was noted in the FEIS. 

15–47 through 15–49. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 85

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–50.15–51.15–52.15–53.15–54.

old road closures in relationship See response 28–66 on 15–50. 

to the no-action alternative.

Comment noted.See response 28–74.See response 28–78.

See response 28–79.

15–51. 15–52. 15–53. 

15–54. 
Comment 

Number Response

86 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–55. 15–56. 15–57.

15–58.15–59.

See response 28–81. 15–55. 

15–56. Comment noted. See response 28–82.

Comment noted.See response 28–84.

Comments noted.

15–57. 15–58. 

15–59. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 87

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–60.15–61.15–62.

e have not planted species that are not 

not 

plant 

e agree. W

adapted to the sites in their current hydrological condition and have no intent to do so in the future. On the first river bottom we restored, ground water was present within 4 feet of the 

others. 

-

-

.

but field, 

e do not have the misOn 

-

. 

in 

vigor

. When damage 

reduces 

the 

reviewed in accordance 

of 

grazing 

part in pits 

livestock 

soil 

only 

our 

The definition of river bottoms is broad because the conditions within and between river bottoms are broad. Each river bottom and part of each river bottom will be managed individually

e agree that both wild and domestic grazers can do 

similar damage to plants. Damages are a result of the total ungulate population using the land. W

that 

W

in 

15–60. surface The mixture of plant species we planted was designed in cooperation with the NRCS to capitalize on the conditions present. 

W 15–61. 

conception a national wildlife refuge wildlife is the priorityto plants is occurring by livestock and wildlife, livestock will be reduced or eliminated before wild grazers. 

Only alternative B would consider the use of food plots 

in restoration of the river bottoms. Refer to objectives B1, C1, and D1 under river bottoms in the FEIS. The habitat management plans will specify what the prescriptive treatment should be. 

e are not in the range management discipline, but W 15–62. 

are focused on wildlife and habitat management. Even though the disciplines of range management and wildlife management have shared goals, we do not have goals for the provision of forage for domestic animals as do the other agencies you mention. (DEIS page 191).

Sentinel species are those that are most likely to decline 

first on the refuge (DEIS page 346 and appendix F). The term sentinel, indicator species or diagnostic species is not unique in scientific journals. About the consistency with range management methods, we disagree that there is no scientific basis. We are in the process of working with range ecologists, statisticians, and other scientific disciplines (DEIS page 67) to develop monitoring protocols. In the FEIS, we clarified that monitoring protocols would be peer with our information quality guidelines.
Comment 

Number Response

88 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–63. 15–64. 15–65.

15–66.

e use many of the concepts you 

-

See response 15–62. W

refer to in the technical reference 1734–6 and have developed protocol specific to our mission, budget, and time constraints.

It is not undisputed that grazing is a vital component 

of healthy range conditions. That would depend upon the in

Damages 

the 

factors. other 

, livestock grazing is a secondary 

mission of the 

and weather, site, duration, 

from poor grazing practices are noted worldwide. The value of grazing for us conducting wildlife management depends upon 

grazed 

Ref

Some species prosper in 

accomplish 

or animal. the species of plant 

areas and some do not.

well 

We do not have a goal to eliminate livestock grazing 

-

(DEIS page 137). Howeveruse on a national wildlife refuge and must be compatible with 

as purposes, as 

15–63. 15–64. tensity, 15–65. refuge uge System. The refuge manager has decided that for livestock 

- grazing to be compatible on the refuge, it must be a prescrip

tive program, which meets wildlife and habitat objectives 

e have added (DEIS page 372 and updated in the FEIS). W

information in the FEIS about the benefits of prescriptive grazing.

The DEIS acknowledged that moving toward a greater 

-

15–66. reliance on prescriptive grazing could impact affect some permittees (pages 326–331). As new habitat management plans are developed, we would communicate with permittees so they can make arrangements in their operations on the refuge over 6–9 years (DEIS page 66). While there are going to be moderate to major impacts to some permittees in alternatives B and D (DEIS page 328), there would also be new opportunities for 

page (DEIS operations their adjust can ranchers that some 

329). Lands that are at rest now could be available for grazing in the future (DEIS page 328, table 54).
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 89

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

15–67.15–68.15–69.15–70.15–71.15–72.

Grazing fees are outside the scope of the CCP and EIS, 

as noted in the DEIS (page 14). The Public Rangelands Improvement Act does not apply to refuge lands (DEIS page 14).

See response 15–67. In 2008 there were 24,000 AUMs 

permitted, but only 18,872 AUMs used. AUM levels on the refuge have declined for several reasons, including higher grazing fees, not transferring permits when land within the refuge sells, and law enforcement (DEIS page 191)—those 

have 

also occurred on other public lands. Between 1941 and 2007, 

- authorized grazing use on BLM lands decreased from 22 mil

lion AUMs to 12.6 million, a 57-percent decrease in livestock grazing (BLM 2008). Furthermore, since 2005 more than 13,000 acres of rangeland have been converted to row crops in the sixcounty area, which has also contributed to the loss of grazing land in the six counties (personal communication with Robert Sanders, Ducks Unlimited, 2010). As AUMs on the refuge have 

six-county 

since 

-

-

to 

-

-

elk 

not 

trends 

most 

and 

year 

Similar 

the 

slightly 

in 

objectives 

the 

alternatives. 

cattle 

increased 

of 

of 

wildlife 

majority 

all 

number 

See response 28–94.

in 

the 

continue 

time, over 

would 

remained relatively stable or 

factors 

has 

15–69. 1986 (DEIS page 248); and the refuge supplies less than 1 percent of the AUMs in the six counties. 

Refuge revenue payments were discussed in the DEIS 

15–67. 15–68. 

decreased area 15–70. (page 313). The purpose of allowing for economic uses on na

meet 

create an economic benefit to taxpayers.

The mission of the Refuge System is not livestock man

vast 

to is refuges wildlife 

Elk choose to rest in places of varying environmental 

, elk on the refuge are more numerous on 

tional agement. Pronghorn, elk, and other species are very much 15–72. conditions. Generallylands without cattle grazing. There is a brief time during early spring when they may seek locations heavily grazed the previous year. An area burned in the previous year will be even 

The 

impeded by fences. 

elk. attractive to 

15–71. more avoid locations used by livestock.
Comment 

Number Response

90 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana 15–73. 15–74. 15–75.

15–76.15–77.15–78.

-

these fires, and we 

-

We value the experience that local ranchers have. As 

the area responded to 

We agree. See response 28–95.

The Missouri River Breaks are a fire prone and fire 

We manage a variety of wildlife and not just large game. 

Management tools such as livestock grazing and fire can cause changes in composition and abundance of plants, which in turn affects bird species composition and numbers (DEIS page 212). When ungrazed and grazed streamside riparian areas were compared on the refuge, almost twice as many birds were found on the ungrazed areas than grazed (DEIS page 212). 15–73. noted in the DEIS (pages 43 and 67), the staff has expertise and experience in range management.

The Black Pulaski Complex was the result of an intense 

15–74. 15–75. dry lightning event immediately followed by a cold frontal passage that produced winds in excess of 40 mph. Every available firefighter in mobilized a national type I incident management team and a northern Rockies type II incident management team to suppress the fires. At no point were these fires ever considered to be managed by any other choice than full suppression. A very similar situation occurred in Garfield County in 2003. 

dependent ecosystem. No matter how aggressive our suppression efforts are, fire will eventually burn across the landscape. The two fire complexes referred to in the comment are examples of what happens when fires are continually suppressed and excluded from playing its role in the ecosystem. These types of fires will continue throughout the Missouri Breaks landscape. Lightning strikes and resulting fires have no respect for land 

ownership or property boundaries. As stated in the DEIS, it is our intent to aggressively suppress any fire that could affect private property or leave the refuge. Many fires can 

to 

as 

impact little very with efficiently and safely managed be 

private property owners or county resources. All fire, both prescribed and wildfire, will be evaluated to determine the 

restoring of goal ultimate 

. 

the with action, of course best 

natural an ecosystem as possible and reduced costs to the local landowners and American taxpayer
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 91

Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana

Determining offsets to the acquisition of private land is 

-

-

-

ildlife Fed

s stake

See response 28–97.Comment noted.

This is an issue between the National W

orld Wildlife Fund, and the permittees (DEIS page 

e do not have a role in these negotiations.

Comment noted.See response 28–103.

Refuge staff already takes part in the Council’

e disagree that the significant issues that were identi W

15–76. 15–77. 15–78. See responses 28–48 and 28–101.15–79. outside the scope of the CCP and EIS.15–80. eration, W136). W15–81. 15–82. 15–83. holder group. 15–84. 

fied in the DEIS (pages 11–13) were not adequately addressed. 

We have valued the contributions of the conservation districts throughout the planning process (DEIS pages 354–357 and updated in the FEIS), as well as the contributions of ranchers, organizations, agencies, citizens, and other stakeholders in this process. 

15–79.15–80.15–81.15–82.15–83.15–84.
Comment 

Number Response

92 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #15: Missouri River Council of Conservation Districts, Great Falls, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 93

Letter #16: Garfield County Conservation Districts, Jordan, Montana

16–1.16–2.

In the FEIS, the Service has clarified the definition of 

prescriptive grazing and provided more examples of how it is currently used on the refuge and how it would be used in the 

grazing 

Strate

use 

68, 

to 

, and timing 

-

-

-

e would use 

page 

refuge 

. 

(DEIS 

the enables 

partners 

grazing 

allows the refuge to control the duration, intensityof grazing to meet specific habitat goals. Specific monitoring protocols for upland sentinel species are being developed (DEIS page 191) using NRCS ecological site descriptions and 

scientific 

Prescriptive 

16–1. future. to benefit all wildlife as mandated by the Improvement Act. It 

other with working 

gies for Upland D1–D9).

We understand your concerns about wildfires and we 16–2. 

would aggressively suppress fires that threaten private lands. Prescribed fire can be beneficial both to overall habitat, as well as for fuels reduction resulting in diminished wildfire oc

. Over time, as more prescribed fire is currence and intensity

employed, lower wildfire occurrence would occur

It is an outlined goal in the CCP to prevent all fires from 

burning off the refuge and affecting neighboring lands. Reference DEIS (page 80–82) and note several references to mitigating impacts to neighboring lands. Wintensive suppression strategies where perimeter areas are threatening to burn off the refuge (DEIS page 81).
Comment 

Number Response

94 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #16: Garfield County Conservation Districts, Jordan, Montana 16–3. 16–4. 16–5. 16–6.

16–7.

-

Coyote hunting is allowed on the refuge from the begin- 16–3. 

ning of pronghorn season until March 1 of the following year. 

This statement is speculative as no data or supporting 16–4. 

documentation is provided. Coyote hunting is allowed on the refuge from the beginning of pronghorn season until March 1 

-

of the following year. 

e disagree; the refuge tends to be the largest recipient 16–5. 

of invasive weeds in the county due to the downstream nature of most of the refuge, open public roads, and waterways that get heavily used during hunting and fishing season. The refuge responds to all new reported areas of knapweed and is actively working at prioritizing and treating saltcedar infestations where possible. Several steps have been taken to prevent the spread of noxious weeds including public outreach and notification, weed wash stations, and requirement of weed free hay.

e believe that communication with local ranchers 

used 

e agree 

e believe 

Americans Native example, For . today ranchers 

W

W 16–6. 

(DEIS page 66), as habitat management plans are developed, provide the best opportunity to share information and incorporate the knowledge that ranchers have as we move forward with carrying out the actions related to habitat and wildlife. 

It is not clear where we would incorporate or evaluate 

raditional Ecological Knowledge” held by indigenous 

cultures or multigenerational families into the document as no specific examples were given as to how this would relate to any specific action in the DEIS. Practices or customs held by indigenous cultures are not necessarily the same as those 

by 

the “Tused prescribed fire (DEIS page 187); were highly mobile (DEIS page 233–234); and they followed the migration patterns of game. Furthermore, bison were central to their culture, which remains the same today (DEIS page 239). Wthat ranchers are very knowledgeable about the land and can provide valuable insight as the plan is carried out. Wthere will be many opportunities to work with local ranchers (DEIS page 66) as habitat management plans are developed.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 95

Letter #16: Garfield County Conservation Districts, Jordan, Montana

16–8.16–9.

16–10.16–11.16–12.

T payments are not addressed by the CCP and 

T (DEIS 

ildlife Federation because the Service was not 

ildlife Fed-

-

-

-

-

- ater Rights Com

-

e acknowledge the impact on Montana De

-

have districts 

PIL 16–7. 

the refuge as no control of the distribution of PILpage 14). The CCP does not address the grazing buyouts by National Winvolved. That interaction was between National Weration and the private producer (DEIS page 330). 

Grazing on the refuge must be compatible with habitat 

improvement and maintenance as legislated by the Improve

The relevancy of this statement is not clear to the eco

16–8. ment Act.16–9. nomic analysis. Wpartment of Natural Resources and Conservation (DNRC) lands and would work with DNRC to assume any permits if existing permittees no longer desired to keep their permit. DNRC showed that this would be acceptable. 

See comment 16–9.

The United States is in the process of quantifying re

W

16–11. pact Commission. The FEIS was modified to include the latest status of this process. 

e value the contributions of the Garfield County Con

16–10. served rights with the Montana Reserved W16–12. servation Districts in the planning process. Local groups in

conservation and commissioners county cluding 

held cooperator status while the CCP was being drafted. Many improvements and changes have been made to the CCP with input from all cooperators. Thank you for your comments.
Comment 

Number Response

96 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #16: Garfield County Conservation Districts, Jordan, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 97

Letter #17: McCone County Conservation Districts, Circle, Montana

17–1.17–2.17–3.

The comment does not state how the CCP and EIS fail 

to provide for the primary species. Objectives and strategies for pronghorn are discussed in the DEIS (pages 88–89). Sharptailed grouse are discussed in the DEIS (page 94) and was expanded in the FEIS. The habitat objectives detailed in the CCP and EIS would benefit pronghorn, sharp-tailed grouse, 

. The United States 

- lan

Adjudicate means to settle judicially

is currently working to quantify reserved water rights (DEIS 

ater Rights Compact page 174) with the Montana Reserved W

Commission. These rights must be resolved as part of MonThe 2011). (DNRC, process adjudication statewide guage in the DEIS (page 33) does not conflict with the current 

The economic impacts of revenue-sharing were dise currently buy inholdings 

from willing sellers and this would not change under any ale have clarified this in the FEIS. The location and timing of future land acquisitions are based on unforeseen 

in 

-

and market conditions. Therefore, changes 

17–1. other big game, and focal bird species.17–2. 

s tana’

process that is in place. 17–3. cussed in the DEIS (page 313). Wternative. Wopportunities property tax revenue and revenue sharing payments of potential future land acquisitions would be speculative at this time. 
Comment 

Number Response

98 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #17: McCone County Conservation Districts, Circle, Montana 17–4. 17–5. 17–6. 17–7. 17–8. 17–9. 17–10. The citation should have been Higgins (1986), which is 

-

-

the 

-

The impact from developing viewing blinds was dis

iewing blinds can direct 

ildlife (2007)). Impacts to sage-grouse would be 

-

Expanding the six existing proposed wilderness areas 

of 

-

e inadvertently left out the acreage for private lands 

, we did show the acreage of 

about 

the of 

Ice jams were discussed in the DEIS (page 195). The 

have affected riparian areas on 

, high densities of cattle during grow

presumptions as 

cost incremental 

references 

None FEIS. 

26, which 

the in 

make 

Any counties. 

further 

six 

that 

the 

the DEIS (page 

been expanded 

factors 

is speculative to 

across 

has 

comment 

W

lands in 

caused 

The 

17–4. found in the bibliography in the DEIS (page 422). In the FEIS, we clarified this. 17–5. cussed in the DEIS (page 287). At most, there would be a couple of lek viewing blinds provided. Vand concentrate visitors, which can lessen impacts (Colorado Division of Wnegligible and visitation can be managed during critical breeding periods.17–6. would have negligible impacts to the economies of the counties. Existing access would not be affected by the relatively small expansions managing expanded wilderness areas is negligible. National wildlife refuges are not managed or intended to support economic uses or generate revenue. 17–7. in the DEIS (page 191). Howeverprivate 40,000 acres), provided a depiction of private lands (DEIS pages 168–169), and acknowledged the changes that could occur for some permittees (DEIS pages 319, 326–329). This discussion actions in the CCP prevent access to existing inholdings within the refuge.17–8. human refuge are loss of beavering seasons, and upland reservoirs that have altered water flow in major drainages.17–9. to what future landowners outside the refuge would do about access. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 99

Letter #17: McCone County Conservation Districts, Circle, Montana

17–11.17–12.17–13.17–14.17–15.

The impacts on the socioeconomic environment were

discussed at length (DEIS pages 126–132) and the analysis was

ildlife would

refuge 

A 

Thefences. 

issue of range specialists was discussed in the DEIS (pages 67

a managed

as 

e support working in partnership

-

-

the 

peer reviewed before the publication of the DEIS. W

not 

on 

such of impediments, removal 

a wildlife refuge and is 

bison to reintroduce 

is 

plans no 

the 

refuge 

have 

from 

The 

e 

143). 

e have no plans to reintroduce wolves or grizzly bears.

benefit in other cooperative partnership ventures (DEIS pages 131–133).

Comment noted.

W

17–10. and rangeland (DEIS page 4). Wwith others to develop monitoring protocols (DEIS page 67) and17–11. 17–12. (DEIS pages 93–94) nor does MFWP at this time. If such a plan was put forward, then it would be subject to more NEP(DEIS page 284).

W 17–13. 

It would be speculative to figure out what the economic impactof those species may be should they migrate to the refuge. Webelieve it is important to specify that a management plan for

-

-

those species should be prepared before any future migration.

in coopera being conducted study 

, we disagree that we lack management

other

- e work coop

control

s ef

along dams, 

to work 

been disturbed 

and weeds 

a 

combating 

is currently There 

tain lions. Any hunting package would not move forward until 

e agree that invasive species are a threat and challenge

expertise as the reason for the increase in weed infestations.Saltcedar is pervasive along the south shore in bays and inlets

e have no control of water levels along the

dam. In many areas that have weeds have proliferated such as Canada thistle. W

USACE in 

(DEIS page 200). W

with 

W

17–14. tion with MFWP to figure out the population levels of mounthere was enough data to support a limited harvest of mountain lions on the refuge (DEIS page 298).17–15. for everyone; howevereratively invasive weeds above the high water mark while USACE’forts are aimed along the lake. In addition, we agree that winningthe war against invasive species will take a coordinated effort byall landowners. Under all the action alternatives, we will increaseour efforts at combating invasive species (DEIS pages 82–84).
Comment 

Number Response

100 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #17: McCone County Conservation Districts, Circle, Montana 17–16. The livestock grazing analysis considers both direct page 317, table 35). 

depen

and secondary economic impacts (DEIS The $41.09 for the value of production per AUM represents the direct change. The $79.52 of economic impact per AUM 

- represents the total change including both direct and second

ary impacts. The total labor earnings estimates ($18.17) and 

of total the represent (.000741) 

both direct and secondary impacts (personal communication 

, 2011). Furthermore, most ranchers are only 

forage (DEIS for grazing land 

page 326) and the refuge only provides four months of forage 

. The level of an increase impact above the direct 

production associated with refuge AUMs would depend on 

- of level ranch’s individual 

estimates 

on Federal 

the including 

employment 

aylor

dependent 

total out of a year

factors 

17–16. with David Tpartially several dency on refuge grazing as well as its overall solvency (DEIS 

e used figures from the six-county area to conduct page 326). W

the analysis.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 101

Letter #17: McCone County Conservation Districts, Circle, Montana

17–17.17–18.17–19.17–20.17–21.

e will use both prescribed fire and prescribed grazing 

as tools for managing wildlife habitat. Grazing alone does not provide the necessary nutrient recycling, vegetative response, and benefit to wildlife, as fire does. A combination of the two is 

It is an outlined goal in the CCP to protect values at 

risk, and there are several objectives and strategies intended to prevent fires from burning off the refuge and affecting 

e would use 

intensive suppression strategies where perimeter areas are 

Prescribed fire can be beneficial for habitat, as well as for 

fuel reduction resulting in diminished wildfire occurrence and 

e agree that prescriptive livestock grazing can be 

a variety 

of tools to reduce fire threats along the boundary including 

e recognize the concern about the

suppression and property cost of large wildfires. The Black Pulaski

-

-

Complex was the result of an intense dry lightning event immediately followed by a cold frontal passage that produced windsin excess of 40 mph. The eight fires making up the complex were

fires

way than full suppres

e

, xxvii, and 

-

crucial for a healthy and resilient ecosystem. threatening to burn off the refuge (DEIS pages 80–82). 

these 

species. W

prescribed fire, prescribed grazing, and mechanical methods.

used. W

. 

neighboring lands (DEIS pages 30 and 80–82). W

employ 

were 

also will 

point no 

e 

other 

At refuge. 

to be managed by any 

See response to 17–18. W

and 

. W

to reduce invasive 

the off on 

W

both 

17–17. 

17–18. intensityused 17–19. started ever considered 

 A very similar situation occurred in Garfield County in 2003. .no

Many fires can be managed safely and efficiently with very 

is

little impact to private property owners or county resources. All fire, both prescribed and wildfire, will be evaluated to figure out the best course of action, with the ultimate goal of restoring as natural an ecosystem as possible and reduced costs to the local landowners and American taxpayer

The comment provides no specific page number or refer

where a biased reference material has been 

17–20. ence to disagree that the socioeconomic analysis has flawed statements.

The comment does not provide a specific example for 17–21. 

response. As stated in the DEIS (inside front coverpage 1), the CCP discusses program levels that are substantially above current budget allocations.
Comment 

Number Response

102 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #17: McCone County Conservation Districts, Circle, Montana 17–22. 17–22. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 103

Letter #18: Phillips County Conservation Districts, Malta, Montana

18–1.

18–2.18–3.

Removal of human-constructed reservoirs and stock 

ponds will not cause turbidity in downstream rivers and 

, removal of artificial impoundments will streams. Moreover

actually have the opposite effect. Once artificial impoundbe restored would functions stream prairie removed, are 18–1. ments along with corresponding riparian areas. As riparian areas develop, beaver could naturally return and beaver ponds could 

ildlife does not require human-made become reestablished. W

impoundments (Krausman 2006) and their benefits are often outweighed by the adverse impacts caused by concentrating wildlife in areas and at numbers that would not have normally 

- stakeand citizens Many management. bison in 

been found. 

The Service does not have plans to reintroduce wolves, 18–2. 

grizzly bears, or bison. From early in the planning process there have been conversations about what role the refuge 

play should 

holder groups have expressed a desire for bison restoration, 

- and this was identified as one of the significant issues to con

sider for habitat and wildlife. Since we began drafting alternatives, with county representatives participating in those discussions, we have been consistent in our message that the State should play a lead role in any bison restoration proposal. 

and the 

-

Act 

Refuge System. It 

they that 

Improvement 

ensuring 

.

of the 

and 

of the 

and mission 

community 

provisions 

purpose 

is a permissible habitat management practice when prescribed in plans to meet wildlife or habitat management objectives 

s program would include looking at all of 

o meet the T 18–3. 

resulting compatibility policy (601FW2) and biological integrity policy (601FW3), livestock grazing must be compatible 

The refuge is managed as a wildlife refuge and not for a 

range, although we noted it in the DEIS (pages 43 and 67), several staff members have expertise and experience in range management. Monitoring for range health generally involves looking at the dominant community plants which are mostly 

the 

grasses. The refuge’

comprise 

the refuge 

that 

, vibrant, and able to reach maturity

plants 

with (601FW3).the are healthy
Comment 

Number Response

104 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #18: Phillips County Conservation Districts, Malta, Montana management we lack , we disagree that We agree that invasive species are a threat and challenge 18–4. for everyone; however expertise as the reason for the increase in weed infestations. Saltcedar is pervasive along the south shore in bays and inlets e have no control of water levels along dams, along disturbed have been that (DEIS page 200). Wareas dam. In many the other weeds have proliferated such as Canada thistle. We work cooperatively with USACE in combating weeds and work to control invasive weeds above the high water mark while USACE’s efforts are aimed along the lake. In addition, we agree that winning the war against invasive species will take a coordinated effort by all landowners. Under all the action alternatives, we will increase our efforts at combating invasive species (DEIS pages 82–84). 18–5. Thank you for your comments. 18–4. 18–5.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 105

Letter #19: Valley County Conservation Districts, Glasgow, Montana

19–1.19–2. to extended was period comment The noted. Comments 

19–1. The Service considers all public input into the process. 

19–2. December 10, 2010. 
Comment 

Number Response

106 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #19: Valley County Conservation Districts, Glasgow, Montana 19–3. 19–4. 19–5. 19–6. refuge boundary is frequently raised. The fire you are referencing was the Missouri Breaks Complex, which had a northern Rockies type II incident management team assigned to it at the time. Any incident

- such as this requires a high degree of organization, and it is man

Firefighting

efforts require a high level of control. Local, organized firefightingcrews who work within the incident management organization arealmost always involved with large fire suppression efforts on the

-redn

The issue of firefighters being turned away at the 

u f

structure. team management incident an under 

19–3. aged refuge, in accordance with an approved memorandum ostanding in place with counties adjacent to the refuge. 

. Lacey are addressed 

plant sentinel of 

The substantive issues raised by Dr

responses. A combination individual the in 

species are used to evaluate landscapes rather than a single 

. Prairie clovers are noted species such as purple prairie clover

to decrease from historic levels with increasing degradation of plant communities in NRCS ecological site descriptions. 

associated exclusively, 

north and east facing 

not but predominantly, 

coulees and on 

slopes. Because each species of plant is associated with a portion of the landscape rather than the entire landscape, we use several species of sentinel plants that occupy different positions with respect to soils and topography when evaluating 

ellow sweet clover and other exotic plants 

that we could use 

is Chokecherry 

with moist areas along whole landscapes. Yare typically less abundant in locations with a healthy and diverse collection of native plant species. Prescribed fire is one 

to component within our management plans 

promote biological diversity and environmental health.

Under the preferred alternative (D), no roads would be 19–4. 

affected by the small wilderness expansions proposed across thesix counties. A small number would be affected in alternative B.In the FEIS, several modifications were made to the proposedwilderness designations and several roads under alternative D. fees, but the fees are based on fair market values and are notset by the refuge. Furthermore, we have no plans to eliminatelivestock grazing or force livestock grazers off the land. However,

We understand the concerns about the high cost of grazing

in order to meet the provisions of the Improvement Act andthe resulting compatibility policy (FWS 2000a) and biologicalintegrity policy (FWS 2001), livestock grazing must be compatiblewith the refuge purposes and mission of the Refuge System. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 107

Letter #19: Valley County Conservation Districts, Glasgow, Montana

-

Comments noted. 

The SB119 had little to do with granting the conserva

River Council of 

19–5. 19–6. tion districts, as represented by the Missouri Conservation Districts and cooperating agency status on the planning effort. The Council attended most of the workshops and meetings, and many changes were made to the internal 

- review document as a result of input by the conservation dis

tricts. Thank you for your comments.
Comment 

Number Response

108 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #20: American Prairie Foundation, Bozeman, Montana 20–1. 20–2.

20–3.20–4.

Refuge management and the CCP must comply with 

Executive Order 7509, Public Land 94–223, Improvement Act, and the National Environmental Policy Act. The Service 

s understanding 

that wildlife and habitat management activities by any land management entity have an effect on adjacent areas, land managers, and we work cooperatively with other agencies. 

e share that view and have emphasized throughout the CCP 

is 

The Service recognizes the threat invasive species pose 

that aggressive 

-

nomically possible. In all of the action alternatives (B, C, and 

-

ious weed species. The DEIS lists 27 strategies (pages 83–84) of how to address invasive species problems and many of them 

other entities. 

-

ditional resources and room for improved communication and 

-

goals achieve 

and 

partners 

control should be applied where logistically feasible and eco

s 

common 

appreciates the American Prairie Foundation’

with 

to 

and agree prevention is best if possible D) we would increase our efforts to combat invasive and nox

coordination 

In combating invasive species, there is always a need for ad

e have updated the acreage figures and made correc

Correction on numbers of American Prairie Foundation’

bison were made in the Final CCP.

and 

with working that 

paramount where possible.

communication 

Wprocess 20–2. emphasize coordination.

W

20–1. 20–3. tions in the FEIS.20–4. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 109

Letter #20: American Prairie Foundation, Bozeman, Montana

20–5.

20–6.

20–7.20–8.20–9.

Road management on the Charles M. Russell Refuge 

e 

preparing 

-

-

Any initiative to restore bison as a wildlife species in 

-

tailored 

-

- , hunting opportuni

management in 

wilderness proposed 

, and private land 

, and other consider

the 

road 

to 

all perspectives on 

changes several 

management plans. These would be 

made e W

20–5. received considerable public comment, as referenced in the DEIS. Many people expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open additional roads, primarily for hunting and game retrieval. Wconsidered the FEIS and determined a hybrid version was best for balancing competing interests.20–6. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 20–7. Montana will be a collaborative, multiagencymanagement effort with ample opportunity for public input. The refuge has always been open to research projects and proposals involving investigations of the effects of ungulates (wild or domestic) on vegetation and wildlife habitat. 

Changes were made to the big game objectives in the 20–8. 

FEIS. In accordance with national policy striving to the extent practicable to achieve consistency with State management objectives and regulations, refuge-specific abundance and population composition objectives could be established through stepdown habitat to regional habitat conditions, productivityations. Those objectives would consider naturally functioning ecosystem processes, biological integrityties, and quality of recreational experiences.20–9. Thank you for your comments.
Comment 

Number Response

110 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #21: Backcounty Hunters and Anglers, Missoula, Montana 21–1. 21–2.

21–3.

- The Service appreciates Montana Chapter of the Back 21–1. 

country Hunters and Anglers understanding of the legal mandates governing how a refuge is managed.

We used an approach similar to this in preparing the 

. We have strived for the CCP to chart a course where 

21–2. CCPmany of the issues raised here are addressed in a responsible manner that fulfills refuge management requirements.

game movement, are many factors that affect big There 21–3. 

including disturbance by motorized vehicles. 

Road management on the Charles M. Russell Refuge 

received considerable public comment, as referenced 

in the DEIS. Many people expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open additional roads, primarily for hunting access and game retrieval. Others expressed the view that any closure 

e considered all perspectives on road was unacceptable. W

management in preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative. The Service did consider time and effort needed to access areas of the refuge after leaving motorized access points (DEIS page 305, figure 47).

boat traffic and 

e tried to obtain data on boat 

important considerations about You raise 

its influence on big game. Wtraffic with cameras, but logistical and technological difficulties limited data collection. Nevertheless, we will monitor motorized water travel and adjust management as necessary to minimize negative influences on big game populations and provide adequate motorized water access for wildlifedependent recreation.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 111

Letter #21: Backcounty Hunters and Anglers, Missoula, Montana

21–4.21–5.

Where possible, management of naturally occurring fires 

-

21–4. for ecological benefit will continue. Invasive species management includes education, prevention, and funding. The DEIS lists 27 strategies on pages 83–84 of how to address invasive species and many of them emphasize communication and coe will continue to work with 

management species 

ordination with other entities. W

address invasive of partners to a variety 

both on and off the refuge.

See response 21–3. 21–5. 
Comment 

Number Response

112 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #21: Backcounty Hunters and Anglers, Missoula, Montana 21–6.

21–7.

wilderness proposed the to changes several made e W 21–6. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 

The 21–3 response acknowledges there are many factors 21–7. 

that affect big game movements, such as hunter activity and the availability of motorized access. While these comments advocate for fewer roads and reduced motorized boat access, we considered all comments and made changes based on public input for the FEIS.

We also recognize that public access for hunting has been 

steadily decreasing and that creates a host of other issues. The FEIS attempts to balance reasonable motorized access, 

, and wildlife-dependent recreation, big game habitat security

but limits placed on public access to lands outside the refuge is 

e agree with not providing “privileged” beyond our control W

or exclusive access and have eliminated such road access not available to the general public wherever possible. In some cases we are required to provide historical road access to private or State lands even though these roads may not be open to the general public.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 113

Letter #21: Backcounty Hunters and Anglers, Missoula, Montana

21–8.

21–9.

21–10.

Any initiative to restore bison as a wildlife species in 

, and private land 

-

Montana will be a collaborative, multiagencymanagement effort with ample opportunity for public input. The refuge has always been open to research projects and 

of ungulates (wild or domestic) 

the big game objectives in the 

, and other consid

, hunting opportuni

the effects 

on vegetation and wildlife habitat. 

Changes were made to 

FEIS. In accordance with national policy striving to the extent practicable to achieve consistency with State management objectives and regulations, refuge-specific abundance and 

through 

would be tailored 

-

-

established be could 

plans. These 

objectives composition 

e have discussed opportunities for bighorn 

W

21–8. proposals involving 21–9. population stepdown habitat management to regional habitat conditions, productivityerations. Those objectives would consider naturally functioning ecosystem processes, biological integrityties, and quality of recreational experiences.

e agree there is extensive, quality bighorn sheep 21–10. 

habitat on the refuge in northern Garfield County (DEIS page 208, figure 28). Wrestoration in this area with MFWP and with local landowners. Montana’s recently approved a Bighorn Sheep Conservation Strategy and will be used to help guide preparation of a translocation proposal. Thank you for your comments.
Comment 

Number Response

114 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #22: Blue Goose Alliance, Albuqueque, NM 22–1. 22–2.

22–3.

The Service agrees that well-designed research projects 22–1. 

are needed to guide future decisions. 

We have made several improvements to the preferred 22–2. 

alternative, which should further the goal of restoring ecologi-

-

cal processes.

We recognize that bison were once a native wildlife un 22–3. 

gulate in the Missouri River Breaks. As with most wildlife restoration efforts, we will continue to work with our partners to evaluate the opportunities for restoring native species to the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 115

Letter #22: Blue Goose Alliance, Albuqueque, NM

22–4.22–5.22–6.22–7.22–8.

Comment noted.

We have no intent to establish another “fenced” bison 

22–4. 

22–5. herd. MFWP is developing a conservation strategy that will outline the plans for reintroducing bison as a native wildlife species. We will continue to work with a variety of interest groups to explore the possibility of introducing bison back into 

Comment noted. Comment noted. Comment noted. 

the wild. 

22–6. 22–7. 22–8. 
Comment 

Number Response

116 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #22: Blue Goose Alliance, Albuqueque, NM 22–9. 22–10.

22–11.

-

Comment noted.

We made several changes to the proposed wilderness 

22–9. 

22–10. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

Following completion of the CCP we will develop a 

incor- have we addition, In refuge. the for plan 

22–11. transportation porated more road management options in alternative D in the FEIS to address wildlife, public use, and safety concerns on the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 117

Letter #22: Blue Goose Alliance, Albuqueque, NM

22–12.22–13.

-

See response 22–3 and 22–5 about bison restoration. We 

refuge 

e 

land exchanges, and 

willing sellers near or 

will Wlands. of divesting 

State 

currently has 

in interested 

refuge. The refuge 

are that 

s realty needs. 

refuge 

22–12. 

are actively involved in land acquisition in and around the ref

The Enhancement Act, uge. 

inholding funds all contribute to addressing acquisition needs on the 

the in 

continue to pursue acquisition opportunities as they arise. 

At this time there is a realty position at the refuge that 

devotes an extensive amount of time to realty issues. This position also works throughout eastern Montana, but we feel it meets refuge’22–13. Thank you for your comments.

The 15 wilderness study areas you refer to are proposed 23–1. 
Comment 

Number Response

118 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 119

Letter #23: Central Montana Wildlands Association, Lewistown, NM

ildlife Service 

-

-

Policy Manual. Management of a proposed wilderness is out

-

-

See comment 23–1. Also, refer to our wilderness stew

e will manage recom

mended wilderness according to the final CCP until the U.S. Congress makes a decision on the area or that we amend the CCP to modify the wilderness recommendation 4.23A. For proposed wilderness we have completed the wilderness review process and documentation of National Environmental Policy Act compliance. The Secretary of the Interior has reviewed and approved the proposal and forwarded it to the President. 

alterna wilderness 

tives after considerable review from the public and others. 

and 

-

alternative B 

recommending for 

wilderness areas, as defined our Fish and Wlined in Part 610 FW 4.23 FWS Policy Manual.

proposed 

in 

ardship plan, Part 610 4.22B and 4.23B. W

acreage 

the 

the 

justification 

to 

to 

changes 

made 

sufficient 

were 

not 

several 

changes 

made 

23–2. D due to mapping errors in the DEIS. In addition, we deter

is there 

e W

Slight mined deletion of any existing proposed wilderness area. 

23–1.23–2.
Comment 

Number Response

120 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM 23–3. All roads in proposed wilderness areas have been closed 

- exist or roads traverse be private inholdings 

23–3. except where tween existing units (refer to figure 7 in the FEIS).
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 121

Letter #23: Central Montana Wildlands Association, Lewistown, NM

- livefrom impact no be would there that imply not did 

We have clarified the definition of prescriptive grazing 23–4. 

in the FEIS and provided more details as to how it was used. 

we Also, 

stock grazing, but once a truly prescriptive grazing program is carried out, impacts would be minimal. Many areas on the refuge that are being prescriptively grazed are being rested or are very lightly grazed.

Comments noted. See response 23–4. Livestock grazing 23–5. 

has not been prohibited in proposed wilderness areas. Whether it occurs in a designated wilderness area depends on whether 

area. wilderness the establishment of the before allowed was it 

The maintenance of supporting facilities that existed in an area before designating it as wilderness would also be allowed.

23–4.23–5.
Comment 

Number Response

122 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 123

Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–6.23–7.

ildlife-dependent recreation is defined in the glossary 

of the CCP as “use of a refuge involving hunting, fishing, wild-

, environmental educacycles. life observation, wildlife photography tion, or interpretation.” The Improvement Act specifies that there are the six priority public uses of the Refuge System. Refer to our policy 601 FW3, 3.15B where it states, - “Our habitat management plans call for the appropriate man agement strategies that mimic historic conditions while still accomplishing refuge objectives. For example, prescribed - manlevel Farming, 

-

water 

management 

or 

habitat 

regimes fire 

hydrological 

or wildlife 

natural 

natural 

meet 

simulate 

mimic 

can 

W

23–7. burning haying, logging, livestock grazing, and other extractive activities are permissible habitat management practices only when 

to plans 

can 

23–6. agement prescribed in objectives, and only when more natural methods, such as fire or grazing by native herbivores, cannot meet refuge goals and objectives.”
Comment 

Number Response

124 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM 23–8. 23–9. See response 23–1 when referring to wilderness study 23–8. areas (WSA). 23–9. See responses 23–2 and 23–3.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 125

Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–10. See response 23–2. 23–10. 
Comment 

Number Response

126 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM 23–11. The Great Plains evolved through a complex interaction 23–11. of fire and grazing and to eliminate it from a manager’s tool- box for managing habitat is not realistic or desired. However, for grazing to continue under all alternatives, including the no-action alternative, we must progressively move toward prescriptive grazing. This is consistent with the Improvement Act, biological integrity policy (FWS 2001), and the compat- ibility policy (FWS 2000a). Prescriptive grazing was clarified further in the FEIS.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 127

Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–12. The primary reason for setting aside the land in Execu- 23–12. 

tive Order 7509 was for the purpose of sustaining the primary species (sharp-tailed grouse and pronghorn) and other secondary wildlife species. All of the game ranges that were originally around in the 1930s had similar if not identical provisions for allowing livestock grazing (among other provisions) to continue to the extent it was compatible with utilization of the lands for the primary purposes. The administrative status of all game ranges was changed by the passage of the Game Range Act (Public Law 94–223) in 1976 when they were brought under 

ildlife Refuge Administration the umbrella of the National W

Act of 1966 (Congress amended Desert Game Range in 1966 and put under the administrative control of the Service). The Improvement Act provided a mission statement for the Refuge System and outlined the requirements for managing all refuges. Livestock grazing must benefit wildlife conservation and it is subject to compatibility.
Comment 

Number Response

128 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–13. Comments noted. 23–13. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 129

Letter #23: Central Montana Wildlands Association, Lewistown, NM
Comment 

Number Response

130 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 131

Letter #23: Central Montana Wildlands Association, Lewistown, NM
Comment 

Number Response

132 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM 23–14. , we developed an approach for achieving the vision, goals, and mandates of the refuge (DEIS pages 29 

-

-

-

and 332) using a range of tools to meet specific habitat objectives. There is an abundance of literature that supports prescriptive grazing and fire and we added more discussion and 

to 

-

review 

grazing For FEIS. the document in the 

In this CCP

to citations 

23–14. several continue under all alternatives, including the no-action alternative, we must progressively move toward prescriptive grazing 

This area was not deemed suitable for wilderness in the 

, but it was revisited during the CCP 

e concluded it was not suitable for a wilderness pro

wilderness 1974 the in 

(DEIS pages 4, 26, and 372).

stated As lands. refuge 

, and intermixed with developments to be man

23–15. 1974 wilderness reviewprocess. Wposal due to the subdivision of lands between State, private, 

the and 

cited in the DEIS and FEIS, all of these subdivisions are too small, narrowaged as wilderness units. 

23–15.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 133

Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–16. 23–16. Comments noted. See response 23–2.
Comment 

Number Response

134 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 135

Letter #23: Central Montana Wildlands Association, Lewistown, NM
Comment 

Number Response

136 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–17. Comments noted. 23–17. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 137

Letter #23: Central Montana Wildlands Association, Lewistown, NM

23–18.

23–19.

We modified the preferred alternative in the FEIS 23–18. 

based on public comments. 23–19. Thank you for your comments. 
Comment 

Number Response

138 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #24: Defenders of Wildlife, Washington D.C.

24–1.

-

-

Comments noted, with several clarifications. The pri

-

ildlife Refuge Administration Act 

Service). the of control administrative 

.

the under put and 

24–1. mary reason for setting aside the land in Executive Order 7509 was for the purpose of sustaining the primary species (sharptailed grouse and pronghorn) and other secondary wildlife species. All of the game ranges that were originally established in the 1930s (Desert, Fort Peck, Sheldon, Cabeza Prieta, and Kofa) had similar if not identical provisions for allowing livestock grazing (among other provisions) to continue to the extent it was compatible with utilization of the lands for the primary purposes. (Hart Mountain was also established as a game range in 1935, but a year later it was changed to a refuge for pronghorn). The administrative status of all game ranges was changed by the passage of the Game Range Act (Public Law 94–223) in 1976 when they were brought under the umbrella of the National Wof 1966 (the U.S. Congress amended Desert Game Range in 1966 The Improvement Act provided a mission statement for the Refuge System and outlined the requirements for managing all refuges. Livestock grazing must benefit wildlife conservation and it is subject to compatibility
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 139

Letter #24: Defenders of Wildlife, Washington D.C.

24–2.24–3. - W

24–2. Thank you for your comments. 

e understand your interest in pursuing bison restora

, we cannot act alone as there are complex and 

24–3. tion. Howevermultijurisdictional issues involved. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagency, and private land management effort with ample 

public input. We recognize management ac- for opportunity 

tions on the refuge may have effects outside the refuge and we will consider such effects. 
Comment 

Number Response

140 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #24: Defenders of Wildlife, Washington D.C. 24–4. 24–5. e considered all perspectives We received many comments about road management on 24–4. the Charles M. Russell Refuge. W on road management in preparing the FEIS, and the balance incorporated that version a hybrid was access vehicular for elements from each alternative. In the FEIS ,we made sev- eral modifications to alternative D (preferred alternative) to incorporate additional seasonal closures. Following completion of the CCP we will develop a transportation plan that defines road management on the refuge. Based on comments received during the public review process, we have revised several road designations to address , disturbance to wildlife, and providing 

wilderness proposed the to 

habitat connectivitysufficient access for public use. 

changes several made e W 24–5. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 141

Letter #24: Defenders of Wildlife, Washington D.C.

24–6. ildland Fire Decisions We evaluate wildfires using the W 24–6. 

Support System to determine management response to each incident. Fire is a key component to a functioning ecosystem 

across the fire each opportunity to use consider we will and 

landscape. 

24–7. Thank you for your comments. 24–7.
Comment 

Number Response

142 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #24: Defenders of Wildlife, Washington D.C. 24–8.

-

We recognize the need to quantify and protect water 24–8. 

resources on the refuge. Riparian studies have been initiated to monitor habitat conditions that are dependent on hydrologic functions on and off the refuge. Independent of the CCP pro

Reserved Water Rights Federal 

e have submitted a compact proater Rights Compact 

have entered into cess, we 

negotiations for the refuge. Wposal to the Montana State Reserved WCommission and for the next two years we will be negotiating and quantifying water rights on the refuge. Additional information on water quality was added to the FEIS. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 143

Letter #24: Defenders of Wildlife, Washington D.C.

24–9. Refer to the DEIS (chapter 1, pages 7 and 8). See also 24–9. 

DEIS (chapter 3, pages 40 and 84–86) and (chapter 5, pages 257–258). The DEIS considers the conditions, precipitated by climate change, which the refuge will deal with including the 

ater is fundamental protection of water and other resources. W

for wildlife and we have revised the FEIS to include more emphasis on water resources and climate change.
Comment 

Number Response

144 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #24: Defenders of Wildlife, Washington D.C. 24–10.

-

The first priority would be to establish baseline in- 24–10. 

formation on birds, small mammals, amphibians, and other species, while carrying out our habitat objectives (DEIS, pages 84–86). The DEIS did not use the term “vulnerabil-

, we would work with universities, ity assessment.” However

partner scientists, and statisticians to conduct population viability analyses of climate sentinel plant species and “first to decline” wildlife species and to assist in carrying out our 

e would take both reactive and 

carbon for landscapes 

strategic climate change plan. W

managing approaches to anticipatory 

sequestration and climatic resilience–heterogeneity of species, structure, and succession. The components of the program would include a focus on monitoring and management of climate sentinels, ecological process sentinels, and adaptation through resilience.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 145

Letter #24: Defenders of Wildlife, Washington D.C.

24–11.24–12.

- eduthat recognize comments and your with agree e W 24–11. 

cation is the key to change (DEIS pages 84–86). In the FEIS, we added climate change as a topic under “environmental education” in all alternatives. 24–12. Thank you for your comments.
Comment 

Number Response

146 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #25: Gallatin Wildlife Association, Bozeman, Montana 25–1.

25–2.

to 

-

assure to FEIS 

an opportunity 

the 

has 

lead bison restoration efforts, but we also have a responsibility for native species restoration and management. Language in the FEIS will clarify that our initiatives to restore native species will be a collaborative, multistakeholder effort with ample 

e received many comments regarding big game and 

that our proposed composition objectives in the DEIS are 

have or plans MFWP 

in 

. Those objectives will also 

.

MFWP 

our in 

language 

recognizes 

opportunity for public input.

found 

the 

than 

adjusted 

Service 

standard 

we 

The 

W

lower 

25–1. 25–2. 

a of 

been achieved with past management under alternative A. Therefore, that management on the refuge meets or exceeds objectives in approved State big game conservation plans. Refuge-specific abundance and composition objectives will be established through habitat management plans and tailored to regional habitat conditions and productivityconsider recreation and experience quality
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 147

Letter #25: Gallatin Wildlife Association, Bozeman, Montana

25–3. The proposed habitat management for sage-grouse 

natural ecological proe will continue 

, Montana), it 

the illustrates 

wildlife prairie 

through management for 

and 

.

, combined with the extensive 

in 

pronghorn on research 

of sagebrush-steppe 

Recent 

range wide 

25–3. and sharp-tailed grouse, providing for the variety of seasonal habitat needs cesses, will meet the needs for those species and many others. Sharp-tailed grouse are identified as one of the many species in Executive Order 7509 that established the purposes of the refuge, and sage-grouse is currently designated a “candidate species” under the Endangered Species Act. Wto monitor population trends and work with partners to ensure their continued health and viability

Given the position of the refuge lands along the Missouri 

River and Fort Peck Reservoirmovements of pronghorn (recently documented from near Swiftcurrent, Saskatchewan, to near Ingomarwould be difficult to establish refuge-specific objectives for pronghorn. landscape scale perspective that managers must think about 

a for 

eastern Montana.
Comment 

Number Response

148 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #26: Helena Hunters and Anglers Association, Helena, Montana 26–1.

26–2.

26–3.

- The Service will prioritize its habitat and wildlife man 26–1. 

agement objectives for the refuge and will also emphasize 

hunting, as recreation, including , wildlife-dependent quality

directed by the Improvement Act.

We recognize the extreme popularity of the Missouri 26–2. 

River Breaks for its wildlife, hunting, fishing, and recreational opportunities. In the DEIS on page 227, we also reference the 

, Theodore Roosevelt Conservation research work of Bill Geer

Partnership, and the article published in Montana Outdoors in 2008 (Dickson 2008). 

Yes, there are similarities among the four alternatives, 26–3. 

but each has a unique managerial approach. It is our belief that alternative D best fulfills NEPA’s requirements. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 149

Letter #26: Helena Hunters and Anglers Association, Helena, Montana

26–4.

26–5.

26–6.26–7.26–8.

-

-

Any initiative to restore bison in Montana will be a col

, and private land management effort 

has always 

-

processes 

exceeds 

public input. The refuge 

ecological 

or meets 

natural 

refuge the 

the 

on 

opportunity for 

with consistent be 

management that 

plan to 

assure 

26–4. laborative, multiagencywith ample been open to research projects and proposals involving the effects of ungulates (wild or domestic) on vegetation and wildlife habitat. 

Many comments were received about big game manage 26–5. 

ment, pertaining to quality hunting viewing experiences, and 

a for 

theme of alternative D. Given the public and agency comments in the DEIS, big game objectives were adjusted in the FEIS to objectives in approved State big game conservation plans. Refuge-specific abundance and composition objectives will be established through habitat management plans and tailored to 

. Those objectives regional habitat conditions and productivity

will also consider wildlife dependent recreation and quality of 

-

experience.

We will pursue maintaining and improving big game 

full 

-

for the habitat management 

, through adoption of manage

consider 

s biodiversity

habitat, but will also range of a refuge’ment for natural ecological processes.

s recently approved Bighorn Sheep Conservation 

e considered all perspectives 

e have discussed opportunities for bighorn restoration W

-

on 

26–6. 26–7. with MFWP and with local landowners. Potential bighorn sheep habitat is described in the DEIS (page 208, figure 28). Montana’Strategy will be used to help guide preparation of a translocation proposal.

Road management on the Charles M. Russell Refuge 26–8. 

received considerable public comment, as referenced in the 

road management in DEIS. W

preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative.
Comment 

Number Response

150 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #27: Hellgate Hunters and Anglers, Helena, Montana 27–1. 27–2.

27–3.27–4.

27–5.27–6.27–7.27–8.

Providing compatible wildlife-dependent recreational op- 27–1. 

portunities can be considered on national wildlife refuges once wildlife habitat and their needs are satisfied. 

The Service recognizes the popularity of the Missouri 

-

27–2. River Breaks for the wildlife and hunting, fishing, and recreational opportunities. In the DEIS (page 227), we also note the 

, Theodore Roosevelt Conservation research work of Bill Geer

Partnership, and the article published in Montana Outdoors in 

wilderness proposed the to changes 

2008 (Dickson 2008). 

Comment noted. 

several made e W

27–3. 27–4. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we 

-

determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 

Considering the public and agency comments on the 27–5. 

DEIS, the big game objectives were adjusted in the FEIS to 

objec exceeds or meets refuge the management on that assure 

tives in approved State big game conservation plans. 

Any initiative to restore bison as a wildlife species in 

, and private land 

27–6. Montana will be a collaborative, multiagencymanagement effort with ample opportunity for public input. 

Comment noted. Comment noted. 

27–7. 27–8. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 151

Letter #27: Hellgate Hunters and Anglers, Helena, Montana

27–9.

27–10.27–11.27–12.27–13.27–14.27–15.27–16.27–17.

-

Comment noted. 

We considered all perspectives on road management in 

27–9. 

27–10. preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alterna

There is extensive quality bighorn sheep habitat on 

tive. 27–11. the refuge in northern Garfield County and we have discussed 

for bighorn restoration in this area with MFWP opportunities 

and local landowners. 

Comment noted. See response 27–6. 

27–12. 27–13. 27–14. See responses 27–5 and 27–10. 

Comment noted. See response 27–11. See response 27–10. 

27–15. 27–16. 27–17. 
Comment 

Number Response

152 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response , Bozeman, Montana Letter #28: Lund Law 28–1.

28–2.

The Service values the contributions the counties have 

-

-

made throughout the planning process. As cooperating agen

meetings attended 

ildlife Service (Region 6) CCPs, in addition to fol

. The 

the of most 

and workshops and provided comments on the internal review document. In the DEIS (pages 353–359) and the FEIS, each provide details of the extensive input that the counties had in the planning process. There are several thoughtful suggestions in this letter that will improve the quality of the information contained in the FEIS. The document follows the style, format, and content found in all Mountain–Prairie Region of the U.S. 

, and 

-

-

s planning policy

e disagree that the indirect or cumulative impacts 

of implementing grazing were not analyzed adequatelyDEIS examined all foreseeable activities including those related to land purchases for hunting, fishing, and other recreational uses in areas surrounding the refuge (DEIS page 136). 

urnover in land is largely due to the demand for recreation 

e also noted that 

- changes in grazing management and stocking rates in alterna

tives B and D could further reduce the availability of grazing 

ith only 24,000 

AUMS permitted in 2008 (of which only 18,872 were used), which makes up less than 1 percent of all the AUMs in the six-county area (DEIS page 316), it would be speculative to determine that lands next to the refuge would sell and be subdivided at higher rates, thus further impacting wildlife off 

the refuge implements prescriptive because 

representatives county 

W

A. 

cies, Fish and Wlowing the steps outlined in the Service’NEP28–2. Tand the aging population (DEIS page 250). Wland in the region (DEIS pages 230–231). W

just refuge 

28–1. the grazing at a more progressive pace than under the no-action 

e have noted in the FEIS that over 13,000 acres alternative. W

in the six-county area were converted to crop lands (personal communication with Robert Sanders, Ducks Unlimited, 2010) from 2005–2009. This would also likely impact available grazing acreage.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 153

Letter #28: Lund Law, Bozeman, Montana

28–3.28–4.28–5.28–6.28–7.28–8.28–9.

28–10.28–11.

, we did identify the acreage of private lands in 

We inadvertently left out the acreage for private lands 28–3. 

in the DEIS (page 191) and this section was corrected in the FEIS. Howeverthe DEIS on page 26 (about 40,000 acres), depicted the private lands DEIS (pages 168–169), and acknowledged the impacts that could occur for some permittees (DEIS pages (319, and 326–329). This discussion has been expanded further in the FEIS.

It is unclear what is meant by less than 50 percent of the 

, nor is it clear 

28–4. wildlife habitat is within the refuge boundarywhat relevancy is to the actions discussed in the DEIS. We would refer you to response 10–7 for additional discussion on this topic.

Changes to the permittees were acknowledged and 

(pages 319 and 326–329). As stated in 

28–5. analyzed in the DEIS response 28–3, the actions would not affect landowner access 

, nor do we have any plan to take a privately to their property

held rights. On refuge lands, grazing is a privilege and not a property right as stated in the DEIS (page 14). 

In the FEIS, we added a discussion of effects from fire 28–6. 

(wildfires and prescribed fires) under invasive species (DEIS page 272). Most of the documented weed infestations on the refuge have not been a result of a fire. The healthier landscapes on the refuge are not as prone to weed infestations as areas that were formerly used for agricultural purposes, are near the lake shoreline, or were once disturbed for other uses. 

occurs it and refuge on the weed prolific most the Saltcedar is 

along the riparian areas (DEIS pages 199–200).

The refuge is primarily downstream of all lands outside 

lands private or State on effect negative Any refuge. 

28–7. 

the of 

would be carefully evaluated before removing a stock pond within our boundaries. The comment does not specify why water resources would be affected outside of the refuge.
Comment 

Number Response

154 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response

-

e note the counties’ opposition to any stock pond re-

, there are more than 1,200 water bodies (av

eraging 18 acres) within the scope of analysis, so the effect of stock pond removal would be negligible. Removal of humanmade reservoirs and stock ponds within the refuge would not concentrate wildlife on the Missouri River to any great 

have 

the opposite effect. Once artificial impoundments are removed, prairie stream functions would be restored along with corresponding riparian areas. As riparian areas develop, beaver 

-

likely would impoundments 

would naturally return and beaver ponds would become rees

human-made impoundments 

(Krausman 2006) and their benefits are often outweighed by 

e 

-

W

require 

artificial 

not 

of 

W

moval. However

Removal 

Wildlife do 

the adverse impacts caused by concentrating wildlife in areas 

found. been normally have not would that numbers 

e have added to the discussion on water quality in the 

degree. 

W

28–8. tablished. 

at and 

have added information to the FEIS on this topic. 

e have added this to the discussion in the FEIS and 28–9. 

agree that we should add similar language about fire suppression on private lands. This was omitted under State and private lands, but was identified and discussed elsewhere in the DEIS.

W 28–10. 

DEIS (page 266) and unavoidable adverse effects.

We have added this language in the FEIS. 28–11. 

Letter #28: Lund Law, Bozeman, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 155

Letter #28: Lund Law, Bozeman, Montana

28–12.28–13.28–14.28–15.28–16.

We have modified the language in the DEIS (page 99) to

s role. Since the gray wolf was delisted from the reflect the State’

endangered species list, the State could play a role in managingthe harvest of this species. As with mountain lion or any newspecies that could be harvested on the refuge, a hunt plan would

- ashington office be have to be developed and approved by the W

fore any regulation that allowed for a hunt could be carried out.

Expanding acreage in some existing proposed wilderor 

-

28–12. 28–13. ness areas would have negligible impacts on the economies of 

(page 263), while it would in the DEIS the counties. As stated 

be possible to hear sounds at the edges of wilderness areas that border refuge roads, these are negligible impacts. All of 

roads series 300 are expansion the border that roads 

, are not maintained, and are lightly traveled. 

The ranching heritage found on the refuge is expressed

the higherlargely by the remains of fencing, homesteads, and corrals.Refuge activities would be reviewed for impact to these resources and would avoid any adverse impacts where possible.Consideration of the ranching history was included in the objec-

-

e have expanded the

28–14. tive and rationale for environmental education (DEIS pages 116and 126), rationale for cultural resources B1–8. The ranching erawas also discussed in the affected environment. While we understand the importance of ranching to the local communities, thereis not a designated ranching heritage area within or next to therefuge. There was significant discussion about the socioeconomicimpacts of livestock grazing in the DEIS. Wdiscussion about livestock grazing in the FEIS.

It is not unusual for an action alternative to require 

-

28–15. more money to implement. All funding is based on annual appropriations.

There has never been a mineral lease or patented re- 28–16. 

source on the refuge. As noted in the DEIS (page 13), any privately held property rights would exist regardless of any actions in the CCP and EIS. As stated in the DEIS (page 173), the mineral estate was withdrawn for 20 years on Charles M. Russell Refuge and permanently on UL Bend Refuge for locat-

- e are seeking another 20-year mineral with able minerals. W

drawal for locatable minerals on the Charles M. Russell Refuge 
Comment 

Number Response

156 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–17. 28–18. 28–19. 28–20. 28–21.

28–22.28–23.28–24.

and we clarified the discussion in the FEIS. Although we are seeking a permanent withdrawal, only the U.S. Congress can 

e have expressed the benefits for 

designations 

through a permanent withdrawal in the FEIS. Since there has never been any mining on the refuge, it would be speculative to describe any impacts to the economy simply from making 

e agree that prescriptive grazing could be a tool, in 

The DEIS (page 78) specifically addressed hazardous 

fuels assessment in wildland–urban interface and mechanical treatment of these areas. Alternative B notes that consideration of the full spectrum of management response would be considered (DEIS page 80). Proactive mechanized thinning 

has 

-

combination with other measures, for combating invasive species in some areas outside of river bottoms or riparian areas. 

-

-

-

-

of Appeals 

National Wild

area 

e are confident 

Court 

special 

under the 

and 

Circuit 

make this determination. W

resources 

9th 

of the refuge 

s forage resources particularly in areas 

refuge’s biological 

two occasions, the 

management 

W

On 

Although the no-action alternative has enabled us to 

the the withdrawal for locatable minerals permanent. 28–17. We clarified this in the FEIS.28–18. could be considered as part of that spectrum.28–19. upheld our life Refuge Administration Act, as amended. Wthat the CCP adheres to the legal mandates described in the DEIS (page 4). Current habitat monitoring, as indicated in the DEIS (page 191), has found that livestock are consuming a fair share of the refuge’with annual grazing where 86 percent of forage is allocated to livestock within 0.5 mile of water on slopes of less than 10 degrees (DEIS page 190). Furthermore, Executive Order 7509 specifically qualified that the provision for livestock grazing was dependent on its compatibility with the primary purposes. The compatibility regulations, codified under 50 Code of Federal Regulations (CFR), were modified in 2000 following passage of the Improvement Act.28–20. make some progress toward improving forage resources, particularly where grazing is absent, continuance of annual grazing is not a comprehensive wildlife management program and not achieve many of the goals set for the project (DEIS page 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 157

Letter #28: Lund Law, Bozeman, Montana

322), nor would it allow us to meet our legal mandates in the Improvement Act and subsequent policies (DEIS page 4). The discussion and several citations to the document in the FEIS. For grazing to continue under all alternatives, including the no-action alternative, we must progressively move toward 

-

a resource manage-

-

ment plan and not a comprehensive management plan. 

, we developed a comprehensive approach 

for achieving the vision, goals, and mandates of the refuge (DEIS pages 29 and 332) using a range of tools to meet specific habitat objectives. There is an abundance of literature that supports prescriptive grazing and fire, and we added additional 

larger sig

riparian 

of the 

it was noted that 1986 EIS 

In this CCP

prescriptive grazing (DEIS pages 4, 26, and 372).

as part grazing 

See response 28–4.

livestock e included 

nificant issue of habitat and wildlife management (DEIS page 11, first bullet under habitat and wildlife management). 

All of the action alternatives call for increased vigilance 

and control of noxious weeds. Canada thistle is more often tied to fluctuating water levels around the lake (DEIS page 200) especially in the disturbance areas around the dam. Areas that have been sprayed for saltcedar using helicopter spraying operations have increased Canada thistle. More discussion of 

ar on studies 

meant to be 

Canada thistle was added to the FEIS.

several of results the e detailed 

W

W

28–21. 

28–22. 28–23. 28–24. eas (DEIS pages 194–199) and the impacts that have occurred from livestock and wild ungulates. 
Comment 

Number Response

158 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana e agree that the use of prescribed fire could add costs to the plan, which is one reason for using natural fire as part 

- , the expecta

-

of a fire program (DEIS pages 80–81). Howevertion is that by using more prescriptive fire and natural fire where possible, in the long-term, wildfire control costs could be significantly reduced in alternatives B and D as compared 

subject 

-

. Carrying out any specific ac

change 

e note 

was 

objectives). 

which 

from 

(study 

fire is 

climate 

data, 

of prescribed 

affect 

DeLuca 

change 

by 

variety of 

Representatives 

use 

negligibly 

the climate 

to the study 

wide 

2008. 

the rationale under 

The 

June 4, 

C. The 

on 

and 

alternatives will 

analysis. 

opposition 

W

Comment noted.

headquarters 

28–25. 

alternative A to 

to annual appropriations; therefore, a full-range of options for managing refuge habitats including prescriptive grazing needs 

In the FEIS, our policy for adhering to Executive Or

in the 

counties’ 

. 

The USGS consulted multiple sources in conducting 

socioeconomic 

to be available. 

county commissioners and representatives to discuss 

28–26. der 13514 (565FW1) was added to the section under climate change in the DEIS (pages 84–85) and in appendix D. All of the suggestions found in the DEIS (pages 84–85) are consistent with the new Executive Ordertion and provide many benefits for carbon sequestration due to the large amount of vegetated land the refuge provides. WThe counties provide no substantive basis as to why it is not a valid study

As stated in comment 28–1, we have incorporated many 

the noted in 28–27. of the counties suggestions into the DEIS and addressed their concerns throughout the process. 28–28. 28–29. the were cited extensively in the document, included sources from other Federal, State and local agencies, as well as private landowners. The USGS social scientists met with several of the local their social and economic issues related to the CCP at the refuge Phillips and McCone Counties provided copies of fact sheets and suggestions for local contacts at the meeting. The USGS followed up with the local contacts in an attempt to gather more information not available through State and national data 

28–25.28–26.28–27.28–28.28–29.28–30.28–31.28–32.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 159

sources. Krystal Steinmetz from the Bear Paw Development 

Phillips 

County and the communities of Malta, Saco, and Dodson. All 

were from existing national 

and State data sources. Anne Boothe from the Phillips County Economic Growth Council was not exactly sure what she had that was not generated through census materials. The USGS was able to locate additional socioeconomic profiles for the local counties completed by Headwater Economics, Economic tem county profiles are from national sources: Bureau of the 

Labor 

Statistics; and the Regional Economic Information System of 

o use consistent and the most up-to-date data across 

the counties, the USGS pulled the most recent demographic 

and 

State sources. These data sources were the same as those used in the reports provided by the counties, but were more up to date. In addition, the socioeconomic analysis went through extensive peer review before the release of the DEIS. In July 2011, we provided the counties with emails and data sources ness to expand further discussions of the affected environment 

until 

e did not 

, USGS staff attended all the local 

research, 

provided a strong foundation for the socioeconomic analysis. 

, one of the economists on livestock grazing from the 

, wrote the analysis for 

-

-

-

Profile System. Databases used for The Economic Profile Sys-

-

about 

of 

national 

counties 

Bureau 

information 

the 

the 

Patterns; 

the Bureau of Economic Analysis, U.S. Department of Com

from 

gave 

directly 

used by USGS in the economic analysis and offered a willing

e 

demographic 

Business 

Wout. left 

County 

was 

provided 

in these reports 

data county-level 

that 

including 

data 

Corporation 

contained 

economic 

was 

Census merce. T

there 

data and if August 15, 2011, to provide us with additional data. Wreceive further communication or data on this topic.

Although individual meetings with county commission

gained from these meet

data and background 

The information 

aylor. D. T yoming, Dr

, ERO Resources, contacted all of the

community meetings. Furtherthe livestock grazing.

Our contractor

28–30. ers were not able to occurings, combined with additional 28–31. counties during the data gathering stage for the DEIS. McConeCounty was the only county that provided us with a plan, and

for relevance to the issues in the DEIS. A

University of Wwe reviewed that plan 

Letter #28: Lund Law, Bozeman, Montana
Comment 

Number Response

160 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–33. 28–34. 28–35. 28–36. 28–37.

28–38.

alley County attended the internal review

meeting in June 2010, but did not reference a resource plan orsend us a copy of it in the months that followed. Subsequently,

-

-

-

in 

-

-

rewe 

s Land Use Policy and the Mc

From early in the planning process there have been 

, the refuge is 

the 

e cooperate with many 

wolves 

and counties, 

Cone Conservation District Annual Plan of Operation, neither of

play 

reintroduce 

six all 

which have relevance to the CCP or the EIS.

Thank you for your comments.

Invasive species control projects continue to be ac

complished around the refuge and we have worked with county 

orking Group, USACE, 

should refuge 

extension agents, Mussellshell River WBLM, and others (DEIS page 200). 

role 

with up 

ceived a copy of Fergus County’

what 

are no plans to 

V

followed 

Comment noted.Comments noted.Comment noted.

about 

restoration. There 

commissioner from 

Resources 

Comment noted.

conversations 

ERO 28–32. 28–33. 28–34. 28–35. 28–36. 28–37. 28–38. many bison management. Many citizens and stakeholder groups have expressed a desire for bison restoration and this was identified as one of the significant issues to consider for habitat and wildlife. Since we began drafting alternatives, with the county representatives taking part in those discussions, we have been consistent in our message that the State should play a lead role in any bison restoration proposal that goes forward. This message did not change in the DEIS. Currentlynot devoting considerable refuge habitat to bison, although we note that there is one permittee on the south side of the refuge that has grazed bison for years. Wnational and international partners to protect wildlife (DEIS page 6, describes partnerships to protect birds). The discussion in the DEIS (page 92) provides the context behind the interest 

bison in 

on the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 161

Letter #28: Lund Law, Bozeman, Montana

28–39.28–40.

-

pacts to some individual permittees as a result of carrying out 

-

-

-

-

im

alterna

tives B and D (DEIS pages 319, 326, 328–329 and 330–331). 

, the economic analysis does not suggest that this 

action would significantly contribute to landowners selling to other conservation groups and negatively impact the economy 

over 

time, the number of cattle in the six-county area has remained relatively stable or increased slightly since 1986 (DEIS page 248), and the refuge supplies less than 1 percent of the AUMS in the six counties. AUM levels on the refuge have declined for a number of reasons. They include higher grazing fees, not transferring permits when land within the refuge sells, and law 

un

refuge have decreased 

. It is a strategy for managing 

AUMs 

be significant 

continue 

program in 

18,872 

will 

only 

there could 

factors 

grazing 

but 

prescriptive 

page 191). These 

e acknowledged that 

As AUMs on the 

permitted, AUMs 

more aggressive 

(DEIS 

24,000 

W

page 33). 

Howeverenforcement der all alternatives. There are many reasons for lands around the refuge to be sold to other interests (DEIS pages 134–137 and 250). Furthermore, since 2005 more than 13,000 acres of range land have been converted to row crops in the six-county area, which has also contributed to the loss of grazing land (personal communication with Robert Sanders, Ducks Unlimited, 2010). 

As explained in many conversations with the coun

ties during the planning process and in the DEIS (pages 14, 138, and 372), livestock grazing is an economic use of a refuge that is subject to compatibilitywildlife habitat. There is no other CCP in Region 6 or in other regions that a set number of AUMs have been identified for a habitat objective. Even under alternative A, due to ongoing ranch sales and other factors, there is no way to predict the number of AUMs that would be grazed on the refuge (in 2008, 

were 

28–39. a (DEIS 28–40. there used). 
Comment 

Number Response

162 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–41. 28–42. 28–43. 28–44.

28–45.

28–46.

the economic 

work 

clear to bullet is not The relevancy of the 

analysis. We acknowledge the potential impact on DNRC 

with we would in the past, done have we As 

28–41. lands. DNRC to assume any permits if permittees no longer desire to retain their permit. DNRC indicated that this would be acceptable for them, so we do not see how there would be an impact to schools. 

There are currently about 670 miles of roads open on 28–42. 

the refuge, which, combined with boat access from the lake and river, provide close access to most of the refuge. Many of the roads identified in DEIS for closure would occur because a landowner has already closed off access, the road is unsafe, the road is duplicative, there is little use, or there are wildlife security issues. The closure of less than 5 percent of roads, many of which are already impassable or duplicative, would have a negligible impact on refuge visitation and the quality of visitor experiences (DEIS 304), particularly since road 209 and possibly other roads would be improved. 

This issue was addressed in the DEIS (pages 328–331) 28–43. 

and we added more text in the FEIS. 

There are seven new positions that would be filled in 28–44. 

the next 15 years (DEIS page 142) as compared to current conditions (DEIS page 324). Given it is a 15-year plan, the projections for staff or visitation increases are conservative for 

in prepared was report economic the of 

a refuge of this size. 

draft first The 28–45. 

2008. Except for the historical employment index (1975–2006) 

- chart (DEIS page 243, figure 37), all data was updated in De

cember of 2009 with the most current data available. 

It is not clear what the relevancy of the comment is to 28–46. 

the analysis of the direct, indirect, and cumulative impacts. During the internal review process, the counties criticized us for using too large of an analysis area.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 163

Letter #28: Lund Law, Bozeman, Montana

28–47.28–48.28–49.28–50.28–51.28–52.28–53.28–54.

- The economic impacts of revenue-sharing were dis

do nor 

e agree, and we have clarified this in the FEIS.

e currently buy inholdings 

-- tax rev

-

-

in property 

refuge, 

the direct and secondary 

Therefore, changes conditions. 

W

market 

Under alternative C, which would result in the greatest 

-

Most infestations of Canada thistle are a result of dis

e have ex28–47. 28–48. cussed in the DEIS (page 313). W from willing sellers, and this will not change under any alterna tive. This is clarified in the FEIS. The location and timing of future land acquisitions are based on unforeseen opportunities and enue and revenue-sharing payments of potential future land acquisitions are speculative. 28–49. increase in refuge visits, there would be a projected increase of fewer than 50,000 visits annually (13,000 plus in alternative D) spread over six counties and hundreds of miles of roads. These increases would occur slowly for the next 15 years (DEIS page 295). Presumably most of these visits would not require emer gency services, and the additional needs for services are small. 28–50. turbance. See responses 28–23 and 28–26.on the wolves no are Currently, there 28–51. we have plans to introduce wolves onto the refuge. An indepth economic study is not required. We will move to prescriptive grazing under all the 28–52. alternatives. Furthermore, it will not necessarily be a “loss” of grazing. Since it would be a prescriptive program, it is not ap propriate to compare it to other refuge activities. W

panded the discussion about prescriptive grazing in the FEIS.

317) looks at (DEIS page Table 35 

effects of grazing on the refuge. The refuge accounts for 4 months of a ranch operation. The economic effect of refuge grazing is considered negligible compared to overall grazing in the six counties. 
Comment 

Number Response

164 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana s estimates of current visitation figures was The refuge’ come from a variety of sources including traffic counters, phys- ical counts, and hunter permits. The estimates of increased visitation for the next 15 years are modest numbers (see re- numbers those behind rationale the and 28–49), 28–53. sponse explained (DEIS pages 105–107 and 112–114). The comment fails to provide any facts as to why the data is inaccurate. In the FEIS, we have clarified the visitation numbers in the DEIS (page 227) The no-action alternative factors in previous reductions in grazing on the refuge (DEIS pages 247–248). As shown in figure 41 (DEIS page 248), cattle inventories in the six counties have remained stable or increased since 1984. Other than the objection to the introductory section 28–54. in the (DEIS page 84), it is not clear what the specific issue is regarding the climate change objectives detailed in the DEIS (84–86). The focus would be on building resiliency of the ref-

-

s habitats by working to reduce stressors like habitat uge’

fragmentation and invasive species, combined with conducting research and monitoring. The U.S. Global Change Research Program coordinates and integrates Federal research on changes in the global environment. It was mandated by 

1990 

and 

of Act Research Change 

a “comprehensive for called 

Global 

which 

the Congress in 

101–606), Land 

U.S. the 

(Public integrated United States research program which will assist the Nation and the world to understand, assess, predict, and respond to human-induced natural processes of global change.” There are many agencies including the Service that contribute research for this program.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 165

Letter #28: Lund Law, Bozeman, Montana

28–55.28–56.28–57.28–58.28–59.28–60.28–61.28–62.28–63.

-

There has been significant observation of visible deg- 28–55. 

radation of vegetation, including loss of vegetation and soil erosion observed by refuge staff and other scientists (DEIS pages 194–199). In the FEIS we updated the discussion on prescriptive grazing.

Prescriptive grazing would enable the refuge to use 28–56. 

grazing to benefit wildlife, which is not currently occurring in many areas of the refuge (DEIS pages 168–169). We would have greater ability to control factors like timing, location, and 

an

for the 

-

e 

-

numbers under a prescriptive program, as compared to an 

annually 

A. 

s remarks you cite 

where livestock grazing is used nual program 

entire grazing season.

The DEIS (pages 268–269) discusses how the shrubs 

are favored by many species including livestock. 

W

28–57. 

The riparian health has improved largely due to a de 28–58. 

crease in annual livestock grazing in some areas (DEIS pages 168–169), but not every stream or local area has shared this improvement. Areas where intensive grazing still occurs have suffered significant decline (DEIS page 197).

There was information provided in chapter 4 discussing 28–59. 

what our monitoring efforts has revealed on the refuge. In the FEIS, we added further discussion. All alternatives will continue to move toward carrying out prescriptive grazing across the refuge, which is consistent with our legal mandates. Only the time frame would vary between alternatives. Whave worked with many ecologists and specialists throughout the planning process. Furthermore, the Improvement Act only requires a refuge manager to look at available science when making a recommendation about whether a use is compatible or not. It is also consistent with the provisions of NEP

e have moved toward carrying out prescriptive graz 28–60. 

ing (34 percent currently), but it is still largely managed as an annual grazing program. In a review of the public transcripts from October 12, 2010, the Barron Crawford’are taken out of context (Lewistown transcript pages 38–40). 
Comment 

Number Response

166 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana

- habi wildlife for 

, heterogeneity

A document is a 

. The 

-

manage to supposed are we that 

Comment noted. 

The use of the word “likely” in a NEP

. Crawford spoke about the sentinel plant concept not being Mr

a new concept. He did say it was new for this refuge, and he emphasized tat and not a range. The intention is not to return to historical 

, conditions, but to promote biological diversity

and resilience. 28–61. 28–62. common practice in describing what impact could occurobservation made in the DEIS (page 187) is based on direct field work on the refuge and the professional opinion of a biologist (DEIS page 350).

The reference was for discussing compatibility of the 28–63. 

livestock grazing program and the time spent by personnel who are directly involved with the grazing program. This has been clarified in the FEIS. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 167

Letter #28: Lund Law, Bozeman, Montana

28–64.28–65.28–66.28–67.28–68.28–69.

The DEIS did discuss the efforts of prescribed fire and 

grazing on refuge resources. The magnitude of the effects on water resources is directly related to fire severity, and wildfires are typically more severe than prescribed fire (Neary et al. 2005). In the FEIS, we added more information about water 

s observa- None of the alternatives rely solely on Murie’

tions and report. It is true that many things have changed during the last 75 years, many of them to the benefit of wildlife 

e use his report, based on site visits 

throughout the refuge and conversations with many residents, 

e have continually maintained that the role of the 

CCP is to identify the roads that are necessary for habitat and wildlife management and public uses. This is consistent with 

-

the guidance found in the Improvement Act and the Service’s 

. The role of the CCP is not to resolve rightse agree that these are important issues, but 

have 

. Given there is substantial 

variance in the records kept by the six counties, these issues 

we However, 

worked with Petroleum County in addressing rights-of-way (DEIS page 231), and it certainly shows that many of these is

neededis what 

e have incorporated

several of these suggestions in the CCP and EIS, includingwinter access for ice fishing as suggested by Fergus County andimprovements to the Knox Ridge road, also in Fergus County.

In defining the no-action alternative (alternative A), 

we reviewed the existing guide map (last revised 2002), 

earlier guide maps, old files, wilderness studies, and other 

e have not found 

any inconsistencies in our interpretation of the no-action 

closures, road 

, there are few 

about 

Past 

them. 

should be addressed at the county level. 

provided suggestions 

for habitat, wildlife, and public uses. W

DEIS. 

resolving 

sues can be resolved good-naturedlyinformation we could find on refuge roads. W

the in 

for tool not 

resources. planning policyof-way disputes. W

is 

W

CCP the 

Counties have 

is portrayed 

the 

it 

28–64. and wildlife habitat. Was an expert reference.28–66. 

alternative as 

some dating back more than 30 years, are not relevant to the 

ith 670 miles of roads open on the 

28–65. no-action alternative. Wrefuge and boat access from the lake and riverplaces on the refuge that cannot be accessed within a mile of existing access. 
Comment 

Number Response

168 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana Road we have changed D, alternative for FEIS, the In 28–67. 315 to seasonally closed from the junction of Road 848 to its Comment noted. Through communication and cooperation, whatever end. 28–68. 28–69. actions are needed to rescue a visitor will be accommodated. Under all alternatives, the Service will carry out management actions through cooperation and collaboration with Federal, State and local governments. Existing facilities should be universally accessible and conform to accessibility standards; however, as noted in the DEIS (page 232), there are hundreds of miles of open refuge roads that are available for hunters of all abilities in addition to the accessible hunting blind.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 169

Letter #28: Lund Law, Bozeman, Montana

28–70.28–71.28–72.28–73.28–74.

A, 

-

We reviewed the policy requirements under NEP

e disagree that the proposed 

s NEPA regulations, and our planning policy including ex

hibit 2 (602 FW3), which lists mandates to consider during the 

e found no information about any procedural 

9–16, 

-

(items a CCP 

regulation, or policy beater Con-

. As stated in the DEIS (page 

-

being necessary for 

CCP process. Wrequirements analysis 18, 20, 21), as there is no rule making, ing developed. 

. 

e reviewed our Energy Management and W W

s water needs, and that of its 

28–71. servation policy 373 FW1, and the actions detailed for all alter

See response 28–70. W

of this policy

Consistent with guidance published by the Council 

28–70. DOI’natives under climate change (DEIS page 86) meet the intent 

, we believe that the actions being 

28–72. For items 15–16, see response 28–70.28–73. on Environmental Qualityconsidered in the CCP will not result in disproportionately high and adverse effects to minority populations, low-income populations, or Indian tribes. 28–74. plan will take private property174), the United States holds Federal reserved water rights on the Charles M. Russell Refuge and UL Bend Refuge. The United States is in the process of quantifying these reserved 

ater Rights Compact rights with the Montana Reserved W

Commission. Furthermore, as stated in the DEIS (page 175), the United States anticipates the compact will protect exist

, BLM. The CCP makes no mention of taking any 

ing private rights, the refuge’sister agencyprivately held right.
Comment 

Number Response

170 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–75. 28–76. 28–78. Preservation 

-

-

and 

Historic 

e addressed the suggestion that there be an alterand 

-

its 

DEIS 

Act 

habitat 

The 

and 

.

managing 

, each refuge is to be managed 

as as 

refuges. 

birds 

System, 

ildlife Refuge System 

ildlife populations are not 

other 

Order 

Executive 

refuge 

Conservation 

well 

the 

of 

Executive 

the 

identified in 

thought 

. Habitat conditions 

species 

Murie 

National 

Resources 

for options 

Refuge 

separating 

250 

levels 

Olaus 

of 

than 

pursue 

See response 28–76.

of the 

species identified in 

the 

that 

ater W

range 

line 

more 

to 

and 

mission 

boundary 

a primary grouse, 

close 

40,000 

regularly 

Soil 

the 

including 

W

the 

fulfill 

of 

are not even 

the or 

e 

the 

W

a reasonable 

refuge, 

7509 

28–75. Act-related consultation and compliance on existing activities planned on the refuge including those in the CCP

See response 28–70. There has been substantial coordi 28–76. 

nation with local governments. Furthermore, your interpreta

of tion 

how it applies to this CCP and EIS is not correct.28–77. 28–78. native that only considers sharp-tailed grouse and livestock grazing in the DEIS (page 138). Our alternative approaches identify public uses. The 9th Circuit Court of Appeals has twice upheld our management of the refuge (DEIS pages 27–28), as has the U.S. District Court in a separate ruling. The alternative approaches are in keeping with previous court decisions. 

As stated in the DEIS (page 4), which describes the 

purpose and need for the CCPto specific purposes. The Improvement Act states that wildlife conservation is the singular National Wmission. Even though UL Bend Refuge and Charles M. Russell Refuge have different establishing purposes (DEIS page 19), they are managed as one unit. Waware (pages 203–224) describes diverse wildlife populations found on the trust species. The refuge has been recognized as a globally important bird area (DEIS page 211). The numbers of sharptailed 7509 Order could support. As Murie found in his original biological assessment (DEIS page 25), sharp-tailed grouse spend time in the river bottoms, as well as the heads of many draws. Their numbers are determined by the food supplysignificantly affect populations whether it is a sharp-tailed grouse, a greater sage-grouse or other species of concern 

28–77.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 171

Letter #28: Lund Law, Bozeman, Montana

found on the refuge (DEIS page 138), or the multitude of other 

The DEIS describes how existing habitat units are failing 

to meet monitoring protocols (DEIS page 191). The DEIS (pages 190–193 and 194–198) discusses the degradation that has occurred on upland and riparian areas due to ungulate 

Livestock grazing is not a goal of the Refuge System, nor 

is it an inherent property right (DEIS pages 14, 28, 137–138). 

ildlife Refuge 

subject and 

Grazing is a privilege, and under the National WSystem Administration, as amended by the Improvement Act, 

refuge a of use secondary 

important grassland birds. grazing including livestock.

a is grazing livestock 

to a determination that it does not materially detract from achieving the primary wildlife purposes of the refuge. In a review of the other game ranges that were established with the same livestock grazing provisions as Charles M. Russell Refuge, we found that livestock grazing, as a secondary use was eliminated or stopped on these refuges, largely due to noncompatibility with the wildlife purposes. The Improvement Act strengthened this requirement even further to ensure compatibility in permitting secondary uses. 

In the CCP and EIS, the refuge manager has decided (DEIS 

page 372) that for livestock grazing to be compatible with its wildlife purposes, it must be a prescriptive grazing program and not simply a continuation of the annual grazing program. This is consistent with the Improvement Act, biological integrity policy (FWS 2001), and the compatibility policy (FWS 2000a).
Comment 

Number Response

172 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–79. 28–80. 28–81.

28–82.

e have no have no intention

of eliminating livestock grazing, as stated in the CCP and EIS.

several

we

s

-

-

- infor

by 

DEIS, 

expressed 

the on commented 

and presenting quality 

This statement is not true. W

grazing livestock 

who some 

to 

including 

of 

28–79. 

spite In 

stakeholders, rejected this suggestion from further consideration (DEIS page137). The Great Plains evolved through a complex interaction ofprescribed fire and grazing, and to eliminate it from a manager’toolbox for managing habitat is not realistic or desired. However, as stated throughout the document, we need to managethe refuge in a manner that achieves wildlife objectives and ourlegal mandates. See response 28–80 about the Data Quality Act.

In a review of our policy (Information Quality Guide

lines) for meeting the Data Quality Act, the guidelines affirm 

distributing 

opposition 

importance of 

28–80. the mation. Of interest in the counties’ comment that the data in DEIS violates the Data Quality Act and is not supported by verifiable science, the guidelines state that the burden is on the requester to show that the information needs to be corrected as well as the type of correction being sought. It is also up to 

there is no 

-

-

exno , 

should 

et, evidence. Y

no page number

how it 

integrity refers 

is incorrect, or 

letter 17–79, 

supporting show to 

the comment. There is 

information why the 

requestor the 

specificity in planation of be corrected. For clarification, in to the security and protection of information, not scientific or 

-

specific, 

-

are hand, 

professional integrity as is suggested here. 

See response 28–78. No alternative will “let nature run 

, they will represent more specific aims of our manage

28–81. its course.” All alternatives include specific action objectives to are intended to be descriptive, open-ended, and broad statements of desired future conditions that convey a purpose, but do not define measurable units. Goals will relate to the vision; 

other on the 

manage habitat and wildlife.

Consistent with our planning policy (FWS 2000c), goals 

Objectives, strategies. 

28–82. howeverment measurable, results-oriented, and time fixed. All of the objectives (DEIS page 59) meet the criteria. Counties participated in both the biological objectives workshop and the public use workshop (each 3 days), and a detailed reference document with this information was provided.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 173

Letter #28: Lund Law, Bozeman, Montana

28–83.28–84.28–85.28–86.28–87.28–88.28–89.

, and , biological integrity The terms biological diversity

environmental health are taken directly from the Improvement Act and the biological integrity policy (601 FW3). They 

(page 40) 

-

DEIS the in used 

e note the counties’ disnot 

are clearly defined in our policy.

was 

Comment noted.

“historic” word The 

28–83. 28–84. or anywhere else in chapter 3 with respect to prairie dogs or in describing alternative concepts. It was used in discussing historic properties under cultural resources and historical fireintervals. Detailed information about black-tailed prairie dogs is discussed in the DEIS (pages 220–221).

Comment noted. Comment noted.

Since “goal” is not used in the DEIS (page 66), we note 

28–85. 28–86. 28–87. that the term “sentinel species” was used in context of the objective, and as part of the objective it includes “reducing a selectivity for sentinel species.” Wagreement with the alternatives, but disagree that there is no scientific basis. Although the word “sentinel” was a term we coined for identifying the species that are most likely to decline first on the refuge (DEIS page 346, appendix F), the term sentinel, indicator species or diagnostic species is not unique in 

e are in the process of working with range scientific journals. W

ecologists, statisticians, and other scientific disciplines (DEIS page 67) to develop monitoring protocols. In the FEIS, we clarified that monitoring protocols would be peer reviewed in accordance with our information quality guidelines.

The term “prescriptive grazing” was defined in the 28–88. 

DEIS (page 345), and in the FEIS, we have clarified the definition and provided more information about its application under all the alternatives. County representatives sat through all the discussions during the planning team meetings and should know that there are no “code words.” 28–89. See response 28–87 on monitoring protocols.
Comment 

Number Response

174 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–90. 28–91. 28–92. 28–93.

28–94.

come 

-

e take great measures to ensure prescribed fires reincurred 

has 

main within their designated boundaries and thus far no prescribed fire ignited on the refuge has ever escaped. If this 

-

Ad-

“not 

back” from the use of prescribed fire on the refuge or of a 

While very 

ort Claims Act (28 United 

escaped onto private land. 

little prescribed fire has been used on the refuge (DEIS page 194), there have been large wildfires that have occurred on the refuge (DEIS pages 188–189). Our prescribed fire objectives are intended to reduce the potential for large catastrophic States Code [U.S.C.]§§ 1346(b), 2671–2680) provides an avenue 

losses 

that 

for 

area an of 

government 

given were 

, the Federal T

the petition 

that has 

sellers through our realty division. 

examples No 

prescribed fire fires. Wevent were to occur

landowners to 

due to government activities. Individual counties also have the option of pursuing expenses incurred during the suppression of escaped prescribed fire as outlined in the Montana Cooperative Fire Management and Stafford Act Response Agreement, 

. The analysis was peer reviewed 

commonly known as the Six Party Agreement. 

Comment noted.

e disagree with the claim that the economic effects W

, the sale of cabin sites (DEIS page 13) will be used 

28–90. were not analyzed properly

W

28–91. 28–92. prior to the release of the DEIS, which we have clarified in the FEIS. Furthermore, the comment provides no specific examples of any inaccuracies. 

Grazing is a privilege and not a right on a national wild 28–93. 

life refuge. As such, grazing permits cannot be capitalized or taken to the bank (DEIS page 28). 

e currently acquire lands within the authorized refuge 

for 28–94. boundary from willing ditionallyin acquiring other lands with greater wildlife and public value. It should have been made clearer in alternative A, although we did note it in the cost analysis and in the DEIS (pages 129, 

e have since clarified this in the FEIS. Also, 130, and 157). W

we do not expect to acquire lands any differently from existing conditions.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 175

Letter #28: Lund Law, Bozeman, Montana

e presume you are referring to several large wildfires 

that occurred in 2003 and again in 2006 (refer to DEIS, page 188). These were lightning-caused fires followed by significant weather events. The rationale behind using prescribed fire is to reduce the number and acreage of large wildfires. See 

e initiate discussions with landowners when 

As stated in the DEIS, we will take aggressive suppression action on any portion of a wildfire that threatens to escape 

the refuge unless agreements with cooperating agencies, counties, or landowners are in place stating otherwise. But, we will 

ildland Fire 

action 

on fires burning within the boundaries of the refuge, per the 

. This fire management 

policy states, “The role of wildland fire as an essential ecologichange agent will be incorporated into 

- the planning process.” Federal agency land and resource man

agement plans set the objectives for the use and desired future 

- The DEIS (page 99) does not propose any reintroduc

The fishing objectives in the DEIS (pages 107–109) 

-

enhancing 

improving 

- the af

continue to evaluate each wildfire through the W

appropriate 

with 

the 

committed to 

by and youths for especially opportunities, 

28–95. their property is next to a burn unit.

determine System Support Decision 

condition of the various public lands. 

e are W

that collaborating 

to 

goal.” 

Comment noted.

the “fishing 

W

response 28–90. W

under 

28–96. 2011 Federal Fire Management Policy

agree 

cal process and natural 

we addition, 

28–97. tion of gray wolf. 28–98. 28–99. were developed to meet the public use goal, so it is unclear where the counties want to add “enhance fishing opportunities” more access. In fected agencies would be important, which was detailed in the partnership objectives in the DEIS (pages 131–133 and 139).

28–95.28–96.28–97.28–98.28–99.
Comment 

Number Response

176 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–100. 28–101. 28–102.

28–103.

Any future rights-of-way needed to develop minerals 

a on considered be 

28–100. are outside the scope of the CCP and EIS.

would development 

See response 28–94.Comment noted.

that agree e W

28–101. 28–102. 28–103. site specific basis and that all tanks should have wildlife ramps installed. The value of providing winter wildlife watering sites is questionable. As with all practices on national wildlife refuges, water development decisions will be based on the need to improve wildlife habitat and how it may affect naturally occurring riparian habitat. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 177

Letter #28: Lund Law, Bozeman, Montana

28–104.28–105.28–106.28–107.

e disagree that we have ignored the 9th Circuit 

e disagree that we did not 

- environ

cultural 

resources, a portion of which are related to ranching (chapter 4, affected environment). Furthermore, the comment does not provide a substantive example of how actions in the CCP and EIS would impact ranching heritage or other significant cultural resources. There is not even a designated heritage site 

- is no speci

all the “legalese” of 

this paragraph, we can only emphatically state that the direct, indirect, and cumulative effects of the full range of alternatives 

e would point out the indepth 

discussion in chapters 4 and 5 regarding past and current 

, livestock 

grazing, access, history and the socioeconomic environment. figure 41 and table 23 (DEIS pages 248–249) depict the past and current impact of the refuge in the six-county area. The 

FEIS, the 

Court of Appeals or that we have not followed NEPA.

the to 

hundred 

impacts 

several 

Since there 

in upon 

within raised 

Comment noted.Comment noted.

See response 28–14. W

refuge boundary. 

potential 

documented 

. W

expanded further been 

analyzing in 

issue 

has refuge 

next to the 

substantive 

has been discussed thoroughlyconditions, including the demise of bison, fire ecology

has 

A 

W

NEP

The 

28–105. 

28–106. 

within or 

or 

which 

28–104. 

28–107. follow ment. ficity DEIS, provides an indepth discussion on issues that are important to counties. 
Comment 

Number Response

178 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #28: Lund Law, Bozeman, Montana 28–108. 28–109. 28–110.

28–111.

-

The DEIS (pages 134–139) described the historical pesocioeconomic impacts 

, there is no other formal designa

CCP 

-

in the actions 

riod including the ranching era and the 

area. All heritage such as a cultural 

and EIS that would impact historical or prehistoric resources would have to be cleared through the State Historic Preserva

Comment noted. The direct, indirect and cumulative 

areas management the special alternatives on the of 

See response 28–78. Executive Order 7509 made a 

provision for livestock grazing only to the extent it remained compatible with the primary purposes. 

Thank you for your comments.

28–108. of the alternatives. Currentlytion tion Office (letter 8).

28–109. effects was addressed.28–110. 

28–111. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 179

Letter #29: Maryland Ornithological Society, Ellicott City, Maryland
Comment 

Number Response

180 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #29: Maryland Ornithological Society, Ellicott City, Maryland
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 181

Letter #29: Maryland Ornithological Society, Ellicott City, Maryland

29–1.29–2.29–3.

Comments noted.

29–1. Comments noted. See response 29–4. 

Comments noted.

29–2. 

29–3. 
Comment 

Number Response

182 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #29: Maryland Ornithological Society, Ellicott City, Maryland 29–4. 29–5. 29–6.

29–7.

-

We made several changes to the proposed wilderness 29–4. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommend

proposed 

ing deletion of any existing proposed wilderness area.

managing for policy The 29–4. response See 29–5. 

wilderness can be found in our wilderness stewardship policy 

ilderness Review and Evaluation” (4.23 and in “Chapter 4—W

4.22 B and C).

Road management on the Charles M. Russell Refuge 29–6. 

received considerable public comment, as referenced in the 

-

management in on road perspectives We considered all DEIS. 

preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative. In the FEIS, we made several modifications to alternative 

seasonal additional alternative) to incorporate D (preferred 

road closures.

The refuge has currently applied for mineral withdrawal 29–7. 

extensions for lands within the refuge boundary and this has been clarified in the FEIS.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 183

Letter #29: Maryland Ornithological Society, Ellicott City, Maryland

29–8.29–9.

Comments noted. 29–8. 

29–9. Thank you for your comments. 
Comment 

Number Response

184 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #30: Missouri River Stewards, Winifred, Montana 30–1.

30–2. -

Comment noted.

Only the U.S. Congress can designate a permanent with

30–1. 

30–2. drawal and we have clarified this in the FEIS. Nonetheless, we will continue to advocate for a permanent withdrawal to protect habitat and wildlife values on the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 185

Letter #30: Missouri River Stewards, Winifred, Montana

30–3.30–4.30–5.30–6.

-

-

e have no intention of taking away any private prop

knowledge, regarding 

e disagree. Grazing permits expire annually and a 

-

-

mineral extraction. To our 

there has never been a mineral lease or patented resource on 

- the refuge. Under existing conditions, there are no direct, indi

rect, or cumulative impacts. This would hold true for all of the alternatives. There is already a mineral withdrawal in effect for locatable minerals, and we are in the process of renewing this and have also clarified the mineral language in the FEIS.

The 

e 

-

privilege. 

socioeconomic 

grazing a refuge on capitalize 

orking Group, USACE, BLM, and others 

cannot 

W

right 

W

e have worked with county extension agents, Mus

We described in detail the impacts to riparian areas.

30–3. erty 30–4. permittee refuge is not managed under a multiple use mandate. Under all alternatives, we carry out a prescriptive grazing program. Whave clarified and provided more information about prescriptive grazing in the FEIS including our legal mandates in the no-action alternative. Furthermore, we stand by the socioeconomic analysis and the comment provides no substantive data as to why the information contained in the analysis was incorrect.

The refuge is not mandated under a multiple use man

30–5. 30–6. date. Wsellshell River W(DEIS page 200).
Comment 

Number Response

186 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #30: Missouri River Stewards, Winifred, Montana 30–7. 30–8. See response 30–6. Comment noted. 30–7. 30–8. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 187

Letter #31: Montana Association of Oil, Gas, & Coal Counties, Inc., Forsyth, Montana

Only the U.S. Congress can designate a permanent with- 31–1. 

drawal and we have clarified this in the FEIS. Nonetheless, we would continue to advocate for a permanent withdrawal to protect habitat and wildlife values on the refuge.

31–1.
Comment 

Number Response

188 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #32: Montana Audubon, Helena, Montana 32–1.

32–2.32–3.

Comment noted.Comment noted.Comment noted.

32–1. 32–2. 32–3. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 189

Letter #32: Montana Audubon, Helena, Montana

32–4.32–5.32–6.32–7.32–8.32–9.

The Service will embark on a transportation plan for the 

. In addition, we have refuge following completion of the CCP

made adjustments to alternative D to incorporate more seasonal road closures, retrieval roads, and permanent closures. 

e considered all perspectives on road management in preparing the FEIS and the balance for vehicular access was a hybrid 

version that incorporated elements from each alternative. 

wilderness proposed the to changes several made e W

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 

Comment noted.Comment noted. Comment noted. Comment noted. 

32–4. W32–5. 32–6. 32–7. 32–8. 32–9. 
Comment 

Number Response

190 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #32: Montana Audubon, Helena, Montana 32–10. 32–11. 32–12. 32–13. 32–14.

32–15.32–16.32–17. -

-

man species 

amarisk (saltcedar) is a major 

levels have exposed soils to 

. 

invasive with involved 

Comment noted.Comment noted.Comment noted.Comment noted.Comment noted.Comment noted.Comment noted.

actively are e W

32–10. 32–11. 32–12. 32–13. 32–14. 32–15. 32–16. 

32–17. agement on the refuge. Russian olive invasion on healthy riparian areas along the Missouri has been minimal and will be addressed in the future. Tproblem on the shoreline of Fort Peck Lake where livestock disturbance and fluctuating water new infestations. The Service and our partners will continue to treat tamarisk infestations as money and manpower allow
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 191

Letter #32: Montana Audubon, Helena, Montana

32–18.32–19.32–20.32–21.32–22.32–23.32–24.

Independent of the CCP process, we are renewing the 

clarified 

-

-

was this 

e do not have 

refuge; 

, it is anticipated that 

are 

the for 

easements 

withdrawal 

The 

mineral 

Comment noted.

Comment noted.Comments noted. Comments noted. Comments noted. 

The explanation of why the sale of cabin sites is not 

protect to intended interests. private 

32–18. locatable in the FEIS. Leasable minerals, such as Federally owned oil and gas, will be susceptible to development depending on administrative policies at the time and compatibility use determinations.32–19. 

32–20. 32–21. 32–22. 32–23. 

32–24. addressed can be found in the DEIS (page 13). Wcontrol of the sale of cabin sites. Howeverall sites that end up selling will be completed by the end of 2013. There is an easement and declaration of covenants that are being recorded with the certificate of surveys prior to divestiture of each lot. These documents provide the assurances required by the Enhancement Act. 

Easements are being retained on all cabin sites that are sold 

to refuge values in and around the cabin site area.
Comment 

Number Response

192 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #32: Montana Audubon, Helena, Montana 32–25. 32–26.

- Checkerboard ownership was avoided as much as pos 32–25. 

sible by creating common boundaries between cabin sites. Cabin site sales and replacement lands were addressed in the 

ildlife Refuge Enhance- 2000 Charles M. Russell National W

ment Act (DEIS page 13). Cabin site sales or acquisition is not part of the CCP process. 

We currently have 11 State land leases totaling 7,800 

-

32–26. acres. In addition, we are currently in the early stages of discussions with Department of Natural Resources and Conservapossibility refuge and the within the State lands tion regarding of relocating those lands outside the executive order boundary. 

it is mutually beneficial to both only be done when This will 

agencies and the public. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 193

Letter #33: Montana Farm Bureau, Bozeman, Montana

33–1.33–2.

Since the implementation of the 1986 EIS record of deci- 33–1. 

sion, there has been a move toward carrying out prescriptive grazing either when a ranch sells or when habitat conditions 

- dictate it. This would not change under the no-action alterna

tive. In the FEIS, the Service has added language clarifying our legal mandates, what prescriptive grazing means, and how 

-

it would continue to be carried out on the refuge.

Fence maintenance is a major labor drain for both live

. Not all fences will be re33–2. stock permittees and our agency

moved, but where it is possible to move livestock to different parts of a larger pasture, with the use of horses and riders, it 

fences maintaining than intensive labor and costly less be will 

over a longer period of time. This method was successfully used with the Whittmier Grazing Association. The decision was made, by the permittee, to move livestock rather than chase lake levels with division fences. 
Comment 

Number Response

194 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #33: Montana Farm Bureau, Bozeman, Montana 33–3. 33–4. 33–5. 33–6.

33–7.

ildlife Refuge 

-

Unlike other public lands, the National W

Administration Act does not provide for the transfer of grazing privileges when a ranch sells. Neither the Public Rangelands Improvement Act of 1978 nor the Federal Land Policy and Management Act of 1976 apply to refuge lands. Privileges cannot be capitalized into the sale of the ranch (DEIS page 14). 

- For this refuge, a policy was put into place to allow for trans

fers of permits when ranches were passed on within families. 

While we understand the concerns expressed, the refuge 

is required to manage for wildlife conservation and not for 

graz

e are committed to 

mandates, legal our meet o grazing. T

working with permittees as new habitat management plans are developed to find ways for them to make arrangements in their 

- , the DEIS did not specifically call for reduc

-

livestock 

for the elimination 

33–3. 33–4. livestock ing needs to be managed prescriptively. Woperations (DEIS page 66).

Comment noted.

To clarify

33–5. 33–6. tions in AUMs. None of the alternatives call of livestock grazing on the refuge, and we chose not to consider this as an alternative (DEIS page 138). However, the refuge 

-

. 

. must be managed for wildlife as a priority

the State as to how we would in cooperation with 

We do not have plans to reintroduce wolves or grizzly 33–7. 

bears onto the refuge (DEIS pages 98–99), but as the comment states these species are found in Montana, and we recognize the potential for these species to migrate down the river cor

. In addition, we think it would be shortsighted to not de ridor

velop a plan manage these species should this migration occur
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 195

Letter #33: Montana Farm Bureau, Bozeman, Montana

33–8.33–9.

33–10.33–11.33–12.

e already cooperate with several partners in carrying 

e take great measures to ensure prescribed fires 

remain within their designated boundaries. No prescribed 

were 

tive Fire Management and Stafford Act Response Agreement, 

-

100

event this 

landowners to petition the government for losses incurred due to government activities. Individual counties also have the option of pursuing expenses incurred during the suppression of escaped prescribed fire as outlined in the Montana Coopera

more than 

If 

10 years, 

escaped. 

ort Claims Act provides an avenue for 

. As stated in the DEIS, 

s plan for prairie dogs.

ever has 

See response 33–7.

Comment noted.

refuge the 

out the State’

on 

W

W

ignited 

33–10. 33–11. commonly known as the Six Party Agreement. 

During the past burn unit. to a 

33–8. 

33–9. to occur the Federal T

e initiate discussions with landowners when their property W

 andcontrol of out get often fires prescribed that 

next 

fire prescribed fires comprising of more than 50,000 acres have beenignited in the Eastern Montana Fire Management District,which includes the refuge. Many of these burns were next toprivate property and several landowners granted us access totheir roads and property lines to more efficiently burn the units.

assertion 

is The damage private property is not factual. The same standards and

e will continue to evaluate 

ildland Fire Decision Support 

. This policy states,“The role of wildland 

principles would apply when burning on the refuge.

e do not have a “let it burn” policy W

we will continue to take aggressive suppression action on any portion of a wildfire that threatens to escape the refuge unless agreements with cooperating agencies, counties, or landowners are in place stating otherwise. Weach wildfire through the WSystem to determine the appropriate action on fires burning within the boundaries of the refuge, per the 2011 Federal Fire Management Policyfire as an essential ecological process and natural change agent will be incorporated into the planning process.” Federal agency land and resource management plans set the objectives for the use and desired future condition of the various public lands.” 

Comment noted. 33–12. 
Comment 

Number Response

196 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #33: Montana Farm Bureau, Bozeman, Montana 33–13. 33–14. 33–15.

33–16.

As stated in the DEIS (page 174), we are in the process 

of quantifying reserved rights, which will be settled by the 

property away any valid of taking intention we have no 

33–13. court; right. Only the U.S. Congress can designate wilderness and until then any new expansion would be managed as a wilderexpansions iden- area. Furthermore, the wilderness ness study tified in alternatives B and D are mostly round outs of existing units. Except for two of the expansions, the units are already being prescriptively grazed, and the permittees are already managing their livestock within the confines of any restrictions imposed by the proposed wilderness designation. There are no private inholdings within the expansions. Alternative D would have no road closure associated with the expansion so it would not affect access. There are several roads that would be closed 

-

page (DEIS 

in alternative B that abutted the expansions.

e currently acquire lands from willing sellers within 

extraction mineral for rights State or 

W

held 

33–14. the authorized boundary and this was clarified in the FEIS.

The CCP and EIS did not address the exercise of pri 33–15. 

Thank you for your comments.

vately 

e have no intention of taking any privately held right, 13). W

nor did the DEIS refer to such (DEIS page 130). Given that our mission is wildlife conservation, wherever possible we would seek to protect those values in future acquisitions.33–16. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 197

Letter #34: Montana Mountain Bike Alliance, Bozeman, Montana

34–1.34–2.34–3.

The refuge agrees that bicycle use as a travel option for 

hunting is appropriate on a national wildlife refuge. You are 

bicycles restrict current regulations do 

, bicycles are also permitted on 

stating that 

34–1. correct in to numbered routes. Howevernumbered routes that are seasonally closed to motorized vehicles. This has been an asset to the bicycle user group and the hunter as a means to gain access to areas not accessible with a motorized vehicle.

Alternatives A, B, and D allow bicycle use on all num- 34–2. 

bered roads, including seasonally closed roads, while alternative C would evaluate additional trails that are open to 

-

-

bicycles. The FEIS was revised to clarify the distinction be

tween the alternatives. Furthermore, the maps referenced in 

roads numbered all of depiction accurate an include chapter 3 

and any changes carried out in each of the alternatives. Alter

- native D does include some additional seasonal road designa

tions, which would benefit the bicyclist in terms of additional access.

You are correct that bicycling was not addressed under 34–3. 

appendix C, “Draft Compatibility Determinations.” It was added to the final document.
Comment 

Number Response

198 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #34: Montana Mountain Bike Alliance, Bozeman, Montana

-

See response 34–2.

Comment noted.

As stated in response 34–2, there are many numbered 

34–4. 

34–5. 

34–6. routes on the refuge that are open to vehicles, and the vast majority of them see little use except for during hunting season. 

34–4.

34–5.34–6.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 199

Letter #35: Montana Petroleum Association, Inc., Helena, Montana

35–1.35–2. Only the U.S. Congress can designate a permanent with35–1. Thank you for your comments. 35–2. 

drawal, which we have clarified in the FEIS. The current 

- 20-year withdrawal we are working to renew applies to locat

the e have clarified this in Wand gas. oil and not minerals able 

FEIS. Nonetheless, we would work to obtain a permanent withdrawal similar to UL Bend Refuge to protect the refuge’s habitat and wildlife values.
Comment 

Number Response

200 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #35: Montana Petroleum Association, Inc., Helena, Montana 35–3. 35–4. 35–5. 35–6.

- We have no intention of taking away any private prop 35–3. 

erty right regarding mineral extraction. There has never been a mineral lease or patented resource on the refuge. Under existing conditions, there are no direct, indirect, or cumulative 

-

impacts. This would hold true for all of the alternatives.

Comment noted.Comment noted.

While we can understand the positive benefits for wild

35–4. 35–5. 35–6. life and habitat by not extracting minerals on the refuge, it would be speculative to predict future impacts to the economy by simply seeking a permanent withdrawal from the U.S. Congress. There is already a mineral withdrawal in effect and we are in the process of renewing this. Furthermore, the refuge was set aside to protect wildlife values and not manage for multiple uses such as BLM lands. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 201

Letter #35: Montana Petroleum Association, Inc., Helena, Montana

35–7.35–8.35–9.

35–10.35–11.

- fuor existing 

be accessed. 

of 

Federal 

including 

-

-

-

ildfires often 

prescriptively 

to 

owner Any 

resilience 

how 

to follow 

leases would 

decision. 

been 

have 

, the summary at xx

of 

requirements, 

speculative to 

mineral 

would 

record 

application 

, prescribed fires in conjunction 

. Diversity is the frontline defense 

provides 

predict 

have 

and diseases 

or State 

the 

in areas that 

and 

in 

and 

be 

privately held 

selected 

regulations 

A analysis for any impacts that would occur 

would 

held mineral right 

It 

. In addition to setting priorities, there are other ways 

Science has demonstrated anthropogenic greenhouse 

intensively 

. The result is less carbon releasing into 

species 

less 

invasive 

State 

Comment noted.Comment noted.

35–7. 

As stated on the inside front cover

ture 

e are not aware of any applications to access minerals on W

the refuge. The process would be the same regardless of the alternative 

privately a 

and conducting a NEPto the surface.35–8. vii, and page 1 of the DEIS, the document discusses program levels that are sometimes substantially above current budget allocations and, as such, are primarily for strategic planning purposes. All agencies, including ours prioritize their expenditures, and we compete both regionally and nationally for moneyof accomplishing the goals including through partnerships and other solutions.35–9. gas emissions are a contributor to climate change. Managing wildlife under the context of a changing climate is one of the priorities of the Service (DEIS page 7). Fire is a natural part of the ecological system and occurs whether planned (prescribed fire) or unplanned (wildfire). More gases are released in a hot summer wildfire, which consume most of the biomass to mineral soil than in cooler prescribed fires. Wburn burned previouslythe atmosphere. Additionallywith other properly managed natural processes can encourage habitat and wildlife diversityagainst disturbances and climate change.35–10. 35–11. 
Comment 

Number Response

202 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #36: Montana Pilots’ Association, Big Fork, Montana 36–1. 36–2.

36–3.

Association s Pilot Montana’ that the It is unfortunate 36–1. 

was not aware of the planning effort. There has been substantial public outreach throughout the process (DEIS pages 353–357). 

In the FEIS, the Service has clarified that seaplane land- 36–2. 

ing sites will be maintained under all alternatives. 

Taxiing of aircraft is only allowed in designated landing 36–3. 

areas. Refuge and USACE regulations do not allow taxing aircraft on ice or open water to be considered as motorized open or frozen water craft. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 203

Letter #37: Montana Seaplane Pilots Association, Big Fork, Montana

37–1.37–2.

The Service does not have any plans to change the 37–1. 

current seaplane landing plan. The plan has worked well to 

minimal that there are agree resources. We wildlife protect 

impacts from seaplanes to wildlife or to the environment under the current policy. We clarified this in the FEIS. 37–2. Thank you for your comments.
Comment 

Number Response

204 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #38: Montana Stockgrowers Association, Helena, Montana 38–1.

38–2.

Cooperating agencies took part throughout the planning 

objectives on alternatives, workshops attending by 

38–1. process and strategies, roads, and discussions on the internal review document. Where possible, the Service incorporated the coe did not incorporate elements that operators’ suggestions. Wwould directly conflict with the Improvement Act. Instead, we 

- developed a range of alternatives for managing habitat, wild

- life, and public uses. Livestock grazing can be used prescrip

is different 

-

habitat. This improving wildlife tively as a tool for 

than traditional rangeland management practices associated with lands that are managed for multiple purposes. 

Prescriptive grazing is defined in the FEIS to give the 38–2. 

reader an understanding of the habitat management technique. The decision to not graze the Silver Dollar Habitat Unit for 10 years was based on habitat objectives which were never met within the unit. Annual habitat evaluations continue in Silver Dollar Habitat Unit and when full recovery occurs and habitat management treatment is needed, a decision will be made on the technique that will best accomplish the objective. The management technique selected may include grazing, prescribed fire, mechanical, or some other available tool.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 205

Letter #38: Montana Stockgrowers Association, Helena, Montana

38–3.38–4.38–5.38–6.38–7.

Specific grazing methods such as seasons of use, duration, and the number of AUMs for a habitat unit were not 

be specificity would 

the 

level of as that 

outlined in habitat management plans (DEIS pages 62–68 and 140). A CCP is a guidance document and not intended to 

suggested. Grazing, fire, and 

goals, and objectives. T

provide detailed prescriptions as other mechanized methods are tools we use to manage habitat, 

o meet 

legal mandates imposed by the U.S. Congress, (DEIS page 4) the refuge must transition to greater reliance on prescriptive grazing. While some permittees could be negatively impacted, for those who can modify their operations to help us achieve our habitat objectives, there will be opportunities for grazing on the refuge. As shown in table 54 of the DEIS (page 328), there will be substantial acreage that could be grazed in the 

Several scientific studies have shown that livestock has 

degraded riparian habitat on the refuge, and this was disThere are more than 1,200 water bodies (averaging 18 acres) within the scope of analysis, and the effect of stock pond 

ildlife does not 

cussed in detail in the DEIS (pages 194–199). removal on waterfowl would be negligible. Wrequire human-made impoundments (Krausman 2006), and any benefits are often outweighed by adverse impacts caused by 

not would that numbers at and areas 

e have added information to the have normally been found. W

FEIS on this topic. The only time a new water source would be created is if it was needed to support a target species, and this 

first The reasons. two for done be 

and wildlife 

in wildlife 

38–3. future.38–4. concentrating would be relatively rare. 

would 

the DEIS, 

Comment noted.

removal 

detailed in achieve habitat 

Fence 

38–5. 38–6. 38–7. would be to remove impediments to wildlife movements, and the second to reduce the labor and cost of maintaining fence by both the permittee and the Service. 
Comment 

Number Response

206 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #38: Montana Stockgrowers Association, Helena, Montana 38–8. 38–9. 38–10. cooper-

-

not 

authority 

e 

-

-

-

do 

has 

we 

State 

that 

the 

suggestion 

, 

the 

Ultimately

with 

issues. 

e disagree W

depredation 

38–8. to mitigate for wildlife damage on adjacent private lands. Wwork cooperatively with the State on carrying out its harvest objectives. Furthermore, we have participated in several community discussions to identify solutions to reduce wildlife damage. During the described wolf depredation episode, we were in constant contact and coordination with MFWP staff and did authorize control action by U.S. Department of Agriculture–Animal and Plant Health Inspection Service (USDA–APHIS). This will continue in the future. 

We agree invasive species are a challenge and will con

on ate 

38–9. tinue to work with all landowners. All of the action alternatives will take a more aggressive approach to noxious weed management.38–10. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 207

Letter #39: Montana Wilderness Association, Helena, Montana
Comment 

Number Response

208 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #39: Montana Wilderness Association, Helena, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 209

Letter #39: Montana Wilderness Association, Helena, Montana

39–1.39–2.

39–3.39–4.

39–5.

wilderness proposed the to changes 

See response 39–4. 

39–1. Thank you for your comment.

The Service agrees with your statement. A road does not 

39–2. 39–3. 

disqualify a unit or give valid reason for deletion. The language was changed in the final EIS. 

several made e W 39–4. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

See response 39–4. 39–5. 
Comment 

Number Response

210 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #39: Montana Wilderness Association, Helena, Montana 39–6. 39–7. 39–8. wilderthe to changes several made have and agree e We are aware of all the inholdings within the refuge 

-

39–6. boundaries. 

W 39–7. 

ness appendix E. 39–8. See responses 39–5 and 39–7.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 211

Letter #39: Montana Wilderness Association, Helena, Montana
Comment 

Number Response

212 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #39: Montana Wilderness Association, Helena, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 213

Letter #39: Montana Wilderness Association, Helena, Montana

39–9.

39–10.

- We agree that prescribed fires have a vital role in ecosys

Comment noted. 

39–9. 

tem management. 

39–10. 
Comment 

Number Response

214 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #39: Montana Wilderness Association, Helena, Montana 39–11. 39–12. e agree that there are impacts associated with boat on , State, USACE, and others to find 

- ilder

is occurring that use boat of amount the at look 

W

would 

The refuge is highly valued by many citizens due to 

39–11. use. Because we have little information about the amount or type of impacts, in all of the alternatives (DEIS pages 104–105) we outlined several strategies for initiating a research project that the refuge, specifically for hunting. The refuge would work with the boating communitysolutions (DEIS page 105).39–12. its protected landscape. Although we did not evaluate the economic value of the landscape itself, we discussed the topic in the DEIS (pages 251–252). For the economic analysis in the EIS, we chose to focus on facts where we can quantify the impacts of our actions (such as our projections for increased visitation). Assigning a value to the landscape is not tied to an action we have proposed. Nonetheless, we appreciate the support for the refuge that has come from the Montana Wness Association.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 215

Letter #39: Montana Wilderness Association, Helena, Montana

39–13. 39–13. Thank you for your comments.
Comment 

Number Response

216 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #40: Montana Wildlife Federation, Helena, Montana 40–1.

40–2.

-

The Service also recognizes the popularity of the Mis- 40–1. 

souri River Breaks for the wildlife and hunting, fishing, and recreational opportunities. In the DEIS (page 227), we note 

, Theodore Roosevelt Conserva

Out- in Montana 

the research work of Bill Geertion Partnership, and the article published doors in 2008 (Dickson 2008).

Comment noted. 40–2. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 217

Letter #40: Montana Wildlife Federation, Helena, Montana

- In the FEIS, we have clarified the definition of prescrip

tive grazing, added more policy information, and providedgreater detail about the grazing program on the refuge. Whilewe understand the concerns expressed about the impacts of livestock grazing, as noted in the DEIS, the refuge evolved for morethan a thousand years with fire and grazing on the landscape.It is not possible to use prescribed fires in all locations on therefuge, nor can we achieve desired habitat conditions throughwild ungulate grazing or by rest alone. While bison could playan important role on the refuge, there are many issues to beresolved before this could be considered (see response 40–4). Nomatter how well we carry out a prescriptive grazing program onthe refuge, there will continue to be some negative impacts.

, and private land management 

e understand your interest in bison restoration, and we W

40–3. 40–4. received many comments about bison restoration. Some were supportive, while others were opposed to having any bison.

We cannot act alone as there are complex and multijurisdictional issues involved. In addition, we recognize 

management actions on the refuge may have effects outside the refuge and we will consider such effects. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multi-agencyeffort with ample opportunity for public input.

The evaluation of bison restoration in the DEIS is consistent 

with the 2008 Department of Interior Bison Conservation Initiative that simply stated, “Charles M. Russell National Wildlife Refuge is in the early stages of considering devoting part of the refuge to bison habitat with adjoining land owners, including the Bureau of Land Management.” 

40–3.40–4.
Comment 

Number Response

218 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #40: Montana Wildlife Federation, Helena, Montana 40–5. The entire refuge is open to public access, except for a 40–5. small administrative area around the Sand Creek Field Station Road management on the 

-

and the 1,200 acre elk viewing area. Charles M. Russell Refuge received considerable public comment, as referenced in the DEIS. Many people expressed a demaintain to wanted others while roads, open fewer see to sire status quo or to open additional roads, primarily for hunting access and game retrieval. Others expressed the view that any 

e considered all perspectives on closure was unacceptable. W

road management in preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative. In addition, we considered time and effort needed to access areas of the refuge after leaving motorized access points (DEIS page 305, figure 47).

Public access for hunting has been steadily decreasing and

that creates a host of other challenges. The FEIS attempts tobalance reasonable motorized access, big game habitat security,and wildlife-dependent recreation, but limits placed on publicaccess to lands outside the refuge is beyond the control of the

e agree with not providing “privileged” or exclusive

to the general public access road eliminated 

Service. Waccess, and have wherever possible. In some cases, we are required to providehistorical road access to private or State lands even thoughthese roads may not be open to the public.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 219

Letter #40: Montana Wildlife Federation, Helena, Montana

40–6.40–7.40–8.

- Many comments were received about big game man 40–6. 

agement pertaining to quality hunting, favorable viewing experiences, and that any plan to be consistent with the natural ecological processes theme of alternative D. Given the public and agency comments on the DEIS, big game objectives were adjusted in the FEIS to assure that management on the refuge meets or exceeds objectives in approved State big game conservation plans. Refuge-specific abundance and composition objectives will be established through habitat management plans and tailored to regional habitat conditions 

consider recreation will also objectives . Those and productivity

and experience quality.

Comments noted.

We made several changes to the proposed wilderness 

40–7. 40–8. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 
Comment 

Number Response

220 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #40: Montana Wildlife Federation, Helena, Montana 40–9. 40–10. 40–11. Comments noted. Comments noted. 40–9. 40–10. 40–11. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 221

Letter #41: Mosby Musselshell Watershed Group, Mosby, Montana

41–1.41–2.41–3.

The Service did provide a definition of prescriptive graz- 41–1. 

ing in the DEIS, and in the FEIS we have clarified it and provided examples of what it means and how it would work on the refuge. In a review of the public transcripts from the 

hearing, we find no mention of Mr. Craw-

- condi

, and 

institutions 

historical 

, heterogeneity

the 

to 

with 

return to not 

cooperatively 

intention is 

are working 

. There are many examples around the 

. This will continue to occur 

e have clarified this in the FEIS.

Lewistown public ford stating that prescriptive grazing is not a proven system. 

. Crawford stated, “the sentinel plant concept is not a new 

concept.” The concept is new for this refuge and he emphasized that the Service is supposed to manage for wildlife habitat and 

The 

e 

range. 

Mrnot tions, but to promote biological diversityresilience. Wyou mentioned. The livestock producers who can adapt their operations to assist us in meeting our wildlife objectives can benefit economicallyService where this currently occurs.

Comment noted.

e currently acquire inholdings from willing sellers W

41–2. 41–3. within our authorized boundaryunder all alternatives, provided there is funding and willing sellers. W
Comment 

Number Response

222 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #41: Mosby Musselshell Watershed Group, Mosby, Montana 41–4. 41–5. It is not clear how we would incorporate or evaluate 41–4. the “Traditional Ecological Knowledge” held by indigenous cultures or multigenerational families into the document as no specific examples were given as to how this would relate to e note that practices any specific action in the CCP and EIS. W or customs held by indigenous cultures are not necessarily the . For example, Native same as those used by ranchers today Americans used prescribed fire (DEIS page 187), and they were highly mobile (DEIS pages 233–234) as they followed the migration patterns of game. Furthermore, bison were central today (DEIS page the same remains to their culture, which 239). The Conservation Districts appear to be opposed to some is the plan of those same practices and beliefs. We agree that ranchers are very knowledgeable about the carried out. insight as valuable can provide land and There will be many opportunities to work with local ranchers (DEIS page 66) as habitat management plans are developed. The habitat management plans provide the best way to share 

information and incorporate the knowledge that ranchers have as we move forward with carrying out the actions related to habitat and wildlife. 41–5. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 223

Letter #42: National Wildlife Federation, Missoula, Montana

42–1. - The Service appreciates the efforts of the National Wild 42–1. 

life Federation in their conservation efforts.

Comments noted. 42–2. 42–2.
Comment 

Number Response

224 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana 42–3.

42–4.

42–5.

In response to public and agency comments on the DEIS, 

meets 

Comments noted.

42–4. the big game objectives were adjusted in the FEIS to assure 

exceeds or refuge the management on game big 

42–3. 

that objectives in approved State conservation plans. In accor-

, which strives to the extent practicable 

and 

-

objectives with State management 

dance with our policyto achieve consistency regulations, refuge-specific abundance and population composition objectives may be refined through stepdown habitat management plans and will be tailored to regional habitat 

- , and other considerations. Those objec conditions, productivity

tives will consider naturally functioning ecosystem processes, 

, hunting opportunities, and quality of recre-

- pre definition of the expanded have we 

biological integrityational experiences.

FEIS, the In 42–5. 

scriptive grazing, explained how we have been making the transition to prescription grazing for more than 20 years, and clarified that under all alternatives we will continue the transition toward carrying out prescriptive grazing. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 225

Letter #42: National Wildlife Federation, Missoula, Montana

42–6.42–7.42–8.42–9.

In the FEIS, we identified the focal bird species for each 42–6. 

type of habitat area, including upland, riparian, and Missouri river. The sentinel plant monitoring will be closely tied with monitoring for focal birds. Other pollinators or other species will be added as additional information is learned.

Comment noted.Comment noted.

We recognize the threat invasive species pose and agree 

42–7. 42–8. 42–9. prevention is best. Aggressive control should be applied where 

lists The DEIS possible. economically and feasible logistically 

27 strategies (pages 83–84) of how to address invasive species problems and many of them emphasize communication and coordination with other entities.
Comment 

Number Response

226 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana 42–10. 42–11. 42–12. 42–13.

42–14.

ildfires that burn uncontrolled across large acreages of the 

e would take advantage of a natural fire when a number of factors have been fully evaluated 

, safety 

issues, and the resources at risk (DEIS page 80–81 and 188). 

fire 

prairie. 

Figure 18 in the DEIS was produced from a review of historic data, soil conditions, climate conditions, and field checks on the 

-

ment; nonetheless, it presents the best information about the 

-

Not all 

agree about fire ecology in the shortgrass 

e agree that some areas may need further refine

fire frequency that exists for the refuge versus the larger re

80), we would and 

See response 42–13. W

for each wildfire including its location, fire behaviorW

gional efforts that have been done. In the FEIS, we noted this. 

Comment noted.

ground. W

As identified in the DEIS (pages 77–78 

42–12. 42–13. 

identify areas for both endangered species and species of concern

that would be adversely impacted by fire and would suppress

identified sage-grouse habitat will be 

data. scientific not ignore competing e do W

42–10. refuge can be far more costly than prescribed fires. 42–11. 

professionals fires in those areas. Critical and protected. The objective of a prescribed fire is to burn underoptimum conditions with low fire intensities in order to benefit a

of focal species. The Raven–Rat Patch wildfire of 2010

ildlife studies have shown genetic linkages

diversity raged across the landscape scorching 28,000 acres and in all likeW destroying sagebrush for many decades. e agree about the importance of the northern Great doohl42–14. Plains to wildlife. Wof sage-grouse between southeastern Alberta and southernPhillips County in Montana. Recent telemetry research hasproven the longest ever recorded migrations of sage-grouse

- from southern Saskatchewan and areas near the Canadian bor

Peck Reser- of Fort even south refuge and on the der to areas 

voir. Other telemetry studies and observations have shown that

i

thousands of pronghorn migrate, or attempt to migrate, fromsouthern Canada to areas as far south as Ingomar, Montana.

In cooperation with several partners, we began a study 

in 2011 on the Missouri River Breaks using radio collars to better understand wildlife movements and potential wildlife 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 227

Letter #42: National Wildlife Federation, Missoula, Montana

42–15.42–16.

corridors, connecting several island mountain ranges in northeastern Montana that extend as far north as the Cypress 

FEIS and DEIS and Saskatchewan. Both the Alberta of Hills 

have acknowledged the effects of fencing on wildlife and will continue to work to remove fencing where practical.42–15. Comments noted. See response 42–5.

We clarified in the FEIS that under all alternatives 42–16. 

we will continue to acquire lands within the refuge boundary and those authorized under the Enhancement Act to protect wildlife and habitat values.
Comment 

Number Response

228 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana 42–17. 42–18. 42–19. The hunting or trapping of all wildlife on national wild- 42–17. life refuges is prohibited, unless specifically authorized. Cur- permitted on trapping of furbearers is hunting or o open those species for public harvest, a proposal 

-

, no rently

the refuge. Tneeds to be prepared that would include justification, popula

monitoring harvest levels, and 

s existing season framework 

tion status, determination of efforts. Consideration of MFWP’would be incorporated into such a proposal.

Comments noted. See response 42–5. 

42–18. 42–19. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 229

Letter #42: National Wildlife Federation, Missoula, Montana

42–20. - Greater sage-grouse has been identified as a focal spe

cies in the FEIS and will be monitored. When the draft CCP and EIS was written, the determination on the sage-grouse listing was just published. The guidance the Refuge System 

regarding 

-

declined, 

-

absence 

have 

the 

e updated this in 

coordinator 

the public harvest of sage-grouse is that hunting is not an issue, provided that habitat remains in good condition and popupopulations 

. Harvest levels likely 

sage-grouse 

where 

national 

areas In healthy. 

our 

it may be wise to close the season. Conditions could vary across national wildlife refuges. On the refuge, sage-grouse populations are generally robust and healthy

on population dynamics. In influence 

from 

are 

limited 

42–20. received lations have of new information, we will adopt State recommended harvest management strategies for sage-grouse. Wthe FEIS.
Comment 

Number Response

230 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana e have spent considerable effort working to recover 

- black-footed ferrets. Such efforts included maintaining bio

logical integrity and restoring the ecosystem for black-tailed prairie dogs to thrive in eastern Montana. Refuge lands have limited habitat suitable for black-tailed prairie dogs, especially in complexes large enough to support a viable black-footed ferret population. Under all alternatives, we will continue conservation efforts for black-tailed prairie dogs and associated species and collaborate with multiple agencies, nongovernmenrefuge. 

-

the 

the 

tal organizations, and private landowners.

e received many comments about bison restoration. 

while 

-

refuge, on 

outside 

bison 

e cannot act alone in a 

having to supportive 

W

were 

42–21. Some others were opposed to the concept. Wbison restoration effort as there are complex and multijurisdictional issues involved. In addition, we recognize management 

effects have 

See response 42–6. 

could refuge the 

W

on 

42–23. actions Any initiative to restore bison as a wildlife species in Montana 

, and private land man

42–22. will be a collaborative multiagencyagement effort with ample opportunity for public input. The objectives in the FEIS are consistent with this. 

42–21.42–22.42–23.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 231

Letter #42: National Wildlife Federation, Missoula, Montana

42–24.42–25.

- We agree there is bighorn sheep habitat on the ref 42–24. 

uge in northern Garfield County (DEIS page 208, figure 28). Furthermore, we have discussed opportunities for bighorn restoration in this area with MFWP and with local landowners. Montana’s recently approved Bighorn Sheep Conservation Strategy would be used to help guide preparation of a translocation proposal.

We made several changes to the proposed wilderness 42–25. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.
Comment 

Number Response

232 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana 42–26. 42–27. Road management on the Charles M. Russell Refuge 42–26. received considerable public comment, as referenced in the DEIS. Many people expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open 

- additional roads, primarily for hunting access and game re

the view that any closure was unacperspectives on road management 

alternative incorpo- the preferred 

e added an emphasis on climate 

expressed Others 

e considered all 

trieval. ceptable. Win preparing the FEIS, and rates elements from several alternatives. 

See response 42–6. W 42–27. 

change research in several of the goal statements in the FEIS.

42–28. Thank you for your comments. 42–28.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 233

Letter #42: National Wildlife Federation, Missoula, Montana
Comment 

Number Response

234 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #42: National Wildlife Federation, Missoula, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 235

Letter #42: National Wildlife Federation, Missoula, Montana
Comment 

Number Response

236 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #43: National Wildlife Refuge Association, Washington D.C. 43–1.

43–2.

- The Service appreciates the efforts of the National Wild 43–1. 

life Refuge Association to strengthen conservation on national 

Comment noted.

wildlife refuges.

43–2. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 237

Letter #43: National Wildlife Refuge Association, Washington D.C.

43–3.43–4.43–5.

pose and 

-

invasive species 

Comment noted.

We recognize the threats 

43–3. 

43–4. agree prevention is best. Aggressive control should be applied where logistically feasible and economically possible. The DEIS lists 27 strategies (pages 83–84) of how to address 

- invasive species problems and many of them emphasize com

munication and coordination with other entities.

We would take advantage of natural fire when a number 43–5. 

of factors have been fully evaluated for each wildfire including 

, safety issues, and the resources at 

ildfires that burn unconits location, fire behavior risk (DEIS pages 80–81 and 188). W

trolled across large acreages of the refuge can be far more costly than prescribed fires. 
Comment 

Number Response

238 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #43: National Wildlife Refuge Association, Washington D.C. 43–6. 43–7.

43–8.

The objectives for prescribed fire are consistent with 

ithin several 

43–6. protecting sage-grouse habitat (DEIS page 78). Wyears of a plan being carried out, the refuge would develop a map for fire managers that would identify critical sagebrush areas to protect.

We agree more research is needed to address challenges 43–7. 

pertaining to wildlife corridors, fences, and connectivity. Therefore, we are committed to reducing unnecessary fencing and where fencing is needed, using wildlife-friendly fencing.

Comment noted. 43–8. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 239

Letter #43: National Wildlife Refuge Association, Washington D.C.

43–9.

43–10.

43–11.

43–12.

-

-

Regardless of how carefully livestock grazing is pre

areas. However, as 

impacts would be 

localized 

s existing season framework 

to impacts be could there 

The hunting or trapping of all wildlife on national wild

permitted on 

-

alternative C, 

harvest levels, and monitoring 

trapping of furbearers is 

to a lesser extent in 

o open those species for public harvest, a proposal 

We clarified in the FEIS that under all alternatives we 

page 13) 

-

-

-

hunting or , no 

Greater sage-grouse has been identified as a focal spe

. Harvest levels likely have 

e updated this in 

43–9. scribed, including fencing out riparian areas to the extent practical, compared to the no-action alternatives, in alternatives B and D, and reduced over time. Using livestock grazing to enhance wildlife habitat under prescribed conditions would also benefit wildlife.43–10. will continue to acquire lands within the refuge boundary and those authorized under the Enhancement Act (DEIS to protect wildlife and habitat values.43–11. life refuges is prohibited, unless specifically authorized. Currentlythe refuge. Tneeds to be prepared that would include justification, population status, determination of efforts. Consideration of MFWP’would be incorporated into such a proposal.43–12. cies in the FEIS and will be monitored, but specific targets have not been set On the refuge, sage-grouse populations are generally robust and healthylimited influence on population dynamics. In the absence of new information, we will adopt State-recommended harvest management strategies for sage-grouse. Wthe FEIS. 
Comment 

Number Response

240 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #43: National Wildlife Refuge Association, Washington D.C. 43–13. 43–14. 43–15. e have spent considerable effort working to recover black-footed ferrets. Such efforts included to maintaining biological integrity and restoring the ecosystem for black- tailed prairie dogs to thrive as a keystone species in eastern Montana. Refuge lands have limited habitat suitable for black- to e cannot act alone in a bison 

restoration effort as there are complex and multijurisdictional issues involved. In addition, we recognize management actions 

-

enough large in complexes 

support a viable black-footed ferret population. Under all alternatives, we will continue conservation efforts for blacktailed prairie dogs and associated species and collaborate with multiple agencies, nongovernmental organizations, and private 

e received many comments about bison restoration. 

Some were supportive to having bison on the refuge, while others were opposed to the idea. Won the refuge could have effects outside the refuge. Any initiative to restore bison as a wildlife species in Montana will be a collaborative multiagency and private land management effort 

the objectives in The input. public 

especially 

Comments noted.

for 

dogs, 

opportunity 

W

prairie 

W

ample 

43–13. tailed landowners.43–14. 

43–15. with FEIS are consistent with this.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 241

Letter #43: National Wildlife Refuge Association, Washington D.C.

43–16.43–17.43–18.

- We agree there is bighorn sheep habitat on the ref 43–16. 

uge in northern Garfield County (DEIS page 208, figure 28). Furthermore, we have discussed opportunities for bighorn restoration in this area with MFWP and with local landowners. Montana’s recently approved Bighorn Sheep Conservation Strategy would be used to help guide preparation of a translocation proposal.

We made several changes to the proposed wilderness 43–17. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

It is important that we consult with climate change 

-

43–18. experts to develop a refuge strategy for climate change, specifically as they relate to our habitat objectives. We added an emphasis on climate change research in several of the goal statements in the FEIS.
Comment 

Number Response

242 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #43: National Wildlife Refuge Association, Washington D.C. 43–19. 43–20. Comments noted. More wildlife-dependent recreation could be provided 43–19. 43–20. on the refuge. The addition of two staff could be dedicated to providing visitor services would enable us to expand education 

and interpretive services.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 243

Letter #43: National Wildlife Refuge Association, Washington D.C.

43–21.43–22.43–23.

In response to public and agency comments on the 

DEIS, the big game objectives were adjusted in the FEIS to assure that big game management on the refuge meets or 

- exceeds objectives in approved State conservation plans. In ac

, which strives to the extent practicable 

and 

-

objectives with State management 

43–21. cordance to our policyto achieve consistency regulations, refuge-specific abundance and population composition objectives may be refined through stepdown habitat management plans and will be tailored to regional habitat 

- , and other considerations. Those objec conditions, productivity

tives will consider naturally functioning ecosystem processes, 

, hunting opportunities, and quality of recre- biological integrity

ational experiences.

In the FEIS, we identified the focal bird species for 

-

-

-

43–22. each type of habitat area, including upland, riparian, and wa

closely tied with monitoring will be 

monitoring for focal birds. Other pollinators or other species will be added as more monitoring occurs.

Road management on the Charles M. Russell Refuge 43–23. 

received considerable public comment, as referenced in the DEIS. Many people expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open 

- additional roads, primarily for hunting access and game re

the view that any closure was unac

perspectives on road management 

alternative incorpo the preferred 

The sentinel plant 

expressed Others 

e considered all 

terways. trieval. ceptable. Win preparing the FEIS, and rates elements from several alternatives. 
Comment 

Number Response

244 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #43: National Wildlife Refuge Association, Washington D.C. 43–24. 43–24. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 245

Letter #43: National Wildlife Refuge Association, Washington D.C.
Comment 

Number Response

246 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #44: Phillips County Livestock Association, Malta, Montana 44–1.

44–2.44–3.44–4.

Charles M. Russell was born in 1864. This was corrected 

aylor 

s attempts to recalculate values 

in the FEIS.

The comment provides no specifics as to how we overestimated recreation and underestimated livestock grazing (see 

. T

response 44–4). 

As explained in the DEIS (page 314), the economic analysis did not include the spending of visitors living within the 

local six-county area. Therefore, three local visitors carpooling 

- from Lewistown would not be included in the analysis. To ac

count for the appropriate amount of time spent on the refuge by nonlocal visitors, the annual number of nonlocal visits was converted to visitor days. For nonlocal, nonconsumptive use visitors, only half a day of spending (4 hours) is accounted for in the analysis. The analysis already discounts what a nonlocal 

-

- and added clarified 

visitor would spend in a day. 

The Service disagrees. Dr. Taylor did not find inconsis

tencies in how the economic impact was calculated by USGS 

we have In the FEIS, 

. Taylor to the Association on April 6, 2011. Dr

44–1. 44–2. 44–3. 44–4. for recreation or grazing, as per the personal communication by Drfound that the Association’overestimated the economic impact. As stated in the DEIS (page 326), there are several factors that would determine the level of an increased economic impact above the direct production associated with refuge AUMs. These issues are beyond the scope of the analysis. Although we are moving to a prescriptive grazing program, we are not eliminating livestock 

more infor grazing. 

mation about what prescriptive grazing is and how it would work on the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 247

Letter #44: Phillips County Livestock Association, Malta, Montana

e stand by the economic analysis done by USGS with 

- . The analysis was peer re

viewed before the publication of the DEIS. As shown in the DEIS (page 249, table 23), the refuge makes up less than 1 

area, which 

is a small impact to the economy (DEIS page 330). None of the action alternatives will change the level of impact to any 

- -market rates across all na

tional wildlife refuges since 1994 (DEIS page 14). The refuge is 

- aylor Graz

ing Act and Public Rangeland Improvement Act do not apply 

See response 44–7. As stated in the DEIS (page 14), 

As stated in the DEIS (page 73, objective B7), we will 

adhere to all regulatory permitting requirements. In the FEIS, we made sure this statement was clear in alternatives C 

Once artificial impoundments are removed, prairie stream 

functions would be restored along with corresponding riparian areas. As riparian areas redevelop, beaver would likely return 

ildlife do not 

require human-made impoundments (Krausman 2006), and their benefits are often outweighed by the adverse impacts 

that 

. 

six-county in the 

aylor

of AUMS 

See responses 44–4 and 44–5. 

e have been charging fair

not managed under a multiple use mandate. The Tto our management of the refuge. See response 44–8.AUM numbers and rates are outside the scope of the CCPand beaver ponds would become reestablished. W

numbers at and areas in wildlife 

. David T

number 

by 

W 44–5. 

the assistance of Dr

of the 

concentrating 

percent significant extent.

W

44–6. 44–7. 44–8. 44–9. and D as well. caused would not have normally been found. 

44–5.44–6.44–7.

44–8.

44–9.
Comment 

Number Response

248 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #44: Phillips County Livestock Association, Malta, Montana 44–10. 44–11. 44–12. 44–13.

44–14.

Although the word “sentinel” was a term we came up 

with for identifying species that are most likely to decline 

term 

sentinel, indicator species or diagnostic species is not unique 

with 

e do not use a single source of 

of our 

-

-

the 

e have no plans to reintroduce these species.

F), 

working of 

often as one 

wild ungulates

appendix 

process 

contain 

and 

the 

346 

do not 

page 

in are 

(DEIS 

e 

Fences 

ild ungulates can easily travel much

refuge 

W journals. 

the on 

(DEIS page 67) to develop monitoring protocols. In the FEIS, 

e are not a multiuse agency like the USDA Forest 

W

scientific 

See response 44–11. Our singular mission is wildlife 

Service (USFS) or the BLM. Winformation when managing for wildlife conservation, but we 

the technical reference you mention 

sources.

Prescriptive livestock grazing may be used only when 

Native herbivores are abundant on the refuge and one

44–10. 

range of ecologists, statisticians, and other scientific disciplines we clarified that monitoring protocols would be peer reviewed in accordance with our information quality guidelines and expanded the discussion and literature review of sentinel plants conservation, as opposed to range management. This mission 

mention. 

(diagnostic).is unique. W

figure you 

44–11. first in 44–12. do use 44–13. it benefits wildlife or wildlife habitat management objectives. It may not be used when prescribed fire or grazing by native herbivores can meet refuge goals and objectives.44–14. of the components of biological diversity on the refuge. Thecapacity to sustain wild ungulates on the refuge is limited whenconsidering the habitat need of thousands of other vertebrateand invertebrate wildlife species. Ungulate density impacts onplants are about the total herbivore population (ungulates andnonungulates both wild and domestic), which is much larger thanthe similarly to livestock. Wlonger distances from water than livestock. Native herbivoresare the primary target for the patch burn grazing or pyric herbivory process we propose. This process mimics the evolutionarypattern of use and abandonment and promotes less selectivityfor sentinel plant species. Although the process is applicable todomestic animals too, it is not a mission of the Service.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 249

Letter #44: Phillips County Livestock Association, Malta, Montana

44–15.44–16.44–17.

Prescriptive livestock grazing may be used to reduce 

fuel loads before a prescribed fire. This would not be annual 

-

grazing, but a single event before a prescribed fire. 

e agree that the use of the science you mention and 

science from other sources is essential when deciding on the 

e use the techniques you describe such 

o clarify the issue 

more accurate to say that more carbon, 

rather than most carbon, is converted into long-term soil storage of black carbon or charcoal in cooler prescribed fire than in a hot summer wildfire. Furthermore, prescribed fire helps to 

data in visitor 

as understory thinning when appropriate. T

have on 

. 

W

use of prescribed fire. W

it would be 

lower potential future fire severity

best estimate we We provided the 

the DEIS and added more detail in the FEIS. The DEIS (page257) acknowledged the negative impacts that visitors and the Service could have on any direct contributions to carbon emissionsfrom driving vehicles on the refuge. Under all the alternatives,we are committed to driving cleaner vehicles, reduce time spentdriving, and developing a transportation plan that would look at

based

e predict

years 

transportation. W

15 over 

e used 2.5 persons per

of forms 

in visitation increases 

alternative 

minor 

increase 

be would 

44–15. 44–16. on carbon, 44–17. 

to ways 

there on these improvements (alternative D would have 10–15 percent,a minor increase over current levels). Many of the field staff livein close proximity to the refuge, and the Lewistown staff does notcommute to the refuge on a daily basis. Wvehicle for a total of 100,000 vehicles (all sources including boats).It is incorrect to assign carbon expenditures to the refuge forchoices a visitor makes while traveling to the refuge. In the DEIS(page 258), we discussed mitigation strategies. Another option forthe refuge to reduce its carbon footprint would be to close moreroads, which the counties do not support. This would increasevegetation and reduce travel on steep, rough roads.
Comment 

Number Response

250 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #44: Phillips County Livestock Association, Malta, Montana 44–18. 44–19. 44–20. Fire will always be a part of the eastern Montana land- scape and the ecological system of the Charles M. Russell Refuge. More carbon is emitted during hot wildfires that burn almost everything to mineral soil than in a cool prescribed fire. Critical smoke concerns are addressed in each individual 

- prescribed burn plan. These plans are very thorough and dis

cuss specific smoke issues, measures to reduce impacts, downwind receptors, and smoke vector maps. The Service obtains clearance from the Montana/Idaho Airshed Group before to conducting any prescribed fire. An air shed coordinator and meteorologist evaluate each prescribed fire information air shed by air shed to anticipate cumulative smoke effects. Key factors include burn elevation, wind speed and direction, type of burn, proximity to smoke-sensitive features, anticipated impacts from nonmember burners, and any other pertinent information made available at the time of the decision. A prescribed burn is not conducted if negative effects cannot be mitigated. 

s concern about the 

spread of invasive species. All of the action alternatives call for a significant effort in mapping invasive species, achieving 

the 

-

-

fish

and monitoring efforts. The refuge is 

largest recipient of noxious weeds in the county due to the downstream nature of most of the refuge, open public roads, 

(DEIS 

and 

invasive 

refuge. 

groups, 

Mitigation strategies were addressed in the DEIS.

hunting 

in 

the 

stakeholder 

heavily 

infestations where possible 

The Service shares the Association’

during used 

potential many 

get 

weeds, 

that 

ing season (DEIS page 200). The refuge responds to all new reported areas of knapweed and is actively working at priori

USACE 

on levels 

with 

lake 

cooperatively 

control 

tizing and treating saltcedar 

as they 

work 

identified 

e 

of 

management 

waterways 

W199). 

44–18. and page species Furthermore, all entities should work cooperatively together to combat invasive species.

have 

reductions 

e W

44–19. 44–20. including communities who can assist us in accomplishing the CCPs objectives and strategies (DEIS page 131–134 and 139). We have also addressed substantive issues in the FEIS as a result of public comments. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 251

Letter #45: South and North Phillips County 

Cooperative State Grazing District, Malta, Montana

The Service does not have plans to reintroduce wolves, 

move 

-

e 

-

to 

nature 

efforts 

.

s comments in 

Any 

reductions of weeds, 

downstream 

refuge. 

the to due 

the bison onto 

species, achieving 

county 

Comment noted.

the in 

or bears, 

45–1. forward with a bison proposal would be led by MFWP

e share your concern about the spread of invasive spe

cies. All of the action alternatives call for a significant effort in mapping invasive and monitoring efforts. The refuge is the largest recipient of 

weeds 

W

45–2. 45–3. noxious of most of the refuge, open public roads, and water ways that get heavily used during hunting and fishing season (DEIS page 200). The refuge responds to all new reported areas of knapweed and is actively working at prioritizing and treating saltcedar infestations where possible (DEIS page 199). Wwork cooperatively with USACE in invasive species management as they control lake levels on the refuge. 

Comment noted.

We have responded to the Association’

grizzly 45–4. 45–5. letter 44. 

45–1.45–2.45–3.45–4.45–5.
Comment 

Number Response

252 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #46: The Nature Conservancy, Helena, Montana

46–1.46–2.

ildlife program works with 

to work is our intent 

s Partners for W The Service’ 46–1. 

ranchers to protect native grasslands. It with neighbors of the refuge and existing permittees to improve habitat conditions for wildlife on the refuge and the surrounding area. 

All habitat management will be and is supported by 

added a discussion of focal the FEIS, we analysis. In 

46–2. scientific birds and their importance in connecting the habitat objectives to focal bird monitoring.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 253

Letter #46: The Nature Conservancy, Helena, Montana

46–3. We support the “grassbanking” concept, and we could 46–3. 

consider using it as a management tool where quantifiable results can be demonstrated.
Comment 

Number Response

254 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #46: The Nature Conservancy, Helena, Montana 46–4. 46–4. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 255

Letter #46: The Nature Conservancy, Helena, Montana
Comment 

Number Response

256 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 257

Letter #47: The Wilderness Society, Bozeman, Montana

47–1. 47–1. Thank you for your comment.
Comment 

Number Response

258 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 259

Letter #47: The Wilderness Society, Bozeman, Montana
Comment 

Number Response

260 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana 47–2. 47–3. wilderness proposed the to changes Comment noted. several made e W 47–2. 47–3. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommend- ing deletion of any existing proposed wilderness area.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 261

Letter #47: The Wilderness Society, Bozeman, Montana

47–4.47–5. our 

See response 47–3.

In the FEIS, the wilderness review was revised. Y

47–4. 

47–5. comments were incorporated. 
Comment 

Number Response

262 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana 47–6. 47–7. 47–8. 47–9.

47–10.

We agree. See response 47–3.We agree. See response 47–3. We agree. See responses 47–3 and 47–5.We agree. See responses 47–3 and 47–5.

Comments noted. 

47–6. 47–7. 47–8. 47–9. 47–10. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 263

Letter #47: The Wilderness Society, Bozeman, Montana

We are aware of all the inholdings within the refuge 47–11. 

boundaries. See responses 47–3 and 47–5.

We agree. See response 47–5.

Comment noted.

47–12. 

47–13. 

47–11.

47–12.47–13.
Comment 

Number Response

264 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana

47–14.

It would be difficult to assess climate change impacts 

s water resources given the largely narrow and 

47–14. on the refuge’linear boundary. We added discussion in the FEIS on water quality impairments. There is an extensive list of objectives and strategies that would improve the health of riparian areas on the refuge which would in turn benefit the refuge’s water resources. The degree to which this would occur is largely 

research projects looking at speculative. We did list several 

climate change and wildlife and habitat in the DEIS (page 

have in the DEIS (pages 73–74), we 

a strategy and added work 

list 

restoration 

the 

the 

addition to 

of 

In 84). 

prioritized some to assess any water quality impairments that may be related to refuge land management practices as part of an effort to improve riparian health on the refuge.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 265

Letter #47: The Wilderness Society, Bozeman, Montana

47–15.

-

e did not conduct vulnerability as- Comment noted. W 47–15. 

sessments, but the actions and the associated impacts in each 

e would and analyzed. W alternative were adequately described 

take both reactive and anticipatory approaches to managing 

resilience- climatic sequestration and carbon for landscapes 

heterogeneity of species, structure, and succession. The compo

and 

sentinels, 

monitoring 

process 

a focus on 

ecological 

include 

sentinels, 

of the program would 

climate 

nents management of and adaptation through resilience.
Comment 

Number Response

266 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana 47–16. e agree with your comments and recognize education 

-

and 

-

, 

complex there 

We understand your interest in supporting bison 

are as alone act cannot e W

W 47–16. 

is key to change (DEIS pages 84–86. In the FEIS, we added climate change as a topic in the environmental education section under all alternatives.47–17. restoration. multijurisdictional issues involved. Furthermore, we recognize management actions on the refuge may have effects outside the refuge and we will consider such effects. It is true that traditional annual grazing of cattle on thousands of acres has been changed to more rest and prescriptive grazing; the spatial arrangement of those lands is simply not large enough or oriented in a way to consider bison restoration without having effects on adjacent lands. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagencyand private land management effort with ample opportunity for public input.

47–17.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 267

Letter #47: The Wilderness Society, Bozeman, Montana
Comment 

Number Response

268 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #47: The Wilderness Society, Bozeman, Montana 47–18. 47–19.

47–20.

e considered many comments about road management 

DEIS. 

-

the as referenced in Refuge, 

agency administrator 

Comments noted. 

Russell 

without 

M. 

land 

W

Charles 

Current refuge fire management policy states, “No 

fire and or 

e intend to maintain this 

47–18. 47–19. 

the on 

Therefore, we determined a hybrid version was best for balancing competing interests. In the FEIS, we added more road closures in the preferred alternative D. Following completion of the CCP we will develop a transportation plan that further defines road management on the refuge.47–20. mechanical equipment or retardant would be used on Service administered management officer approval.” Wstandard through the foreseeable future.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 269

Letter #47: The Wilderness Society, Bozeman, Montana

47–21.47–22. -

The refuge will continue to use the best available sci- 47–21. 

ence in the process of developing a management response to wildfire. We recognize the value of fire and plan to use it in 

ilderness Soci

s habitats. managing the refuge’

We appreciate the contributions of the W 47–22. 

ety in developing this plan.
Comment 

Number Response

270 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 271

Letter #48: Western Watersheds Project, Missoula, Montana

48–1.48–2.

-

ation of grazing across the refuge in just about every area where grazing has historically taken place.” There has been a substantial reduction in the number of AUMs and acreage grazed since we took control in 1976 (DEIS page 190). More 

-

agement, much of that gain has occurred within the last 15 years. Almost all of these areas are being rested or are very lightly grazed, and on about 10 percent of the refuge there is 

- alterna

grazing 

across the refuge in accordance with national policies. In the FEIS, we have clarified both the definition of prescriptive 

- grazing and added more information about how we would man

age a prescriptive program, and how quickly we could carry out prescriptive grazing under all alternatives. The preferred 

e agree that livestock grazing has resulted in a number 

of impacts on the refuge, but we have also improved the health 

-

that 

grazing 

, 

The Service disagrees that there has been a “continu

than 34 percent of the refuge is now under prescriptive man

-

prescriptive 

alternative would build on the changes that have been made.in many areas (DEIS pages 198–199). Not all of the improve

tool is a 

D, as described in 

riparian 

no-action 

that 

prescriptive 

across most of the refuge, continue to fence the boundary

restore 

the In 

out 

although 

out 

328). 

stock 

page 

to carry 

carry 

areas, 

alternative 

ponds, and 

off 

and 

(DEIS 

continue 

fencing 

The preferred 

progressively 

fencing 

allotted 

A, we would 

due to 

used. 

would 

grazing 

are 

internal 

W

been 

FEIS, 

48–1. no tive 48–2. ments has the remove areas. These improvements cannot be made overnight. Furthermore, as stated in the DEIS (pages 198–199), improving riparian health is not a simple matter of just removing cows. There must be effective harvest and management of other wild ungulates and invasive species management. 
Comment 

Number Response

272 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–3. 48–4. 48–5.

-

. As discussed in the DEIS (page 14), we follow procedures referenced 

in the Refuge Manual 6 RM 9 (FWS 1982), decisions made in the 1986 EIS, court decisions (DEIS page 26), and other policies. These policies and procedures have guided the management of livestock grazing privileges on the refuge. In a review of Executive Order 7509 and of other former game ranges, the allowance for livestock grazing was a provision that could be accommodated, provided it was compatible with our primary purposes. As stated in the DEIS (pages 137–138), the use of livestock grazing on the refuge remains an important tool for managing habitat. In the FEIS, we added more discussion 

the statement that the purpose of a 

refuge is in conflict with our mission. The primary purpose of the refuge is sustaining sharp-tailed grouse, pronghorn, and 

little doubt 

that an executive order written today compared to 75 years 

- ago might look different from a wildlife management per

in its interpretation, but it still remains a secondary use and one that has to be compatible with the primary purposes of the 

s interest 

is There 

, your statement suggesting that livestock 

in 

, a grazing permit expires annually

Executive Order 7509 has resulted in a number of challenges in bison restoration, but we cannot act alone as there are com-

-

provision 

Furthermore, we 

incorrect. Its 

atersheds Project’

involved. 

species. 

refuge is 

estern W

issues 

of the 

, and private land management effort 

about those benefits.

e disagree with 

spective. However

purpose is a 

multijurisdictional 

To clarify

W

e understand W

48–3. 48–4. other nonpredatory secondary grazing 

W

and 

refuge.48–5. plex recognize management actions on the refuge may have effects outside the refuge and will consider such effects. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagencywith ample opportunity for public input.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 273

Letter #48: Western Watersheds Project, Missoula, Montana

48–6.48–7.48–8.

refuge and the place on take could 

still be compatible, depending on stipulations placed on them. 

- alterna

e have heard 

-

of range consider a to required 

from many people who have advocated for more of these uses on the refuge. In the DEIS (page 332), we rated how well the alternatives would meet the goals of the planning process, and in the Record of Decision, we will identify the environmentally preferred alternative. Any public or economic use is going to have some level of impact. No use is going to be without im

Act, U.S. Congress recognized the 

six priority public uses (hunting, fishing, wildlife observation 

-

- , the compatibility determina

-

preferred on 

Congress 

o clarify

economic uses 

, environmental education, and interpretation) 

tives and alternative C meets the definition. Wpacts. In the Improvement are appropriate and expected to continue to be compatible. 

considthe eliminate not did 

eration of other uses on national wildlife refuge, but reaffirmed 

- alterna the done 

that all uses must be compatible.

are 

Comment noted. T

FEIS 

e considered a no-grazing alterna

are 

U.S. 

and 

we 

the 

Several 

A, NEP

and photographyFurthermore, 

DEIS the 

Under 

in 

See response 48–6. W

48–6. 

48–7. tions tive.48–8. tive and discussed the reasons for eliminating it from further consideration (DEIS page 137). 
Comment 

Number Response

274 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–9. A compatibility determination for grazing has been 48–9. completed and deemed compatible with refuge goals and ob- jectives. Stipulations were noted. Refer to FEIS (part C.12, 

appendix C). In addition, the draft compatibility determinations were part of the DEIS.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 275

Letter #48: Western Watersheds Project, Missoula, Montana

48–10.48–11. As rest. includes grazing prescriptive definition The 

48–10. See responses 48–1 and 48–8. 

of 48–11. 

stated in response 48–1, most of the areas under prescriptive 

e have clarified this in grazing are currently being rested. W

the FEIS.
Comment 

Number Response

276 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–12. 48–13.

-

a specific in needed was grazing that determined we If 48–12. 

area to meet a habitat need, a temporary water development structure could be used. This would make more sense than put

-

ting in a new impoundment.

We disagree that livestock grazing cannot be compat 48–13. 

ible with restoring the refuge. It is a tool that can be used effectively for managing habitat.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 277

Letter #48: Western Watersheds Project, Missoula, Montana

48–14.48–15.

Comment noted. Alternative B emphasizes abundant 48–14. 

wildlife and sustainable habitat conditions. 

Comment noted. 48–15. 
Comment 

Number Response

278 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–16. 48–17.

-

Comment noted. There has been substantial coopera- 48–16. 

tion with MFWP on wildlife management issues, includingnative species reintroductions.

We made several changes to the proposed wilderness 48–17. 

alternatives after considerable review from the public andothers. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 279

Letter #48: Western Watersheds Project, Missoula, Montana

48–18.48–19.48–20.

Road management in the Charles M. Russell Refuge 48–18. 

received considerable public comment on the DEIS. Many 

- people expressed a desire to see fewer open roads, while oth

ers wanted to maintain status quo or to open additional roads, primarily for hunting access and game retrieval. Others ex-

- pressed the view that any closure was unacceptable. We con

sidered all perspectives on road management in preparing the Final CCP and the balance for vehicular access was a hybrid version that incorporated elements from each alternative.

Comment noted. Comment noted.

48–19. 48–20. 
Comment 

Number Response

280 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–21. 48–22. - Comment noted. “Limited” could include rest or elimination of an activ 48–21. 48–22. ity. While we recognize your comments are primarily directed toward livestock grazing, economic uses could include other uses including commercial recreation on the refuge. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 281

Letter #48: Western Watersheds Project, Missoula, Montana

48–23.48–24. e recognize the effects of roads 

and motorized uses and concur that there are increasing demands for recreational use in some areas on the refuge like the 

season and much 

TVs on 

the 

-

iewing Area or popular fishing sites. However, most of 

in lake the 

hunting of 

of the refuge remains inaccessible during the winter months or during wet periods. In addition, there has historically been good compliance with our regulations for operating A

access snowmobiles to 

Comment noted.

See response 48–18. W

outside are lightly used 

using or roads 

roads 

48–23. 

48–24. Elk Vthe refuge winter. Nonetheless, we recognize that more data is needed to assess transportation management and its impacts on refuge resources and that a transportation plan should be developed 

substantial new recommendations about before making any 

road closures. Closing a road in one place can result in unintended impacts and consequences elsewhere.
Comment 

Number Response

282 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–25. 48–26. - See response 48–5 on bison. There are no plans to rein- 48–25. troduce wolves on the refuge. In the FEIS, we have revised the gray wolf objectives. Comment noted. The American bison is not a trust spe 48–26. cies for the Service, and it would be more appropriate for the State to take the lead on any bison restoration. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 283

Letter #48: Western Watersheds Project, Missoula, Montana

48–27. During scoping, several people expressed a desire for 48–27. 

more hunting opportunities. Federal law prohibits hunting or trapping wildlife on national wildlife refuges, unless specifically 

, no hunting or trapping of furbearers 

o open those species for public 

authorized. Currentlyis permitted on the refuge. Tharvest, a proposal needs to be prepared that would include a justification, population status, determination of harvest 

additional public input, and compliance with levels, monitoring, 

A. NEP
Comment 

Number Response

284 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–28. 48–29. 48–30.

48–31.

See response 48–5.See response 48–5. Comment noted. Comments noted. 

48–28. 48–29. 48–30. 48–31. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 285

Letter #48: Western Watersheds Project, Missoula, Montana
Comment 

Number Response

286 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana to Refer refuge. the on methane monitored not have e W 48–32. the DEIS (“Chapter 5—Environmental Consequences,” page 

- Wolf reintroduction is not being considered. See re

257).48–33. sponse 48–25.

48–32.48–33.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 287

Letter #48: Western Watersheds Project, Missoula, Montana

48–34.48–35.48–36.48–37.

-

See response 48–18.Comment noted.

In the FEIS, we expanded the discussion on focal birds 

48–34. 48–35. 

48–36. and tied monitoring for these species with the habitat objectives. It was not the intent of alternative B to single out big game. See response 48–14 about alternative B and 48–5 for bison. There are no plans to reintroduce grizzly bears or wolves. See response 48–25 on wolves.

Comment noted. 48–37. 
Comment 

Number Response

288 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #48: Western Watersheds Project, Missoula, Montana 48–38. 48–39. Comment noted. An analysis of that extent is outside the scope of this 48–38. 48–39. planning document. Reintroducing wolves or grizzlies is not considered in any of the alternatives. See also response 48–5 for bison.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 289

Letter #48: Western Watersheds Project, Missoula, Montana

48–40.48–41.

, 

We agree that more information about birds and small 48–40. 

mammals found on the refuge would be useful. Currently

- monitoring of these populations has been very limited. How

habitat each for species bird focal the identified have we ever, 

type in the FEIS.48–41. Thank you for your comments.
Comment 

Number Response

290 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #49: Wildlife Conservation Society, Bozeman, Montana 49–1. The Service understands and appreciates the history of 49–1. bison and agrees that they should be valued for their role in the ecology of the Great Plains and human culture. However, we also recognize the formidable challenges and controversy that will surround attempts to achieve ecological restoration of bison. As required by the Improvement Act and our Biological , we will, maintain existing levels of biological Integrity Policy , diversity, and environmental health on the refuge. integrity
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 291

Letter #49: Wildlife Conservation Society, Bozeman, Montana

49–2.49–3.

e cannot act alone in a 

See comment 49–1.

We received many comments about bison restoration. 

49–2. 

49–3. Some were supportive to having bison on the refuge, while others were opposed to the concept. Wbison restoration effort as there are complex and multijurisdictional issues involved. In addition, we recognize management actions on the refuge may have effects outside the refuge and will consider such effects. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagency, and private land management effort with ample opportunity for public input.
Comment 

Number Response

292 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana 50–1.

50–2.

50–3.

referenced requirements legal the on 

Comments noted.

relies Service The 

50–1. 

50–2. to guide management on the refuge.

See response 50–2. 50–3. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 293

Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana

50–4.50–5.50–6.

-

Comments noted. 

Road management on the Charles M. Russell Refuge 

50–4. 

50-5. received considerable public comment, as referenced in the DEIS. Many people expressed a desire to see fewer open roads, while others wanted to maintain status quo or to open additional roads, primarily for hunting access and game re

the view that any closure was unacperspectives on road management expressed Others e considered all trieval. ceptable. W

in preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative.

We made several changes to the proposed wilderness 50-6. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area. 
Comment 

Number Response

294 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana 50–7. Comments noted.

Comments noted. 

50–7. 50–8. 50–8.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 295

Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana

50–9.

50–10.

50–11.50–12.

-

, and private land management effort with ample 

We understand the economics of the refuge management 

, there are other factors that we must consider 

is con-

-

the DEIS 

Bison Conserva

restoration in of bison The evaluation 

with the 2008 Department of Interior 

See response 50–10.See response 50–10.

50–9. are complex. There can be both positive and negative effects associated with our decisions on wildlife and livestock management. Howeverin when managing the refuge.50–10. sistent tion Initiative. 

We received numerous comments about bison restoration. 

Some were supportive to having bison on the refuge, while others were opposed to the concept. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagencyopportunity for public input.50–11. 50–12. 
Comment 

Number Response

296 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana 50–13.

-

We have spent considerable effort working to recover 50–13. 

black-footed ferrets. Such efforts included maintaining biological integrity and restoring the ecosystem for black-tailed prairie dogs in eastern Montana. Refuge lands have limited habitat suitable for black-tailed prairie dogs, especially in complexes large enough to support a viable black-footed ferret population. Direction in the FEIS will continue conservation efforts for black-tailed prairie dogs and associated species and will rely on 

- nongov agencies, multiple with cooperation and collaboration 

ernmental organizations, and private landowners. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 297

Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana

50–14.

50–15.

and 86) 85– (page DEIS the in length 

Comments noted.

We agree that climate change is a significant issue, 

50–14. 

50–15. which is why it was highlighted in the DEIS (page 7, chapter 

at discussed also is It 1). 

elsewhere in the document. There are several objectives and strategies aimed at managing the refuge as the climate warms. 

the concepts , we would manage habitat by using Specifically

of resilience management, in addition to undertaking several research projects and reducing our carbon footprint. It was 

“Partnerships in the DEIS (page 13, significant issue noted as a 

and Collaboration”) and in the FEIS we added a bullet under habitat and wildlife as well. 

We agree that research, monitoring, and conservation 

planning must be done to address climate change. We added several of your suggestions to the climate change discussion in chapters 2 and 3 in the FEIS. 
Comment 

Number Response

298 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #50: World Wildlife Fund–Northern Great Plains Region, Bozeman, Montana 50–16. Thank you for your comments. 50–16. 
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 299

Letter #51: Yellowstone Buffalo Foundation, Bozeman, Montana

51–1.51–2.51–3.51–4.51–5.51–6.51–7.51–8.51–9.

51–10.

wilderness proposed the to changes 

Comment noted.

several made e W

51–1. 

51–2. alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

Road management on the Charles M. Russell Refuge 51-3. 

received considerable public comment, as referenced in the 

e considered all perspectives on road management in DEIS. W

preparing the FEIS and the balance for vehicular access was a 

- hybrid version that incorporated elements from each alterna

Comment noted. Comment noted. Comment noted. 

We received many comments about bison restoration. 

tive.51–4. 51–5. 51–6. 51–7. Some were supportive to having bison on the refuge, while others were opposed to the concept. Any initiative to restore bison as a wildlife species in Montana will be a collaborative, multiagency, and private land management effort with ample opportunity for public input.

Comment noted.Comment noted. 

See response 51–7.

51–8. 51–9. 51–10. 
Comment 

Number Response

300 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana Comment number Response Letter #52: Yellowstone Safari Company, Bozeman, Montana 52–1. 52–2. 52–3. 52–4.

52–5.52–6.

wilderness proposed the to changes several made e W 52–1. 

alternatives after considerable review from the public and others. Slight changes were made to the acreage in alternative B and D due to mapping errors in the DEIS. In addition, we determined there is not sufficient justification for recommending deletion of any existing proposed wilderness area.

Road management on the Charles M. Russell Refuge 

-

on road management in 

-

e considered all perspectives 

We understand the economics of the refuge management 

, there are other factors that we must consider 

52–2. received considerable public comment, as referenced in the DEIS. Wpreparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alterna

Thank you for your comments.

tive.

52–3. 52–4. Information about minerals was clarified in the FEIS.52–5. are complex. There can be both positive and negative effects associated with our decisions on wildlife and livestock management. Howeverin when managing the refuge.52–6. Thank you for your comments.
Response Comment Number

VOLUME 2, Chapter 2—Comments from Agencies and Organizations 301

Letter #53: Yellowstone Valley Audubon Society, Billings, Montana

-

In the FEIS we have clarified that only the U.S. Con- 53–1. 

gress can make a mineral withdrawal permanent. The Service clarified this in the FEIS.

Comment noted.

Road management on the Charles M. Russell Refuge 

53–2. 53–3. received considerable public comment, as referenced in the DEIS. The Service considered all perspectives on road management in preparing the FEIS and the balance for vehicular access was a hybrid version that incorporated elements from each alternative.53–4. Thank you for your comments.

53–1.53–2.53–3.53–4.

CHAPTER 3—Comments from 

Individuals

The Service tracked the number of individuals who 

expressed each type of comment and responded to 

those that were substantive and of strong public 

interest. This chapter includes general responses to 

individual comments, which are grouped by topic in 

table 1. The number of comments received does not 

include form letters, which are addressed after the 

table under “Summary of Form Letters.” The Service reviewed all supporting attachments; however, 

such attachments are not included in this volume.

How to Find Responses to 

Individual Comments

All of the comment codes and the number of individual comments that contained each code are in table 1. 

■■ Comments are organized by topic in table 1, with 

each comment assigned a corresponding number.

■■ Comment code numbers identified with bold text 

and an asterisk are considered to be substantive 

and received a response.

■■ Look up the comment code in table 1 for the comment of interest.

■■ Find the Service’s responses to substantive comments, each arranged by comment code and followed by a response, beginning on page 315.

Comment codes are not sequential because not 

all comment codes were used. Some comments have 

been summarized and paraphrased.

Most Common Concerns or 

Issues

The 10 most common concerns or issues expressed 

in the individual comments (not including form letters) were:

1. Support of expanded wilderness designation 

(comment code number 3402)

2. Opposition to removal of proposed wilderness 

(3404)

3. Support for managing the refuge for wildlife 

because the refuge is not intended for multiple 

use (1106)

4. Editorial suggestions or errors in the 

document (5205)

5. Support of general wildlife restoration and 

protection (3247)

6. Support of alternative B (3021)

7. Support of expansion of prescriptive grazing 

and reduction in livestock (3112)

8. Advocacy for road closures and reduced 

motorized vehicle access (3322)

9. Support of the no-action alternative (3011)

10. General habitat and wildlife management 

(3102)

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

Purpose and need—national and regional mandates and plans

1101 Comment about conformance with existing policies, mandates, or plans 4 <1%

1102* Specific substantive comment about existing policies, mandates, and 

plans 3 <1%

1103 Comment about the authority and responsibilities of the Service 8 <1%

1105 Comment that the refuge should be managed as a multiuse resource 7 <1%

1106 Comment that the refuge should be managed for wildlife and is not 

intended for multiple use 85 9%
304 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

1107* Comment that the Service is allowing Service policies to be influenced 

by other agencies and stakeholders 3 <1%

Scope of the analysis and issues not addressed

1222* Comment that the CCP and EIS should analyze the effects of mineral 

withdrawal 1 <1%

1224 Comment supporting mineral withdrawal and prohibition of mineral 

activity on the refuge 27 3%

1225* Comment that mineral rights on the refuge should be opened to leasing 3 <1%

1226* Comment that the EIS should analyze the economic effects of mineral 

withdrawal 2 <1%

1232 General comment about the management of water levels on Fort Peck 

Lake 1 <1%

1241* Specific substantive comment about grazing fees, permits, and AUMs 2 <1%

1242 General comment opposing Service grazing policies 8 <1%

1243 Comment opposing increases in grazing fees 4 <1%

1244 Comment opposing livestock grazing on public land 2 <1%

1245 Comment supporting elimination of all grazing in the Charles M. Russell 

Refuge 5 <1%

1246 Comment supporting historical AUMs for grazing 1 <1%

1247* Comment that grazing fees should be part of the CCP process 1 <1%

1248 Comment supporting grazing at current levels 6 <1%

1253 Comment opposing the Service’s revenue sharing practices 2 <1%

1262* Comment that the CCP and EIS should address and validate R.S. 2447 

and petitioned roads 4 <1%

Refuge history

2001 General comment about refuge history 6 <1%

2002* Specific substantive comment about refuge history 1 <1%

2003 Comment about management history 6 <1%

Refuge vision and goals

2101 General comment about refuge vision and goals 3 <1%

2102* Specific substantive comment about vision and goals 1 <1%
VOLUME 2, Chapter 3—Comments from Individuals 305

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment 

code Comment description Number of comments

Percentage 

of comments

Alternatives

3001 General comment about alternatives 5 <1%

3002* Specific substantive comment about alternatives 4 <1%

3003 Comment that the range of alternatives is too narrow 4 <1%

3004 Comment suggesting a new alternative 2 <1%

3005 Comment opposed to all alternatives 5 <1%

Alternative A–no-action

3011 Comment in support of the no-action alternative 31 3%

3012 Comment opposed to the no-action alternative 3 <1%

Alternative B–wildlife and habitat emphasis

3021 Comment in support of alternative B 39 4%

3022 Comment opposed to alternative B 1 <1%

3023 Comment in support of alternative B with modifications 1 <1%

Alternative C–public use and economic use emphasis

3031 Comment in support of alternative C 8 <1%

3032 Comment opposed to alternative C 4 <1%

Alternative D–ecological processes emphasis

3041 Comment in support of alternative D 20 2%

3042 Comment opposed to alternative D 6 <1%

3043 Comment in support of alternative D with modifications 12 1%

Alternative objective preferences

3051 Comment preferring upland habitat and grazing objectives in 

alternative D 2 <1%

3052 Comment preferring wilderness objectives in alternative B 24 3%

3053 Comment preferring road closure and access objectives in alternative B 18 2%

3056 Comment preferring the mineral development objectives from 

alternative A

2 <1%
306 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

Habitat management objectives

3101* Specific substantive comment about habitat and wildlife management 10 1%

3102 General comment about habitat and wildlife management 28 3%

3103 General comment opposing the Service’s habitat and wildlife 

management 7 <1%

3104 General comment supporting plant and habitat diversity 10 1%

3105 Comment supporting plant and habitat restoration 1 <1%

3110 Comment about upland habitat management 3 <1%

3111* Specific substantive comment about proposed upland habitat 

management 15 2%

3112 Comment supporting expansion of prescriptive grazing and reduction in 

livestock 38 4%

3113 Comment opposed to the expansion of prescriptive grazing 14 2%

3114 Comment that reduced grazing will result in additional large-scale 

wildfires 1 <1%

3115 Comment that it will be difficult to secure and maintain prescriptive 

grazing lessees 3 <1%

3116* Comment that the scientific evidence to support proposed management 

changes is insufficient 9 <1%

3117 Comment supporting the removal of interior fences 21 2%

3118 Comment opposed to the removal of interior fences 6 <1%

3119* Comment questioning the validity of sentinel plant assumptions 5 <1%

3120 Comment supporting the sentinel species approach to management 3 <1%

3121 Specific suggestion regarding upland habitat management 7 <1%

3131 General comment about river bottom habitat management 1 <1%

3133 Comment supporting river bottom restoration 1 <1%

3141 General comment about riparian and wetland habitat management 2 <1%

3142* Specific substantive comment about riparian and wetland habitat 

management 4 <1%

3143 Comment supporting the removal of upland reservoirs and stock ponds 1 <1%

3144 Comment opposed to the removal of upland reservoirs and stock ponds 1 <1%
VOLUME 2, Chapter 3—Comments from Individuals 307

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

3145 Comment supporting fencing to exclude livestock from riparian habitats 1 <1%

3160 Comment about fire management 1 <1%

3161* Specific substantive comment about fire management 16 2%

3162 Comment supporting the use of fire (prescribed or otherwise) as a 

management tool 27 3%

3163 Comment opposing use of fire (prescribed or otherwise) as a 

management tool 11 <1%

3164 Comment that grazing is important in limiting wildfires 7 <1%

3165 Comment opposed to prescribed fire because of air quality and climate 

change concerns 5 <1%

3166* Comment that the CCP and EIS is lacking detailed information about 

the impacts of fire management. 1 <1%

3171 General comment about noxious weed management 5 <1%

3173 Comment that the proposed noxious weed management approaches are 

insufficient 5 <1%

3174 Comment that the Service should coordinate with ranchers on noxious 

weed management 1 <1%

3175 Comment that the use of prescribed fire will result in the spread of 

noxious weeds 3 <1%

Wildlife management objectives

3211 General comment about big game management 5 <1%

3212* Specific substantive comment about big game management 6 <1%

3215 Comment supporting bighorn sheep restoration 5 <1%

3216* Specific suggestion regarding big game management 21 2%

3231* Specific substantive comment about furbearer and predator 

management 2 <1%

3232 Comment supporting predator control or hunting on the refuge 7 <1%

3233 Comment opposing predator control or hunting on the refuge 10 1%

3234 Comment supporting swift fox reintroduction 1 <1%

3235 Specific suggestion regarding furbearer or predator management 4 <1%

3240 Comment about species reintroduction 1 <1%

3241* Specific substantive comment about wildlife species restoration 4 <1%
308 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

3242 Comment opposed to any species reintroduction on the refuge 4 <1%

3243 Comment supporting bison restoration on the refuge 21 2%

3244 Comment opposed to bison restoration on the refuge 12 1%

3245 Comment opposed to wolf populations on the refuge 5 <1%

3246 Comment supporting wolf populations on the refuge 2 <1%

3247 Comment supporting general wildlife restoration and protection 58 6%

3248* Comment opposed to the Service deferring to the State on bison 

restoration 5 <1%

3249 Comment concerned about reintroduction of wolves and grizzly bears 1 <1%

3250 Comment concerned about bison restoration on the refuge 3 <1%

3251* Specific substantive comment about bird or other wildlife management 8 <1%

3252 Comment supporting proposed sage-grouse management 2 <1%

3261* Specific substantive comment about TES and species of concern 

management 1 <1%

3264 Comment supporting efforts to enhance black-footed ferret populations 1 <1%

Public use and education objectives

3330 Comment about seasonal road closures 1 <1%

3311* Specific substantive comment about hunting management and 

opportunities 4 <1%

3312 General comment about hunting management and opportunities 13 1%

3313 Comment opposed to hunting on the refuge 3 <1%

3321* Specific substantive comment about access management 9 <1%

3322* Comment advocating for road closures and reduced motorized vehicle 

access

31 3%

3324* Comment supporting road closures to improve habitat security for 

wildlife 19 2%

3325 Comment opposing road access from adjacent private lands 1 <1%

3326 Comment that refuge roads should be better maintained 1 <1%

3327* Comment that bicycle access should be further considered and described 2 <1%
VOLUME 2, Chapter 3—Comments from Individuals 309

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

3328 Comment opposing road closures on the refuge 23 3%

3329 Comment supporting more access to river and lake 1 <1%

3331* Specific substantive comment about recreational use 4 <1%

3332 Comment supporting proposed camping management 1 <1%

3333 Comment opposing proposed camping management 1 <1%

3334* Comment that road closures limiting access for the elderly and disabled 

violates ADA (Americans with Disabilities Act) and other policies 5 <1%

Wilderness objectives

3401* Specific substantive comment about wilderness management 3 <1%

3402* Comment supporting expanded wilderness designation 117 13%

3403* Comment opposing expanded wilderness designation 14 2%

3404 Comment opposed to removal of proposed wilderness 87 9%

3405 Comment that the Service should implement the 1974 wilderness 

proposal 4 <1%

3406* Comment supporting East and West Beachamp and East Hell Creek as 

wilderness 24 3%

3407 General comment supporting protection of wilderness qualities and 

values 23 3%

3408 Comment about specific “roadless wilderness” management and 

administrative closure 1 <1%

3409 Comment about criteria used to determine miles of roads closed 1 <1%

3410 Comment about wilderness management 4 <1%

Refuge operations and partnerships objectives

3601* Specific substantive comment about refuge operations and partnerships 10 1%

3602 Comment opposed to additional staff on the refuge 1 <1%

3603 Comment supporting additional staff on the refuge 1 <1%

3604 Comment opposed to the expected costs of CCP implementation 3 <1%

3902 Comment opposing the rationale for eliminating alternatives from 

further analysis 1 <1%

3905* Comment that management should be limited to Executive Order 7509 

objectives pertaining to sharp-tailed grouse, pronghorn, and livestock

2 <1%
310 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment 

code Comment description Number of comments

Percentage 

of comments

Affected environment an

consideration

d environmental consequences—elements considered but eliminated from further 

4001* Specific substantive comment about the affected environment or 

environmental consequences 1 <1%

4002 General comment about the affected environment and resource values 8 <1%

Physical environment

4112 Comment supporting strategic plan addressing climate change 4 <1%

4113 Comment about Service policies on climate change 1 <1%

4120 Comment about air quality 1 <1%

4121* Specific substantive comment about air quality 1 <1%

4131* Specific substantive comment about visual resources 1 <1%

4160 Comment about water resources management 1 <1%

4161* Specific substantive comment about water resources 1 <1%

4162 Comment opposing the validity of Federal water rights on the refuge 1 <1%

4163 Comment about the effects of removing water impoundments on private 

water rights 2 <1%

Biological resources

4201* Specific substantive comment about biological resources 7 <1%

4202 Comment about the need for long-term monitoring on the refuge 1 <1%

4203 Comment about the need for additional surveys and studies to establish 

a baseline of existing conditions 1 <1%

4205 Comment about disturbance factors affecting ecological processes 2 <1%

4206 Comment about the ecological effects of livestock grazing 4 <1%

4207 Comment about the ecological effects of roads and vehicles 7 <1%

4211* Specific substantive comment about upland habitat resources and 

analysis 6 1%

4212* Comment that the Service should use the same methods as other 

agencies to assess rangeland health 2 <1%

4213 Comment that the implementation of prescriptive grazing will eliminate 

any livestock grazing 1 <1%

4221* Specific substantive comment and riparian and wetland habitat 

resources and analysis 2 <1%

4232 General comment about the effects of noxious weeds 1 <1%
VOLUME 2, Chapter 3—Comments from Individuals 311

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

4233 Comment about the spread of noxious weeds from the refuge onto 

adjacent lands 6 <1%

4251 Comment about the importance of large habitat blocks for wildlife 2 <1%

4252 Comment about the effects of wildlife depredation on adjacent private 

lands 4 <1%

4261 Comment that increased predators adversely affect other wildlife 

populations on and off the refuge 9 1%

4266 Comment supporting free-ranging bison in the refuge 3 <1%

4267 Comment opposing free-ranging bison in the refuge 2 <1%

4271 Comment supporting efforts to protect grassland birds 1 <1%

4272 Comment supporting bird conservation 3 <1%

4280 Comment about threatened and endangered species and species of 

concern

2 <1%

4281 Comment about need for more protection for sensitive species 1 <1%

4282 Comment supporting biological goals for priority species populations 1 <1%

Special management areas

4310 Comment about wilderness analysis or effects 2 <1%

Visitor services

4401* Specific substantive comment about visitor services 2 <1%

4410 Comment about hunting 1 <1%

4430 Comment about commercial uses on the refuge 2 <1%

4431 Comment opposing commercial uses on the refuge 1 <1%

4456 Comment about need to expand recreation opportunities for visitors 

with disabilities 1 <1%

4457 Comment about refuge facilities 1 <1%

Human history and cultural resources

4501* Specific substantive comment about human history and cultural 

resources

1 <1%

4510 Comment about prehistoric history 1 <1%

4520 Comment about historical period 1 <1%

Paleontological resources

4601* Specific substantive comment about paleontological resources 1 <1%
312 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

4602 Comment about paleontological resources 1 <1%

4603 Comment supporting protecting paleontological resources 1 <1%

Socioeconomics

4701* Specific substantive comment about socioeconomics 4 <1%

4702* Comment that the economic analysis does not accurately represent local 

conditions and the analysis is flawed 8 <1%

4703 Comment about the economic value of wildlife 7 <1%

4710 Comment about the regional economic setting 3 <1%

4750 Comment about land use and ownership changes surrounding the refuge 5 <1%

4741 Comment that grazing management changes will create an economic 

hardship for ranchers 10 1%

4742 Comment about lost revenue due to reduced livestock grazing 6 <1%

4743 Comment about the effects of reduced livestock grazing on the local tax 

base 7 <1%

Refuge operations and partnerships

4801* Specific substantive comment about effects from refuge operations, 

partnerships, or adjacent lands 6 <1%

4802 Comment about the negative effects of refuge management on adjacent 

State lands 3 <1%

4804 Comment about the negative effects of refuge management on adjacent 

private lands 6 <1%

4805 Comment advocating for better collaboration between Federal and 

State land managers in the region 1 <1%

4806 Comment advocating for land swaps with the State to consolidate the 

refuge 1 <1%

Planning and NEPA processes

5001* Specific substantive comment about the planning and NEPA process 2 <1%

5002 General comment about planning and NEPA process 2 <1%

5003* Comment that the NEPA process has not been adequately followed 3 <1%

5004 General comment that more studies and analysis should be completed 1 <1%

5020 Comment that the Service appears to have already made its decision 1 <1%

Public involvement process

5101 Comment on the format of public meetings 3 <1%

5104* Comment that the public involvement process has been inadequate 6 <1%
VOLUME 2, Chapter 3—Comments from Individuals 313

Table 1. Number of individual comments by grouped comment codes and comment descriptions.

Comment Number of Comment description code commentsPercentage 

of comments

5105 Comment that the public involvement process has been positive and 

sufficient 1 <1%

5107* Comment that local and State government coordination has been 

inadequate 5 <1%

5110 Request that the comment period be extended 9 <1%

Draft CCP and EIS

5201* Specific substantive comment about the draft CCP and EIS document 3 <1%

5202 Comment about draft CCP and EIS document 4 <1%

5204* Comment that the analysis in the draft CCP and EIS is inadequate 4 <1%

5205* Comment detailing specific editorial suggestions or errors in the 

document 60 7%

Other comments

6001 Comment that the Service is unduly influenced by outside interest 

groups

22 3%

6002 Comment that refuge management should be determined by local 

communities 7 <1%

6003 Comment that outside organizations do not represent local interests 3 <1%

6100 No comment included 144 16%

Summary of Form Letters

The Service received five types of mass correspondence (form letters) commenting on the DEIS:

■ nonaffiliated local communities

■ National Wildlife Federation

■ The Wilderness Society

■ Defenders of Wildlife

■ Concerned Citizens for Garfield County

The correspondence received from each source 

and the comments contained in each are described 

below. Comments that were added to the standard 

form letter text were recorded as individual comments. Comments contained in this correspondence 

that received a response (indicated with bold text 

and an asterisk in table 1) are described and responded to below under “Responses to Individual 

Comments.” Some of the comments do not meet the 

definition of “substantive” (as defined in chapter 

1). However, the Service has opted to respond to 

specific nonsubstantive comments where the public 

displayed a strong interest. 

NONAFFILIATED LOCAL COMMUNITIES

The Service received 120 copies of a form letter with 

the following comments:

■ comment in support of the no-action alternative 

(comment code number 3011) 

■ comment supporting expanded wilderness designation (3042)

■ comment opposed to bison restoration on the refuge (3244)

■ comment concerned about reintroduction of 

wolves and grizzly bears (3249)

■ comment about specific “roadless wilderness” 

management and administrative closure (3408)

■ comment that increased predators adversely 

affect other wildlife populations on and off the 

refuge (4261)

■ comment about lost revenue due to reduced livestock grazing (4742)

■ comment about the negative effects of refuge 

management on adjacent private lands (4804)

■ comment that the Service is unduly influenced by 

outside interest groups (6001)
314 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

NATIONAL WILDLIFE FEDERATION

The Service received 11,278 copies of a form letter 

with the following comments:

■ comment in support of alternative D (3041)

■ comment supporting expansion of prescriptive 

grazing and reduction in livestock (3112)

■ comment supporting bison restoration on the refuge (3243)

■ comment opposed to the Service deferring to the 

State on bison restoration (3248)

■ comment about the ecological effects of livestock 

grazing (4206)

THE WILDERNESS SOCIETY

The Service received 7,503 copies of a form letter 

with the following comments:

■ comment supporting expanded wilderness designation (3402)

■ comment opposed to removal of proposed wilderness (3404)

■ general comment supporting protection of wilderness qualities and values (3407)

DEFENDERS of WILDLIFE

The Service received 694 copies of a form letter with 

the following comments:

■ specific substantive comment about alternatives 

(3002)

■ comment supporting expansion of prescriptive 

grazing and reduction in livestock (3112)

■ comment opposing predator control or hunting on 

the refuge (3233)

■ comment supporting bison restoration on the refuge (3243)

■ comment supporting expanded wilderness designation (3402)

■ comment opposed to removal of proposed wilderness (3404)

■ comment about the historical ecological role of 

bison in eastern Montana (4268)

CONCERNED CITIZENS 

for GARFIELD COUNTY

The Service received 32 copies of a form letter with 

the following comments:

■ comment that the refuge should be managed as a 

multiuse resource (1105)

■■ general comment opposing Service grazing policies (1242)

■■ comment opposing increases in grazing fees 

(1243)

■■ comment opposing the Service’s revenue sharing 

practices (1253)

■■ comment in support of the no-action alternative 

(3011)

■■ comment opposed to the expansion of prescriptive grazing (3113)

■■ comment that it will be difficult to secure and 

maintain prescriptive grazing lessees (3115)

■■ comment that the scientific evidence to support 

proposed management changes is insufficient 

(3116)

■■ comment opposed to the removal of interior 

fences (3118)

■■ comment opposed to the removal of upland reservoirs and stock ponds (3144)

■■ comment that the proposed noxious weed management approaches are insufficient (3173)

■■ comment opposed to any species reintroduction 

on the refuge (3242)

■■ comment opposing expansion of black-tailed prairie dogs (3263)

■■ comment opposing road closures on the refuge 

(3328)

■■ comment opposed to the expected costs of CCP 

implementation (3604)

■■ comment about the effects of removing water 

impoundments on private water rights (4163)

■■ comment that the Service should use the same 

methods as other agencies to assess rangeland 

health (4212)

■■ comment that increased predators adversely 

affect other wildlife populations on and off the 

refuge (4261)

■■ comment that grazing management changes will 

create an economic hardship for ranchers (4741)

■■ comment about the negative effects of refuge 

management on adjacent State lands (4802)

■■ comment about the negative effects of refuge 

management on adjacent BLM lands (4803)

■■ comment about the negative effects of refuge 

management on adjacent private lands (4804)

■■ comment that the Service is unduly influenced by 

outside interest groups (6001)
VOLUME 2, Chapter 3—Comments from Individuals 315

Responses to Individual 

Comments

1000–Purpose and Need

COMMENT 1102: Specific substantive comment 

about existing policies, mandates, and plans 

(specific text)

Comment 1102a. If the biologic integrity policy and 

improvement act of 1997 supersedes EO 7509, why 

do you list the details of EO 7509 under the refuge 

purposes?

Response 1102a. As described in the DEIS (pages 2–5, 

Section 1.1. and 1.2), the purpose for any national 

wildlife refuge may come from one or more authorities. Each national wildlife refuge shall be managed 

to fulfill the mission of the National Wildlife Refuge System, as well as the specific purposes of the 

refuges. The biological integrity was a policy document that stemmed from passage of the Improvement Act.

Comment 1102b. All the enabling documents in the 

game range and the wildlife refuge contain the savings provision...which says, “Subject to valid preexisting rights, (FWS) has historically ignored and 

continues to ignore the existence of private rights.” 

That would include grazing rights.

Response 1102b. Executive Order 7509 allowed a provision for forage resources to be available for domestic livestock grazing only to the extent it remains 

“compatible with the utilization of said lands for the 

purposes for which they were acquired.” The Service has never taken a privately held right nor is 

there any intention to do so. On refuge lands, livestock grazing is a privilege and not a property right. 

Comment 1102c. Regarding the Federal Land Policy Management Act: You must report any management decision or action...to both houses of Congress, 

and it is debated with no amendments allowed if 

any multiple uses are taken away in the new EIS/

RMP for the CMR.

Response 1102c. Unlike the BLM, national wildlife 

refuges are not managed for multiple uses and are 

not subject to the Federal Land Policy Management 

Act. The Service manages the refuge, and this CCP 

planning process is pursuant to the Improvement 

Act and other laws and policies.

COMMENT 1107: Comment that the Service is 

allowing Service policies to be influenced by other 

agencies and stakeholders

Response 1107. The Service is governed by legal mandates on how each refuge is managed. While we 

strive to work in cooperation with other agencies 

and stakeholders for the conservation of public lands, 

proposed actions and decisions made by us are made 

in accordance with these legal mandates.

COMMENT 1222: Comment that the CCP and EIS 

should analyze the effects of mineral withdrawal

Response 1222. As stated in the DEIS (page 173), the 

mineral estate was withdrawn for 20 years on the 

Charles M. Russell National Wildlife Refuge and 

permanently on UL Bend National Wildlife Refuge. 

The Service is seeking another 20-year mineral withdrawal for locatable minerals on the Russell Refuge 

and we clarified this in the FEIS. It does not apply to 

leaseable minerals. 

Although we are seeking a permanent withdrawal, only the U.S. Congress can make this determination. We have articulated the benefits for the refuge’s 

biological resources and special area designations 

through a permanent withdrawal in the FEIS. Since 

there has never been any mining on the refuge, it 

would be speculative to describe any impacts to the 

economy by making the current withdrawal permanent.

COMMENT 1225: Comment that mineral rights on 

the refuge should be opened to leasing

Response 1225. See response 1222. To our knowledge, 

there has never been a mineral lease or patented 

resource on the refuge.

COMMENT 1226: Comment that the EIS should 

analyze the economic effects of mineral 

withdrawal

Response 1226. See response 1222.

COMMENT 1241: Specific substantive comment 

about grazing fees, permits, and animal unit months 

(AUMs) (specific text)

Comment 1241a. The FWS fails to understand carrying capacity...The forage requirement of the big game 

animals greatly exceeds the forage allocation established in the 1986 record of decision. Based on the 

above relationships, the ability of the FWS to analyze forage production and establish grazing capacities is highly suspect. I strongly recommend that 

FWS seek outside assistance in conducting rangeland inventories, establishing carrying capacities, 

and regulating wildlife populations.
316 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Response 1241a. See response 3116. The refuge is managed for wildlife and not a range. The Service strives 

to manage the refuge for biological integrity, diversity, and function, rather than rangeland carrying 

capacity. Monitoring for range health involves looking at the dominant community plants and determining their viability. We work closely with MFWP, who 

has the primary responsibility in regulating wildlife 

populations in the State.

COMMENT 1247: Comment that grazing fees should 

be part of the CCP process

Response 1247. As noted in the DEIS (page 14), grazing fees are determined by Service policy across all 

States. The fees are based on U.S. Department of 

Agriculture (USDA) statistics and are outside the 

scope of the CCP and EIS.

COMMENT 1262: Comment that the CCP and 

EIS should address and validate R.S. 2447 and 

petitioned roads

Response 1262. The role of this CCP is to identify the 

roads that are necessary for habitat, wildlife management, and public uses. This is consistent with the 

guidance found in the Improvement Act and the Service’s planning policy. While we agree that RS 2447 

and petitioned roads are important issues, the CCP 

is not the tool for resolving them.

2000–Refuge History, Vision, and Goals

COMMENT 2002: Specific substantive comment 

about Refuge history (specific text)

Comment 2002a. In Summary on page xvi under Refuge Purposes you state, “In 1936, Charles M. Russell National Wildlife Refuge was established by 

Executive Order 7509...” EO No. 7509 did not establish CMR NWR. It established the Fort Peck Game 

Range. There is a vast difference in a game range 

and a refuge. On Feb. 25, 1963, Fort Peck Game 

Range became Charles M. Russell Game Range.

Response 2002a. The Service described the history of 

the Fort Peck Game Range and its eventual change 

to a national wildlife refuge in the summary page xvi 

of the DEIS. The CCP is about managing Charles 

M. Russell National Wildlife Refuge and UL Bend 

National Wildlife Refuge. Like many national wildlife refuges, it has different authorities.

COMMENT 2102: Specific substantive comment 

about vision and goals (specific text)

Comment 2102a. The Vision Statement does not comply with the guidelines, in Part 602 NWRS Planning Handbook.

Response 2102a. The Service disagrees. The vision 

statement is consistent with existing policies and 

guidelines.

3000–Alternatives and Objectives

COMMENT 3002: Specific substantive comment 

about alternatives (specific text)

Comment 3002a. This alternative [Alternative P] has 

been given the letter P because it focuses on partnerships to achieve preservation...Before making radical changes, the Service would first take an inventory 

of the diversity of habitats on the refuge. This inventory would identify which areas are in need of radical change and which areas need to be protected 

from change. Working with a variety of partners, but 

especially with the ranches that have traditionally 

used the land, the Service would develop management plans that remedy problems without removing 

ranches from the ecosystem.

Response 3002a. The singular mission of the U.S. Fish 

and Wildlife Service is wildlife conservation, rather 

than range management, and the habitat objectives 

are designed to ensure the biological diversity, integrity, and health of the refuge is maintained. We have 

no intention of removing ranches from the ecosystem, but in order to comply with our legal mandates, 

we must emphasize the use of prescriptive grazing 

that is compatible with wildlife habitat conservation. 

The DEIS does provide substantial detail on refuge 

issues, goals, objectives, strategies, and the actions 

we would take in each of the alternative scenarios. 

We agree that partnerships are important in carrying out the CCP, which is why we discussed the topic 

in depth (DEIS pages 131–133 and 139). Although we 

appreciate the ideas that went into outlining alternative P, it does not provide a substantially different 

alternative to analyze.

Comment 3002b. There are several thousand acres of 

DNRC and private land within the boundaries of the 

refuge. There is no mention of any plan to try and 

acquire these parcels. Doing a land swap with the 

DNRC, for a single parcel of land within the refuge 

would allow the public access to the DNRC land and 

alleviate the current checker boarding. There should 

be a goal to accomplish this.

Response 3002b. The Service buys inholdings from 

willing sellers, and this would not change in any of 

the alternatives. Additionally, the actions outlined in 

the Enhancement Act already provide us with the 

mechanism for acquiring or exchanging other lands 

with greater wildlife and public value. Therefore, the 
VOLUME 2, Chapter 3—Comments from Individuals 317

CCP planning process did not need to add a land protection planning component.

Comment 3002c. The Service could turn over management of the range resource to a committee of 

agencies with experience and competency in range 

management. This group would coordinate with 

the counties. A pilot project could be implemented 

with one half of each side of the river participating. 

Trends would be measured after 15 years to determine which group has been most successful. The 

management of the entire resource would be determined accordingly.

Response 3002c. The Service has a singular mission 

based on wildlife and not multiple-use management 

of rangeland. Turning over management of the wildlife forage resources is not an option for us based on 

laws, policies, and Federal mandates. Based on the 

Improvement Act, biological integrity policy (FWS 

2001), and the compatibility policy (FWS 2000a), any 

livestock grazing must be compatible with the refuge’s wildlife purposes. Furthermore, it must be a 

prescriptive grazing program and not simply a continuation of the annual grazing program. 

COMMENT 3101: Specific substantive comment 

about habitat and wildlife management (specific 

text)

Comment 3101a. B1–B8 Rationale. Why use station 

boundaries as Habitat Management Plan (HMP) 

boundaries’ use the reverse (HMP boundaries for 

station boundaries).

Response 3101a. Several factors would be used in 

determining boundaries of the habitat management 

units. This could include soil characteristics, historical fire occurrence, hunting districts, and station 

boundaries.

Comment 3101b. C7. It needs to be stated that these 

huge tracts of vegetation will be monitored using 

reliable (statistical) sampling.

Response 3101b. The Service is in the process of working with ecologists, statisticians, and other scientific 

disciplines (DEIS page 67) to develop monitoring 

protocols. In the FEIS, we clarified that monitoring 

protocols would be peer reviewed in accordance with 

our information quality guidelines.

Comment 3101c. The discussion of habitat should 

include an explanation of how rested pastures, fire 

treated areas, and other techniques will foster an 

improved plant composition, vigor, density, and soil 

production.

Response 3101c. The Service revised the habitat 

objectives and provided more detail about the use of 

prescriptive grazing in the FEIS. 

Comment 3101d. Page 51 Wildlife. The discussion of 

livestock needs is putting wildlife in less than first 

priority. This action isn’t legal. The discussion 

needs to be subject to the compatibility of all activities. This is not stated.

Response 3101d. The CCP does have a discussion about 

compatibility, and in the FEIS, we strengthened the 

discussion. Although the referenced description of 

alternative C seeks to balance big game and livestock, it would still be subject to the Improvement 

Act, and other laws and policies. Alternative C also 

includes a transition to prescriptive grazing on the 

refuge.

Comment 3101e. I would like to say that I believe in the 

ecological value of conservation grazing—I would 

like to suggest that for the CMR’s benefit from this 

type of [prescriptive] grazing the rancher must also, 

and the rancher must clearly not support prescriptive grazing...why not come up with the range that 

supports your goal and then help the rancher meet 

that and let the rancher have some stability.

Response 3101e. Livestock grazing is a secondary use 

on a national wildlife refuge and must be compatible with refuge purposes, as well as accomplish the 

mission of the Refuge System. The refuge manager 

has decided that for livestock grazing to be compatible on the refuge, it must be a prescriptive program 

that meets wildlife and habitat objectives (DEIS 

page 372 and updated in the FEIS). The Service 

recognizes that some individual ranchers may be 

adversely affected as we move to a greater emphasis on prescriptive grazing in all of the alternatives. 

However, these changes would be carried out over 

time, and we would work with willing permittees to 

develop and carry out appropriate grazing management plans.

Comment 3101f. Prescribed grazing, in close lockstep 

with judicious use of prescribed fire, will be more 

beneficial to climate management than will be a fullscale shift from grazing to fire as a habitat management tool.

Response 3101f. The proposed plan, which incorporates prescriptive grazing and prescribed fire, will 

have many ecological benefits.

COMMENT 3111: Specific substantive comment 

about proposed upland habitat management 

(specific text)

Comment 3111a. Page 264. Expansion of livestock 

grazing discussion would be improved if explained 

that the adverse effects on grazed plants is mitigated 

by rest, thus allowing the composition to change in 

favor of desirable plants which can dominate over 

time and treatment. Class of livestock, species of 
318 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

livestock, and season of use also change plant composition of vegetative communities.

Response 3111a. In the FEIS, the Service clarified and 

added more information on our legal mandates and 

the data collected on various sites of the refuge, as 

well as information about how prescriptive grazing 

would work. The use of prescriptive grazing would 

be detailed in stepdown habitat management plans 

and would differ depending on the wildlife species, 

weed species, native plant species, or specific habitat conditions the prescription is designed to affect. 

Long periods of rest would also be a condition that is 

prescribed to benefit wildlife.

Comment 3111b. Based on my 17 years of experience 

in developing, monitoring, and administering prescribed grazing programs, they are costly, complex 

and not feasible in some situations. Outcomes and 

costs of prescribed grazing are highly variable based 

on the particular circumstances of people, environment, yearly conditions, and other aspects... It is 

incredibly foolhardy to move forward on such an 

incomplete and tenuous basis of knowledge.

Response 3111b. See response 3116. The proposed 

plan entails prescriptive grazing on the refuge and 

we will adapt management prescriptions based on 

monitoring, scientific literature, and ongoing managerial experience.

Comment 3111c. MFWP has indicated that less than 

50% of the wildlife habitat is within the CMR NWR 

boundary. With wildlife numbers at current levels 

the majority of these animals are going to be on private and BLM land which have substantially higher 

AUMs than CMR NWR land. It is clear then that 

the management on both private and BLM land is 

maintaining range and habitat conditions without 

prescriptive grazing.

Response 3111c. All land can be considered “wildlife 

habitat,” depending on its characteristics. The comment seems to suggest that the refuge comprises a 

relatively small proportion of administrative hunting district boundaries as established by MFWP. 

Those hunting districts contain continuous wildlife 

habitat on and next to the refuge. Wildlife distribution is variable over time as native ungulates are 

mobile and respond to habitat conditions, weather, 

seasons, and other factors. Managing lands within 

the refuge for native wildlife should result in fewer 

impacts to adjacent lands. The commenter is correct 

in that more AUMs per unit are grazed by livestock 

on lands next to the refuge, which may be a factor 

contributing to the relatively high proportion of elk 

found on the refuge compared to the relatively small 

proportion of the total elk habitat on the refuge.

Comment 3111d. Page 271 Alt C. The discussions of 

wildlife grazing and livestock grazing center around 

forage consumption; the very real and significant 

social intolerance of elk for cattle also needs to be 

considered and addressed in management activities.

Response 3111d. It is not clear what the commenter 

thinks should be added to the discussion (DEIS page 

271) or in the objectives and strategies. The Service 

has a mission of managing for the benefit of wildlife 

habitat.

Comment 3111e. The document is based on an incomplete representation of the range of scientific literature pertaining to wildlife habitat preferences of 

key wildlife species. Throughout the document the 

ubiquitous underlying presumption that grazing 

my livestock is detrimental to wildlife habitat, and 

that rest from livestock grazing will improve wildlife 

habitat. This is directly contrary to a sizable library 

of published, peer-reviewed literature over the last 30 

years.

Response 3111e. See response 3116.

Comment 3111f. What would the impact be if a reduction in livestock grazing in sensitive areas...were to 

occur? Could other areas sustain increased grazing 

to offset the reductions?

Response 3111f. To increase grazing in other areas for 

the purpose of offsetting reduced grazing in riparian areas would not meet our compatibility requirements. Prescribed grazing can only be used to 

improve wildlife habitat and this cannot be accomplished through wildlife grazing or other natural 

means, such as fire.

Comment 3111g. Page 75. With all the monitoring suggested it seems in strategies for C1–C8 that annual 

monitoring is not practical if done to detect small 

changes year to year.

Response 3111g. As stated in the DEIS (page 75), utilization of riparian areas would be monitored annually. Reaching long-term resource objectives would 

be monitored over a longer period.

Comment 3111h. Page 72. The watering of planted 

shrubs may be possible but it seems too costly and 

not practical on a large scale.

Response 3111h. We agree, but it would not be done 

on a large scale.

Comment 3111i. Sentinel species: It must be noted, 

though, that these species are quite compatible with 

sound management of livestock grazing. Many of 

the species decline with extended rest and exclusion 

from grazing, just as they will with improper grazing use. It is also critical to note that these species 

are responsive to climate...and other variables.

Response 3111i. Sentinel plant species are early warning signs for ecosystems and are more sensitive to 

changes in management or environmental conditions 
VOLUME 2, Chapter 3—Comments from Individuals 319

than general plant communities. The Service agrees 

that sentinel species may be responsive to grazing 

management, climate, and other variables. The purpose of sentinel species monitoring is not to presume future grazing management prescriptions, but 

instead provide an indicator of the effectiveness and 

implications of current or future management. 

Comment 3111j. All alternatives call for continued reduction (or elimination) of annual grazing 

leases. It is stated at multiple points in the CCP that 

annual grazing has resulted in widespread deleterious effects to environments and native wildlife. This 

may perhaps be true in the past, but that outcome 

is not inherent in the annual grazing lease option, 

but instead it is the result of CMR staff’s lack of 

understanding of grazing alternatives, partnership 

administration, and adaptive management. 

Response 3111j. Livestock grazing is a secondary use 

on a national wildlife refuge. As such, it must be compatible with refuge purposes, and assist the Service 

in accomplishing the mission of the Refuge System. 

In addition, it must conform to the Improvement Act 

and other policies (DEIS page 372 and updated in 

the FEIS). See response 3116.

Comment 3111k. The interrelationship of sagebrush 

communities, threatened and endangered species 

and rangeland health are not adequately analyzed 

in the EIS. 

Response 3111k. The Service manages for wildlife 

habitat and not rangeland health, which traditionally focuses on plant communities under a multipleuse mandate. It is not clear what specific threatened 

endangered species were not analyzed adequately, 

but all information on the species was updated in the 

FEIS. 

COMMENT 3116: Comment that the scientific 

evidence to support proposed management 

changes is insufficient

Response 3116. The Service disagrees that there is no 

scientific basis for the proposed management objectives, particularly prescriptive grazing and sentinel 

species monitoring. The current authorized grazing program fails to meet established wildlife habitat objectives. There is considerable science on the 

use of prescriptive grazing and fire, and we added 

more discussion on this topic in the FEIS. Similarly, 

the concept of sentinel, indicator species or diagnostic species is not unique in scientific journals. We are 

working with ecologists, statisticians, and other scientific disciplines (DEIS page 67) to develop monitoring protocols. In the FEIS, we clarified that 

monitoring protocols would be peer reviewed in 

accordance with our information quality guidelines.

COMMENT 3119: Comment questioning the validity 

of sentinel plant assumptions

Response 3119. See response 3116. The Service is 

involved in wildlife management and not range 

management. Even though the disciplines of range 

management and wildlife management have commonalities, we do not have goals that reference the 

provision of forage for domestic animals. Sentinel 

species monitoring provides early warning indicators for ecosystems. We have been monitoring the 

health of sentinel species on the refuge since 2003 

and have found that some are beginning to diminish due to the changes to natural processes. A combination of sentinel plant species are used to evaluate 

landscapes. Because each species of plant is associated with a portion of the landscape rather than the 

entire landscape, we use several species of sentinel 

plants that occupy different positions with respect 

to soils and topography when evaluating landscapes. 

The description of sentinel species and their monitoring has been expanded in the FEIS. 

COMMENT 3121: Specific suggestion regarding 

upland habitat management

Response 3121. The Service appreciates the suggestions identified in the comments received. Each of 

these suggested changes was reviewed, and where 

appropriate, has been incorporated into the FEIS.

COMMENT 3142: Specific substantive comment 

about riparian and wetland habitat management 

(specific text)

Comment 3142a. Different riparian areas provide habitat for different ranges of animals...Each riparian 

habitat has different priorities and should be managed differently.

Response 3142a. The Service agrees with this statement. The CCP is intended to provide guidance 

for future management. Specific management prescriptions for specific locations will be determined 

through stepdown habitat management plans.

COMMENT 3161: Specific substantive comment 

about fire management (specific text)

Comment 3161a. I am very concerned on the issue of 

prescriptive burning. There are certain pockets in 

the refuge that if you were to destroy that area and 

those travel ways, you would cut the movement of 

the elk. There was a fire in the early 2000’s on the CK 

Ridge coming out the Nicholls Coulee. Prior to that 

fire, there were elk everywhere on that area. Since 

that fire, there’s no elk on that area...
320 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Response 3161a. The CK Creek fire was a large wildland fire that made a run of 6 miles in one afternoon 

and burned more than 11,000 acres before burning sparse vegetation (DEIS page 188). Large catastrophic fires can result in a loss of vegetation, among 

other consequences for many years. A prescribed 

fire is conducted under a project specific prescription of requirements for conditions, such as weather, 

fuel moisture, and soil moisture. The prescription is 

designed to confine the fire to a predetermined area 

and produce the intensity of heat and rate of spread 

required for the fuel consumption that would accomplish the objectives. To date, no prescribed fire has 

escaped its prescription on the refuge. 

Comment 3161b. Page 77. The discussion of fire management should reference areas where no fire or 

managed wildfire will be used. Limited suppression 

is not mentioned.

Response 3161b. The objectives, rationale, and strategies in the DEIS (pages 77–79) address areas where 

prescribed fire would not be used. Limited suppression activities would apply to wildfires and be based 

on an approved fire management plan. Wildfire 

objectives and management actions were detailed in 

the DEIS (pages 80–82).

Comment 3161c. Page 80 Wildfire. This discussion 

seems lacking the role of managed wildfire to reduce 

fire size and intensity and to encourage the vegetative mosaic that would exist in the breaks if suppression had not altered the way in which fire operates 

today. This management is very similar for all 

alternatives. Suggest this section be shortened.

Response 3161c. There is a different approach toward 

fire management in all of the alternatives. Alternatives B and D are essentially combined, but alternative C would have less emphasis on the role of 

natural fire.

Comment 3161d. The authors of the EIS (page 177) 

indicate that 15 prescriptive burns were ignited 

since 1992, treating 3,077 acres. In addition, wildfires have burnt 180,230 acres on the refuge during 

the past 28 years (page 188). While these records 

indicate that about 6,450 acres burn annually, simple math indicates that if 1/10 of the landscape burnt 

once every 10 years, 100,000 acres would burn annually. Even if fire occurred once every 20 years, then 

about 50,000 acres would burn annually. Clearly, 

these acreages are significantly greater than the 171 

(3077/18=years) that the FWS has treated annually 

during the last 18 years, and significantly greater 

than the 6,450 acres of wildfire that occurred annually during the last 28 years.

Response 3161d. Comment noted. The CCP and EIS 

provides broad estimates on the number of acres that 

could be prescriptively burned each year. Very specific details about exact acreage, location, and vegetation objectives will be detailed in the stepdown fire 

management plan. There are about 250,000 acres of 

lake and river in addition to areas that do not burn. 

See response 3161e.

Comment 3161e. Frost’s 1998 article indicates that 

fires occurred at intervals of 5–7 years in this region. 

This estimate is consistent with other published 

research. Therefore, the relationships depicted in 

Figure 18 are highly suspect.

Response 3161e. Figure 18 in the DEIS was produced by Dr. Cecil Frost in 2008, where he focused 

on the refuge instead of just the region. In addition 

to researching refuge wildfire data, soils, vegetation, 

historical photographs, climate patterns, and other 

relevant data, Dr. Frost has spent time looking at 

sites. His work will continue to be refined as more is 

learned about the refuge’s fire history. Currently, it 

presents the best picture of fire frequency intervals 

for the refuge. 

Comment 3161f. The contention projected in the EIS 

that fires in riparian areas and woody draws were 

infrequent (as depicted in Fig. 18) is not supported 

by published literature, and the strategy to target 

uplands for burning is ecologically unjustified.

Response 3161f. Many of the woody draws depicted in 

figure 18 of the DEIS hold water throughout the fire 

season and tend to be natural barriers to fire spread. 

Many of the large fires on the refuge are a result of 

strong northwest winds following a cold front passage, which subsequently can be the source of lightning strikes. The flanking fire burns up to the woody, 

moist draws and tends to go out. This is not always 

the case and fires do burn over these woody draws, 

but as figure 18 indicates, this is highly variable. 

Comment 3161g. Page 269, Alt A Paragraph 3. The 

15 year total for prescribed fire is 7,875 acres. This 

amount if done in conjunction with managed wildfire could be a positive measurable action. The use 

of prescribed fire in high density stands of Douglas fir and ponderosa pine would destroy the habitat 

that Bruce Campbell and Robert Watts discovered 

were important security cover for elk and actually 

contributed to the carrying capacity of the areas for 

elk. Suggest that managed wildfire be used to treat 

these areas. Often fire fuels carry breaks fire, making 

grazing an important regulating action.

Response 3161g. The Service is proposing to use prescribed fire in the dense stands of Douglas fir and 

ponderosa pine for some of the reasons suggested. 

Many wildfires are intense and have eliminated 

valuable security cover. This is due to aggressive 

fire suppression strategies that have allowed large, 

unnatural buildups of fuel. Managed wildfire will be 

used to treat some of these areas, but wildfires do 
VOLUME 2, Chapter 3—Comments from Individuals 321

not always occur where the habitat needs are greatest. Thus, there is a need to treat more areas outside 

the high fire occurrence zones of the refuge. 

Comment 3161h. The key to soil productivity is organic 

matter. Fire leaves ashes which have a temporary 

fertilization effect, but most of the carbon-based 

(organic) compounds enter the atmosphere...Carbon 

sequestration in healthy prairie soils is considered 

extremely beneficial.

Response 3161h. A significant amount of larger diameter vegetation (twigs, brush, branches, and trees) are 

not completely consumed by wildfire or prescribed 

fire and are converted to charcoal, which is stored in 

the soil and above ground for many decades. Literature has shown fire can be an effective means for carbon sequestration (DeLuca et al 2008). 

COMMENT 3166: Comment that the CCP and EIS is 

lacking detailed information about the impacts of 

fire management

Response 3166. The Service addressed wildfire under 

a number of impact topics. It is not clear from the 

comment what specific detailed information is lacking and how it might add to the analysis of the actions.

COMMENT 3175: Comment that the use of 

prescribed fire will result in the spread of noxious 

weeds

Response 3175. Where possible, management of naturally occurring fires for ecological benefits will 

continue. The Service has found that there is not 

an abundance of noxious weeds in the first new regrowth after fire unless the land has a history of overgrazing by livestock or other disturbance resulting in 

high populations of weeds already present. Japanese 

brome, for example, decreases for a few years after 

fire on most sites when a healthy and diverse native 

collection of plants occurs on the site. It is not possible to generalize on the response of weeds to wildfire 

or prescribed fire. It depends on the species of weed, 

species of native plants present, soil, moisture conditions before and after a fire, time of year, and intensity of a fire. Invasive species management includes 

education, prevention and control to the extent funding and labor permit. The DEIS lists 27 strategies 

(pages 83–84) on how to address invasive species 

problems and many of them emphasize communication and coordination with other entities. We will continue to work with our partners to address invasive 

species management both on and off the refuge.

COMMENT 3212: Specific substantive comment 

about big game management (specific text)

Comment 3212a. It doesn’t seem logical to manage 

mule deer to a standard dictated by the MFWP when 

the CMR has the professional staff, habitat and ability to manage to a higher standard.

Response 3212a. In response to public and agency 

comments on the DEIS, the big game objectives 

were adjusted in the FEIS to assure that big game 

management on the refuge meets or exceeds objectives in approved State of Montana conservation 

plans. In accordance with national policy striving to 

the extent practicable to achieve consistency with 

State management objectives and regulations, refuge-specific abundance and population composition 

objectives may be established through stepdown 

habitat management plans and will be tailored to 

regional habitat conditions, productivity, and other 

considerations. Those objectives will consider naturally functioning ecosystem processes, biological 

integrity, hunting opportunities, and quality of recreational experiences.

Comment 3212b. Values for ages of harvested deer 

(objectives) are not the same in all sections and need 

to be explained as do bighorn sheep ram ages.

Response 3212b. There are no specific age-related 

objectives for harvested mule deer or elk in any of 

the alternatives in the DEIS, only male-to-female 

ratio and density objectives. See responses 3212a, 

3212d and 3212f. There are specific age-based objectives for harvested bighorn sheep with an objective 

of 7.5 years old in alternative A. There are no specified age-based objective in alternatives B and C, but 

implied with management to resemble a “lightly harvested” population (DEIS page 88); the average age 

of harvested rams would be expected to be at least 

7.5 years old. In alternative D, there was an error. 

The objective was supposed to be an average age 

of at least 6.5 years old, the same as described in 

MFWP Bighorn Sheep Conservation Plan.

Comment 3212c. How will big game populations be 

managed during the next 5 years? Would the population objectives for elk and mule deer as described 

on page 86, obj. A1 (elk 2.5 per sq. mi.) and A2 (mule 

deer 10 per sq. mi.) under current management 

be continued until HMP’s are completed? If so, it 

should be stated here.

Response 3212c. Comment noted. Big game populations will be managed as described in alternative A 

until the stepdown habitat management plans are 

completed. See response 3212a.

Comment 3212d. Page 203, Elk and Mule Deer: Recommend including the elk and mule deer survey information you sent us following our inquiry about survey 

information. This would provide a better description 

of recent population conditions which allows for a better comparison and evaluation of the alternatives.
322 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Response 3212d. We revised the big game objectives 

and discussion in the FEIS. 

Comment 3212e. It is difficult to understand how Alt 

D was selected when it does not meet current conditions on the CMR. There is some indication that it 

was an attempt to compromise with the MFWP in 

how they are managing mule deer populations on 

other Federal land in eastern Montana.

Response 3212e. See responses 3212a, 3212d, and 

3212f.

Comment 3212f. In Alternative A, the objective discusses mature bucks; however, when a person moves 

onto Alternative B the discussion switches to adult 

bucks and in the final and preferred Alternative D, 

only total bucks per 100 does is discussed. It seems 

that population dynamics and composition would 

be totally different for each of these alternatives and 

this makes it difficult to determine just exactly what 

the plan is trying to attain.

Response 3212f. In response to public and agency 

comments on the DEIS, big game objectives were 

adjusted in the FEIS to assure that big game management on the refuge meets or exceeds objectives 

in approved State of Montana conservation plans. 

In accordance with national policy striving to the 

extent practicable to achieve consistency with State 

management objectives and regulations, refuge-specific abundance and population composition objectives may be established through stepdown habitat 

management plans and will be tailored to regional 

habitat conditions, productivity and other considerations. Those objectives will consider naturally functioning ecosystem processes, biological integrity, 

hunting opportunities, and quality of recreational 

experiences.

COMMENT 3216: Specific suggestion regarding big 

game management (specific text) 

Comment 3216a. Recommend replacing the objective 

of 25 total bucks per 100 does to a ratio of at least 33 

bucks per does.

Comment 3216b. Page 89. Suggest indepth analysis 

of grasslands and forb stands in northern Garfield 

County to determine presence of long worm parasites.

Comment 3216c. I would like to see all mule deer tags 

in the breaks be a trophy draw area.

Comment 3216d. Page 89, Big Game D4: Restate the 

first sentence of this objective to read a minimum of 

6.5 years rather than an average age of 6.5 years...

Comment 3216e. Recommend replacing the “20-3- bull 

to cow post hunting season ratio” to at least 29 browtined bulls (or a total bull equivalent) per 100 cows...

Comment 3216f. I strongly support closing the mule 

deer buck season two weeks before the end of the 

Montana deer season, retaining a good number of 

mature bucks as opposed to allowing maximum 

buck kill during the rut.

Comment 3216g. Population objectives should be based 

on long-term habitat productivity which I believe is 

best performed when HMP’s are completed. I view 

establishing sex and age composition targets and 

harvest strategies as a non-HMP function. I recommend establishing sex and age composition targets 

separately and in accordance with 605 FW 1.6 on 

obtaining quality.

Comment 3216h. I would like to see the Breaks 

returned to great trophy mule deer hunting. This 

could be achieved by having a trophy draw system 

or by not allowing 2 points to be shot and given a 

chance to mature.

Comment 3216i. A4. The average age of 7.5 is good but 

other figures & measurements must be used to pull 

together the different harvest notes of the 3 MFWP 

regional staffs.

Comment 3216j. B1. FWS must base the aging on tooth 

annuli not horn growth.

Comment 3216k. I would like to see all mule deer tags 

go to a trophy status on a draw system instead of it 

being a general deer tag area.

Comment 3216l. B6. FWS should set the number of 

sheet tags based on FWS harvest data and not try to 

combine all the various harvest ideas of MFWP in 

nearby sheep populations.

Comment 3216m. D2. The bull ratio is too low: should be 

35 observed branch-antlered bulls post-hunt, based 

on reporting of lightly hunted elk herds in western 

U.S. Now the total bull ratio in the western sections 

of the refuge are 32:100. This is way below the goal. 

Suggest lowering hunting pressure on bulls.

Comment 3216n. Page 86 A1. Suggest using the same 

measurement of animal density with MFWP so 

good comparison is possible.

Comment 3216o. Page 90. The objectives for big game 

are acceptable for antelope, mule deer, and sheep 

but elk bull ratios are too low. The need for reducing hazardous fuels for wintering pronghorn is not 

necessary.

Comment 3216p. Page 279 Alt B. Under this alternative the increased wildlife populations over the long 

term would require increased harvest rates to balance forage use with wildlife numbers. The number 

of hunters would increase with a larger harvest as 

would numbers of other visitors.

Comment 3216q. I hope that big game populations are 

maintained as large and diverse in age class as possible. I support the continuation of a hunting district 
VOLUME 2, Chapter 3—Comments from Individuals 323

specifically for trophy mule deer buck hunting on the 

refuge. I would be against policies which could alter 

this.

Comment 3216r. Page 120 D1–D4 Rationale. The meeting of MFWP harvest objectives should be deleted 

to say providing for FWS harvest objectives (which 

may or may not agree with MFWP).

Comment 3216s. Page 111 B2. Combine this with harvest surveys.

Comment 3216t. Page 120 Strategies D1–D4. Item 2 

indicates that game retrieval is a habitat objective, 

which it is not. It is a hunting harvest technique. 

Wildlife values are harmed by extensive motorized 

game retrieval.

Comment 3216u. I do not support a policy of not permitting antler harvesting on the refuge. I hope that 

this can be revised such that antler harvesting is 

allowed in places and in seasons in which there 

would be no deleterious effects on wildlife.

Response 3216a–u. The Service appreciates the suggestions identified in the comments received. Each 

of these suggested changes was reviewed and, where 

appropriate, has been incorporated into the FEIS.

COMMENT 3231: Specific substantive comment 

about furbearer and predator management (specific 

text)

Comment 3231a. The CCP document systematically 

excepts predators from other species of interest as 

not being hunted unless “monitoring verified that 

population levels could be sustained.” As employed 

in the text this statement is contradictory to the 

stated purposes of both Alternative B and Alternative D. None of the game species on the NWR, prey 

or predator, should be hunted unless monitoring 

verifies that populations can be sustained! ... CMR 

should simply manage predator species as part of 

the ecosystem. If ecosystem health will be served by 

hunting them then allow a hunt and vice versa.

Response 3231a. Prior to any new species being 

approved for hunting on a national wildlife refuge, 

a hunt plan must be developed and approved by the 

Washington office, and then new regulations are 

issued. Monitoring would be required to show that 

population levels could be sustained before approving a new hunt plan. Currently, there is a hunt plan 

in place for many species like deer and elk. Hunting 

is one of the six priority public uses that are to be 

considered on a national wildlife refuge, and it is not 

contradictory to the emphasis of alternative B and 

D. Mountain lion hunting would not be proposed in 

alternative B. 

Comment 3231b. Since publication of the DEIS, the 

gray wolf was delisted under the Endangered Species Act. The FEIS was updated to reflect the wolf’s 

current status and future management should 

wolves migrate to the refuge.

Response 3231b. As described in the DEIS (page 99), 

the Service intends to develop refuge management 

plans for wolf and grizzly bear, and would do so in 

cooperation with MFWP and with Federal and State 

plans and policies.

COMMENT 3235: Specific suggestion regarding 

furbearer or predator management

Comment 3235a. B10. The investigation of the CMR 

lion population is just starting. Before considering 

a season this work should be finished.

Comment 3235b. Page 92. The monitoring of populations of furbearers & small predators should be 

basic and not intensive to keep down the costs of data 

gathering.

Comment 3235c. Remove 20 lions, close the CMR to all 

deer hunting for 2 years and we will have big numbers again. Maybe a special lion draw area would 

peak interest.

Comment 3235d. Page 280 Paragraph 2. The curtailment of grazing in “B” would result in more forage, 

more wildlife, and more deer & elk prey for lions; 

thus more lions. The populations of lions would be 

significantly larger.

Response 3235a–d. The Service appreciates the suggestions identified in the comments received. Each 

of these suggested changes was reviewed, and where 

appropriate, has been incorporated into the FEIS.

COMMENT 3241: Specific substantive comment 

about wildlife species restoration (specific text)

Comment 3241a. Please reword the paragraph on p. 

284 to clearly state that FWS has the obligation to 

restore native species to the refuge (unless deemed 

“inappropriate”).

Response 3241a. The Service is not obligated to 

restore all native species. Bison restoration has generated significant interest in this planning process. 

Any initiative to restore bison as a wildlife species 

in Montana will be a collaborative, multi-agency, and 

private land management effort with ample opportunity for public input. We recognize management 

actions on the refuge may have effects outside the 

refuge and we will consider such effects; we cannot 

act alone as there are complex and multijurisdictional issues involved. 
324 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Comment 3241b. The term “free-roaming” is often 

applied indiscriminately when discussing management of bison as wildlife. This is an error the CCP 

should correct. Much precedent exists for management of “wild” ungulates, and predators, in which 

the range of these animals is constrained by human 

action.

Response 3241b. Comment noted.

Comment 3241c. Any significant bison numbers could 

quite easily result in herds spending the entire summer and fall on limited river bottom areas with good 

grazing and water, resulting in damage to those 

riparian areas.

Response 3241c. See response 3248.

Comment 3241d. Regarding fencing concerns, if surrounding ranchers do not want bison on their property, it is not unreasonable for them to bear the 

responsibility to construct fences to accomplish that, 

just as CMR must construct fences to block private 

cattle from entering CMR lands.

Response 3241d. Currently, the refuge is not devoting 

considerable refuge habitat to bison, although there 

is one permittee on the south side of the refuge that 

has grazed bison for years. Any initiative to restore 

bison as a wildlife species in Montana will be a collaborative, multi-agency, and private land management 

effort with ample opportunity for public input. Any 

fencing considerations would be discussed at that 

time and are not within the scope of this CCP.

COMMENT 3248: Comment opposed to the Service 

deferring to the State on bison restoration

Response 3248. The Service received several comments about bison restoration. Some were very supportive, while others were opposed to having any 

bison on the refuge. We cannot act alone in a bison 

restoration effort as there are complex and multijurisdictional issues involved. In addition, we recognize management actions on the refuge may have 

effects outside the refuge and we will consider such 

effects. 

COMMENT 3251: Specific substantive comment 

about bird or other wildlife management (specific 

text)

Comment 3251a. Page 287 Public Use and Access. 

This section states sharp-tail and sage grouse populations are stable. (The monitoring is for a very 

recent period). The historical records indicate that 

both these species enjoyed much higher numbers, 

which should be considered in setting population 

goals.

Response 3251a. While the Service recognizes the 

historic fluctuations in various species of birds and 

other wildlife on the refuge, our goal is to manage 

the ecosystem. The intention is not to return to historical conditions, but to improve biological integrity, diversity, heterogeneity, and resilience.

Comment 3251b. P. 97, other wildlife D: Recommend 

including another strategy to identify and delineate 

important or critical seasonal habitats for greater 

sage grouse and sharp-tailed grouse.

Response 3251b. In the FEIS, the Service has identified focal bird species, which include greater sagegrouse and sharp-tailed grouse.

Comment 3251c. Page 286 Grazing. The heavy grazing 

by elk referred to is most often small local sites, and 

it is doubtful if this would be measurable in terms of 

adverse impacts to birds.

Response 3251c. Comment noted.

Comment 3251d. Page 94. A2. The cost of determining 

density of sharp tailed grouse over large blocks of 

grassland is huge. Why cite 2005?

Response 3251d. Comment noted. The Service agrees 

that measuring sharp-tailed grouse density over 

large areas is challenging and cost prohibitive, rendering the objective of 30 sharp-tailed grouse per 

square mile unmeasurable. The last three lines 

of bird objective A2 on page 94 of the DEIS were 

deleted in the FEIS.

Because Executive Order 7509 specifies management for a maximum of 400,000 sharp-tailed grouse, 

the Service uses over 300 listening stations to monitor 

their presence each spring. Trends from this broad distribution and abundance index are also supplemented 

with counts of birds on leks, but such data can be problematic to meaningfully interpret over large areas.

Comment 3251e. Page 268 Alt B. Most sharp-tailed 

grouse investigations I reviewed in college found 

grazing was detrimental to this species.

Response 3251e. Comment noted. 

Comment 3251f. A5. Suggest selecting only a few ponds 

for waterfowl management...all is including a lot of 

mud holes.

Response 3251f. Comment noted. 

Comment 3251g. A2. Include attention for osprey and 

geese.

Response 3251g. Comment noted. 

Comment 3251h. B1, Item 5. These conditions are 

almost nonexistent on CMR. Stocking of “livestock 

ponds” is generally not practical since most don’t 

have adequate depth, a primary spillway, or meaningful life expectancies.

Response 3251h. Comment noted. 
VOLUME 2, Chapter 3—Comments from Individuals 325

COMMENT 3261: Specific substantive comment 

about threatened and endangered species (TES) 

and species of concern management (specific text)

Comment 3261a. The expansion of prairie dogs should 

be allowed to occur naturally without intervention 

through livestock grazing or mechanical treatment.

Response 3261a. Comment noted.

COMMENT 3311: Specific substantive comment 

about hunting management and opportunities 

(specific text)

Comment 3311a. I am skeptical about the numbers for 

hunting days. Certain allotments must be visited 

more than others. I do not believe 7th Point Allotment is visited as heavily as the numbers would 

indicate.

Response 3311a. Comment noted.

Comment 3311b. Page 122 C2. The use of motorized 

game retrieval methods in WSAs isn’t compatible 

with protecting WSAs. Foot or horseback are the 

only legal means.

Response 3311b. The use of motorized game retrieval 

methods in WSAs was not considered.

Comment 3311c. Page 122 Rationale for C1–C2. Use of 

commercial guiding to extract extra cows (elk) from 

the WSAs should be attempted ONLY when the cow 

elk numbers in the WSAs are under harvested by 

other means.

Response 3311c. Comment noted.

Comment 3311d. I support the continuation of special 

seasons and permits for juvenile hunters and permits for hunters with disabilities. I would support 

the expansion of such programs, specifically a limited number of either-sex elk permits for our younger 

and disabled hunters.

Response 3311d. Comment noted.

COMMENT 3321: Specific substantive comment 

about access management (specific text)

Comment 3321a. Page 51 Fishing. Access to shoreline 

for fishing in winter would need to be authorized by 

both COE and FWS.

Response 3321a. The Service works with the USACE 

on winter access. 

Comment 3321b. Access. The closure of 23 miles of 

roads may encourage wildlife movements but it does 

not result in significant benefits for fire management 

and game harvest. Retrieval of downed game on 

closed roads damages vegetation and disturbs wildlife and would disqualify areas for wilderness.

Response 3321b. See response 3322. The Service modified the preferred alternative to include the conversion 

of several roads on the north side for game retrieval, 

as shown in the FEIS. This is an effective first step in 

reducing wildlife disturbance off ridge lines and also 

allowing access for retrieval during limited hours. 

Comment 3321c. Page 272 Alt B. The shifting of vehicle use from 106 miles of roads & trails now open to 

other routes would result in damage to the remaining open roads; thus only providing a very small 

benefit to vegetation. The main benefit to wildlife is 

lack of disturbance in areas where roads are closed.

Response 3321c. Many of the roads identified in DEIS 

for closure would occur because a landowner has 

already closed off access, the road is unsafe, duplicative, of little use, or there are wildlife security issues. 

The closure of less than 5 percent of the roads, many 

of which are already impassable or duplicative, 

would have a negligible impact on refuge visitation 

(DEIS page 04).

Comment 3321d. Page 118 B5. Allow no landing of aircraft anywhere on the refuge except in dive emergencies. Require aircraft to maintain 1500ft AGL [above 

ground level] when over the refuge and in primitive 

areas, e.g. wilderness.

Response 3321d. Comment noted. 

Comment 3321e. Under alternatives D and C the 

upgrading of Knox Ridge Road would cost millions 

with very little benefit to the management of CMR.

Response 3321e. There has been interest expressed by 

BLM and others to improve access along the Knox 

Ridge road. There are pros and cons to any decision 

to improve access. Improving the Knox Ridge road 

would result in some localized impacts to vegetation 

(3.6 acres), but most impacts could be minimized. Graveling the Knox Ridge Road could also detract from 

the Wild and Scenic River designation values of the 

Missouri River. Traffic, including dust and noise from 

vehicle use, would be visible from the river in some 

places. Graveling the road does not equate to all season access, and during the winter months, access could 

remain limited. Any road project that was funded 

under the Service’s refuge road program would need 

to meet prioritization and eligibility criteria. 

Comment 3321f. Page 120 item 2. The adverse impacts 

to vegetation, soils, the view shed, and other nonwildlife resources should also regulate access NOT 

just wildlife considerations.

Response 3321f. The Service’s first priority is protection and conservation of wildlife within the refuge; 

however, impacts to other natural resources are also 

a priority and will receive full consideration as the 

health of these resources directly impacts the health 

of the wildlife. 
326 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Comment 3321g. I would ask that you consider minimizing motor craft traffic on the Missouri River 

within the proposed wilderness boundaries.

Response 3321g. Comment noted. The Missouri River 

lies outside of any proposed wilderness boundary. 

COMMENT 3322: Comment advocating for road 

closures and reduced motorized vehicle access

Response 3322. Road management on the refuge 

received considerable public comment on the DEIS. 

Many people expressed a desire to see fewer open 

roads, while others expressed a desire to maintain 

status quo or to open additional roads, primarily for 

hunting access and game retrieval. Others, however, 

expressed the view that any closure was unacceptable. The Service considered all perspectives on road 

management in preparing the Final CCP and EIS 

and the balance for vehicular access was a hybrid 

version that incorporated elements from each alternative.

COMMENT 3324: Comment supporting road 

closures to improve habitat security for wildlife

Response 3324. See response 3322.

COMMENT 3327: Comment that bicycle access 

should be further considered and described

Response 3327. Bicycle access for hunting is an appropriate use on a national wildlife refuge. Alternatives 

A, B, and D allow bicycles on all numbered roads, 

including seasonally closed roads, while alternative 

C would evaluate more bicycle trails. The FEIS was 

revised to clarify the difference between the alternatives. There are several numbered routes on the 

refuge that are open to bicycles, and the vast majority of them see little use except for during hunting 

season. 

COMMENT 3331: Specific substantive comment 

about recreational use (specific text)

Comment 3331a. Page 107 A1–A2. The existing and 

potential fishing reservoirs are next to nil. Poor 

sites, high siltation & erosive soil render this opportunity next to zero.

Response 3331a. Comment noted. 

Comment 3331b. The popularity of the Slippery Ann 

Elk Viewing Area reveals a demand to see more and 

know more about this region and its wildlife. I recommend creating three more such areas—one in 

each quadrant of the NWR with emphasis on both 

aquatic and avian wildlife as well as ungulates etc.

Response 3331b. Comment noted. The Service agrees 

that the Slippery Ann Elk Viewing Area provides a 

valuable opportunity for access and education. Alternatives C and D include strategies to work with our 

partners to improve the viewing area and potentially 

establish additional viewing areas. 

Comment 3331c. Public camping is one of the more 

ecologically destructive human activities. The popularity of large RV [recreational vehicle] campers 

and trailers leads to high-impact scars to terrain 

where campers frequent. I recommend a system of 

rules which limit unrestricted dispersed camping 

to tents. Establish a system of camping areas for 

wheeled or hard-sided camping vehicles.

Response 3331c. The refuge does enforce camping 

restrictions outside of the established recreation 

areas managed by USACE. Many of the routes on 

the refuge prevent the use of a large campers or 

trailers due to rough terrain. 

Comment 3331d. Page 107, Hunting D1–D6: Recommend deleting the statement “continue to restrict all 

camping to within 100 yards of a numbered route” 

and replace it with the compatibility determination 

stipulation for camping on page 366 which states 

“Except where designated as closed, camping (other 

than backpacking) must take place within 100 yards 

(of the Missouri River or refuge numbered roads) 

that are designated as open to use.”

Response 3331d. Comment noted. The FEIS was modified to be consistent between alternative D and the 

first compatibility determination stipulation.

COMMENT 3334: Comment that road closures limit 

ing access for the elderly and disabled violates 

ADA and other policies

Response 3334. See response 3322. There are currently about 670 miles of roads open on the refuge, 

which, combined with boat access from the lake and 

river, provide close access to most of the refuge. The 

closure of less than 5 percent of the roads, many of 

which are already impassable or duplicative, would 

have a negligible impact on refuge visitation and the 

quality of visitor experiences, and would not violate 

the letter or spirit of the Americans with Disabilities Act. 

COMMENT 3401: Specific substantive comment 

about wilderness management (specific text)

Comment 3401a. Page 307, wilderness. Since the goal 

for visitors is to experience a “quality” experience, 

the consideration of WSAs 2, 3, 5, 9, 12, 13, and 15 

should be done in addition to those units already 

proposed. The inholdings can be exempted or traded 
VOLUME 2, Chapter 3—Comments from Individuals 327

out of the units. Facility maintenance is now essentially done without wilderness conflicts.

Response 3401a. Comment noted. See response 3402.

Comment 3401b. The wilderness review process is 

clear in only one section and unclear in several others. It seems that the second review process should 

take place after the CCP record of decision is final. 

Then, given refuge requirements, the remaining refuge lands not needed for nonwilderness activities 

can be reviewed.

Response 3401b. The wilderness review in appendix E 

was revised for the Final CCP and EIS.

Comment 3401c. Add to all alternatives your strategies for how you will be removing all roads and 

structures from all 15 WSAs and the UL Bend Wilderness Area. The existence of these roads and structures within the WSA and WA boundaries is against 

Federal law and it is your duty to see to their immediate removal.

Response 3401c. In 2002, all roads in proposed wilderness units that did not provide historical access 

to private or State land were closed to comply with 

Service policy. With the exception of a few historical homesites and old fences, there are no structures 

within the proposed wilderness or designated wilderness.

COMMENT 3402: Comment supporting expanded 

wilderness designation

Response 3402. The Service received considerable 

comments on expanding, contracting, or eliminating 

existing proposed wilderness areas). We considered 

all perspectives on wilderness management in preparing the FEIS, including clarifying and enhancing 

the wilderness review. 

COMMENT 3403: Comment opposing expanded 

wilderness designation

Response 3403. See response 3402.

COMMENT 3406: Comment supporting East and 

West Beachamp and East Hell Creek as wilderness

Response 3406. See response 3402. 

COMMENT 3601: Specific substantive comment 

about refuge operations and partnerships (specific 

text)

Comment 3601a. The anti-livestock bias of recent management of CMR, as well as the portent for that to 

continue and increase if this CCP is implemented, 

precludes widespread, creative, and effective partnerships necessary to bring forth huge strides for 

prairie wildlife throughout a six county region surrounding CMR.

Response 3601a. The Services disagrees that recent 

management of the refuge has an “anti-livestock 

bias.” In spite of opposition to livestock grazing 

expressed by a number of stakeholders, including 

some who commented on the DEIS, we rejected 

this suggestion from further consideration (DEIS 

page 137). The Great Plains evolved through a complex interaction of fire and grazing, and to eliminate it from a manager’s toolbox is not realistic or 

desired. However, as stated throughout the document, we need to manage the refuge in a manner 

that achieves our wildlife objectives and legal mandates. The direction provided by the Improvement 

Act and our policies is that livestock grazing needs 

to be done prescriptively for the benefit of wildlife 

resources (FWS 2000a, FWS 2001). 

Comment 3601b. CMR should move forward with creating a community services organization to provide 

visitor support and logistical assistance to the NWR.

Response 3601b. Comment noted. Alternatives B, C, 

and D direct the Service to develop a volunteer program and friends group. 

Comment 3601c. Personnel. In addition to the personnel in Alternative D, the refuge would need personnel to assess and inventory habitat, negotiate and 

design grazing plans, and perform range monitoring...Alternative P requires annual vegetation monitoring in every pasture. Where it is not financially 

feasible to add staff, the Service would need research 

partners from universities, from other agencies, and 

from the community.

Response 3601c. The Service agrees that partnerships 

are important and looks forward to continued partnerships with researchers, other agencies, and the 

community. 

Comment 3601d. Page 131 Partnerships B4. Suggest 

MOAs with other agencies. Use advisory boards for 

NGOs & private individual input.

Response 3601d. Comment noted. 

Comment 3601e. Page 59. The required staff for “D” 

seems to be smaller than for a public use alternative. 

Why have all the I&R staff with lower visits?

Response 3601e. The staff requirements for alternative D is based on all refuge management activities 

not just visitation. The emphasis would be to restore 

ecological processes, while providing for quality 

wildlife-dependent public uses and experiences. Currently, there is not a dedicated full-time staff person 

for managing public use. Alternative D would strive 

for two positions, one for Fort Peck and another for 
328 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

the rest of the refuge. Two positions would enable the 

Service to program and provide for quality opportunities for wildlife observation, photography, interpretation, and environmental education.

Comment 3601f. I think you need to consider how you 

would use citizen volunteers to accomplish some 

of your work in the future, what kind of things the 

public could help you on, and to get more volunteer 

involvement on carrying out refuge programs.

Response 3601f. The Service agrees. Alternatives B, 

C, and D direct us to develop a volunteer program 

and friends group. 

COMMENT 3905: Comment that management should 

be limited to Executive Order 7509 objectives, 

pertaining to sharp-tailed grouse, pronghorn, and 

livestock

Response 3905. The Service considered, but eliminated this as an alternative in the DEIS. Refer to 

DEIS (page 138). Since the refuge was established, 

there have been several executive orders, laws, and 

policies that have provided guidance on refuge management. Furthermore, not all lands within the refuge were set aside or acquired under Executive 

Order 7509. We are now managed under the provisions of the National Wildlife Refuge Administration 

Act, as amended by the Improvement Act. Livestock 

grazing is a provision only if it remains compatible 

with the primary purposes, which are sharp-tailed 

grouse, pronghorn, and other wildlife populations. 

4000–Affected Environment and 

Environmental Consequences

COMMENT 4001: Specific substantive comment 

about the affected environment or environmental 

consequences (specific text)

Comment 4001a. On Page XXIV...your degree of effect 

was based on using quantitative numeric or modeled estimates or qualitative or relative estimates 

using literature. We would like to see the actual scientific data and not estimates from the literature. 

We would also like to see a qualified range manager 

interpret any data that’s available.

Response 4001a. It is unclear from the comment what 

data needs to be reviewed. The Service’s approach 

for analyzing and disclosing effects is consistent 

with NEPA and our guidelines, and is appropriate 

for a CCP, which is intended to provide guidance for 

future management plans and decisions. As stated in 

the DEIS (page 67), many of the existing staff that 

were involved in the plan development have expertise and education in range management. Monitoring for range health involves looking at the dominant 

community plants, mostly grasses to determine if 

they are viable. Our mission is wildlife conservation, 

so the focus is different than what would occur on 

multiple-use lands. 

COMMENT 4121: Specific substantive comment 

about air quality (specific text)

Comment 4121a. Page 160, air quality. Include a statement that at times the use of refuge roads by cattlemen and hunters generates dusty conditions for 

refuge users.

Response 4121a. Comment noted.

COMMENT 4131: Specific substantive comment 

about visual resources (specific text)

Comment 4131a. Page 161, visual resources. This discussion of road visibility should mention that in 

many years of sweet clover’s second year of growth 

all the two track roads are overgrown and not visible. Like-wise during the winter snow cover and during much of the mid and late summer, these same 

2 track roads are not noticeable due to regrowth of 

grasses/forbs.

Response 4131a. Comment noted.

COMMENT 4161: Specific substantive comment 

about water resources (specific text)

Comment 4161a. Regarding the water resources on ...

Page XVII, wildlife populations both on and off the 

refuge are affected by water quality and access to 

water. How many water sources off the refuge have 

you studied and so where is the data?...Again, you 

blame livestock grazing for degradation of water 

resources off the refuge for which, one, we believe 

there is no data and two, it is outside of your jurisdiction.

Response 4161a. The Service is the downstream 

receiver of any impacts that occur upstream of the 

refuge. More information was added to the FEIS 

about water quality and water impoundments on and 

off the refuge. 

COMMENT 4201: Specific substantive comment 

about biological resources (specific text)

Comment 4201a. When was the last time a game count 

was made on the CMR NWR to determine if populations of antelope and sharp tail grouse, the primary 

species for which the game range was established, 

have been achieved?
VOLUME 2, Chapter 3—Comments from Individuals 329

Response 4201a. We detailed what is known about 

sharp-tailed grouse (DEIS page 210–211) and pronghorn (DEIS page 206) on the refuge. Because Executive Order 7509 specifies management for a maximum 

of 400,000 sharp-tailed grouse, the Service uses over 

300 listening stations to monitor their presence each 

spring. Trends from this broad distribution and 

abundance index are also supplemented with counts 

of birds on leks, but such data can be problematic to 

meaningfully interpret over large areas.

Although large numbers of pronghorn were 

stranded on the south side of the Missouri River following the heavy snows during the winter of 2011, 

much of the refuge is not considered pronghorn habitat as the topography is too rough (DEIS page 206). 

About 15,000 sharp-tailed grouse have been counted 

on the refuge in recent years. Managing for increased 

levels of sharp-tailed grouse requires diverse vegetative cover including shrubs, forbs, grasses, and 

trees. They utilize a variety of leafy materials, buds, 

and fruits of woody species. Insects also play an important role in their diet. The objectives and strategies outlined in alternatives B and D are consistent 

with providing for the greatest biological diversity, 

which should benefit sharp-tailed grouse, among 

other birds on the refuge. In the Final CCP and EIS, 

we added a discussion of focal bird species, including 

sharp-tailed grouse and tied the plant monitoring to 

the focal bird species. 

Comment 4201b. On page 186, the authors discussing 

forbs write, “unlike grasses, their growing points are 

on the tips of their stems.” Their discussion suggests 

that the authors need to review the location of meristematic stem tissue on native bunch grasses.

Response 4201b. Apical meristem tissues are located 

at the tips of roots and the base of shoots in grasses 

(including native bunch grasses) during vegetative 

growth. As grass shoots begin to elongate, the growing point moves from the base of the plant to a higher 

position along the main shoot. Apical meristem is 

found at the root tips and tip of the main shoot in 

forbs. These areas of plants are where new growth is 

initiated. As the discussion on sentinel plant species 

points out (DEIS page 186), grasses are not considered as the first-to-decline sentinel species. 

Comment 4201c. On page 187, the authors write, 

“shrubs and trees that are the first to decline due to 

grazing and browsing by ungulates (herbivory) are 

usually fire-adapted species.” In contrast to their 

statement, my experience indicates that fringed 

sagewort is a fire-adapted species, and it is one of 

the last plants to decline with grazing. Furthermore, 

winterfat and saltbush are not generally regarded 

as fire-adapted species, yet they are some of the first 

plants to decline due to excessive grazing.

Response 4201c. The DEIS did not specifically discuss 

fringed sagewort (page 187) or elsewhere in the document. Depending on the literature, it is often classified as a forb or a subshrub. The Service agrees 

that it is fire adapted and is one of the last plants to 

decline from grazing. The comment about shrubs and 

trees was taken out of context from the discussion in 

the DEIS, which stated that these species have the 

ability to resprout after disturbances, such as fire 

and herbivory. On the refuge, we have found winterfat and saltbush tend to return immediately after 

fire by sprouting. They tend to be some of the first 

plants to decline due to excessive grazing.

Comment 4201d. The recognition of four vegetation 

types is far inferior to the use of the NRCS ecological 

site descriptions and state and transition models...

There is a protocol for analyzing a plant community, a basis for describing the extent and direction 

of changes that have taken place, and predicting 

those that may result from the implementation of a 

specific treatment or management.

Response 4201d. As described in the DEIS (page 177), 

the Service opted to group the complex vegetation 

on the refuge into four broad categories, rather than 

plant community designations. The reasoning for 

these categories was explained in the DEIS. These 

categories were not intended to describe plant communities. The Service does refer to the NRCS ecological site descriptions and transition models, as 

well as other literature for specific management 

applications.

Comment 4201e. The text calls for many on-going 

monitoring activities...leaving the reader feeling 

that most of the time the refuge staff will not get to 

do anything but study. Some discussion of the ways 

in which these activities will be carried out in simple and often inexpensive ways should be fully 

explained.

Response 4201e. The Service agrees that monitoring activities must be kept in line with available 

resources. However, the CCP process is also based 

on the concept of adaptive management, and monitoring is necessary to ensure that we’ve achieved 

the plan’s objectives or that we can adapt to changing conditions. The sentinel plant monitoring would 

be based on monitoring specific sites. There needs 

to be some baseline monitoring of focal bird species 

or other priority wildlife species. Some of this could 

be accomplished using university students or volunteers.

Comment 4201f. Sentinel plant information is interesting. Has the Service conducted any survey on 

varieties and population densities of sentinel plants 

in CMR wildlife exclosures?
330 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Response 4201f. The Service does not have total wildlife exclosures that exclude all wildlife (for example, 

they do not exclude small mammals or birds). We currently have some exclosures, containing most species 

of sentinel plants, that exclude large ungulates. 

Comment 4201g. Figure 36 in Ch. 4 is not an appropriate representation of the wildlife in the CMR area. 

This map, developed by the TRCP [Theodore Roosevelt Conservation Partnership], is based on an 

unscientific poll and may only reflect TRCP member opinions. This map is inappropriate to use in 

the CCP or any other NEPA document because it is 

anecdotal information versus bona fide representation of wildlife in the area. (We feel) this is disingenuous to the NEPA process...

Response 4201g. Figure 36 in the DEIS is useful at 

determining the value the public places on the refuge’s hunting program, especially since little other 

data exists about what brings hunters to the refuge. 

The refuge receives thousands of inquiries annually about its hunting opportunities. In 2010, USGS 

conducted a survey of refuge visitors, which will be 

used in a national report about national wildlife refuge visitations. When completed, this report will aid 

in our understanding why visitors come to the refuge. The more we understand about visitor values 

and experiences, the more likely we can provide a 

greater experience for visitors. 

COMMENT 4211: Specific substantive comment 

about upland habitat resources and analysis 

(specific text)

Comment 4211a. Livestock numbers are currently lower 

than any time in the past century, yet throughout the 

whole DEIS, livestock grazing is the cause of continual deterioration of the refuge. With livestock numbers at such an all time low, why haven’t the CMR 

range conditions improved and wildlife increased? 

Remember, FWS has had control for the past 34 years.

Response 4211a. Livestock grazing is not listed as 

the cause of continual deterioration of the refuge 

in the DEIS. The total wild ungulate population 

has grown during the past 34 years, while livestock 

numbers have dropped. The pressure on grasses has 

decreased with the lessening of summer livestock 

use, but the pressures on sentinel shrubs and forbs 

are still high in many places due to the combination 

of wild and domestic ungulate use.

Comment 4211b. Livestock grazing—well-managed, 

well-monitored, outcome-based—is not only fully 

compatible with the purposes for which CMR was 

established, it is a proven cost-effective and flexible 

tool for management of wildlife habitat. The FEIS 

fails to fully cover this.

Response 4211b. Managed livestock grazing may be a 

useful tool under certain conditions. However, livestock grazing is a secondary use on a national wildlife 

refuge and it must be compatible with refuge purposes, as well as accomplish the mission of the refuge System. The refuge manager has decided that 

for livestock grazing to be compatible on the refuge, it must be a prescriptive program that meets 

wildlife and habitat objectives (DEIS page 372 and 

updated in the FEIS). Livestock grazing is a useful tool in areas that lack wild ungulates and have 

high precipitation and good soils that produce abundant vegetation. The refuge has low precipitation, 

poor soils, sparse vegetation, and high populations of 

wild ungulates. In some areas, these characteristics 

severely limit the usefulness of livestock as a wildlife 

management tool. See response 3116.

Comment 4211c. There is no basis for objectives such 

as the one for Upland Habitat (Alternative D)...

Apparently the authors of the EIS are not aware 

that research has not correlated cover of forbs and 

shrubs to weight units in the northern Great Plains.

Response 4211c. The Service is not correlating cover 

to weight units. Cover and weight units (biomass) 

are both useful measures as are frequency and density, but they do not measure the same characteristics. Each measure is useful for some purposes, but 

not others. We may use them all, as appropriate, for 

specific tasks.

Comment 4211d. Without additional background 

information, it is impossible to interpret the summary statistics reported in the EIS (for example, 

Figure 19 on page 192).

Response 4211d. Summary statistics, such as the referenced figure, are intended to provide an illustrative example of the type of data used in the CCP 

process and ongoing refuge management. The particular section referenced (Vegetation Monitoring in 

the Uplands) was revised in the FEIS to emphasize 

the importance of the example data to refuge management. The transects in figure 19 of the DEIS are 

matched to the extent possible for soils and topography to provide nonbiased information on grazing 

intensity and distribution relative to sharp-tailed 

grouse nesting requirements.

Comment 4211e. Re: the record from a 1962 inspection (p. 190): As everybody knows by April the country is just coming out of winter and the land looks 

drab, grass, if any, is dried up and washed out. From 

July 1957 to early April of 1962, the area surrounding CMR had been suffering from a drought. By mid 

April in 1962, it started to rain and the country rejuvenated and that year was a very good year.

Response 4211e. Comment noted.
VOLUME 2, Chapter 3—Comments from Individuals 331

Comment 4211f. The document is based on inadequate review and presentation of pertinent scientific information available on habitat management 

for wildlife, especially in relation to livestock grazing alternatives and effects in prairie and riparian 

ecosystems.

Response 4211f. See responses 3116 and 4212.

COMMENT 4212: Comment that the Service should 

use the same methods as other agencies to assess 

rangeland health

Response 4212. The Service is not in the range management discipline, but is instead focused on wildlife and habitat management. Even though the 

disciplines of range management and wildlife management have commonalities, we do not have goals 

for the provision of forage for domestic animals, as 

do other agencies. Regarding consistency with range 

management methodologies, we are familiar with the 

habitat assessment methods used by other agencies, 

and may integrate them as appropriate. We are in the 

process of working with ecologists, statisticians, and 

other scientific disciplines (DEIS page 67) to develop 

monitoring protocols. In the FEIS, we clarified that 

monitoring protocols would be peer reviewed in 

accordance with our information quality guidelines.

COMMENT 4221: Specific substantive comment 

about riparian and wetland habitat resources and 

analysis (specific text)

Comment 4221a. (Regarding riparian stream assessment data): To be meaningful, the authors of the EIS 

need to provide information regarding their studies: were the study sites systematically selected, randomly selected, or chosen by the FWS to be sampled 

because they were believed to be “sore spots.” These 

data and their respective background information 

should be made available to reviewers.

Response 4221a. An information summary on streams 

selected, reasons for selection, and results is presented in the DEIS (pages 196–199). The CCP and 

EIS is not the place to provide detailed background 

on the referenced studies. However, these studies 

are available for review upon request. 

Comment 4221b. I am also concerned that the riparian assessments are based on one-time observations, 

some of which were made over 20 years ago.

Response 4221b. The riparian assessments were not 

a one-time observation. The Riparian and Wetland 

Research Program assessed 82 streams from 1995–

1997 (DEIS page 196). Ecological Solutions Group 

(2009) resurveyed most of the same locations in addition to additional survey areas. 

COMMENT 4401: Specific substantive comment 

about visitor services (specific text)

Comment 4401a. Page 110 A1. Include the upgrading 

of all signs to service standards.

Response 4401a. Changed. 

Comment 4401b. Page 106 C2. Suggest vault toilets, 

not pit type.

Response 4401b. Changed to toilets. 

COMMENT 4501: Specific substantive comment 

about human history and cultural resources 

Comment 4501a. I feel that your new management 

plan should focus on preserving both the habitat and 

the culture and traditions of the CMR including sustainable private ranching.

Response 4501a. The ranching heritage on the refuge is 

largely the remains of fencing, homesteads, and corrals. Refuge activities would be reviewed for impact 

to these resources and would avoid adverse impacts 

where possible. Consideration of the ranching history was included in the objective and rationale for 

environmental education (DEIS pages 116 and 126), 

rationale for cultural resources (DEIS B1–8). The 

ranching era was also discussed in the affected environment. While we understand the importance of 

ranching to the local communities, there is not a designated ranching heritage area within or next to the 

refuge. 

COMMENT 4601: Specific substantive comment 

about paleontological resources (specific text)

Comment 4601a. Page 126 Cultural & Paleontological. This section could be shortened into 2 or 3 paragraphs to treat Alt A, B, & D the same with a slightly 

expanded protection and education effort in Alternative C.

Response 4601a. Comment noted.

COMMENT 4701: Specific substantive comment 

about socioeconomics (specific text)

Comment 4701a. FWS and the CMR should become 

more invested in gathering, interpreting and communicating the benefits to people derived from the 

NWR. The money stream flowing to local economies 

is the benefit of greatest importance and should get 

appropriate management attention.

Response 4701a. Comment noted.

Comment 4701b. The separate analyses of recreation 

and livestock activities make it impossible to evaluate the impacts of the alternatives. These activities 

are not mutually exclusive, and it was economically 
332 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

incorrect to analyze them separately. (All activities) 

and aggregate impacts need to be addressed simultaneously, in a single model.

Response 4701b. The Service stands by the approach 

used in the analysis. The economic contribution of 

current recreation and grazing levels were estimated 

using Impact Analysis for Planning (IMPLAN), a 

regional input–output modeling system that is used 

by government agencies, colleges and universities, 

nonprofit organizations, corporations, and business 

development and community planning organizations 

(Minnesota IMPLAN Group, 2011). This approach is 

consistent with the approach that is typically taken 

for CCPs on national wildlife refuges. We are able 

to anticipate changes in wildlife-dependent recreation across management alternatives allowing for 

the economic impacts to be estimated. However, the 

number of AUMS used under the action alternatives 

would be based on habitat needs for wildlife, which 

cannot be easily predicted nor is the purpose of it 

to support economic revenue. The impact of refuge 

grazing on the six adjacent counties is less than 1 

percent and negligible, and none of the alternatives 

would change the overall effect on the six counties 

(DEIS pages 249 and 330)

Comment 4701c. Page 329 Conclusion. The relatively 

smaller local output of 23.3M [million] appears to 

be too low given the refuge highly productive habitats 

in this alternative.

Response 4701c. The Service stands by the economic 

analysis. See response 4702.

Comment 4701d. The annual economic contribution 

of the refuge is greatly embellished by the reported 

$20 to $23 million estimate in the EIS. Carver and 

Caudill’s estimated expenditures per refuge visitor 

is based on national statistics, and do not accurately 

reflect conditions in northeastern Montana.

Response 4701d. The spending estimates from Carver 

and Caudill are based on regional, not national statistics that were derived from the 2006 National 

Survey of Fishing, Hunting, and Wildlife-Associated Recreation. This national survey reports triprelated spending of State residents and nonresidents 

for several different wildlife recreational activities. 

For each recreation activity, spending is reported 

in the categories of lodging, food and drink, transportation, and other expenses. Carver and Caudill 

(2007) calculated the average per person and per day 

expenditures by recreation activity for each Fish 

and Wildlife Service region. The spending profiles 

developed for the Service’s Region 6 (the region the 

refuge is located in) were used in this study. Region 

6 consists of the following States: Montana, North 

Dakota, South Dakota, Nebraska, Wyoming, Utah, 

Colorado, and Kansas. 

COMMENT 4702: Comment that the economic 

analysis does not accurately represent local 

conditions/analysis is flawed 

Response 4072. USGS consulted multiple sources in 

conducting the socioeconomic analysis. The data, 

which were cited in the document, included sources 

from other Federal, State, and local agencies, and 

private landowners. In addition to the meetings with 

county commissioners and other local organizations, 

the USGS obtained the most recent demographic 

and economic county-level data from national and 

State sources. These data sources were the same as 

those used in the reports provided by the counties, 

but more up-to-date. In addition, the socioeconomic 

analysis went through extensive peer review prior 

to the release of the DEIS. 

The Service disagrees that the economic impacts 

were not adequately analyzed. We recognize that 

there could be impacts to some permittees as a result of us carrying out a more aggressive prescriptive grazing program in alternatives B and D (DEIS 

pages 319, 326, 328–331). However, the economic 

analysis does not suggest this action would negatively impact the economy (DEIS page 330).

COMMENT 4801: Specific substantive comment 

about effects from refuge operations, partnerships, 

or adjacent lands (specific text)

Comment 4801a. ...in the EIS......it would be helpful to 

address...these indirect benefits of the protected public lands. I think most of the comments generally 

agree that protected public lands benefit local communities and to look at that more closely, I think. In 

areas where you’re losing population, I think this is 

something to consider and that these protected public relations are features that make communities 

attractive and figure out how to benefit from that.

Response 4801a. The indirect benefits of the refuge 

to local communities are addressed in two areas: 

the economic impacts of refuge staff and visitors are 

described in the socioeconomic affects section (DEIS 

page 312), while the attitudes, values, and perceptions of local communities are discussed as part of 

the socioeconomic affected environment (DEIS page 

252). 

Comment 4801b. How do you plan to handle private 

property within the CMR boundary? Is this where 

“willing seller-willing buyer” comes in to play? You 

remove interior fences and use prescriptive grazing which is unbeneficial to ranchers to force them 

to nonuse and eventually drop their CMR permits, 

thus squeezing them off the CMR. Will FWS then 

buy the deeded land for a fair market price? Or a 

price FWS deems appropriate and compatible?
VOLUME 2, Chapter 3—Comments from Individuals 333

Response 4801b. The Service currently buys inholdings from willing sellers, and this would not change in 

any of the alternatives. We have clarified this in the 

FEIS. The location and timing of future land acquisitions are based on unforeseen opportunities and 

market conditions, and all acquisitions go through an 

appraisal process.

Comment 4801c. In Chapter 4, under “State and Private Lands,” no mention is made of private land in 

DEIS page 191.

Response 4801c. The Service inadvertently left out 

the acreage for private lands in the DEIS (page 191), 

and this section was corrected in the FEIS. However, we did identify the acreage of private lands in 

the DEIS (page 26) and depicted the private lands in 

the DEIS on pages 168–169.

Comment 4801d. Another issue that we have is the fact 

that there is very little mention of State and private 

lands within the document. On Page 191 you mention the present grazing on DNRC lands but mention nothing about private.

Response 4801d. See response 4801c.

Comment 4801e. Every one of these ranchers in here 

have a land patent, and if they bring that land patent 

up into their name, that’s proof of our title against 

the Federal Government, including all apprentices. 

All enabling documents contain the savings rezinum, subject to valid, preexisting rights. All ranchers have water rights and grazing rights on the 

CMR. Lands which have private rights and claims 

attached are not public lands. Nowhere in this document of this plan that you have do you recognize to 

protect private rights.

Response 4801e. On refuge lands, livestock grazing 

is a privilege and not a property right. As stated in 

the DEIS (page 174), the United States holds Federal reserved water rights on the Charles M. Russell National Wildlife Refuge and UL Bend National 

Wildlife Refuge. The United States is in the process 

of quantifying these reserved rights with the Montana Reserved Water Rights Compact Commission. 

The CCP makes no mention of taking any privately 

held right.

5000–Planning and NEPA Processes and 

the Draft CCP and EIS

COMMENT 5001: Specific substantive comment 

about the planning and NEPA processes (specific 

text)

Comment 5001a. On Page 24 through 25...it states that 

you have a lot of emphasis on the assessment that 

was done by Murray of 1935. And I was just wondering why you do not use more recent assessments 

or monitoring that you have done and were dating 

clear back to 1935?...And...you didn’t address climate change 6,000 years ago, or even back in 1935, so 

I would like to see some more research or some more 

current monitoring to help with this CCP.

Response 5001a. None of the alternatives rely solely 

on Olaus Murie’s observations and report. It is true 

that many things have changed during the last 75 

years, many of them to the benefit of wildlife habitat. The Service used his report, based on site visits 

throughout the refuge and conversations with several residents, as an expert reference. Many sources 

for assessment and monitoring were used in the 

development of the CCP.

Comment 5001b. Page 96 C1–C4. Suggest using the refuge manual for guidance in writing a wildlife inventory plan.

Response 5001b. Comment noted.

COMMENT 5003: Comment that the NEPA process 

has not been adequately followed 

Response 5003. The Service disagrees. This CCP and 

NEPA process has consistently met or exceeded 

the standards set by the Council on Environmental Quality, U.S. Department of the Interior, and our 

policies, and other applicable policies and guidelines.

COMMENT 5104: Comment that the public 

involvement process has been inadequate

Response 5104. The Service disagrees. Opportunities 

for public input and comment have met or exceeded 

NEPA and our policies. After the release of the 

Draft CCP and EIS in September 2010, seven public 

meetings were held and the public comment period 

was extended to provide ample opportunity for public involvement. See response 5107.

COMMENT 5107: Comment that local and State 

government coordination has been inadequate

Response 5107. See response to 5104. Cooperating 

agencies, county, and State representatives attended 

most of the meetings, workshops, and provided comments on the internal review document. The DEIS 

(pages 353–359) provides details of the input the 

counties had in the planning process.
334 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

COMMENT 5201: Specific substantive comment 

about the Draft CCP and EIS document (specific 

text)

Comment 5201a. Page 140 Table 3: The time lines set 

for delivering a workable plan seem drawn out. They 

should be given a priority rating, based on the issues 

that are most beneficial to the public and the refuge 

wildlife, and accomplished in that order.

Response 5201a. The record of decision on the FEIS 

will enable the Service to carry out the CCP. Stepdown plans are specific, topic-oriented plans that 

provide us the guidance of carrying out refuges’ 

objectives and strategies. Some stepdown plans are 

relatively easy to write and would not require further public review, while others are more detailed 

and could warrant additional public input. The timelines identified in table 3 of the DEIS take into 

account the complexities of carrying out the objectives and strategies, including the development of 

any stepdown plans. 

Comment 5201b. Page 139 Monitoring and Evaluation: The process they would be accomplished with 

should have been explained and included as part of 

the Plan/EIS.

Response 5201b. Existing and proposed monitoring and evaluation methods for specific resources 

are discussed elsewhere in the DEIS for particular 

topic areas. The Service is in the process of working with ecologists, statisticians, and other scientific disciplines (DEIS page 67) to refine monitoring 

protocols. In the FEIS, we clarified that monitoring 

protocols would be peer reviewed in accordance with 

our information quality guidelines.

Comment 5201c. Page 282, Alt. D [Big Game]: Recommend including the quantitative differences between 

Alternative D and A, to more accurately describe 

the difference between current management and the 

proposed action.

Response 5201c. Differences between the alternatives 

and their effects on all resources are summarized in 

the DEIS (page 145, table 7 and page 335, table 56). 

Quantitative differences between the alternatives 

are found in the big game objectives (DEIS page 86).

COMMENT 5204: Comment that the analysis in the 

Draft CCP and EIS is inadequate

Response 5204. The Service recognizes the objections 

made by some individuals about some of the proposed management objectives, particularly those 

related to prescriptive grazing, road and access management, wilderness, and bison restoration. Despite 

these areas of contention, we stand by the analysis 

of effects described in the DEIS and FEIS. Based 

on the several comments and suggestions on the 

DEIS, we made changes to the alternatives and clarified some of the key concepts and analyses. These 

changes in the FEIS are summarized in appendix B.

COMMENT 5205: Comment detailing specific 

editorial suggestions or errors in the document

Response 5205. The Service appreciates the editorial 

suggestions and errors identified in the comments 

received. Each of these suggested changes was 

reviewed, and where appropriate, has been incorporated into the FEIS.
CHAPTER 4—Public Hearing Testimony

The Service held seven public hearings after release 

of the DEIS to gather input and comments from the 

public on the analysis and management alternatives. 

Responses to substantive comments from the public 

hearings are included in the responses to individual 

comments in chapter 3.

The following pages contain copies of the transcripts from each of the hearings.

■■ Billings, Montana; September 28, 2010 (see pages 

336–353)

■■ Bozeman, Montana; September 29, 2010 (354–369)

■■ Great Falls, Montana; September 30, 2010 (370–

380)

■■ Lewistown, Montana; October 12, 2010 (381–394)

■■ Jordan, Montana; October 13, 2010 (395–412)

■■ Glasgow, Montana; October 14, 2010 (413–426)

■■ Malta, Montana; October 14, 2010 (427–437)
336 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 1

 TRANSCRIPT OF PROCEEDINGS

 U.S. DEPARTMENT OF THE INTERIOR

 U.S. Fish & Wildlife Service

 Charles M. Russell and UL Bend

 National Wildlife Refuges

 The TRANSCRIPT OF PROCEEDINGS at Billings

Hotel Convention Center, Billings, Montana, on

the 28th day of September, 2010, beginning at

7:00 p.m.

PANEL:

BARRON CRAWFORD Project Leader

BILL BERG Deputy Project Leader

LAURIE SHANNON Planner

MIMI MATHER Speaker Facilitator

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

1 (Pages 1 to 4)

Page 2

1 SPEAKERS PAGE

CAL CUMIN 14

GRANT BARNARD 15

MARGARET WEBSTER 17

LESLEY ROBINSON 18, 59

SUSAN GILBERTZ 18

JEFF HUNNES 19

BERNARD ROSE 19

ARLYS RIEGER 22

JANELLE HOLDEN 23

MARK GOOD 25

BERNIE QUETCHENBACH 26

RANDALL GLOEGE 27

DAVE PIPPIN 29, 52

KATHY TETER 32

SUSAN NEWELL 34

MIKE BRYANT 60

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1 P R O C E E D I N G S

 7:00 p.m.

 MS. MATHER: So, thanks, everybody, for

coming tonight.

 The purpose of the meeting is to

collect feedback from you all on the public

Draft.

 We're going to start the meeting with a

brief presentation that Barron is going to give,

an overview of the CCP and a preview of the

alternatives.

 And then we're going to turn the floor

over to you. And anybody who has signed up, and

anybody who hasn't signed up, if you would like

to, can have the floor; have the mic. We're

going to limit it to three minutes.

 We have a court reporter that will be

recording your comments.

 If you are uncomfortable or would

rather not provide comments by standing up here

at the mic, we have handed out these sheets.

 You can enter your comment on the back.

There's also information on here where you can

email your comment, or fax it. So, many

different ways to comment. We just encourage

2

3

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7

8

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10

11

12

13

14

15

16

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Page 4

1 that you comment in some way, and look forward

to hearing what you say.

 So, with that, I'm going to turn it to

Barron and let him give a quick presentation.

 MR. CRAWFORD: Welcome, everybody. My

name is Barron Crawford. I'm the Refuge Manager

for the Charlie Russell Refuge and UL Bend, and

I appreciate everybody coming out tonight.

 For about, oh, 15, 20 minutes here,

I'll just give you a brief overview of what we

have been doing for the past three years and a

little bit about the alternatives that we've

been formulating here during that process, and

talk a little bit about the comment period.

 So, we started back in January of

2007. We've held 14 public meetings so far.

The public scoping period, we received about

24,000 comments. We've had numerous meetings

with our cooperators, and through all those

meetings, we're up to this point now where we

have a Draft Plan that's ready for the public to

see and provide comments on.

 So, this is kind of the timeline. This

shows the steps we have gone through, and where

we are currently, you know, right here. We're

2

3

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Page 1

NGS

TERIOR

NGS at Billings

ana, on

ing at

er

r

r

Page 2

AGE

4

15

17

18, 59

18

Page 3

1 P R O C E E D I N G S

 7:00 p.m.

 MS. MATHER: So, thanks, everybody, for

coming tonight.

 The purpose of the meeting is to

collect feedback from you all on the public

Draft.

 We're going to start the meeting with a

brief presentation that Barron is going to give,

an overview of the CCP and a preview of the

alternatives.

 And then we're going to turn the floor

over to you. And anybody who has signed up, and

anybody who hasn't signed up, if you would like

to, can have the floor; have the mic. We're

going to limit it to three minutes.

 We have a court reporter that will be

recording your comments.

 If you are uncomfortable or would

rather not provide comments by standing up here

at the mic, we have handed out these sheets.

 You can enter your comment on the back.

There's also information on here where you can

email your comment, or fax it. So, many

different ways to comment. We just encourage

2

3

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5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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Page 4

1 that you comment in some way, and look forward

to hearing what you say.

 So, with that, I'm going to turn it to

Barron and let him give a quick presentation.

 MR. CRAWFORD: Welcome, everybody. My

iBCfdI'thRfM

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:f

BIG SKY REPORTING - FRANCES L

Page 2

1 SPEAKERS PAGE

CAL CUMIN 14

GRANT BARNARD 15

MARGARET WEBSTER 17

LESLEY ROBINSON 18, 59

SUSAN GILBERTZ 18

JEFF HUNNES 19

BERNARD ROSE 19

ARLYS RIEGER 22

JANELLE HOLDEN 23

MARK GOOD 25

BERNIE QUETCHENBACH 26

RANDALL GLOEGE 27

DAVE PIPPIN 29, 52

KATHY TETER 32

SUSAN NEWELL 34

MIKE BRYANT 60

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 If you 

rather not pr

at the mic, w

 You ca

There's also 

email your c

different way

19

20

21

22

23

24

25

1 that you com

to hearing wh

 So, with 

Barron and le

 MR. CR

name is Barro

for the Charli

I appreciate e

 For abo

I'll just give y

have been do

little bit abou

been formula

talk a little bi

 So, we 

2007. We've 

The public sc

24,000 comm

with our coop

meetings, we

have a Draft 

see and provi

 So, this 

shows the ste

we are curren

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

1 (Pages 1 to 4)

Page 1

 TRANSCRIPT OF PROCEEDINGS

 U.S. DEPARTMENT OF THE INTERIOR

 U.S. Fish & Wildlife Service

 Charles M. Russell and UL Bend

 National Wildlife Refuges

 The TRANSCRIPT OF PROCEEDINGS at Billings

Hotel Convention Center, Billings, Montana, on

the 28th day of September, 2010, beginning at

7:00 p.m.

PANEL:

BARRON CRAWFORD Project Leader

BILL BERG Deputy Project Leader

LAURIE SHANNON Planner

MIMI MATHER Speaker Facilitator

Page 2

1 SPEAKERS PAGE

CAL CUMIN 14

GRANT BARNARD 15

MARGARET WEBSTER 17

LESLEY ROBINSON 18, 59

SUSAN GILBERTZ 18

JEFF HUNNES 19

BERNARD ROSE 19

ARLYS RIEGER 22

JANELLE HOLDEN 23

MARK GOOD 25

BERNIE QUETCHENBACH 26

RANDALL GLOEGE 27

DAVE PIPPIN 29, 52

KATHY TETER 32

SUSAN NEWELL 34

MIKE BRYANT 60

2

3

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8

9

10

11

12

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18

19

20

21

22

23

24

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Page 3

1 P R O C E E D I N G S

 7:00 p.m.

 MS. MATHER: So, thanks, everybody, for

coming tonight.

 The purpose of the meeting is to

collect feedback from you all on the public

Draft.

 We're going to start the meeting with a

brief presentation that Barron is going to give,

an overview of the CCP and a preview of the

alternatives.

 And then we're going to turn the floor

over to you. And anybody who has signed up, and

anybody who hasn't signed up, if you would like

to, can have the floor; have the mic. We're

going to limit it to three minutes.

 We have a court reporter that will be

recording your comments.

 If you are uncomfortable or would

rather not provide comments by standing up here

at the mic, we have handed out these sheets.

 You can enter your comment on the back.

There's also information on here where you can

email your comment, or fax it. So, many

different ways to comment. We just encourage

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 4

1 that you comment in some way, and look forward

to hearing what you say.

 So, with that, I'm going to turn it to

Barron and let him give a quick presentation.

 MR. CRAWFORD: Welcome, everybody. My

name is Barron Crawford. I'm the Refuge Manager

for the Charlie Russell Refuge and UL Bend, and

I appreciate everybody coming out tonight.

 For about, oh, 15, 20 minutes here,

I'll just give you a brief overview of what we

have been doing for the past three years and a

little bit about the alternatives that we've

been formulating here during that process, and

talk a little bit about the comment period.

 So, we started back in January of

2007. We've held 14 public meetings so far.

The public scoping period, we received about

24,000 comments. We've had numerous meetings

with our cooperators, and through all those

meetings, we're up to this point now where we

have a Draft Plan that's ready for the public to

see and provide comments on.

 So, this is kind of the timeline. This

shows the steps we have gone through, and where

we are currently, you know, right here. We're

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
VOLUME 2, Chapter 4—Public Hearing Testimony 337

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

2 (Pages 5 to 8)

Page 5

1 releasing the Draft out. We're going to be open

for a 60-day comment period.

 After that, Refuge staff will be

spending their time assessing those comments and

formulating the Final Plan.

 So, why do we do a CCP?

 And basically the National Wildlife

Refuge System Improvement Act mandates that we

have CCPs for all of our refuges. And in that

Act, it said that all refuges will have a

completed Plan by 2012.

 So, that's what we are working towards

right now, meeting that deadline.

 What are some of the key elements of a

CCP?

 It basically provides the management

direction and guidance based upon the refuge

purposes and the mission of the National

Wildlife Refuge System.

 It outlines the vision statement,

goals, objectives and strategies for that

management.

 It is accompanied by some type of a

NEPA document, either an Environmental

Assessment or an Environmental Impact

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

22

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24

25

Page 6

1 Statement. For the CMR, and we did an

Environmental Impact Statement.

 And it's to provide that long-term

guidance, that long-term management. And our

plans cover 15 years.

 Now, that doesn't mean that they can't

be gone back and revisited during that time

period. What that means is that at the end of

that 15 years, you need to have another plan

started.

 So, this is just another kind of a

diagram of the CCP process. And again, you

know, we are sitting down here, "Draft Plan",

"Draft NEPA document", "Comment Period", and

then it goes up here for the preparing of the

Final.

 So, a little bit about the

alternatives.

 We have four alternatives. The first

one is Alternative A, and that's the "No Action"

alternative. It's basically maintain the

existing wildlife and habitat management goals

and objectives that we're currently operating

under from the 1986 EIS.

 Continue to provide wildlife-dependent

2

3

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10

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12

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Page 7

1 public and economic uses at current levels.

 We will have a few changes in managing

existing wildlife populations and habitat. Some

of those, you know, we'll still manage under the

'65 Habitat EIS that we have now.

 We'll gradually implement prescriptive

grazing, like we've been doing over the past 10

years or so.

 Big game will still be managed at the

levels that were stated in the '86 EIS.

 We'll still keep, you know, the 670

miles of roads that are out there.

 And we will continue to protect the

155,000 acres of proposed wilderness.

 Alternative B. We call this one the

"Wildlife and Habitat alternative". And it's

basically manage the landscape in cooperation

with our partners to emphasize the abundance and

diversity of wildlife populations using both

balanced, natural ecological processes, such as

fire and wildlife ungulate herbivory and some

synthetic methods, such as farming, tree

planting, flooding.

 We'll still encourage

wildlife-dependent public uses. That's hunting

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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Page 8

1 and fishing and wildlife viewing and wildlife

observation, wildlife photography and

environmental education and interpretation.

 And we will limit some of those

economic uses when they compete for habitat

resources.

 This is just a map. And we've got

these maps scattered around the room here, so

when we're done, if you wanted a closer look,

you can come up and look at them. They're also

in the document, obviously.

 But this shows the wilderness areas.

Where we're proposing to expand some wilderness

areas; roads that we're proposing to close.

 This is the west side of the refuge.

This is the east side of the refuge. This is

all under Alternative B.

 Some of the differences in

Alternative B is we will actively manage and

manipulate habitats to create wildlife food and

cover.

 Implement prescriptive grazing on 50 to

65% of the refuge within the next four to seven

years.

 Aggressively restore the river bottoms

2

3

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Page 5

ing to be open

 be

se comments and

Wildlife

t mandates that we

 And in that

ave a

ing towards

lements of a

nagement

n the refuge

National

ent,

or that

type of a

onmental

 Impact

Page 6

e did an

.

g-term

ment. And our

t they can't

Page 7

1 public and economic uses at current levels.

 We will have a few changes in managing

existing wildlife populations and habitat. Some

of those, you know, we'll still manage under the

'65 Habitat EIS that we have now.

 We'll gradually implement prescriptive

grazing, like we've been doing over the past 10

years or so.

 Big game will still be managed at the

levels that were stated in the '86 EIS.

 We'll still keep, you know, the 670

miles of roads that are out there.

 And we will continue to protect the

155,000 acres of proposed wilderness.

 Alternative B. We call this one the

"Wildlife and Habitat alternative". And it's

basically manage the landscape in cooperation

with our partners to emphasize the abundance and

diversity of wildlife populations using both

balanced, natural ecological processes, such as

fire and wildlife ungulate herbivory and some

synthetic methods, such as farming, tree

planting, flooding.

 We'll still encourage

wildlife-dependent public uses. That's hunting

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 8

1 and fishing and wildlife viewing and wildlife

observation, wildlife photography and

environmental education and interpretation.

 And we will limit some of those

economic uses when they compete for habitat

resources

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

Wildlife Refuge System.

 It outlines the vision statement,

goals, objectives and strategies for that

management.

 It is accompanied by some type of a

NEPA document, either an Environmental

Assessment or an Environmental Impact

19

20

21

22

23

24

25

Page 6

1 Statement. For the CMR, and we did an

Environmental Impact Statement.

 And it's to provide that long-term

guidance, that long-term management. And our

plans cover 15 years.

 Now, that doesn't mean that they can't

be gone back and revisited during that time

period. What that means is that at the end of

that 15 years, you need to have another plan

started.

 So, this is just another kind of a

diagram of the CCP process. And again, you

know, we are sitting down here, "Draft Plan",

"Draft NEPA document", "Comment Period", and

then it goes up here for the preparing of the

Final.

 So, a little bit about the

alternatives.

 We have four alternatives. The first

one is Alternative A, and that's the "No Action"

alternative. It's basically maintain the

existing wildlife and habitat management goals

and objectives that we're currently operating

under from the 1986 EIS.

 Continue to provide wildlife-dependent

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

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20

21

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24

25

diversity 

balanced

fire and 

syntheti

planting

 W

wildlife

19

20

21

22

23

24

25

1 and fish

observa

environm

 An

econom

resource

 Th

these m

when w

you can 

in the do

 Bu

Where w

areas; ro

 Th

This is t

all unde

 So

Alternat

manipul

cover.

 Im

65% of 

years.

 Ag

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

2 (Pages 5 to 8)

Page 5

1 releasing the Draft out. We're going to be open

for a 60-day comment period.

 After that, Refuge staff will be

spending their time assessing those comments and

formulating the Final Plan.

 So, why do we do a CCP?

 And basically the National Wildlife

Refuge System Improvement Act mandates that we

have CCPs for all of our refuges. And in that

Act, it said that all refuges will have a

completed Plan by 2012.

 So, that's what we are working towards

right now, meeting that deadline.

 What are some of the key elements of a

CCP?

 It basically provides the management

direction and guidance based upon the refuge

purposes and the mission of the National

Wildlife Refuge System.

 It outlines the vision statement,

goals, objectives and strategies for that

management.

 It is accompanied by some type of a

NEPA document, either an Environmental

Assessment or an Environmental Impact

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 6

1 Statement. For the CMR, and we did an

Environmental Impact Statement.

 And it's to provide that long-term

guidance, that long-term management. And our

plans cover 15 years.

 Now, that doesn't mean that they can't

be gone back and revisited during that time

period. What that means is that at the end of

that 15 years, you need to have another plan

started.

 So, this is just another kind of a

diagram of the CCP process. And again, you

know, we are sitting down here, "Draft Plan",

"Draft NEPA document", "Comment Period", and

then it goes up here for the preparing of the

Final.

 So, a little bit about the

alternatives.

 We have four alternatives. The first

one is Alternative A, and that's the "No Action"

alternative. It's basically maintain the

existing wildlife and habitat management goals

and objectives that we're currently operating

under from the 1986 EIS.

 Continue to provide wildlife-dependent

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 7

1 public and economic uses at current levels.

 We will have a few changes in managing

existing wildlife populations and habitat. Some

of those, you know, we'll still manage under the

'65 Habitat EIS that we have now.

 We'll gradually implement prescriptive

grazing, like we've been doing over the past 10

years or so.

 Big game will still be managed at the

levels that were stated in the '86 EIS.

 We'll still keep, you know, the 670

miles of roads that are out there.

 And we will continue to protect the

155,000 acres of proposed wilderness.

 Alternative B. We call this one the

"Wildlife and Habitat alternative". And it's

basically manage the landscape in cooperation

with our partners to emphasize the abundance and

diversity of wildlife populations using both

balanced, natural ecological processes, such as

fire and wildlife ungulate herbivory and some

synthetic methods, such as farming, tree

planting, flooding.

 We'll still encourage

wildlife-dependent public uses. That's hunting

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 8

1 and fishing and wildlife viewing and wildlife

observation, wildlife photography and

environmental education and interpretation.

 And we will limit some of those

economic uses when they compete for habitat

resources.

 This is just a map. And we've got

these maps scattered around the room here, so

when we're done, if you wanted a closer look,

you can come up and look at them. They're also

in the document, obviously.

 But this shows the wilderness areas.

Where we're proposing to expand some wilderness

areas; roads that we're proposing to close.

 This is the west side of the refuge.

This is the east side of the refuge. This is

all under Alternative B.

 Some of the differences in

Alternative B is we will actively manage and

manipulate habitats to create wildlife food and

cover.

 Implement prescriptive grazing on 50 to

65% of the refuge within the next four to seven

years.

 Aggressively restore the river bottoms

2

3

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338 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

3 (Pages 9 to 12)

Page 9

1 to native vegetation.

 Work with Montana Fish, Wildlife &

Parks to provide quality hunting opportunities

and sustain populations of big game and habitat

for nongame.

 Close approximately 106 miles of road,

and expand acreage of proposed wilderness by

25,000 acres in six units.

 Alternative C is what we call the

"Public Use and Economic Use alternative". And

this is basically manage the landscape in

cooperation with our partners and emphasize and

promote maximum compatible wildlife-dependent

public uses and economic uses while protecting

wildlife populations and habitats. Minimize

damaging impacts to wildlife habitats while

using a variety of management tools to enhance

and diversify public and economic opportunities.

 Under this alternative, we're not

proposing to close any roads, and we're not

proposing to expand any wilderness areas --

oops, excuse me. We will be closing one.

That's the East Hell Creek proposed wilderness

area.

 There is just a pre-synopsis of that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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Page 10

1 alternative. Manage habitats to provide more

opportunities for recreation.

 Work with the Montana Fish, Wildlife &

Parks to maintain balance numbers of big game

and livestock.

 Work with Montana Fish, Wildlife &

Parks to expand and maximize hunting

opportunities.

 Improve access to boat ramps; seasonal

closures in other areas.

 And, recommend eliminating four

proposed wilderness areas, for a total of 35,000

acres.

 And then Alternative D. This is our

Proposed Action alternative, and this is the one

we've called the "Natural Processes", or the

"Ecological Processes alternative".

 And again, working with our partners.

Intensively use natural ecological processes,

such as fire and grazing, and active management

to restore and maintain the biological diversity

and biological integrity and environmental

health of the refuges.

 Once natural processes are restored, a

more passive management approach is adapted.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

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Page 11

1 Provide for quality wildlife-dependent public

uses and experiences, and limit economic use

when they are injurious to ecological processes

or habitats.

 In this one, we are proposing to close

a few roads. We're proposing to expand a few

wilderness areas, and we're proposing to

eliminate a couple of others.

 A brief synopsis of this alternative.

Economic uses would be limited when they're

injurious to the processes.

 Apply management practices that mimic

and restore natural processes.

 Use fire and wild ungulate herbivory

and/or prescriptive livestock grazing on 50 to

75% of the refuge to mimic historic fire/grazing

interaction.

 Work with Montana Fish, Wildlife &

Parks to maintain health and diversity of all

species.

 Implement permanent or seasonal road

closures on 23 miles of roads.

 And, recommend expanding six proposed

wilderness areas, for an increase of 18,500

acres, and eliminate three units, for a decrease

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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19

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Page 12

1 of 26,000 acres.

 So, as Mimi was saying, we want to hear

your comments.

 We have several ways in which you can

comment. You can get up today, give your

proposed testimony, which will be recorded.

 The sheets that were handed out, you

can write a comment on that and drop them in the

envelope that Laurie has over there.

 You can send us written comments that

are in the Planning Updates, and you could mail

those to us.

 Or, you can send us an email to our web

address.

 All of those -- it doesn't matter which

way you use, they're all counted the same. It's

not a voting contest. What we are looking for

is succinct comments that are relevant to this

planning process.

 Right now, our comment period is

scheduled to end on November 16th. We have

received a couple of requests to extend that

comment period, and we haven't acted on those

yet. We're going to wait and see how the

commenting goes before we make that decision.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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Page 9

ife &

rtunities

nd habitat

of road,

erness by

e

ative". And

 in

phasize and

fe-dependent

protecting

nimize

 while

o enhance

portunities.

re not

reas --

one.

wilderness

hat

Page 10

de more

ildlife &

 big game

Page 11

1 Provide for quality wildlife-dependent public

uses and experiences, and limit economic use

when they are injurious to ecological processes

or habitats.

 In this one, we are proposing to close

a few roads. We're proposing to expand a few

wilderness areas, and we're proposing to

eliminate a couple of others.

 A brief synopsis of this alternative.

Economic uses would be limited when they're

injurious to the processes.

 Apply management practices that mimic

and restore natural processes.

 Use fire and wild ungulate herbivory

and/or prescriptive livestock grazing on 50 to

75% of the refuge to mimic historic fire/grazing

interaction.

 Work with Montana Fish, Wildlife &

Parks to maintain health and diversity of all

species.

 Implement permanent or seasonal road

closures on 23 miles of roads.

 And, recommend expanding six proposed

wilderness areas, for an increase of 18,500

acres, and eliminate three units, for a decrease

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 12

1 of 26,000 acres.

 So, as Mimi was saying, we want to hear

your comments.

 We have several ways in which you can

comment. You can get up today, give your

2

3

4

5

(406)248-4064 Fax:(406)256-5525 E-Mail:f

BIG SKY REPORTING - FRANCES L

 Under this alternative, were not

proposing to close any roads, and we're not

proposing to expand any wilderness areas --

oops, excuse me. We will be closing one.

That's the East Hell Creek proposed wilderness

area.

 There is just a pre-synopsis of that

19

20

21

22

23

24

25

Page 10

1 alternative. Manage habitats to provide more

opportunities for recreation.

 Work with the Montana Fish, Wildlife &

Parks to maintain balance numbers of big game

and livestock.

 Work with Montana Fish, Wildlife &

Parks to expand and maximize hunting

opportunities.

 Improve access to boat ramps; seasonal

closures in other areas.

 And, recommend eliminating four

proposed wilderness areas, for a total of 35,000

acres.

 And then Alternative D. This is our

Proposed Action alternative, and this is the one

we've called the "Natural Processes", or the

"Ecological Processes alternative".

 And again, working with our partners.

Intensively use natural ecological processes,

such as fire and grazing, and active management

to restore and maintain the biological diversity

and biological integrity and environmental

health of the refuges.

 Once natural processes are restored, a

more passive management approach is adapted.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Parks to mai

species.

 Implem

closures on 

 And, r

wilderness a

acres, and el

19

20

21

22

23

24

25

1 of 26,000 ac

 So, as 

your comme

 We ha

comment. Y

proposed tes

 The sh

can write a c

envelope tha

 You ca

are in the Pl

those to us.

 Or, yo

address.

 All of 

way you use

not a voting 

is succinct c

planning pro

 Right n

scheduled to 

received a c

comment pe

yet. We're g

commenting 

2

3

4

5

6

7

8

9

10

11

12

13

14

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18

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20

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22

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25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

3 (Pages 9 to 12)

Page 9

1 to native vegetation.

 Work with Montana Fish, Wildlife &

Parks to provide quality hunting opportunities

and sustain populations of big game and habitat

for nongame.

 Close approximately 106 miles of road,

and expand acreage of proposed wilderness by

25,000 acres in six units.

 Alternative C is what we call the

"Public Use and Economic Use alternative". And

this is basically manage the landscape in

cooperation with our partners and emphasize and

promote maximum compatible wildlife-dependent

public uses and economic uses while protecting

wildlife populations and habitats. Minimize

damaging impacts to wildlife habitats while

using a variety of management tools to enhance

and diversify public and economic opportunities.

 Under this alternative, we're not

proposing to close any roads, and we're not

proposing to expand any wilderness areas --

oops, excuse me. We will be closing one.

That's the East Hell Creek proposed wilderness

area.

 There is just a pre-synopsis of that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 10

1 alternative. Manage habitats to provide more

opportunities for recreation.

 Work with the Montana Fish, Wildlife &

Parks to maintain balance numbers of big game

and livestock.

 Work with Montana Fish, Wildlife &

Parks to expand and maximize hunting

opportunities.

 Improve access to boat ramps; seasonal

closures in other areas.

 And, recommend eliminating four

proposed wilderness areas, for a total of 35,000

acres.

 And then Alternative D. This is our

Proposed Action alternative, and this is the one

we've called the "Natural Processes", or the

"Ecological Processes alternative".

 And again, working with our partners.

Intensively use natural ecological processes,

such as fire and grazing, and active management

to restore and maintain the biological diversity

and biological integrity and environmental

health of the refuges.

 Once natural processes are restored, a

more passive management approach is adapted.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 11

1 Provide for quality wildlife-dependent public

uses and experiences, and limit economic use

when they are injurious to ecological processes

or habitats.

 In this one, we are proposing to close

a few roads. We're proposing to expand a few

wilderness areas, and we're proposing to

eliminate a couple of others.

 A brief synopsis of this alternative.

Economic uses would be limited when they're

injurious to the processes.

 Apply management practices that mimic

and restore natural processes.

 Use fire and wild ungulate herbivory

and/or prescriptive livestock grazing on 50 to

75% of the refuge to mimic historic fire/grazing

interaction.

 Work with Montana Fish, Wildlife &

Parks to maintain health and diversity of all

species.

 Implement permanent or seasonal road

closures on 23 miles of roads.

 And, recommend expanding six proposed

wilderness areas, for an increase of 18,500

acres, and eliminate three units, for a decrease

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 12

1 of 26,000 acres.

 So, as Mimi was saying, we want to hear

your comments.

 We have several ways in which you can

comment. You can get up today, give your

proposed testimony, which will be recorded.

 The sheets that were handed out, you

can write a comment on that and drop them in the

envelope that Laurie has over there.

 You can send us written comments that

are in the Planning Updates, and you could mail

those to us.

 Or, you can send us an email to our web

address.

 All of those -- it doesn't matter which

way you use, they're all counted the same. It's

not a voting contest. What we are looking for

is succinct comments that are relevant to this

planning process.

 Right now, our comment period is

scheduled to end on November 16th. We have

received a couple of requests to extend that

comment period, and we haven't acted on those

yet. We're going to wait and see how the

commenting goes before we make that decision.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
VOLUME 2, Chapter 4—Public Hearing Testimony 339

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

4 (Pages 13 to 16)

Page 13

1 So, right now, as it stands,

November 16th is the comment period.

 So, we're going to open the floor up.

We ask that you be respectful of your time.

It's not going to be a problem here tonight. We

got a small enough crowd that we should have

ample time for everybody to get their comments

in. And, look forward to hearing from you.

 Thanks.

 MS. MATHER: Okay.

 So, here's how Part 2 of the meeting

will run.

 I've got the list of everybody that's

signed up that wants to speak. If you haven't

signed up, or you're inspired by somebody else's

comment, go ahead and see Matt and sign up.

 We're going to hold people to three

minutes just so we're not here all night, so,

please summarize your thoughts and get it down

to three minutes.

 I will be a rather strict timekeeper up

here. I've got a stopwatch going, and I will

give you a flag when you have one minute left;

when you have 20 seconds left, and when you are

out of time, and then I pull you off the mic.

2

3

4

5

6

7

8

9

10

11

12

13

14

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22

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Page 14

1 So, three minutes.

 I know some of you mentioned that you

don't have a comment, per se, but you have a

question, so please come up; say your question.

 We're going to be recording those, and

then after all the comments are spoken, Bill,

Laurie and Barron will take the time to respond

to those questions.

 So, even if you have a 30-second

question, go ahead and come up and say it.

 We would like you to withhold any

applause or cheering. Let's just try to move

through this smoothly with one after the other.

 So, what I'm going to do is call

somebody up. I'm also going to let you know who

is on deck so that person can be ready to jump

up here.

 So with that, Cal.

 And then I've got Grant. So, come on

up.

 CAL CUMIN: My name is Cal Cumin. Last

name spelled C-U-M-I-N. I'm from Billings.

 I would like to compliment the U.S.

Fish & Wildlife Service on its effort to try to

address the -- or to try to bring some consensus

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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22

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25

Page 15

1 to the always contentious issues of land use,

environment and property rights that is extant

in Montana, especially eastern Montana.

 I'm very familiar with this whole

area. I grew up -- I'm a fourth-generation

Montanan. I absolutely love the "empty corner",

as some people call eastern Montana.

 As far as your plan, I like

Alternative D, your last one.

 I don't like to see you close

wilderness areas, proposed wilderness areas, or

expand roads. That's kind of a bottom line.

 But, in the interest of trying to work

together with other interests that I know feel

just as strongly, I would support Plan D.

 Thank you.

 MS. MATHER: Grant, and then Margaret.

 GRANT BARNARD: My name is Grant

Barnard. I live in Red Lodge. Raised in

central Montana.

 I have a question or two that someone

might be able to comment on.

 I would like to know about your road

density. What is the road density currently in

the refuge, and what it would be when you

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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Page 16

1 subtracted some of the roads that you propose in

Alternative B.

 I'd also like to have a clear

understanding of who manages river traffic, and

who is the authority and how that is to be

managed through wilderness, proposed wilderness

areas in the Alternative B, and also in D.

 And I would like to know how you plan

to manage RV use. I think I have an idea, and

if it is to keep RVs completely on designated

roads, that sounds good to me.

 I'd also support any road closures that

are off these -- that you have in

Alternative B.

 And I'd like to know a little bit more

about why the proposed wilderness areas would be

dropped from Alternative B.

 And those, it seems to be because

there's a road through the middle of each of

those, but in my opinion, that would not be a

significant reason to eliminate that from

possible wilderness designation. After all,

there is more than 5,000 acres of proposed

wilderness on each side of those roads in both

of those areas that are proposed to be dropped.

2

3

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8

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Page 13

period.

 floor up.

your time.

e tonight. We

e should have

their comments

 from you.

 meeting

y that's

 you haven't

omebody else's

 and sign up.

 to three

 night, so,

and get it down

keeper up

 and I will

ne minute left;

nd when you are

ff the mic.

Page 14

ned that you

t you have a

your question.

g those, and

pokenBill

Page 15

1 to the always contentious issues of land use,

environment and property rights that is extant

in Montana, especially eastern Montana.

 I'm very familiar with this whole

area. I grew up -- I'm a fourth-generation

Montanan. I absolutely love the "empty corner",

as some people call eastern Montana.

 As far as your plan, I like

Alternative D, your last one.

 I don't like to see you close

wilderness areas, proposed wilderness areas, or

expand roads. That's kind of a bottom line.

 But, in the interest of trying to work

together with other interests that I know feel

just as strongly, I would support Plan D.

 Thank you.

 MS. MATHER: Grant, and then Margaret.

 GRANT BARNARD: My name is Grant

Barnard. I live in Red Lodge. Raised in

central Montana.

 I have a question or two that someone

might be able to comment on.

 I would like to know about your road

density. What is the road density currently in

the refuge, and what it would be when you

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 16

1 subtracted some of the roads that you propose in

Alternative B.

 I'd also like to have a clear

understanding of who manages river traffic, and

who is the authority and how that is to be

managed through wildernessproposed wilderness

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

please summarize your thoughts and get it down

to three minutes.

 I will be a rather strict timekeeper up

here. I've got a stopwatch going, and I will

give you a flag when you have one minute left;

when you have 20 seconds left, and when you are

out of time, and then I pull you off the mic.

19

20

21

22

23

24

25

Page 14

1 So, three minutes.

 I know some of you mentioned that you

don't have a comment, per se, but you have a

question, so please come up; say your question.

 We're going to be recording those, and

then after all the comments are spoken, Bill,

Laurie and Barron will take the time to respond

to those questions.

 So, even if you have a 30-second

question, go ahead and come up and say it.

 We would like you to withhold any

applause or cheering. Let's just try to move

through this smoothly with one after the other.

 So, what I'm going to do is call

somebody up. I'm also going to let you know who

is on deck so that person can be ready to jump

up here.

 So with that, Cal.

 And then I've got Grant. So, come on

up.

 CAL CUMIN: My name is Cal Cumin. Last

name spelled C-U-M-I-N. I'm from Billings.

 I would like to compliment the U.S.

Fish & Wildlife Service on its effort to try to

address the -- or to try to bring some consensus

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Barnard

central M

 I h

might b

 I w

density. 

the refu

19

20

21

22

23

24

25

1 subtract

Alternat

 I'd 

understa

who is t

manage

areas in 

 An

to mana

if it is to 

roads, th

 I'd 

are off t

Alternat

 An

about w

dropped 

 An

there's a 

those, b

significa

possible 

there is 

wildern

of those 

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

4 (Pages 13 to 16)

Page 13

1 So, right now, as it stands,

November 16th is the comment period.

 So, we're going to open the floor up.

We ask that you be respectful of your time.

It's not going to be a problem here tonight. We

got a small enough crowd that we should have

ample time for everybody to get their comments

in. And, look forward to hearing from you.

 Thanks.

 MS. MATHER: Okay.

 So, here's how Part 2 of the meeting

will run.

 I've got the list of everybody that's

signed up that wants to speak. If you haven't

signed up, or you're inspired by somebody else's

comment, go ahead and see Matt and sign up.

 We're going to hold people to three

minutes just so we're not here all night, so,

please summarize your thoughts and get it down

to three minutes.

 I will be a rather strict timekeeper up

here. I've got a stopwatch going, and I will

give you a flag when you have one minute left;

when you have 20 seconds left, and when you are

out of time, and then I pull you off the mic.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 14

1 So, three minutes.

 I know some of you mentioned that you

don't have a comment, per se, but you have a

question, so please come up; say your question.

 We're going to be recording those, and

then after all the comments are spoken, Bill,

Laurie and Barron will take the time to respond

to those questions.

 So, even if you have a 30-second

question, go ahead and come up and say it.

 We would like you to withhold any

applause or cheering. Let's just try to move

through this smoothly with one after the other.

 So, what I'm going to do is call

somebody up. I'm also going to let you know who

is on deck so that person can be ready to jump

up here.

 So with that, Cal.

 And then I've got Grant. So, come on

up.

 CAL CUMIN: My name is Cal Cumin. Last

name spelled C-U-M-I-N. I'm from Billings.

 I would like to compliment the U.S.

Fish & Wildlife Service on its effort to try to

address the -- or to try to bring some consensus

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 15

1 to the always contentious issues of land use,

environment and property rights that is extant

in Montana, especially eastern Montana.

 I'm very familiar with this whole

area. I grew up -- I'm a fourth-generation

Montanan. I absolutely love the "empty corner",

as some people call eastern Montana.

 As far as your plan, I like

Alternative D, your last one.

 I don't like to see you close

wilderness areas, proposed wilderness areas, or

expand roads. That's kind of a bottom line.

 But, in the interest of trying to work

together with other interests that I know feel

just as strongly, I would support Plan D.

 Thank you.

 MS. MATHER: Grant, and then Margaret.

 GRANT BARNARD: My name is Grant

Barnard. I live in Red Lodge. Raised in

central Montana.

 I have a question or two that someone

might be able to comment on.

 I would like to know about your road

density. What is the road density currently in

the refuge, and what it would be when you

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 16

1 subtracted some of the roads that you propose in

Alternative B.

 I'd also like to have a clear

understanding of who manages river traffic, and

who is the authority and how that is to be

managed through wilderness, proposed wilderness

areas in the Alternative B, and also in D.

 And I would like to know how you plan

to manage RV use. I think I have an idea, and

if it is to keep RVs completely on designated

roads, that sounds good to me.

 I'd also support any road closures that

are off these -- that you have in

Alternative B.

 And I'd like to know a little bit more

about why the proposed wilderness areas would be

dropped from Alternative B.

 And those, it seems to be because

there's a road through the middle of each of

those, but in my opinion, that would not be a

significant reason to eliminate that from

possible wilderness designation. After all,

there is more than 5,000 acres of proposed

wilderness on each side of those roads in both

of those areas that are proposed to be dropped.

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340 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

5 (Pages 17 to 20)

Page 17

1 Thank you for the time.

 MS. MATHER: Thank you.

 Okay, Margaret, and then Lesley on

deck.

 MARGARET WEBSTER: My name is Margaret

Webster, like the dictionary, W-E-B-S-T-E-R.

 I have a comment and sort of a

question.

 I support Alternative D. I don't

believe that there should be a reduction of

wilderness area. I think it should at least

stay at the present number of acres, or increase

it.

 Also, as part of the mission of the

refuge is to provide habitat for a variety of

wildlife. It seems like most of the discussion

surrounds big game species, but I would like to

know about the plans for the nongame species,

such as the prairie dogs, which are threatened

by sylvatic plague.

 Over 100 vertebrate species are

associated with the black-tail prairie dog

habitat, including four species of regional

concern, such as the burrowing owl, swift fox,

ferruginous hawk and mountain plover.

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Page 18

1 MS. MATHER: Thank you.

 Lesley, and then Susan on deck.

 LESLEY ROBINSON: Lesley Robinson.

It's R-O-B -- Lesley is L-E-S-L-E-Y. Robinson

is R-O-B-I-N-S-O-N. I'm a Phillips County

Commissioner.

 We just had a six-county meeting this

afternoon, and we will be sending an official

request for an extension of 60 days for the

comment period.

 And that's all my comments for this

evening.

 MS. MATHER: Susan, and then Jeff.

 SUSAN GILBERTZ: Hi. I'm Susan

Gilbertz, G-I-L-B-E-R-T-Z.

 And conceptually, I like Plan D, as in

dog, with one exception, and that would be the

reduction of acreage of wilderness area.

 I am sympathetic to the notion of

changing some areas to kind of capture areas

that are perhaps better suited for that

management style, but overall, I would hate to

see a reduction in the number of acreage.

 Thanks.

 MS. MATHER: Jeff, and then Bernard.

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Page 19

1 JEFF HUNNES: Good evening. My name's

Jeff Hunnes. Last name is spelled H-U-N-N-E-S.

 I live here in Billings, but I grew up

in Miles City and spent a lot of time at Hell

Creek, and I'm really excited that you guys are

proposing some wilderness in that area because I

know what a special remote and wild area it is,

and I want to commend you for that.

 In general, I would support

Alternative B, as in boy. I would be in favor

of increased wilderness, or proposed wilderness

designation in the refuge.

 I had a comment -- or a question, if

you are able to kind of explain the difference

in the management priorities between the Fish &

Wildlife Service and, for example, the Bureau of

Land Management or the Forest Service, and

whether any of these alternatives is more in

keeping with the priorities that this particular

agency has?

 Thank you.

 MS. MATHER: Bernard. And Arlys on

deck.

 BERNARD ROSE: Hi. I'm Bernard Rose,

the way it sounds.

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Page 20

1 I'm concerned that often when we talk

about wilderness, people seem to think that

wilderness has no value to local people; that

somehow or another, if we make it into

wilderness, no one will come.

 I know there are studies which indicate

that people value wilderness; that people come

to hunt in the wilderness; that people come to

enjoy the wilderness; that they are a real

amenities values.

 I think we see this in the western part

of the state where areas we have significant

wilderness or desirable places for people to

live and to build homes and to do all of these

kinds of things.

 And sometimes it seems to me that when

you mention wilderness, it's kind of the "Big W

word", one of those things that you're not

supposed to say, because it takes away from the

value.

 And, you know, if there's grazing, and

if we remove grazing, although grazing is still

allowed in wilderness, existing wilderness, such

as existing grazing rights are protected in

wilderness, which I think most people normally

2

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Page 17

n

me is Margaret

-E-R.

f

crease

of

sion

like to

ecies,

ened

l

ft fox,

Page 18

Robinson.

Robinson

County

Page 19

1 JEFF HUNNES: Good evening. My name's

Jeff Hunnes. Last name is spelled H-U-N-N-E-S.

 I live here in Billings, but I grew up

in Miles City and spent a lot of time at Hell

Creek, and I'm really excited that you guys are

proposing some wilderness in that area because I

know what a special remote and wild area it is,

and I want to commend you for that.

 In general, I would support

Alternative B, as in boy. I would be in favor

of increased wilderness, or proposed wilderness

designation in the refuge.

 I had a comment -- or a question, if

you are able to kind of explain the difference

in the management priorities between the Fish &

Wildlife Service and, for example, the Bureau of

Land Management or the Forest Service, and

whether any of these alternatives is more in

keeping with the priorities that this particular

agency has?

 Thank you.

 MS. MATHER: Bernard. And Arlys on

deck.

 BERNARD ROSE: Hi. I'm Bernard Rose,

the way it sounds.

2

3

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Page 20

1 I'm concerned that often when we talk

about wilderness, people seem to think that

wilderness has no value to local people; that

somehow or another, if we make it into

wilderness, no one will come.

I know there are studies which indicate

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

such as the prairie dogs, which are threatened

by sylvatic plague.

 Over 100 vertebrate species are

associated with the black-tail prairie dog

habitat, including four species of regional

concern, such as the burrowing owl, swift fox,

ferruginous hawk and mountain plover.

19

20

21

22

23

24

25

Page 18

1 MS. MATHER: Thank you.

 Lesley, and then Susan on deck.

 LESLEY ROBINSON: Lesley Robinson.

It's R-O-B -- Lesley is L-E-S-L-E-Y. Robinson

is R-O-B-I-N-S-O-N. I'm a Phillips County

Commissioner.

 We just had a six-county meeting this

afternoon, and we will be sending an official

request for an extension of 60 days for the

comment period.

 And that's all my comments for this

evening.

 MS. MATHER: Susan, and then Jeff.

 SUSAN GILBERTZ: Hi. I'm Susan

Gilbertz, G-I-L-B-E-R-T-Z.

 And conceptually, I like Plan D, as in

dog, with one exception, and that would be the

reduction of acreage of wilderness area.

 I am sympathetic to the notion of

changing some areas to kind of capture areas

that are perhaps better suited for that

management style, but overall, I would hate to

see a reduction in the number of acreage.

 Thanks.

 MS. MATHER: Jeff, and then Bernard.

2

3

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5

6

7

8

9

10

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keeping with 

agency has?

 Thank 

 MS. M

deck.

 BERNA

the way it so

19

20

21

22

23

24

25

1 I'm con

about wilder

wilderness h

somehow or 

wilderness, n

 I know 

that people v

to hunt in the 

enjoy the wil

amenities va

 I think 

of the state w

wilderness o

live and to bu

kinds of thin

 And so

you mention 

word", one o

supposed to 

value.

 And, yo

if we remove 

allowed in w

as existing gr

wilderness, w

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

5 (Pages 17 to 20)

Page 17

1 Thank you for the time.

 MS. MATHER: Thank you.

 Okay, Margaret, and then Lesley on

deck.

 MARGARET WEBSTER: My name is Margaret

Webster, like the dictionary, W-E-B-S-T-E-R.

 I have a comment and sort of a

question.

 I support Alternative D. I don't

believe that there should be a reduction of

wilderness area. I think it should at least

stay at the present number of acres, or increase

it.

 Also, as part of the mission of the

refuge is to provide habitat for a variety of

wildlife. It seems like most of the discussion

surrounds big game species, but I would like to

know about the plans for the nongame species,

such as the prairie dogs, which are threatened

by sylvatic plague.

 Over 100 vertebrate species are

associated with the black-tail prairie dog

habitat, including four species of regional

concern, such as the burrowing owl, swift fox,

ferruginous hawk and mountain plover.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

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22

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Page 18

1 MS. MATHER: Thank you.

 Lesley, and then Susan on deck.

 LESLEY ROBINSON: Lesley Robinson.

It's R-O-B -- Lesley is L-E-S-L-E-Y. Robinson

is R-O-B-I-N-S-O-N. I'm a Phillips County

Commissioner.

 We just had a six-county meeting this

afternoon, and we will be sending an official

request for an extension of 60 days for the

comment period.

 And that's all my comments for this

evening.

 MS. MATHER: Susan, and then Jeff.

 SUSAN GILBERTZ: Hi. I'm Susan

Gilbertz, G-I-L-B-E-R-T-Z.

 And conceptually, I like Plan D, as in

dog, with one exception, and that would be the

reduction of acreage of wilderness area.

 I am sympathetic to the notion of

changing some areas to kind of capture areas

that are perhaps better suited for that

management style, but overall, I would hate to

see a reduction in the number of acreage.

 Thanks.

 MS. MATHER: Jeff, and then Bernard.

2

3

4

5

6

7

8

9

10

11

12

13

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Page 19

1 JEFF HUNNES: Good evening. My name's

Jeff Hunnes. Last name is spelled H-U-N-N-E-S.

 I live here in Billings, but I grew up

in Miles City and spent a lot of time at Hell

Creek, and I'm really excited that you guys are

proposing some wilderness in that area because I

know what a special remote and wild area it is,

and I want to commend you for that.

 In general, I would support

Alternative B, as in boy. I would be in favor

of increased wilderness, or proposed wilderness

designation in the refuge.

 I had a comment -- or a question, if

you are able to kind of explain the difference

in the management priorities between the Fish &

Wildlife Service and, for example, the Bureau of

Land Management or the Forest Service, and

whether any of these alternatives is more in

keeping with the priorities that this particular

agency has?

 Thank you.

 MS. MATHER: Bernard. And Arlys on

deck.

 BERNARD ROSE: Hi. I'm Bernard Rose,

the way it sounds.

2

3

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5

6

7

8

9

10

11

12

13

14

15

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Page 20

1 I'm concerned that often when we talk

about wilderness, people seem to think that

wilderness has no value to local people; that

somehow or another, if we make it into

wilderness, no one will come.

 I know there are studies which indicate

that people value wilderness; that people come

to hunt in the wilderness; that people come to

enjoy the wilderness; that they are a real

amenities values.

 I think we see this in the western part

of the state where areas we have significant

wilderness or desirable places for people to

live and to build homes and to do all of these

kinds of things.

 And sometimes it seems to me that when

you mention wilderness, it's kind of the "Big W

word", one of those things that you're not

supposed to say, because it takes away from the

value.

 And, you know, if there's grazing, and

if we remove grazing, although grazing is still

allowed in wilderness, existing wilderness, such

as existing grazing rights are protected in

wilderness, which I think most people normally

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
VOLUME 2, Chapter 4—Public Hearing Testimony 341

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

6 (Pages 21 to 24)

Page 21

1 forget.

 But I wonder how much you've taken this

into account? Because I think it really

enhances the value of an area. And I'm not

really sure -- I have been inactive in this kind

of business for quite a long time, and I'm not

sure when it turned to the point where all of a

sudden, wilderness was a negative economic

value.

 I have been an economist, sometimes I

think for all my life. But I was trained to do

that.

 And there's tremendous value in

wilderness, and I really want to make sure that

you're taking that into account as you think

about wilderness, and not reduce the amount of

potential wilderness, because it's tremendously

attractive to an awful lot of people.

 And as I said, you know, it doesn't

take away from some of the traditional uses.

 Some of them, it does. People want to

drive vehicles. People want to ride mountain

bikes, and I know that's often a contentious

issue in the western part of the state, and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 you'll run into that as you work through this.

Page 22

1 But it's really, really important to

remember that wilderness has a particular

positive value, and I wonder how much you are

taking that into account as you do this

analysis.

 Thank you very much.

 MS. MATHER: Arlys, and then Janelle on

deck.

 Did I have your name correct?

 ARLYS RIEGER: Yes.

 I'm Arlys Rieger. A-R-L-Y-S;

R-I-E-G-E-R. I grew up in Garfield County. I

live in Billings.

 I am concerned about a couple of

things. And I haven't had a chance to review A,

B, C, D, because I couldn't get ahold of it, but

I will do that and hopefully comment later.

 But I've heard a lot of complaints --

concerns from the locals in Garfield County, the

ranchers, and I'm sure there's a lot of rumors

going around out there that aren't true, and I'm

hoping that you will be able to do something to

help them understand what is actually going on.

 But it is very much of a concern to the

ranchers and what you actually are planning to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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Page 23

1 do, and what you are going to allow to do and

what you are not going to allow to do.

 And one of my concerns, and one that

I'm sure you've heard many times before is that

you are going to turn bison loose on the Charlie

Russell Memorial, and there has been no

explanation of how that is going to happen.

 You know, are you going to put fences

up, or are we going to wake up one day and find

20 buffalo in our wheat fields?

 I think this is a real concern of the

local ranchers in Garfield County because we are

not getting very good information about what is

actually going on. So, I would appreciate

information on that.

 Thank you.

 MS. MATHER: Janelle, and then Mark.

 JANELLE HOLDEN: Hi. I'm Janelle

Holden, J-A-N-E-L-L-E; H-O-L-D-E-N, with the

Wilderness Society out of Bozeman.

 And I just want to echo a few things

that folks have already said tonight; namely,

that Alternative D has a lot of great points in

it.

 We really appreciate the effort to put

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Page 24

1 fire back into the ecosystem and to try to

restore some of those ecological processes and

build wildlife habitat. I think that's a really

important thing, and fire should definitely

remain part of the refuge management system.

 In terms of the wilderness, proposed

wilderness, we do have some concerns about

reducing proposed wilderness acreage overall in

the preliminary preferred and support

Alternative B, the expansion of proposed

wilderness.

 And that's in part because prairie

wilderness experience is fairly rare in this

country. If you think about Montana itself,

we've got 34 million designated wilderness

acres, and only 32,000 are in the prairie, of

which 20,000 is in the refuge already.

 So, limiting people's access to prairie

wilderness experience, or taking that away seems

to not be the direction we should be going in.

We really do need to expand wilderness in the

wilderness system.

 The other thing that I'm concerned

about that I want to bring up tonight is the

lack of any discussion in your presentation and

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Page 21

u've taken this

really

nd I'm not

 in this kind

and I'm not

where all of a

e economic

ometimes I

ained to do

ue in

make sure that

 you think

the amount of

tremendously

e.

doesn't

tional uses.

ple want to

de mountain

ontentious

ate, and

hrough this.

Page 22

ant to

articular

 much you are

o this

Page 23

1 do, and what you are going to allow to do and

what you are not going to allow to do.

 And one of my concerns, and one that

I'm sure you've heard many times before is that

you are going to turn bison loose on the Charlie

Russell Memorial, and there has been no

explanation of how that is going to happen.

 You know, are you going to put fences

up, or are we going to wake up one day and find

20 buffalo in our wheat fields?

 I think this is a real concern of the

local ranchers in Garfield County because we are

not getting very good information about what is

actually going on. So, I would appreciate

information on that.

 Thank you.

 MS. MATHER: Janelle, and then Mark.

 JANELLE HOLDEN: Hi. I'm Janelle

Holden, J-A-N-E-L-L-E; H-O-L-D-E-N, with the

Wilderness Society out of Bozeman.

 And I just want to echo a few things

that folks have already said tonight; namely,

that Alternative D has a lot of great points in

it.

 We really appreciate the effort to put

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 24

1 fire back into the ecosystem and to try to

restore some of those ecological processes and

build wildlife habitat. I think that's a really

important thing, and fire should definitely

remain part of the refuge management system.

Itf thildd

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 And as I said, you know, it doesn't

take away from some of the traditional uses.

 Some of them, it does. People want to

drive vehicles. People want to ride mountain

bikes, and I know that's often a contentious

issue in the western part of the state, and

19

20

21

22

23

24

25 you'll run into that as you work through this.

Page 22

1 But it's really, really important to

remember that wilderness has a particular

positive value, and I wonder how much you are

taking that into account as you do this

analysis.

 Thank you very much.

 MS. MATHER: Arlys, and then Janelle on

deck.

 Did I have your name correct?

 ARLYS RIEGER: Yes.

 I'm Arlys Rieger. A-R-L-Y-S;

R-I-E-G-E-R. I grew up in Garfield County. I

live in Billings.

 I am concerned about a couple of

things. And I haven't had a chance to review A,

B, C, D, because I couldn't get ahold of it, but

I will do that and hopefully comment later.

 But I've heard a lot of complaints --

concerns from the locals in Garfield County, the

ranchers, and I'm sure there's a lot of rumors

going around out there that aren't true, and I'm

hoping that you will be able to do something to

help them understand what is actually going on.

 But it is very much of a concern to the

ranchers and what you actually are planning to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Holden, 

Wildern

 An

that folk

that Alte

it.

 W

19

20

21

22

23

24

25

1 fire back 

restore s

build wi

importa

remain p

 In 

wilderne

reducing 

the preli

Alternat

wilderne

 An

wilderne

country

we've go

acres, an

which 2

 So

wilderne

to not be 

We real

wilderne

 Th

about th

lack of a

2

3

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5

6

7

8

9

10

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12

13

14

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20

21

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25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

6 (Pages 21 to 24)

Page 21

1 forget.

 But I wonder how much you've taken this

into account? Because I think it really

enhances the value of an area. And I'm not

really sure -- I have been inactive in this kind

of business for quite a long time, and I'm not

sure when it turned to the point where all of a

sudden, wilderness was a negative economic

value.

 I have been an economist, sometimes I

think for all my life. But I was trained to do

that.

 And there's tremendous value in

wilderness, and I really want to make sure that

you're taking that into account as you think

about wilderness, and not reduce the amount of

potential wilderness, because it's tremendously

attractive to an awful lot of people.

 And as I said, you know, it doesn't

take away from some of the traditional uses.

 Some of them, it does. People want to

drive vehicles. People want to ride mountain

bikes, and I know that's often a contentious

issue in the western part of the state, and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 you'll run into that as you work through this.

Page 22

1 But it's really, really important to

remember that wilderness has a particular

positive value, and I wonder how much you are

taking that into account as you do this

analysis.

 Thank you very much.

 MS. MATHER: Arlys, and then Janelle on

deck.

 Did I have your name correct?

 ARLYS RIEGER: Yes.

 I'm Arlys Rieger. A-R-L-Y-S;

R-I-E-G-E-R. I grew up in Garfield County. I

live in Billings.

 I am concerned about a couple of

things. And I haven't had a chance to review A,

B, C, D, because I couldn't get ahold of it, but

I will do that and hopefully comment later.

 But I've heard a lot of complaints --

concerns from the locals in Garfield County, the

ranchers, and I'm sure there's a lot of rumors

going around out there that aren't true, and I'm

hoping that you will be able to do something to

help them understand what is actually going on.

 But it is very much of a concern to the

ranchers and what you actually are planning to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 23

1 do, and what you are going to allow to do and

what you are not going to allow to do.

 And one of my concerns, and one that

I'm sure you've heard many times before is that

you are going to turn bison loose on the Charlie

Russell Memorial, and there has been no

explanation of how that is going to happen.

 You know, are you going to put fences

up, or are we going to wake up one day and find

20 buffalo in our wheat fields?

 I think this is a real concern of the

local ranchers in Garfield County because we are

not getting very good information about what is

actually going on. So, I would appreciate

information on that.

 Thank you.

 MS. MATHER: Janelle, and then Mark.

 JANELLE HOLDEN: Hi. I'm Janelle

Holden, J-A-N-E-L-L-E; H-O-L-D-E-N, with the

Wilderness Society out of Bozeman.

 And I just want to echo a few things

that folks have already said tonight; namely,

that Alternative D has a lot of great points in

it.

 We really appreciate the effort to put

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1 fire back into the ecosystem and to try to

restore some of those ecological processes and

build wildlife habitat. I think that's a really

important thing, and fire should definitely

remain part of the refuge management system.

 In terms of the wilderness, proposed

wilderness, we do have some concerns about

reducing proposed wilderness acreage overall in

the preliminary preferred and support

Alternative B, the expansion of proposed

wilderness.

 And that's in part because prairie

wilderness experience is fairly rare in this

country. If you think about Montana itself,

we've got 34 million designated wilderness

acres, and only 32,000 are in the prairie, of

which 20,000 is in the refuge already.

 So, limiting people's access to prairie

wilderness experience, or taking that away seems

to not be the direction we should be going in.

We really do need to expand wilderness in the

wilderness system.

 The other thing that I'm concerned

about that I want to bring up tonight is the

lack of any discussion in your presentation and

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342 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

7 (Pages 25 to 28)

Page 25

1 in some of the bullet points that you've used in

terms of planning about climate change.

 I've seen it come up in the

partnership's part. And I haven't gotten

through the whole draft yet, so maybe you can

address this in the questions part, but I would

like to know how you are going to use research

on climate change to manage the refuge, and

where that will come into play, and how you plan

to integrate that within your planning process,

because I think that's very important.

 So, that's all I have for tonight.

Thanks.

 MS. MATHER: Mark, and then Bernie on

deck.

 MARK GOOD: Hi. My name is Mark Good,

G-O-O-D. No E, just pure good.

 That's a joke.

 I work with the Montana Wilderness

Association, and I just want to comment about

what Beauchamp area, that proposed wilderness

area that's being reduced -- or eliminated.

 And my experience up there is that,

yeah, it's probably not as dramatic as some of

the other areas in the refuge, but it seems to

2

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1 me that it still maintains the wilderness

character, you know, as a big, open grassland

prairie landscape.

 And I think part of it is how we maybe

perceive wilderness. But grasslands are just as

worthy for wilderness consideration as some of

the peaks or Breaks, even, that we generally

perceive. So, I hope you will reconsider that

as you work through this process.

 Second is really a question, and I was

wondering if before the end of this, you could

talk a little bit more about what prescriptive

grazing and prescriptive use of fire means, and

how that improves habitat for wildlife.

 I think that would be helpful because I

think there's a lot of confusion about what that

means and how it might affect a variety of

users.

 So, thanks. Appreciate the

opportunity.

 MS. MATHER: Bernie.

 And I'm having trouble reading this

last one, Randall Gloery?

 BERNIE QUETCHENBACH: Hi. My name is

Bernie Quetchenbach, and I'll spell that out

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1 because it's not easy. Q-U-E-T-C-H-E-N-B-A-C-H.

 And I also want to express concerns

about reducing wilderness and support as much as

we can have in that area.

 But I would also like to ask a question

about grazing, and particularly about range.

Not about cattle grazing necessarily as such,

but a question about the range conditions, what

range conditions do you aspire to for the

refuge? What are you looking to do with the

range, and how has the range condition changed

over the past century of use?

 Thank you.

 MS. MATHER: Randall, and then David on

deck.

 RANDALL GLOEGE: My name is Randall

Gloege, G-L-O-E-G-E.

 I come from a long line of

conservationists. And at the outset, I want to

admit that I'm an ardent wilderness nut, and I

think I would be less than candid if I didn't

say so.

 I find myself surprised to be in

agreement with a federal agency that the

preferred alternative is the best one that you

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Page 28

1 have listed.

 I do have some reservations about it,

but mostly I want you to consider enhancing or

increasing the areas reserved for wilderness.

 The fact is, as a couple of

commentators have already mentioned, we have

very little wilderness in eastern Montana, and

being a Miles City boy when I was young, I have

a very real feeling for prairie country.

 I think that we need to consider vastly

expanding our notion of what might constitute

legitimate areas for wilderness consideration in

eastern Montana, and the Charlie Russell is an

ideal place to start talking about that.

 The other thing I want to observe is

that wilderness designation and the charge of

the Charlie Russell, I feel, are identical. In

other words, the best way to nurture wildlife,

to allow it to promulgate, increase and in

health, I think is to carry out the idea of

wilderness classification for as much of the

area of the Charlie Russell as you possibly can

consider.

 And this would include, in my view,

holding a blind eye to two trail roads and just

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Page 25

e used in

e.

n

 you can

 would

 research

ge, and

w you plan

process,

 Bernie on

s Mark Good,

ness

nt about

wilderness

ed.

hat,

ome of

ms to

Page 26

sland

aybe

 just as

some of

Page 27

1 because it's not easy. Q-U-E-T-C-H-E-N-B-A-C-H.

 And I also want to express concerns

about reducing wilderness and support as much as

we can have in that area.

 But I would also like to ask a question

about grazing, and particularly about range.

Not about cattle grazing necessarily as such,

but a question about the range conditions, what

range conditions do you aspire to for the

refuge? What are you looking to do with the

range, and how has the range condition changed

over the past century of use?

 Thank you.

 MS. MATHER: Randall, and then David on

deck.

 RANDALL GLOEGE: My name is Randall

Gloege, G-L-O-E-G-E.

 I come from a long line of

conservationists. And at the outset, I want to

admit that I'm an ardent wilderness nut, and I

think I would be less than candid if I didn't

say so.

 I find myself surprised to be in

agreement with a federal agency that the

preferred alternative is the best one that you

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

22

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24

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Page 28

1 have listed.

 I do have some reservations about it,

but mostly I want you to consider enhancing or

increasing the areas reserved for wilderness.

 The fact is, as a couple of

commentators have already mentionedwe have

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:f

BIG SKY REPORTING - FRANCES L

 I work with the Montana Wilderness

Association, and I just want to comment about

what Beauchamp area, that proposed wilderness

area that's being reduced -- or eliminated.

 And my experience up there is that,

yeah, it's probably not as dramatic as some of

the other areas in the refuge, but it seems to

19

20

21

22

23

24

25

Page 26

1 me that it still maintains the wilderness

character, you know, as a big, open grassland

prairie landscape.

 And I think part of it is how we maybe

perceive wilderness. But grasslands are just as

worthy for wilderness consideration as some of

the peaks or Breaks, even, that we generally

perceive. So, I hope you will reconsider that

as you work through this process.

 Second is really a question, and I was

wondering if before the end of this, you could

talk a little bit more about what prescriptive

grazing and prescriptive use of fire means, and

how that improves habitat for wildlife.

 I think that would be helpful because I

think there's a lot of confusion about what that

means and how it might affect a variety of

users.

 So, thanks. Appreciate the

opportunity.

 MS. MATHER: Bernie.

 And I'm having trouble reading this

last one, Randall Gloery?

 BERNIE QUETCHENBACH: Hi. My name is

Bernie Quetchenbach, and I'll spell that out

2

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conservation

admit that I'm 

think I would 

say so.

 I find m

agreement w

preferred alte

19

20

21

22

23

24

25

1 have listed.

 I do ha

but mostly I 

increasing th

 The fac

commentator

very little wi

being a Mile

a very real fe

 I think 

expanding ou

legitimate ar

eastern Mon

ideal place to 

 The oth

that wilderne

the Charlie R

other words, 

to allow it to 

health, I thin

wilderness c

area of the C

consider.

 And th

holding a bli

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

7 (Pages 25 to 28)

Page 25

1 in some of the bullet points that you've used in

terms of planning about climate change.

 I've seen it come up in the

partnership's part. And I haven't gotten

through the whole draft yet, so maybe you can

address this in the questions part, but I would

like to know how you are going to use research

on climate change to manage the refuge, and

where that will come into play, and how you plan

to integrate that within your planning process,

because I think that's very important.

 So, that's all I have for tonight.

Thanks.

 MS. MATHER: Mark, and then Bernie on

deck.

 MARK GOOD: Hi. My name is Mark Good,

G-O-O-D. No E, just pure good.

 That's a joke.

 I work with the Montana Wilderness

Association, and I just want to comment about

what Beauchamp area, that proposed wilderness

area that's being reduced -- or eliminated.

 And my experience up there is that,

yeah, it's probably not as dramatic as some of

the other areas in the refuge, but it seems to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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Page 26

1 me that it still maintains the wilderness

character, you know, as a big, open grassland

prairie landscape.

 And I think part of it is how we maybe

perceive wilderness. But grasslands are just as

worthy for wilderness consideration as some of

the peaks or Breaks, even, that we generally

perceive. So, I hope you will reconsider that

as you work through this process.

 Second is really a question, and I was

wondering if before the end of this, you could

talk a little bit more about what prescriptive

grazing and prescriptive use of fire means, and

how that improves habitat for wildlife.

 I think that would be helpful because I

think there's a lot of confusion about what that

means and how it might affect a variety of

users.

 So, thanks. Appreciate the

opportunity.

 MS. MATHER: Bernie.

 And I'm having trouble reading this

last one, Randall Gloery?

 BERNIE QUETCHENBACH: Hi. My name is

Bernie Quetchenbach, and I'll spell that out

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

20

21

22

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24

25

Page 27

1 because it's not easy. Q-U-E-T-C-H-E-N-B-A-C-H.

 And I also want to express concerns

about reducing wilderness and support as much as

we can have in that area.

 But I would also like to ask a question

about grazing, and particularly about range.

Not about cattle grazing necessarily as such,

but a question about the range conditions, what

range conditions do you aspire to for the

refuge? What are you looking to do with the

range, and how has the range condition changed

over the past century of use?

 Thank you.

 MS. MATHER: Randall, and then David on

deck.

 RANDALL GLOEGE: My name is Randall

Gloege, G-L-O-E-G-E.

 I come from a long line of

conservationists. And at the outset, I want to

admit that I'm an ardent wilderness nut, and I

think I would be less than candid if I didn't

say so.

 I find myself surprised to be in

agreement with a federal agency that the

preferred alternative is the best one that you

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 28

1 have listed.

 I do have some reservations about it,

but mostly I want you to consider enhancing or

increasing the areas reserved for wilderness.

 The fact is, as a couple of

commentators have already mentioned, we have

very little wilderness in eastern Montana, and

being a Miles City boy when I was young, I have

a very real feeling for prairie country.

 I think that we need to consider vastly

expanding our notion of what might constitute

legitimate areas for wilderness consideration in

eastern Montana, and the Charlie Russell is an

ideal place to start talking about that.

 The other thing I want to observe is

that wilderness designation and the charge of

the Charlie Russell, I feel, are identical. In

other words, the best way to nurture wildlife,

to allow it to promulgate, increase and in

health, I think is to carry out the idea of

wilderness classification for as much of the

area of the Charlie Russell as you possibly can

consider.

 And this would include, in my view,

holding a blind eye to two trail roads and just

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
VOLUME 2, Chapter 4—Public Hearing Testimony 343

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

8 (Pages 29 to 32)

Page 29

1 simply closing the roads and let them recover on

their own.

 So, I compliment you on choosing a good

alternative. I'd just encourage you to carry it

a bit farther.

 Thank you.

 MS. MATHER: David?

 DAVE PIPPIN: My name is Dave Pippin.

D-A-V-E; P-I-P-P-I-N.

 I'm a third-generation Valley County

person and also a Valley County Commissioner.

 And I formally would like to ask this

commission that Valley County be just as a

coordinator an not a cooperative on our status.

 But the first thing I want to ask about

is that 670 miles of road that you would like to

close in one of your plans. Are those

petitioned roads? Are those roads that were

brought into action by a formal petition done

under the Montana constitution, MCA?

 Because there's no doubt in my mind

that you need to take and go through due process

on roads like that. You don't have power of

acclimation on that.

 The second thing is that, I heard a

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Page 30

1 Public Service Announcement by Laurie here the

other day, and I want to know -- I'm sure it was

you.

 Is there a Public Service Announcement

right on the CCP plan?

 MS. SHANNON: I haven't made one.

 MR. PIPPIN: Okay. So I just wanted to

bring that right now and ask that forward.

 MS. SHANNON: Perhaps we put out a

press release.

 MR. PIPPIN: Okay. Maybe that's what

it was.

 All right. Thank you very much.

 On the fire management, as a neighbor

to the CMR, we are very nervous about your

policy on fires. It's very irresponsible in our

regard.

 The other thing I don't like is that

it's a possibility that you would use fire and

not go out and do your homework and check out

for sage grouse leks, and et cetera. And I've

questioned you on that before, that you need to

be very sure that you're not burning out some

sage grouse lek when you do this.

 The other thing is that your

2

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Page 31

1 prescriptive grazing on your plan effectively

puts the rancher out of business. These are

cow/calf pairs, and they run on AUMs.

 30 years ago, there was 60,000 cattle,

AUMS, on the thing, on the CMR. Today, there is

17, 18,000. Serious cut for a county like

Valley County. So, I think that needs to be

taken in consideration.

 And this wilderness that everybody

wants to preserve, you know why it's there?

Because of that rancher. Because he didn't

abuse the land, and he didn't take advantage of

it. He's been an integral part of that, and to

penalize him on this is unfair.

 So, there's a lot of things that need

to be talked about on this. And I think the

roads are a big thing, and I think that there

are a lot of things that you need to address on

this.

 But, I appreciate the opportunity to

come and talk to you tonight, and I would

welcome any dialogue on any of this.

 Thank you.

 MS. MATHER: So I have reached the end

of my list.

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Page 32

1 Is there anybody else who has been

inspired to come up and talk?

 KATHY TETER: I'm kind of late, so I

feel a little bad about this.

 MS. MATHER: That's fine.

 MS. TETER: My name is Kathy Teter. I

am a member of Yellowstone County Farm Bureau.

 We had a pretty lively discussion about

some of these proposals, some of the rumors,

some of the facts.

 I looked on -- there was like

400-and-some pages to read, which is obviously

something that I didn't get done last night. I

doubt a whole lot of folks have gotten that part

done yet.

 And my comment, Farm Bureau is going to

make formal comments on all of these plans. But

one of the things that I wanted to bring forward

is that we basically oppose any plan that closes

roads, that decreases grazing, that does not --

we would like to maintain access to maintain the

livestock.

 The producers need to be able to get to

do what they need to do to care for their

livestock because they are good stewards of

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Page 29

hem recover on

oosing a good

u to carry it

s Dave Pippin.

y County

Commissioner.

o ask this

e just as a

on our status.

ask about

would like to

hose

s that were

etition done

MCA?

my mind

ugh due process

e power of

eard a

Page 30

 Laurie here the

'm sure it was

nouncement

made one

Page 31

1 prescriptive grazing on your plan effectively

puts the rancher out of business. These are

cow/calf pairs, and they run on AUMs.

 30 years ago, there was 60,000 cattle,

AUMS, on the thing, on the CMR. Today, there is

17, 18,000. Serious cut for a county like

Valley County. So, I think that needs to be

taken in consideration.

 And this wilderness that everybody

wants to preserve, you know why it's there?

Because of that rancher. Because he didn't

abuse the land, and he didn't take advantage of

it. He's been an integral part of that, and to

penalize him on this is unfair.

 So, there's a lot of things that need

to be talked about on this. And I think the

roads are a big thing, and I think that there

are a lot of things that you need to address on

this.

 But, I appreciate the opportunity to

come and talk to you tonight, and I would

welcome any dialogue on any of this.

 Thank you.

 MS. MATHER: So I have reached the end

of my list.

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Page 32

1 Is there anybody else who has been

inspired to come up and talk?

 KATHY TETER: I'm kind of late, so I

feel a little bad about this.

 MS. MATHER: That's fine.

MSTETER: My name is Kathy TeterI

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

brought into action by a formal petition done

under the Montana constitution, MCA?

 Because there's no doubt in my mind

that you need to take and go through due process

on roads like that. You don't have power of

acclimation on that.

 The second thing is that, I heard a

19

20

21

22

23

24

25

Page 30

1 Public Service Announcement by Laurie here the

other day, and I want to know -- I'm sure it was

you.

 Is there a Public Service Announcement

right on the CCP plan?

 MS. SHANNON: I haven't made one.

 MR. PIPPIN: Okay. So I just wanted to

bring that right now and ask that forward.

 MS. SHANNON: Perhaps we put out a

press release.

 MR. PIPPIN: Okay. Maybe that's what

it was.

 All right. Thank you very much.

 On the fire management, as a neighbor

to the CMR, we are very nervous about your

policy on fires. It's very irresponsible in our

regard.

 The other thing I don't like is that

it's a possibility that you would use fire and

not go out and do your homework and check out

for sage grouse leks, and et cetera. And I've

questioned you on that before, that you need to

be very sure that you're not burning out some

sage grouse lek when you do this.

 The other thing is that your

2

3

4

5

6

7

8

9

10

11

12

13

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this.

 Bu

come an

welcom

 Th

 M

of my li

19

20

21

22

23

24

25

1 Is 

inspired 

 KA

feel a lit

 MS

 MS

am a me

 We 

some of 

some of 

 I lo

400-and

somethin

doubt a 

done yet

 An

make fo

one of th

is that w

roads, th

we woul

livestock

 Th

do what 

livestock 

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

8 (Pages 29 to 32)

Page 29

1 simply closing the roads and let them recover on

their own.

 So, I compliment you on choosing a good

alternative. I'd just encourage you to carry it

a bit farther.

 Thank you.

 MS. MATHER: David?

 DAVE PIPPIN: My name is Dave Pippin.

D-A-V-E; P-I-P-P-I-N.

 I'm a third-generation Valley County

person and also a Valley County Commissioner.

 And I formally would like to ask this

commission that Valley County be just as a

coordinator an not a cooperative on our status.

 But the first thing I want to ask about

is that 670 miles of road that you would like to

close in one of your plans. Are those

petitioned roads? Are those roads that were

brought into action by a formal petition done

under the Montana constitution, MCA?

 Because there's no doubt in my mind

that you need to take and go through due process

on roads like that. You don't have power of

acclimation on that.

 The second thing is that, I heard a

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 30

1 Public Service Announcement by Laurie here the

other day, and I want to know -- I'm sure it was

you.

 Is there a Public Service Announcement

right on the CCP plan?

 MS. SHANNON: I haven't made one.

 MR. PIPPIN: Okay. So I just wanted to

bring that right now and ask that forward.

 MS. SHANNON: Perhaps we put out a

press release.

 MR. PIPPIN: Okay. Maybe that's what

it was.

 All right. Thank you very much.

 On the fire management, as a neighbor

to the CMR, we are very nervous about your

policy on fires. It's very irresponsible in our

regard.

 The other thing I don't like is that

it's a possibility that you would use fire and

not go out and do your homework and check out

for sage grouse leks, and et cetera. And I've

questioned you on that before, that you need to

be very sure that you're not burning out some

sage grouse lek when you do this.

 The other thing is that your

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Page 31

1 prescriptive grazing on your plan effectively

puts the rancher out of business. These are

cow/calf pairs, and they run on AUMs.

 30 years ago, there was 60,000 cattle,

AUMS, on the thing, on the CMR. Today, there is

17, 18,000. Serious cut for a county like

Valley County. So, I think that needs to be

taken in consideration.

 And this wilderness that everybody

wants to preserve, you know why it's there?

Because of that rancher. Because he didn't

abuse the land, and he didn't take advantage of

it. He's been an integral part of that, and to

penalize him on this is unfair.

 So, there's a lot of things that need

to be talked about on this. And I think the

roads are a big thing, and I think that there

are a lot of things that you need to address on

this.

 But, I appreciate the opportunity to

come and talk to you tonight, and I would

welcome any dialogue on any of this.

 Thank you.

 MS. MATHER: So I have reached the end

of my list.

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Page 32

1 Is there anybody else who has been

inspired to come up and talk?

 KATHY TETER: I'm kind of late, so I

feel a little bad about this.

 MS. MATHER: That's fine.

 MS. TETER: My name is Kathy Teter. I

am a member of Yellowstone County Farm Bureau.

 We had a pretty lively discussion about

some of these proposals, some of the rumors,

some of the facts.

 I looked on -- there was like

400-and-some pages to read, which is obviously

something that I didn't get done last night. I

doubt a whole lot of folks have gotten that part

done yet.

 And my comment, Farm Bureau is going to

make formal comments on all of these plans. But

one of the things that I wanted to bring forward

is that we basically oppose any plan that closes

roads, that decreases grazing, that does not --

we would like to maintain access to maintain the

livestock.

 The producers need to be able to get to

do what they need to do to care for their

livestock because they are good stewards of

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344 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

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BIG SKY REPORTING - FRANCES L. MOCK

9 (Pages 33 to 36)

Page 33

1 their livestock and of the land.

 That is -- I agree with the gentlemen

ahead of me. This is why the land is still

there, because there have been very good

stewards of that land previous to now.

 I think one of the other comments was

made about the "Big W word" being scary. I

don't think it's the "Big W word" that scares

people. It's "Big Government" that scares

people.

 And I think that when you make a big

wilderness area, the ability for people to

actually enjoy that when you close roads and

limit access and do not allow folks that can get

there to actually get there, who actually gets

to enjoy it?

 I think the "Big W" is just too much

"Big Government", and I think big government

scares everybody.

 And it should. It should scare

everybody in this room when we have too much

regulation on our lands, on our basic freedoms.

 And I guess that's about as far as I'll

take this. I'll let Farm Bureau go ahead with

some professional comments.

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Page 34

1 But just kind of wanted to make it

clear that we're not afraid of wilderness. We

like it. We like seeing the animals out there

like anybody else, like good plants, like the

whole area. We love it. We love what we have.

We don't need to have somebody regulate it to

tell us how we need to like it.

 Thank you.

 MS. MATHER: Okay, if nobody else has

any comments -- oops, one more.

 SUSAN NEWELL: I'm Susan Newell,

N-E-W-E-L-L.

 And I like your Alternative D because

it looks at the ecological processes and the

interweavings of the whole country out there.

 I would like for you to look at

reducing road density a bit, and I would like no

net loss of wilderness acres, and I think more

emphasis on restoring and increasing the

cottonwood bottoms and the cottonwood galleries,

and continue the ban on mineral activity,

consider continuing that.

 Thank you.

 MS. MATHER: Anybody else?

 MIKE BRYANT: Are you opening the floor

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Page 35

1 to comments, is that what you --

 MS. MATHER: Well, I'm going to keep

you up to the mic, and then we'll let these guys

answer the questions.

 MR. BRYANT: I've just got some

questions, so I'll wait.

 MS. MATHER: Okay.

 Barron, Bill, Laurie, you want to

tackle questions?

 MR. CRAWFORD: I'll tackle the easy

ones.

 Ah, some great questions.

 Grant, your question on road density,

and what would it be if we closed roads in

Alternative B?

 I don't know, to be perfectly honest.

 There's 670 miles of road on the refuge

now. We're proposing to close 106, so that's

roughly -- help me out with some math here. I'm

from Tennessee. I have got take my shoes off.

 But, it's what, probably about 20%?

 MIKE BRYANT: Yeah, pretty close.

 MR. CRAWFORD: We estimate right now

with the 670 miles of roads, and with the river

and the lake, that 80 to 85% of the refuge is

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Page 36

1 accessible within one mile of some type of

motorized access.

 So, if you closed that 106 miles of

road, you would probably change that -- and I'm

just guesstimating here -- probably where 70% of

the refuge would be accessible to some type of

motorized access.

 Who manages the river traffic?

 Right now, we have got the Upper

Missouri River Wild and Scenic designation,

which flows through the Monument and into the

first 10 miles of the refuge.

 The BLM has management responsibility

for the Wild and Scenic river, so they're the

ones that post the motorboat restriction on the

river at this time.

 We had originally, as part of the plan,

looked at boat use on the river, and we're

looking at what type of impacts may be occurring

due to that river use.

 And what we have put in the plan is

that we're going to continue to evaluate

motorboat activity on the refuge, and is that

activity impacting wildlife in some way. We've

got a couple of studies proposed trying to

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Page 33

men

still

ood

ts was

cary. I

scares

ares

 a big

 to

ads and

at can get

ly gets

much

vernment

e too much

freedoms.

s I'll

ad with

Page 34

 it

ss. We

t there

ke the

at we have.

ulate it to

Page 35

1 to comments, is that what you --

 MS. MATHER: Well, I'm going to keep

you up to the mic, and then we'll let these guys

answer the questions.

 MR. BRYANT: I've just got some

questions, so I'll wait.

 MS. MATHER: Okay.

 Barron, Bill, Laurie, you want to

tackle questions?

 MR. CRAWFORD: I'll tackle the easy

ones.

 Ah, some great questions.

 Grant, your question on road density,

and what would it be if we closed roads in

Alternative B?

 I don't know, to be perfectly honest.

 There's 670 miles of road on the refuge

now. We're proposing to close 106, so that's

roughly -- help me out with some math here. I'm

from Tennessee. I have got take my shoes off.

 But, it's what, probably about 20%?

 MIKE BRYANT: Yeah, pretty close.

 MR. CRAWFORD: We estimate right now

with the 670 miles of roads, and with the river

and the lake, that 80 to 85% of the refuge is

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Page 36

1 accessible within one mile of some type of

motorized access.

 So, if you closed that 106 miles of

road, you would probably change that -- and I'm

just guesstimating here -- probably where 70% of

the refuge would be accessible to some type of

2

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5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

scares everybody.

 And it should. It should scare

everybody in this room when we have too much

regulation on our lands, on our basic freedoms.

 And I guess that's about as far as I'll

take this. I'll let Farm Bureau go ahead with

some professional comments.

19

20

21

22

23

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25

Page 34

1 But just kind of wanted to make it

clear that we're not afraid of wilderness. We

like it. We like seeing the animals out there

like anybody else, like good plants, like the

whole area. We love it. We love what we have.

We don't need to have somebody regulate it to

tell us how we need to like it.

 Thank you.

 MS. MATHER: Okay, if nobody else has

any comments -- oops, one more.

 SUSAN NEWELL: I'm Susan Newell,

N-E-W-E-L-L.

 And I like your Alternative D because

it looks at the ecological processes and the

interweavings of the whole country out there.

 I would like for you to look at

reducing road density a bit, and I would like no

net loss of wilderness acres, and I think more

emphasis on restoring and increasing the

cottonwood bottoms and the cottonwood galleries,

and continue the ban on mineral activity,

consider continuing that.

 Thank you.

 MS. MATHER: Anybody else?

 MIKE BRYANT: Are you opening the floor

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roughly  he

from Tennes

 But, it's 

 MIKE 

 MR. CR

with the 670 

and the lake, 

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20

21

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25

1 accessible w

motorized ac

 So, if y

road, you wo

just guesstim

the refuge w

motorized ac

 Who m

 Right n

Missouri Riv

which flows 

first 10 miles 

 The BL

for the Wild 

ones that pos

river at this t

 We had 

looked at boa

looking at w

due to that ri

 And wh

that we're go

motorboat ac

activity impa

got a couple 

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

9 (Pages 33 to 36)

Page 33

1 their livestock and of the land.

 That is -- I agree with the gentlemen

ahead of me. This is why the land is still

there, because there have been very good

stewards of that land previous to now.

 I think one of the other comments was

made about the "Big W word" being scary. I

don't think it's the "Big W word" that scares

people. It's "Big Government" that scares

people.

 And I think that when you make a big

wilderness area, the ability for people to

actually enjoy that when you close roads and

limit access and do not allow folks that can get

there to actually get there, who actually gets

to enjoy it?

 I think the "Big W" is just too much

"Big Government", and I think big government

scares everybody.

 And it should. It should scare

everybody in this room when we have too much

regulation on our lands, on our basic freedoms.

 And I guess that's about as far as I'll

take this. I'll let Farm Bureau go ahead with

some professional comments.

2

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5

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8

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Page 34

1 But just kind of wanted to make it

clear that we're not afraid of wilderness. We

like it. We like seeing the animals out there

like anybody else, like good plants, like the

whole area. We love it. We love what we have.

We don't need to have somebody regulate it to

tell us how we need to like it.

 Thank you.

 MS. MATHER: Okay, if nobody else has

any comments -- oops, one more.

 SUSAN NEWELL: I'm Susan Newell,

N-E-W-E-L-L.

 And I like your Alternative D because

it looks at the ecological processes and the

interweavings of the whole country out there.

 I would like for you to look at

reducing road density a bit, and I would like no

net loss of wilderness acres, and I think more

emphasis on restoring and increasing the

cottonwood bottoms and the cottonwood galleries,

and continue the ban on mineral activity,

consider continuing that.

 Thank you.

 MS. MATHER: Anybody else?

 MIKE BRYANT: Are you opening the floor

2

3

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8

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Page 35

1 to comments, is that what you --

 MS. MATHER: Well, I'm going to keep

you up to the mic, and then we'll let these guys

answer the questions.

 MR. BRYANT: I've just got some

questions, so I'll wait.

 MS. MATHER: Okay.

 Barron, Bill, Laurie, you want to

tackle questions?

 MR. CRAWFORD: I'll tackle the easy

ones.

 Ah, some great questions.

 Grant, your question on road density,

and what would it be if we closed roads in

Alternative B?

 I don't know, to be perfectly honest.

 There's 670 miles of road on the refuge

now. We're proposing to close 106, so that's

roughly -- help me out with some math here. I'm

from Tennessee. I have got take my shoes off.

 But, it's what, probably about 20%?

 MIKE BRYANT: Yeah, pretty close.

 MR. CRAWFORD: We estimate right now

with the 670 miles of roads, and with the river

and the lake, that 80 to 85% of the refuge is

2

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4

5

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7

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9

10

11

12

13

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Page 36

1 accessible within one mile of some type of

motorized access.

 So, if you closed that 106 miles of

road, you would probably change that -- and I'm

just guesstimating here -- probably where 70% of

the refuge would be accessible to some type of

motorized access.

 Who manages the river traffic?

 Right now, we have got the Upper

Missouri River Wild and Scenic designation,

which flows through the Monument and into the

first 10 miles of the refuge.

 The BLM has management responsibility

for the Wild and Scenic river, so they're the

ones that post the motorboat restriction on the

river at this time.

 We had originally, as part of the plan,

looked at boat use on the river, and we're

looking at what type of impacts may be occurring

due to that river use.

 And what we have put in the plan is

that we're going to continue to evaluate

motorboat activity on the refuge, and is that

activity impacting wildlife in some way. We've

got a couple of studies proposed trying to

2

3

4

5

6

7

8

9

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12

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VOLUME 2, Chapter 4—Public Hearing Testimony 345

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

10 (Pages 37 to 40)

Page 37

1 figure out exactly what that use is, and what

type of impacts are occurring from that.

 Manage RV use?

 Yes, the plan states we will continue

to manage RVs as we're doing now. They're

restricted to our numbered routes, which is what

cars and trucks can drive on.

 And why are we proposing to eliminate

some wilderness in D?

 We looked at it, and you're absolutely

right in your comment about the road going

through Beauchamp. Does that detract from that

wilderness area?

 And it's kind of a judgment call, to be

really honest with you. You know, it is small.

It is 5,000 acres on either side of the road.

That road is one of our main refuge roads. It

traverses most of the west end of the refuge.

It does get quite a bit of seasonal use.

 So we threw it out there to see what

kind of comments we might get. And obviously

tonight, we heard a lot of comments that people

would like to see that as proposed wilderness.

 And those are the exact type of

comments that we're looking for.

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Page 38

1 The East Hell Creek wilderness area,

there are two private in-holdings in that area

with the road that runs all the way up through

the middle of it. Does that detract? It's a

huge wilderness area. I think it's 26,000

acres.

 You know, great comments again. I

think that's something we should go back and

look at.

 What else do we have here?

 Margaret was talking about nongame

species management plans.

 Yes, we did address nongame.

 There were some things that we did

drop. We had to look at staffing and funding -

how much can we -- physically think we can

accomplish given the current resources that we

have, or the projected resources that we think

we may have over the next 15 years?

 And there were some small game stuff

that we dropped out. We had some fur bearer

stuff in there. We scaled that back. We had

some amphibian stuff in there. We scaled that

back.

 We kept some things in there, some

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Page 39

1 basic inventory and monitoring stuff that we

think is important, especially as it relates to

climate change.

 We put quite a bit of emphasis in this

plan on grassland bird species. That's

something that the refuge has not done a lot of

work in.

 Beverly Skinner has just moved into a

new position at the refuge, and she's going to

be doing quite a bit of bird work, not only

grasslands birds, but our forest birds,

migrates, breeding birds. So, we're going to

see quite a bit of bird work occurring on the

refuge in the next 15 years, hopefully.

 Prairie dogs are definitely an

important keystone species, and we do have a

pretty good section here devoted to prairie dogs

and prairie dog management for the future.

 What else do we have here?

 Question: Difference in management

priorities between the Fish & Wildlife Service

and the BLM? Great question, Jeff.

 The Fish & Wildlife Service is the only

federal agency that has been mandated to manage

for fish and wildlife resources, okay. That is

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Page 40

1 our sole purpose, fish and wildlife habitat.

 The Forest Service and the BLM have a

multiple-use mandate. So they have to strike

that balance between recreational opportunities,

economic opportunities, wilderness, wildlife and

habitat, and they get stretched pretty thin.

There's no doubt about it.

 And I feel very fortunate that we have

that very direct mission that tells us that you

guys only have to worry about fish, wildlife and

their habitats. So, that is one of the big

differences.

 Now we also, as part of the Improvement

Act, did identify those six wildlife-dependent

recreational uses. And that's the hunting, the

fishing, the wildlife observation, the wildlife

photography, the environmental education and

interpretation.

 So, we throw those out there as also

being important for managing a natural wildlife

refuge. However, they cannot conflict with the

purpose of the refuge and what you're trying to

accomplish from a wildlife and habitat

management standpoint. So, there is a little

bit of a balancing act there.

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Page 37

s, and what

m that.

 continue

w. They're

, which is what

to eliminate

absolutely

road going

etract from that

 call, to be

w, it is small.

the road.

ge roads. It

 the refuge.

use.

see what

And obviously

nts that people

d wilderness.

e of

Page 38

ness area,

in that area

y up through

t? It's a

26,000

Page 39

1 basic inventory and monitoring stuff that we

think is important, especially as it relates to

climate change.

 We put quite a bit of emphasis in this

plan on grassland bird species. That's

something that the refuge has not done a lot of

work in.

 Beverly Skinner has just moved into a

new position at the refuge, and she's going to

be doing quite a bit of bird work, not only

grasslands birds, but our forest birds,

migrates, breeding birds. So, we're going to

see quite a bit of bird work occurring on the

refuge in the next 15 years, hopefully.

 Prairie dogs are definitely an

important keystone species, and we do have a

pretty good section here devoted to prairie dogs

and prairie dog management for the future.

 What else do we have here?

 Question: Difference in management

priorities between the Fish & Wildlife Service

and the BLM? Great question, Jeff.

 The Fish & Wildlife Service is the only

federal agency that has been mandated to manage

for fish and wildlife resources, okay. That is

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Page 40

1 our sole purpose, fish and wildlife habitat.

 The Forest Service and the BLM have a

multiple-use mandate. So they have to strike

that balance between recreational opportunities,

economic opportunities, wilderness, wildlife and

habitatand they get stretched pretty thin

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

It does get quite a bit of seasonal use.

 So we threw it out there to see what

kind of comments we might get. And obviously

tonight, we heard a lot of comments that people

would like to see that as proposed wilderness.

 And those are the exact type of

comments that we're looking for.

19

20

21

22

23

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25

Page 38

1 The East Hell Creek wilderness area,

there are two private in-holdings in that area

with the road that runs all the way up through

the middle of it. Does that detract? It's a

huge wilderness area. I think it's 26,000

acres.

 You know, great comments again. I

think that's something we should go back and

look at.

 What else do we have here?

 Margaret was talking about nongame

species management plans.

 Yes, we did address nongame.

 There were some things that we did

drop. We had to look at staffing and funding -

how much can we -- physically think we can

accomplish given the current resources that we

have, or the projected resources that we think

we may have over the next 15 years?

 And there were some small game stuff

that we dropped out. We had some fur bearer

stuff in there. We scaled that back. We had

some amphibian stuff in there. We scaled that

back.

 We kept some things in there, some

2

3

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6

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 W

 Qu

prioritie

and the B

 Th

federal a

for fish 

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20

21

22

23

24

25

1 our sole 

 Th

multiple

that bala

economi

habitat, 

There's n

 An

that very 

guys onl

their hab

differen

 No

Act, did 

recreatio

fishing, 

photogra

interpret

 So

being im

refuge. 

purpose 

accompl

managem

bit of a b

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

10 (Pages 37 to 40)

Page 37

1 figure out exactly what that use is, and what

type of impacts are occurring from that.

 Manage RV use?

 Yes, the plan states we will continue

to manage RVs as we're doing now. They're

restricted to our numbered routes, which is what

cars and trucks can drive on.

 And why are we proposing to eliminate

some wilderness in D?

 We looked at it, and you're absolutely

right in your comment about the road going

through Beauchamp. Does that detract from that

wilderness area?

 And it's kind of a judgment call, to be

really honest with you. You know, it is small.

It is 5,000 acres on either side of the road.

That road is one of our main refuge roads. It

traverses most of the west end of the refuge.

It does get quite a bit of seasonal use.

 So we threw it out there to see what

kind of comments we might get. And obviously

tonight, we heard a lot of comments that people

would like to see that as proposed wilderness.

 And those are the exact type of

comments that we're looking for.

2

3

4

5

6

7

8

9

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13

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1 The East Hell Creek wilderness area,

there are two private in-holdings in that area

with the road that runs all the way up through

the middle of it. Does that detract? It's a

huge wilderness area. I think it's 26,000

acres.

 You know, great comments again. I

think that's something we should go back and

look at.

 What else do we have here?

 Margaret was talking about nongame

species management plans.

 Yes, we did address nongame.

 There were some things that we did

drop. We had to look at staffing and funding -

how much can we -- physically think we can

accomplish given the current resources that we

have, or the projected resources that we think

we may have over the next 15 years?

 And there were some small game stuff

that we dropped out. We had some fur bearer

stuff in there. We scaled that back. We had

some amphibian stuff in there. We scaled that

back.

 We kept some things in there, some

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1 basic inventory and monitoring stuff that we

think is important, especially as it relates to

climate change.

 We put quite a bit of emphasis in this

plan on grassland bird species. That's

something that the refuge has not done a lot of

work in.

 Beverly Skinner has just moved into a

new position at the refuge, and she's going to

be doing quite a bit of bird work, not only

grasslands birds, but our forest birds,

migrates, breeding birds. So, we're going to

see quite a bit of bird work occurring on the

refuge in the next 15 years, hopefully.

 Prairie dogs are definitely an

important keystone species, and we do have a

pretty good section here devoted to prairie dogs

and prairie dog management for the future.

 What else do we have here?

 Question: Difference in management

priorities between the Fish & Wildlife Service

and the BLM? Great question, Jeff.

 The Fish & Wildlife Service is the only

federal agency that has been mandated to manage

for fish and wildlife resources, okay. That is

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1 our sole purpose, fish and wildlife habitat.

 The Forest Service and the BLM have a

multiple-use mandate. So they have to strike

that balance between recreational opportunities,

economic opportunities, wilderness, wildlife and

habitat, and they get stretched pretty thin.

There's no doubt about it.

 And I feel very fortunate that we have

that very direct mission that tells us that you

guys only have to worry about fish, wildlife and

their habitats. So, that is one of the big

differences.

 Now we also, as part of the Improvement

Act, did identify those six wildlife-dependent

recreational uses. And that's the hunting, the

fishing, the wildlife observation, the wildlife

photography, the environmental education and

interpretation.

 So, we throw those out there as also

being important for managing a natural wildlife

refuge. However, they cannot conflict with the

purpose of the refuge and what you're trying to

accomplish from a wildlife and habitat

management standpoint. So, there is a little

bit of a balancing act there.

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346 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

11 (Pages 41 to 44)

Page 41

1 Which alternate supports the mission

best? Another great question.

 We feel that like looking in National

Wildlife Refuge System Improvement Act, and

those 13 things that are outlined in there as

what the Secretary shall do, we feel that

Alternative D best fits what's outlined in the

Improvement Act and the mission of the Fish &

Wildlife Service the best.

 What other questions did we have?

 MS. SHANNON: Grazing.

 MR. CRAWFORD: Grazing. Yeah, I'll get

to that in a minute.

 A great question from Arlys concerning

helping folks understand the plan.

 The bison reintroduction one. We've

been obviously addressing the bison issue for

the past three years, and the language has not

changed in three years.

 We are not proposing to reintroduce

bison on the CMR. Bison are a state trust

responsibility. They are not a federal trust

responsibility.

 A federal trust responsibility are

threatened and endangered species, migratory

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Page 42

1 birds and anadromous fish.

 Now, if bison become listed, does that

put a new spin on it? Maybe. Hard telling.

 You know, we have a lot of listed

species right now that we're not proposing to do

any reintroductions on the refuge.

 The grey wolf and the grizzly bear is a

prime example. Those are currently two listed

species, and there is no mention in our plan of

reintroducing either of those species to the

refuge.

 So, does changing bison's

classification to a threatened species change

potentially reintroduction on the refuge?

Probably not, you know. I can't say for

certain, but probably not.

 All I can say is, they're not a listed

species right now. They are a state trust

species, and there's nothing in the plan that

the Fish & Wildlife Service plans to do any

reintroductions on the refuge.

 Climate change research. There is a

section on Page 85, Janelle, that goes into

pretty good detail about climate change.

 Obviously there is a huge emphasis

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1 right now on climate and what are the impacts

going to be, and what can we do as far as a land

management agency to maybe make sure that fish

and wildlife have adequate habitats, have

corridors so that they can move as these

landscapes change. And so that is something

that we did take into consideration.

 And scattered throughout the uplands

and the riparian, we also have stuff in there

that talks about building resilience. Habitats

that are resilient can accommodate change much

better than those habitats that are kind of

extremely stressed, and so we kind of built that

into this plan as well.

 What is prescriptive grazing and

prescriptive fire, and how is it going to

improve habitat on the wildlife? Mark asked

that question. Another great question.

 Prescriptive grazing is basically using

grazing as a wildlife and habitat management

tool, okay.

 This area evolved with fire and grazing

as those two primary ecological processes that

drove this landscape.

 What we're looking to do in

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Page 44

1 Alternative D is to restore those processes.

Obviously, we can just let fire run across the

landscape like it did 200 years ago. You know,

Dave brought up a great point about that. We

have to be extremely cautious as how we use and

manage fire so that we don't impact our

neighbors.

 So, what we're looking at doing is

through this combination of restoring prescribed

fire out there, that will reduce wildlife

occurrence across the refuge, restore

prescriptive grazing. And basically what I mean

by prescriptive grazing is using those animals

to achieve a specific wildlife and/or habitat

management objective.

 And a classic example would be, if you

have an area, and you want to manage it for

mountain plovers, now mountain plovers like to

nest in those areas with prairie dogs towns.

 Prairie dogs like to have very short

grass. So that's a place where we could go in

there, use a little prescriptive fire, reduce

the grass cover. Put livestock in there. Let

livestock graze it down. Encourage prairie dogs

to expand, which would encourage mountain

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Page 41

ssion

onal

t Act, and

ere as

hat

 in the

he Fish &

ve?

Yeah, I'll get

cerning

We've

ssue for

has not

duce

rust

trust

igratory

Page 42

es that

elling.

d

sing to do

Page 43

1 right now on climate and what are the impacts

going to be, and what can we do as far as a land

management agency to maybe make sure that fish

and wildlife have adequate habitats, have

corridors so that they can move as these

landscapes change. And so that is something

that we did take into consideration.

 And scattered throughout the uplands

and the riparian, we also have stuff in there

that talks about building resilience. Habitats

that are resilient can accommodate change much

better than those habitats that are kind of

extremely stressed, and so we kind of built that

into this plan as well.

 What is prescriptive grazing and

prescriptive fire, and how is it going to

improve habitat on the wildlife? Mark asked

that question. Another great question.

 Prescriptive grazing is basically using

grazing as a wildlife and habitat management

tool, okay.

 This area evolved with fire and grazing

as those two primary ecological processes that

drove this landscape.

 What we're looking to do in

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Page 44

1 Alternative D is to restore those processes.

Obviously, we can just let fire run across the

landscape like it did 200 years ago. You know,

Dave brought up a great point about that. We

have to be extremely cautious as how we use and

manage fire so that we don't impact our

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

changed in three years.

 We are not proposing to reintroduce

bison on the CMR. Bison are a state trust

responsibility. They are not a federal trust

responsibility.

 A federal trust responsibility are

threatened and endangered species, migratory

19

20

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22

23

24

25

Page 42

1 birds and anadromous fish.

 Now, if bison become listed, does that

put a new spin on it? Maybe. Hard telling.

 You know, we have a lot of listed

species right now that we're not proposing to do

any reintroductions on the refuge.

 The grey wolf and the grizzly bear is a

prime example. Those are currently two listed

species, and there is no mention in our plan of

reintroducing either of those species to the

refuge.

 So, does changing bison's

classification to a threatened species change

potentially reintroduction on the refuge?

Probably not, you know. I can't say for

certain, but probably not.

 All I can say is, they're not a listed

species right now. They are a state trust

species, and there's nothing in the plan that

the Fish & Wildlife Service plans to do any

reintroductions on the refuge.

 Climate change research. There is a

section on Page 85, Janelle, that goes into

pretty good detail about climate change.

 Obviously there is a huge emphasis

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 Prescri

grazing as a 

tool, okay.

 This ar

as those two 

drove this lan

 What w

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20

21

22

23

24

25

1 Alternative D 

Obviously, w

landscape lik

Dave brough

have to be ex

manage fire 

neighbors.

 So, wh

through this 

fire out there

occurrence a

prescriptive g

by prescripti

to achieve a 

management 

 And a c

have an area

mountain plo

nest in those 

 Prairie 

grass. So tha

there, use a l

the grass cov

livestock gra

to expand, w

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

11 (Pages 41 to 44)

Page 41

1 Which alternate supports the mission

best? Another great question.

 We feel that like looking in National

Wildlife Refuge System Improvement Act, and

those 13 things that are outlined in there as

what the Secretary shall do, we feel that

Alternative D best fits what's outlined in the

Improvement Act and the mission of the Fish &

Wildlife Service the best.

 What other questions did we have?

 MS. SHANNON: Grazing.

 MR. CRAWFORD: Grazing. Yeah, I'll get

to that in a minute.

 A great question from Arlys concerning

helping folks understand the plan.

 The bison reintroduction one. We've

been obviously addressing the bison issue for

the past three years, and the language has not

changed in three years.

 We are not proposing to reintroduce

bison on the CMR. Bison are a state trust

responsibility. They are not a federal trust

responsibility.

 A federal trust responsibility are

threatened and endangered species, migratory

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

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24

25

Page 42

1 birds and anadromous fish.

 Now, if bison become listed, does that

put a new spin on it? Maybe. Hard telling.

 You know, we have a lot of listed

species right now that we're not proposing to do

any reintroductions on the refuge.

 The grey wolf and the grizzly bear is a

prime example. Those are currently two listed

species, and there is no mention in our plan of

reintroducing either of those species to the

refuge.

 So, does changing bison's

classification to a threatened species change

potentially reintroduction on the refuge?

Probably not, you know. I can't say for

certain, but probably not.

 All I can say is, they're not a listed

species right now. They are a state trust

species, and there's nothing in the plan that

the Fish & Wildlife Service plans to do any

reintroductions on the refuge.

 Climate change research. There is a

section on Page 85, Janelle, that goes into

pretty good detail about climate change.

 Obviously there is a huge emphasis

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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19

20

21

22

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24

25

Page 43

1 right now on climate and what are the impacts

going to be, and what can we do as far as a land

management agency to maybe make sure that fish

and wildlife have adequate habitats, have

corridors so that they can move as these

landscapes change. And so that is something

that we did take into consideration.

 And scattered throughout the uplands

and the riparian, we also have stuff in there

that talks about building resilience. Habitats

that are resilient can accommodate change much

better than those habitats that are kind of

extremely stressed, and so we kind of built that

into this plan as well.

 What is prescriptive grazing and

prescriptive fire, and how is it going to

improve habitat on the wildlife? Mark asked

that question. Another great question.

 Prescriptive grazing is basically using

grazing as a wildlife and habitat management

tool, okay.

 This area evolved with fire and grazing

as those two primary ecological processes that

drove this landscape.

 What we're looking to do in

2

3

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5

6

7

8

9

10

11

12

13

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15

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24

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Page 44

1 Alternative D is to restore those processes.

Obviously, we can just let fire run across the

landscape like it did 200 years ago. You know,

Dave brought up a great point about that. We

have to be extremely cautious as how we use and

manage fire so that we don't impact our

neighbors.

 So, what we're looking at doing is

through this combination of restoring prescribed

fire out there, that will reduce wildlife

occurrence across the refuge, restore

prescriptive grazing. And basically what I mean

by prescriptive grazing is using those animals

to achieve a specific wildlife and/or habitat

management objective.

 And a classic example would be, if you

have an area, and you want to manage it for

mountain plovers, now mountain plovers like to

nest in those areas with prairie dogs towns.

 Prairie dogs like to have very short

grass. So that's a place where we could go in

there, use a little prescriptive fire, reduce

the grass cover. Put livestock in there. Let

livestock graze it down. Encourage prairie dogs

to expand, which would encourage mountain

2

3

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5

6

7

8

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10

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VOLUME 2, Chapter 4—Public Hearing Testimony 347

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

12 (Pages 45 to 48)

Page 45

1 plovers to expand.

 So, that's how you use fire and grazing

to achieve a very specific wildlife and/or

habitat management tool.

 MS. SHANNON: Do you want to give

another example of that?

 MR. CRAWFORD: Do I want to give

another example of that?

 Another example would be some of these

fire-dependent plants. They basically need fire

in order for them to continue their survival.

 And there's several places on the

refuge where fire has been excluded, and so

basically these plants are being severely

impacted through continuous grazing or

continuous browsing.

 And so by putting fire back into those

areas, they're fire-adaptive. They respond very

quickly. They resprout. They grow quickly.

 And as you continue to move those

patches of fire around, you continue to move

those animals around, and therefore reduce that

overall pressure on that plant, and it allows

the plant to grow up, reach maturity, fruit,

reproduce, and the cycle starts all over again.

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Page 46

1 So, a good example of that would be

like a chokecherry or a buffalo berry that's

extremely important to like sharp-tail grouse.

 I should have had Bob here for that.

 Another question from Bernie. Range

conditions, and what we aspire to.

 In Alternative C, we focus on range

condition as being our primary measuring tool as

to looking at whether we're meeting our wildlife

and our habitat objectives.

 In Alternative D, we're looking to use

what's called the sentinel plant approach. And

these are basically plants that are extremely

important to wildlife. They are plants that are

currently in decline across the refuge.

 They're those ice cream plants.

They're the plants that whenever an elk, a deer,

a cow, a rabbit walks by, that's the first thing

they eat. You know, it's very delicious, very

nutritious.

 So what we're looking in Alternative D

is to restore again those natural processes, and

then measure our success by looking at these

sentinel plants, and are those plants

increasing? Are they growing? Are they

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Page 47

1 reaching fruit-producing age? Are they

expanding in density, expanding in cover?

 So that's how we are going -- that's

the technique that we're going to use to

determine whether our management actions are

meeting our stated objectives for what we have

outlined under the Upland section of plan.

 A lot of folks equate range condition

and habitat condition as being the same. From

my standpoint, I look at them as very

different.

 Range condition relates to primarily

grass cover, and is the grass cover out there as

what you would expect it to be at the end of the

grazing season.

 Whereas wildlife habitat conditions,

depending on the wildlife species that you are

talking about, varies tremendously.

 You could have great habitat conditions

for elk but have very poor wildlife habitat

conditions for sage grouse.

 So, when you're looking at habitat

conditions, you first have to look at the

wildlife species that you're trying to provide

habitat for. And you can't just go across and

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Page 48

1 paint this broad paintbrush and say the habitat

across the refuge is good, fair or poor.

 Well, is it good for elk and poor for

sage grouse, or is it good for everything?

 And in Alternative D, we're hoping to

make it good for everything; promote that

diversity.

 What other questions did we have?

 I had a comment concerning sage grouse;

do our homework.

 We did go through the plan, and when

we're talking about fire and talking about

restoring that fire, definitely looking at sage

grouse habitat.

 The last thing we want to do is do some

type of management action that's going to affect

a species that's now been listed as a species

that's warranted for including on the threatened

and endangered species list.

 So definitely as we're developing our

prescribed fire plans, working with our wildlife

biologists, working with the state, identifying

those core areas that are sage grouse habitat,

not only leks and breeding grounds, but also

that winter habitat that's extremely important,

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Page 45

and grazing

e and/or

want to give

want to give

some of these

cally need fire

r survival.

n the

ded, and so

everely

zing or

 into those

 respond very

ow quickly.

ve those

nue to move

ore reduce that

d it allows

ity, fruit,

 over again.

Page 46

would be

erry that's

-tail grouse.

 for that.

nie. Range

Page 47

1 reaching fruit-producing age? Are they

expanding in density, expanding in cover?

 So that's how we are going -- that's

the technique that we're going to use to

determine whether our management actions are

meeting our stated objectives for what we have

outlined under the Upland section of plan.

 A lot of folks equate range condition

and habitat condition as being the same. From

my standpoint, I look at them as very

different.

 Range condition relates to primarily

grass cover, and is the grass cover out there as

what you would expect it to be at the end of the

grazing season.

 Whereas wildlife habitat conditions,

depending on the wildlife species that you are

talking about, varies tremendously.

 You could have great habitat conditions

for elk but have very poor wildlife habitat

conditions for sage grouse.

 So, when you're looking at habitat

conditions, you first have to look at the

wildlife species that you're trying to provide

habitat for. And you can't just go across and

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Page 48

1 paint this broad paintbrush and say the habitat

across the refuge is good, fair or poor.

 Well, is it good for elk and poor for

sage grouse, or is it good for everything?

 And in Alternative D, we're hoping to

make it good for everything; promote that

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

quickly. They resprout. They grow quickly.

 And as you continue to move those

patches of fire around, you continue to move

those animals around, and therefore reduce that

overall pressure on that plant, and it allows

the plant to grow up, reach maturity, fruit,

reproduce, and the cycle starts all over again.

19

20

21

22

23

24

25

Page 46

1 So, a good example of that would be

like a chokecherry or a buffalo berry that's

extremely important to like sharp-tail grouse.

 I should have had Bob here for that.

 Another question from Bernie. Range

conditions, and what we aspire to.

 In Alternative C, we focus on range

condition as being our primary measuring tool as

to looking at whether we're meeting our wildlife

and our habitat objectives.

 In Alternative D, we're looking to use

what's called the sentinel plant approach. And

these are basically plants that are extremely

important to wildlife. They are plants that are

currently in decline across the refuge.

 They're those ice cream plants.

They're the plants that whenever an elk, a deer,

a cow, a rabbit walks by, that's the first thing

they eat. You know, it's very delicious, very

nutritious.

 So what we're looking in Alternative D

is to restore again those natural processes, and

then measure our success by looking at these

sentinel plants, and are those plants

increasing? Are they growing? Are they

2

3

4

5

6

7

8

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 Yo

for elk b

conditio

 So

conditio

wildlife 

habitat f

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20

21

22

23

24

25

1 paint thi

across th

 W

sage gro

 An

make it 

diversity

 W

 I h

do our h

 W

we're tal

restoring 

grouse h

 Th

type of m

a specie

that's wa

and enda

 So 

prescrib

biologis

those co

not only 

that win

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

12 (Pages 45 to 48)

Page 45

1 plovers to expand.

 So, that's how you use fire and grazing

to achieve a very specific wildlife and/or

habitat management tool.

 MS. SHANNON: Do you want to give

another example of that?

 MR. CRAWFORD: Do I want to give

another example of that?

 Another example would be some of these

fire-dependent plants. They basically need fire

in order for them to continue their survival.

 And there's several places on the

refuge where fire has been excluded, and so

basically these plants are being severely

impacted through continuous grazing or

continuous browsing.

 And so by putting fire back into those

areas, they're fire-adaptive. They respond very

quickly. They resprout. They grow quickly.

 And as you continue to move those

patches of fire around, you continue to move

those animals around, and therefore reduce that

overall pressure on that plant, and it allows

the plant to grow up, reach maturity, fruit,

reproduce, and the cycle starts all over again.

2

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5

6

7

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Page 46

1 So, a good example of that would be

like a chokecherry or a buffalo berry that's

extremely important to like sharp-tail grouse.

 I should have had Bob here for that.

 Another question from Bernie. Range

conditions, and what we aspire to.

 In Alternative C, we focus on range

condition as being our primary measuring tool as

to looking at whether we're meeting our wildlife

and our habitat objectives.

 In Alternative D, we're looking to use

what's called the sentinel plant approach. And

these are basically plants that are extremely

important to wildlife. They are plants that are

currently in decline across the refuge.

 They're those ice cream plants.

They're the plants that whenever an elk, a deer,

a cow, a rabbit walks by, that's the first thing

they eat. You know, it's very delicious, very

nutritious.

 So what we're looking in Alternative D

is to restore again those natural processes, and

then measure our success by looking at these

sentinel plants, and are those plants

increasing? Are they growing? Are they

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1 reaching fruit-producing age? Are they

expanding in density, expanding in cover?

 So that's how we are going -- that's

the technique that we're going to use to

determine whether our management actions are

meeting our stated objectives for what we have

outlined under the Upland section of plan.

 A lot of folks equate range condition

and habitat condition as being the same. From

my standpoint, I look at them as very

different.

 Range condition relates to primarily

grass cover, and is the grass cover out there as

what you would expect it to be at the end of the

grazing season.

 Whereas wildlife habitat conditions,

depending on the wildlife species that you are

talking about, varies tremendously.

 You could have great habitat conditions

for elk but have very poor wildlife habitat

conditions for sage grouse.

 So, when you're looking at habitat

conditions, you first have to look at the

wildlife species that you're trying to provide

habitat for. And you can't just go across and

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Page 48

1 paint this broad paintbrush and say the habitat

across the refuge is good, fair or poor.

 Well, is it good for elk and poor for

sage grouse, or is it good for everything?

 And in Alternative D, we're hoping to

make it good for everything; promote that

diversity.

 What other questions did we have?

 I had a comment concerning sage grouse;

do our homework.

 We did go through the plan, and when

we're talking about fire and talking about

restoring that fire, definitely looking at sage

grouse habitat.

 The last thing we want to do is do some

type of management action that's going to affect

a species that's now been listed as a species

that's warranted for including on the threatened

and endangered species list.

 So definitely as we're developing our

prescribed fire plans, working with our wildlife

biologists, working with the state, identifying

those core areas that are sage grouse habitat,

not only leks and breeding grounds, but also

that winter habitat that's extremely important,

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348 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

13 (Pages 49 to 52)

Page 49

1 and in the plan, identify those areas and make

sure that we protect them from wildfire

occurrence so that we do not have an impact on a

sage grouse for the future.

 What else?

 MS. SHANNON: Roads.

 MR. CRAWFORD: Roads.

 What am I supposed to say about roads,

Laurie?

 MS. SHANNON: There seemed to be some

question, I think, about how many roads were

actually -- or I think I heard a question that

we're closing 670 miles of road. I think that's

-- and our ownership of roads, and whether we

have looked at roads that are petitioned or

not.

 MR. CRAWFORD: Okay.

 Alternative B, it talks about closing

106 miles of roads.

 Alternative C, I don't believe we

proposed any road closures in that.

 MS. SHANNON: Right.

 MR. CRAWFORD: In Alternative D, it is

23.

 Did we look at petitioned roads? No,

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Page 50

1 we did not.

 Basically we sat there, and we went

through it, and we said, what are roads that we

need to consider in order for us to meet our

wildlife, our habitat objectives, provide for

quality public use, boom, boom, boom, boom.

 Now, what I look at petitioned roads is

that's a process that is outside the CCP, okay,

and that will need to be addressed through a

separate planning process, whether it's through

a transportation plan that will be developed

after the CCP, or whether it's through some type

to have court documents.

 And I'm not an expert when it comes to

Montana law and sitting here and going, "Yeah,

that's a valid petition. We need to accept it."

 We're going to need somebody that

that's their area of expertise to sit down and

say, "Okay, Barron, you've overstepped your

boundary here. That's a valid petition. You

can't close that road."

 So we decided that we weren't going to

address the petitioned road issue as part of

this plan. So that's going to have to be

addressed separately.

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1 Anything else?

 MS. SHANNON: I think that's all.

 MR. CRAWFORD: I think I caught all the

questions.

 Was there anything that I missed?

 MR. BERG: I guess the one thing that I

would like to add, and I took it to be somewhat

of a question from Bernard, you talked little

bit about the positive value of wilderness.

 And we do address a little bit of that

in our economic analysis. But also, as part of

this planning process, we're charged with going

back and looking at those proposed wilderness

areas and evaluating those, as we did in the

late 1970s, to determine if they still maintain

those wilderness values. So, that's what we

have done in alternative D.

 The three areas that we're proposing to

not include as proposed wilderness areas, we

felt those didn't meet the criteria as well as

they could. But again, that's somewhat

subjective, and that's why we're looking for

comments from folks like you out there.

 So, yes, we do consider that as part of

the process, and that's kind of evaluation

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Page 52

1 process that we have to go through for each

one.

 MS. MATHER: Any other questions for

these guys?

 MR. PIPPIN: You guys got me inspired.

 But the original Fort Peck Game Range,

which is the CMR now, had a management practice,

and grazing was part of that.

 And what I wonder is that when you look

at this new plan, are you going back and

realizing that grazing and those things were

there?

 The people that were on that land were

there 40 years before they even thought about

doing this, before they became a game range.

They had been there for 75 years.

 And so that's why your prescriptive

grazing really has me kind of concerned because

that is a break from tradition, 150 years of

tradition. Why would you change that now,

because these ranches are built on that

inception.

 So, are you managing this in a

consistent manner with the original Executive

Order? And have you taken time to sit back and

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Page 49

nd make

re

impact on a

t roads,

d to be some

ds were

n that

nk that's

ether we

d or

ing

ive D, it is

 No,

Page 50

went

s that we

et our

de for

mboom

Page 51

1 Anything else?

 MS. SHANNON: I think that's all.

 MR. CRAWFORD: I think I caught all the

questions.

 Was there anything that I missed?

 MR. BERG: I guess the one thing that I

would like to add, and I took it to be somewhat

of a question from Bernard, you talked little

bit about the positive value of wilderness.

 And we do address a little bit of that

in our economic analysis. But also, as part of

this planning process, we're charged with going

back and looking at those proposed wilderness

areas and evaluating those, as we did in the

late 1970s, to determine if they still maintain

those wilderness values. So, that's what we

have done in alternative D.

 The three areas that we're proposing to

not include as proposed wilderness areas, we

felt those didn't meet the criteria as well as

they could. But again, that's somewhat

subjective, and that's why we're looking for

comments from folks like you out there.

 So, yes, we do consider that as part of

the process, and that's kind of evaluation

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Page 52

1 process that we have to go through for each

one.

 MS. MATHER: Any other questions for

these guys?

 MR. PIPPIN: You guys got me inspired.

But the original Fort Peck Game Range

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

106 miles of roads.

 Alternative C, I don't believe we

proposed any road closures in that.

 MS. SHANNON: Right.

 MR. CRAWFORD: In Alternative D, it is

23.

 Did we look at petitioned roads? No,

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Page 50

1 we did not.

 Basically we sat there, and we went

through it, and we said, what are roads that we

need to consider in order for us to meet our

wildlife, our habitat objectives, provide for

quality public use, boom, boom, boom, boom.

 Now, what I look at petitioned roads is

that's a process that is outside the CCP, okay,

and that will need to be addressed through a

separate planning process, whether it's through

a transportation plan that will be developed

after the CCP, or whether it's through some type

to have court documents.

 And I'm not an expert when it comes to

Montana law and sitting here and going, "Yeah,

that's a valid petition. We need to accept it."

 We're going to need somebody that

that's their area of expertise to sit down and

say, "Okay, Barron, you've overstepped your

boundary here. That's a valid petition. You

can't close that road."

 So we decided that we weren't going to

address the petitioned road issue as part of

this plan. So that's going to have to be

addressed separately.

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not include a

felt those did

they could. B

subjective, a

comments fr

 So, yes

the process, 

19

20

21

22

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24

25

1 process that w

one.

 MS. MA

these guys?

 MR. PI

 But the 

which is the C

and grazing w

 And wh

at this new pl

realizing that 

there?

 The peo

there 40 year

doing this, be

They had bee

 And so 

grazing really 

that is a break 

tradition. Wh

because these 

inception.

 So, are 

consistent ma

Order? And 

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

13 (Pages 49 to 52)

Page 49

1 and in the plan, identify those areas and make

sure that we protect them from wildfire

occurrence so that we do not have an impact on a

sage grouse for the future.

 What else?

 MS. SHANNON: Roads.

 MR. CRAWFORD: Roads.

 What am I supposed to say about roads,

Laurie?

 MS. SHANNON: There seemed to be some

question, I think, about how many roads were

actually -- or I think I heard a question that

we're closing 670 miles of road. I think that's

-- and our ownership of roads, and whether we

have looked at roads that are petitioned or

not.

 MR. CRAWFORD: Okay.

 Alternative B, it talks about closing

106 miles of roads.

 Alternative C, I don't believe we

proposed any road closures in that.

 MS. SHANNON: Right.

 MR. CRAWFORD: In Alternative D, it is

23.

 Did we look at petitioned roads? No,

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Page 50

1 we did not.

 Basically we sat there, and we went

through it, and we said, what are roads that we

need to consider in order for us to meet our

wildlife, our habitat objectives, provide for

quality public use, boom, boom, boom, boom.

 Now, what I look at petitioned roads is

that's a process that is outside the CCP, okay,

and that will need to be addressed through a

separate planning process, whether it's through

a transportation plan that will be developed

after the CCP, or whether it's through some type

to have court documents.

 And I'm not an expert when it comes to

Montana law and sitting here and going, "Yeah,

that's a valid petition. We need to accept it."

 We're going to need somebody that

that's their area of expertise to sit down and

say, "Okay, Barron, you've overstepped your

boundary here. That's a valid petition. You

can't close that road."

 So we decided that we weren't going to

address the petitioned road issue as part of

this plan. So that's going to have to be

addressed separately.

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Page 51

1 Anything else?

 MS. SHANNON: I think that's all.

 MR. CRAWFORD: I think I caught all the

questions.

 Was there anything that I missed?

 MR. BERG: I guess the one thing that I

would like to add, and I took it to be somewhat

of a question from Bernard, you talked little

bit about the positive value of wilderness.

 And we do address a little bit of that

in our economic analysis. But also, as part of

this planning process, we're charged with going

back and looking at those proposed wilderness

areas and evaluating those, as we did in the

late 1970s, to determine if they still maintain

those wilderness values. So, that's what we

have done in alternative D.

 The three areas that we're proposing to

not include as proposed wilderness areas, we

felt those didn't meet the criteria as well as

they could. But again, that's somewhat

subjective, and that's why we're looking for

comments from folks like you out there.

 So, yes, we do consider that as part of

the process, and that's kind of evaluation

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Page 52

1 process that we have to go through for each

one.

 MS. MATHER: Any other questions for

these guys?

 MR. PIPPIN: You guys got me inspired.

 But the original Fort Peck Game Range,

which is the CMR now, had a management practice,

and grazing was part of that.

 And what I wonder is that when you look

at this new plan, are you going back and

realizing that grazing and those things were

there?

 The people that were on that land were

there 40 years before they even thought about

doing this, before they became a game range.

They had been there for 75 years.

 And so that's why your prescriptive

grazing really has me kind of concerned because

that is a break from tradition, 150 years of

tradition. Why would you change that now,

because these ranches are built on that

inception.

 So, are you managing this in a

consistent manner with the original Executive

Order? And have you taken time to sit back and

2

3

4

5

6

7

8

9

10

11

12

13

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VOLUME 2, Chapter 4—Public Hearing Testimony 349

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

14 (Pages 53 to 56)

Page 53

1 read what the Executive Order asked and

promised?

 Just a question.

 MR. CRAWFORD: I'll go first, and then

you can add what I forget. How's that?

 MR. BERG: Good.

 MR. CRAWFORD: Yeah, Dave's right.

Refuge was originally established in 1936 as a

game range.

 There were several refuges established

in that mid-30s, you know, right when the dust

bowl was occurring, as game ranges, and the

Executive Order was written.

 And the Executive Order has several

points to that. And if you read through it

point by point, you know, first it talks about

400,000 sharp-tail grouse and 1500 pronghorn

antelope.

 And then it talks about range

condition. And then it talks about what's left

should be equally split between wildlife and

livestock, okay.

 And so we've met with our lawyers, the

Solicitor's Office, and have gone through the

Executive Order word by word.

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Page 54

1 We have been to court three times --

four times? Four times now over this issue, and

each time the courts have said, yes, the U.S.

Fish & Wildlife Service is meeting the mandates

as outlined in the Executive Order.

 There is a priority established for

those forage resources on the refuge, and the

priority is, sharp-tail grouse and pronghorn

antelope first; secondary wildlife to provide

for a balanced ecosystem out there, and then

third, what's left over is to be equally shared

between wildlife and livestock, okay.

 So, you know, yeah, there has been a

long tradition of interaction between the local

ranchers and grazing on the refuge.

 With the passage of the Improvement Act

in 1997, even before that, when the Fort Peck

Game Range was converted and changed to a

Natural Wildlife Refuge, it fell under the sole

jurisdiction of the U.S. Fish & Wildlife

Service.

 From 1936 to 1976, it was co-managed

between the U.S. Fish & Wildlife Service and the

Bureau of Land Management, with the Fish &

Wildlife Service having responsibility for the

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Page 55

1 wildlife out there, and the Bureau of Land

Management having responsibility for the

grazing. And that's how it operated for those

40 years.

 And then in '76, Congress decided that

all of the game ranges in the United States

would be managed solely by Fish & Wildlife

Service, would be managed under the National

Wildlife Refuge System, and so that the laws and

the policies of the Fish & Wildlife Service and

the National Wildlife Refuge System would apply

to those game ranges.

 So, that was the National Wildlife

Refuge System Administration Act back in 1966,

and then it was the National Wildlife Refuge

System Improvement Act in 1997.

 So we've got the Executive Order

mandate; We've got the Refuge Administration

Act; and, we've got the Improvement Act.

 And those were all the things that we

looked at as we were lining out this plan. And

as we presented it to our lawyers, the lawyers

said, yeah, you are meeting not only your

original mandates, but also all the other laws

and policies that have been set forth that guide

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Page 56

1 management on a National Wildlife Refuge

2 System.

 Anything you want to add, Bill?

 MR. BERG: I was just going to touch on

prescriptive grazing.

 There seems to be quite a bit of

confusion and concern about the prescriptive

grazing that we're proposing to do.

 And actually, we have been involved

with prescriptive grazing not only on CMR for

several years, but also refuges throughout the

country.

 In a nutshell, what it is, we're using

livestock to manage habitat for wildlife. And

if you look at some of the permits we currently

have on CMR, the permits are issued annually for

the same time period, for the same number of

livestock year in year, out year every year.

 So if you think back about some the

plant issues that Barron mentioned where those

animals are seeking out the same plants year

after year, same time of year, there's a

tendency for those species to decrease on the

landscape.

 Those same species are the ones we're

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Page 53

ked and

first, and then

s that?

Dave's right.

d in 1936 as a

established

when the dust

ges, and the

as several

rough it

talks about

00 pronghorn

e

t what's left

wildlife and

lawyers, the

through the

Page 54

e times --

 this issue, and

es, the U.S.

ng the mandates

r.

ed for

Page 55

1 wildlife out there, and the Bureau of Land

Management having responsibility for the

grazing. And that's how it operated for those

40 years.

 And then in '76, Congress decided that

all of the game ranges in the United States

would be managed solely by Fish & Wildlife

Service, would be managed under the National

Wildlife Refuge System, and so that the laws and

the policies of the Fish & Wildlife Service and

the National Wildlife Refuge System would apply

to those game ranges.

 So, that was the National Wildlife

Refuge System Administration Act back in 1966,

and then it was the National Wildlife Refuge

System Improvement Act in 1997.

 So we've got the Executive Order

mandate; We've got the Refuge Administration

Act; and, we've got the Improvement Act.

 And those were all the things that we

looked at as we were lining out this plan. And

as we presented it to our lawyers, the lawyers

said, yeah, you are meeting not only your

original mandates, but also all the other laws

and policies that have been set forth that guide

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3

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Page 56

1 management on a National Wildlife Refuge

2 System.

 Anything you want to add, Bill?

 MR. BERG: I was just going to touch on

prescriptive grazing.

There seems to be quite a bit of

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 And then it talks about range

condition. And then it talks about what's left

should be equally split between wildlife and

livestock, okay.

 And so we've met with our lawyers, the

Solicitor's Office, and have gone through the

Executive Order word by word.

19

20

21

22

23

24

25

Page 54

1 We have been to court three times --

four times? Four times now over this issue, and

each time the courts have said, yes, the U.S.

Fish & Wildlife Service is meeting the mandates

as outlined in the Executive Order.

 There is a priority established for

those forage resources on the refuge, and the

priority is, sharp-tail grouse and pronghorn

antelope first; secondary wildlife to provide

for a balanced ecosystem out there, and then

third, what's left over is to be equally shared

between wildlife and livestock, okay.

 So, you know, yeah, there has been a

long tradition of interaction between the local

ranchers and grazing on the refuge.

 With the passage of the Improvement Act

in 1997, even before that, when the Fort Peck

Game Range was converted and changed to a

Natural Wildlife Refuge, it fell under the sole

jurisdiction of the U.S. Fish & Wildlife

Service.

 From 1936 to 1976, it was co-managed

between the U.S. Fish & Wildlife Service and the

Bureau of Land Management, with the Fish &

Wildlife Service having responsibility for the

2

3

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Act; and

 An

looked a

as we pr

said, yea

original 

and poli

19

20

21

22

23

24

25

1 managem

2 System.

 An

 MR

prescrip

 Th

confusio

grazing 

 An

with pre

several y

country.

 In 

livestock 

if you lo

have on 

the same 

livestock 

 So 

plant iss

animals 

after yea

tendency 

landscap

 Th

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

14 (Pages 53 to 56)

Page 53

1 read what the Executive Order asked and

promised?

 Just a question.

 MR. CRAWFORD: I'll go first, and then

you can add what I forget. How's that?

 MR. BERG: Good.

 MR. CRAWFORD: Yeah, Dave's right.

Refuge was originally established in 1936 as a

game range.

 There were several refuges established

in that mid-30s, you know, right when the dust

bowl was occurring, as game ranges, and the

Executive Order was written.

 And the Executive Order has several

points to that. And if you read through it

point by point, you know, first it talks about

400,000 sharp-tail grouse and 1500 pronghorn

antelope.

 And then it talks about range

condition. And then it talks about what's left

should be equally split between wildlife and

livestock, okay.

 And so we've met with our lawyers, the

Solicitor's Office, and have gone through the

Executive Order word by word.

2

3

4

5

6

7

8

9

10

11

12

13

14

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1 We have been to court three times --

four times? Four times now over this issue, and

each time the courts have said, yes, the U.S.

Fish & Wildlife Service is meeting the mandates

as outlined in the Executive Order.

 There is a priority established for

those forage resources on the refuge, and the

priority is, sharp-tail grouse and pronghorn

antelope first; secondary wildlife to provide

for a balanced ecosystem out there, and then

third, what's left over is to be equally shared

between wildlife and livestock, okay.

 So, you know, yeah, there has been a

long tradition of interaction between the local

ranchers and grazing on the refuge.

 With the passage of the Improvement Act

in 1997, even before that, when the Fort Peck

Game Range was converted and changed to a

Natural Wildlife Refuge, it fell under the sole

jurisdiction of the U.S. Fish & Wildlife

Service.

 From 1936 to 1976, it was co-managed

between the U.S. Fish & Wildlife Service and the

Bureau of Land Management, with the Fish &

Wildlife Service having responsibility for the

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Page 55

1 wildlife out there, and the Bureau of Land

Management having responsibility for the

grazing. And that's how it operated for those

40 years.

 And then in '76, Congress decided that

all of the game ranges in the United States

would be managed solely by Fish & Wildlife

Service, would be managed under the National

Wildlife Refuge System, and so that the laws and

the policies of the Fish & Wildlife Service and

the National Wildlife Refuge System would apply

to those game ranges.

 So, that was the National Wildlife

Refuge System Administration Act back in 1966,

and then it was the National Wildlife Refuge

System Improvement Act in 1997.

 So we've got the Executive Order

mandate; We've got the Refuge Administration

Act; and, we've got the Improvement Act.

 And those were all the things that we

looked at as we were lining out this plan. And

as we presented it to our lawyers, the lawyers

said, yeah, you are meeting not only your

original mandates, but also all the other laws

and policies that have been set forth that guide

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Page 56

1 management on a National Wildlife Refuge

2 System.

 Anything you want to add, Bill?

 MR. BERG: I was just going to touch on

prescriptive grazing.

 There seems to be quite a bit of

confusion and concern about the prescriptive

grazing that we're proposing to do.

 And actually, we have been involved

with prescriptive grazing not only on CMR for

several years, but also refuges throughout the

country.

 In a nutshell, what it is, we're using

livestock to manage habitat for wildlife. And

if you look at some of the permits we currently

have on CMR, the permits are issued annually for

the same time period, for the same number of

livestock year in year, out year every year.

 So if you think back about some the

plant issues that Barron mentioned where those

animals are seeking out the same plants year

after year, same time of year, there's a

tendency for those species to decrease on the

landscape.

 Those same species are the ones we're

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350 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

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BIG SKY REPORTING - FRANCES L. MOCK

15 (Pages 57 to 60)

Page 57

1 trying to manage for the benefit of wildlife.

 So, what prescriptive truly is, is

going in and treating that landscape or pasture

or allotment, or whatever you want to call it,

in such a manner to where you get a flush of

growth afterwards.

 So, what would happen, rather than us

issuing a permit year in year out for the same

pasture, we might set it up where one year, this

pasture is grazed, probably a little bit heavier

than it would have normally. The next year

would be in a different pasture. And we would

make that rotation to get those benefits out of

that grazing treatment that we prescribed.

 Granted, that's going to be a change in

how some of our permits are managed.

 In my opinion, there's still going to

be opportunities for people with a cow/calf

operation to utilize grazing privileges on CMR.

 There will be instances where a

yearling operation might be more conducive to

what we are trying to accomplish out there.

 There might also be units that are

better managed by fire, where we've got those

boundaries and capabilities to use fire in a

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Page 58

1 situation, and then maybe following that with

more of a prescriptive grazing later on.

 So, it sounds pretty, you know, I guess

intrusive to current operations, but that will

be one of our challenges after this plan is

formalized, where we will sit down and actually

do habitat management plans for a smaller unit

of the refuge, and it will probably encompass

several permittees that we have currently, and

we'll sit down and try to figure out how we can

best manage that habitat out there with the use

of livestock, where we're going to use livestock

as that tool.

 So, I'm not sure if that clears it up,

but that's a little bit more of a definition of

how we plan to use prescriptive grazing.

 MR. CRAWFORD: And just to follow up

with what Bill is saying. You know, we're

currently prescriptively grazing 35% of the

refuge now.

 Alternative D says move to 50 to 75%

over the next seven to nine, I think.

 MS. SHANNON: You're right.

 MR. CRAWFORD: Yeah, seven to nine

years.

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Page 59

1 So, we're at 35% right now. So just

another 15% gets us to that 50% that we have

outlined in Alternative D.

 And basically the way we have been able

to move to prescriptive grazing on the refuge

now is as ranches sell to a nonfamily member, we

take that permit, and we take that habitat unit,

and we roll it into the Prescriptive Grazing

Program.

 That's how we have it outlined right

now in the Draft Plan, is to continue to use

that process as ranches sell to a third party.

 We're continuing to transfer permits

within the family. So, if a rancher wants to

transfer his ranch to a son or daughter, we are

still doing those generational transfers of that

permit. We're only talking about those ranches

that sell to a nonfamily member.

 MS. MATHER: Lesley?

 MS. ROBINSON: Lesley Robinson.

 I was just wondering, how are you

planning on handling, then, the private lands,

the private AUMs that are in the CMR and then

the privately held state leases within the CMR?

 MR. BERG: This plan only applies to

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Page 60

1 federal lands within the refuge.

 If a permittee has a state section or a

private inholding, so to speak, those would

still be at the discretion of the landowner or

the leaseholder owner.

 And we have got several examples of

those, but we've also got examples where, say a

permittee currently has a state lease or a

private parcel that's outside the normal grazing

units, oftentimes we'll transfer those AUMs into

the one that's being grazed, you know, with

their herd, so to speak, so it's not an

inconvenience to stick 20 head in for two months

or something like that.

 I'm guessing that's the way it's going

to occur in the future.

 You know, there's a little bit of an

effort going on to maybe shift around some of

those state lands so they are better situated

within the refuge, or adjacent to it, which

might accommodate some of those changes also.

 MS. MATHER: Yes.

 MIKE BRYANT: My name is Mike Bryant,

B-R-Y-A-N-T, right here in Billings.

 Actually I have a couple of questions

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Page 57

ldlife.

r pasture

 call it,

lush of

han us

he same

year, this

heavier

t year

we would

s out of

bed.

nge in

d.

 to

w/calf

on CMR.

ducive to

there.

e

ot those

 in a

Page 58

hat with

n.

 guess

at will

n is

nd actually

Page 59

1 So, we're at 35% right now. So just

another 15% gets us to that 50% that we have

outlined in Alternative D.

 And basically the way we have been able

to move to prescriptive grazing on the refuge

now is as ranches sell to a nonfamily member, we

take that permit, and we take that habitat unit,

and we roll it into the Prescriptive Grazing

Program.

 That's how we have it outlined right

now in the Draft Plan, is to continue to use

that process as ranches sell to a third party.

 We're continuing to transfer permits

within the family. So, if a rancher wants to

transfer his ranch to a son or daughter, we are

still doing those generational transfers of that

permit. We're only talking about those ranches

that sell to a nonfamily member.

 MS. MATHER: Lesley?

 MS. ROBINSON: Lesley Robinson.

 I was just wondering, how are you

planning on handling, then, the private lands,

the private AUMs that are in the CMR and then

the privately held state leases within the CMR?

 MR. BERG: This plan only applies to

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Page 60

1 federal lands within the refuge.

 If a permittee has a state section or a

private inholding, so to speak, those would

still be at the discretion of the landowner or

the leaseholder owner.

And we have got several examples of

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

operation to utilize grazing privileges on CMR.

 There will be instances where a

yearling operation might be more conducive to

what we are trying to accomplish out there.

 There might also be units that are

better managed by fire, where we've got those

boundaries and capabilities to use fire in a

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25

Page 58

1 situation, and then maybe following that with

more of a prescriptive grazing later on.

 So, it sounds pretty, you know, I guess

intrusive to current operations, but that will

be one of our challenges after this plan is

formalized, where we will sit down and actually

do habitat management plans for a smaller unit

of the refuge, and it will probably encompass

several permittees that we have currently, and

we'll sit down and try to figure out how we can

best manage that habitat out there with the use

of livestock, where we're going to use livestock

as that tool.

 So, I'm not sure if that clears it up,

but that's a little bit more of a definition of

how we plan to use prescriptive grazing.

 MR. CRAWFORD: And just to follow up

with what Bill is saying. You know, we're

currently prescriptively grazing 35% of the

refuge now.

 Alternative D says move to 50 to 75%

over the next seven to nine, I think.

 MS. SHANNON: You're right.

 MR. CRAWFORD: Yeah, seven to nine

years.

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 MS. M

 MS. RO

 I was ju

planning on 

the private A

the privately 

 MR. BE

9

20

21

22

23

24

25

1 federal lands 

 If a per

private inhol

still be at the 

the leasehold

 And we 

those, but we

permittee cur

private parce

units, oftenti

the one that's 

their herd, so 

inconvenienc

or something 

 I'm gue

to occur in th

 You kn

effort going 

those state la

within the re

might accom

 MS. M

 MIKE 

B-R-Y-A-N-

 Actuall

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

15 (Pages 57 to 60)

Page 57

1 trying to manage for the benefit of wildlife.

 So, what prescriptive truly is, is

going in and treating that landscape or pasture

or allotment, or whatever you want to call it,

in such a manner to where you get a flush of

growth afterwards.

 So, what would happen, rather than us

issuing a permit year in year out for the same

pasture, we might set it up where one year, this

pasture is grazed, probably a little bit heavier

than it would have normally. The next year

would be in a different pasture. And we would

make that rotation to get those benefits out of

that grazing treatment that we prescribed.

 Granted, that's going to be a change in

how some of our permits are managed.

 In my opinion, there's still going to

be opportunities for people with a cow/calf

operation to utilize grazing privileges on CMR.

 There will be instances where a

yearling operation might be more conducive to

what we are trying to accomplish out there.

 There might also be units that are

better managed by fire, where we've got those

boundaries and capabilities to use fire in a

2

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Page 58

1 situation, and then maybe following that with

more of a prescriptive grazing later on.

 So, it sounds pretty, you know, I guess

intrusive to current operations, but that will

be one of our challenges after this plan is

formalized, where we will sit down and actually

do habitat management plans for a smaller unit

of the refuge, and it will probably encompass

several permittees that we have currently, and

we'll sit down and try to figure out how we can

best manage that habitat out there with the use

of livestock, where we're going to use livestock

as that tool.

 So, I'm not sure if that clears it up,

but that's a little bit more of a definition of

how we plan to use prescriptive grazing.

 MR. CRAWFORD: And just to follow up

with what Bill is saying. You know, we're

currently prescriptively grazing 35% of the

refuge now.

 Alternative D says move to 50 to 75%

over the next seven to nine, I think.

 MS. SHANNON: You're right.

 MR. CRAWFORD: Yeah, seven to nine

years.

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Page 59

1 So, we're at 35% right now. So just

another 15% gets us to that 50% that we have

outlined in Alternative D.

 And basically the way we have been able

to move to prescriptive grazing on the refuge

now is as ranches sell to a nonfamily member, we

take that permit, and we take that habitat unit,

and we roll it into the Prescriptive Grazing

Program.

 That's how we have it outlined right

now in the Draft Plan, is to continue to use

that process as ranches sell to a third party.

 We're continuing to transfer permits

within the family. So, if a rancher wants to

transfer his ranch to a son or daughter, we are

still doing those generational transfers of that

permit. We're only talking about those ranches

that sell to a nonfamily member.

 MS. MATHER: Lesley?

 MS. ROBINSON: Lesley Robinson.

 I was just wondering, how are you

planning on handling, then, the private lands,

the private AUMs that are in the CMR and then

the privately held state leases within the CMR?

 MR. BERG: This plan only applies to

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Page 60

1 federal lands within the refuge.

 If a permittee has a state section or a

private inholding, so to speak, those would

still be at the discretion of the landowner or

the leaseholder owner.

 And we have got several examples of

those, but we've also got examples where, say a

permittee currently has a state lease or a

private parcel that's outside the normal grazing

units, oftentimes we'll transfer those AUMs into

the one that's being grazed, you know, with

their herd, so to speak, so it's not an

inconvenience to stick 20 head in for two months

or something like that.

 I'm guessing that's the way it's going

to occur in the future.

 You know, there's a little bit of an

effort going on to maybe shift around some of

those state lands so they are better situated

within the refuge, or adjacent to it, which

might accommodate some of those changes also.

 MS. MATHER: Yes.

 MIKE BRYANT: My name is Mike Bryant,

B-R-Y-A-N-T, right here in Billings.

 Actually I have a couple of questions

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VOLUME 2, Chapter 4—Public Hearing Testimony 351

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

16 (Pages 61 to 64)

Page 61

1 for you guys.

 In your Draft Plan, you state that

currently there are 11 commercial hunting

operations on CMR.

 And I'd like to know if you have a plan

in place, or recommend that maybe you put a cap

on it?

 I don't know what that would be, and

that's not up to me to decide. But 40 seems

like it might be too much.

 You know, 11, if we're all happy now,

that's fine.

 Also, I wonder if you have any

projection for what ecotourism might be coming

down the pike?

 In the next few years, APF, your

neighbor to the north, so we know that that's

going ramp up in some fashion.

 Also, I think I noted that 90% of the

suitable bighorn sheep habitat on the south side

in Garfield County is on CMR. I'm sure that's a

hot potato, but have you addressed that in the

plan?

 You know, strictly as a sportsman

and a hunter, I would like to see it. If I

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Page 62

1 was a rancher up on the Bench, I probably

wouldn't. So, I don't know where Garfield

County ranchers or Commissioners stand with

that.

 And the other one is a Catch-22,

depending literally on which side of the fence

you are on. Bison is either livestock, or it's

wildlife. And I think the courts are going to

take that into consideration.

 But, if you are issuing livestock

permits, then I think you need to be aware

somebody's going to say, well, I'm going to

bring my livestock bison down here and try and

get a grazing permit out of it.

 I don't know what -- what's Glenda? Is

she BLM? Is she wildlife or livestock or what?

 MR. CRAWFORD: She has a livestock

permit.

 MR. BRYANT: And before I spend a lot

of money on a jet boat, I'd like to know if you

guys are going to restrict the river use or

not.

 So, thank you.

 MR. CRAWFORD: Those are your

questions.

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Page 63

1 MR. BERG: We'll start out with the

outfitting question.

 First of all, any commercial activity

on a National Wildlife Refuge requires special

authorization or a Special Use Permit.

 So whether it's outfitting, cattle

grazing, commercial paleo activities, those kind

of things all require a permit.

 Regarding the hunting outfitting on the

refuge, in 1988 -- up until 1988, we did not

permit any outfitting on the refuge, but we knew

it was going on.

 So what we did is open it up to people

that could historically show some use on the

refuge. And at that time, in '88, we issued 36

permits to hunting outfitting. Today, we have

11.

 Probably two-thirds of those have

dropped out because of game type violations

where we've canceled permits for inappropriate

hunting activities. The other third have

probably just gotten out of the business for one

reason or another, so we're down to 11.

 Whether or not that's the right number,

lower or higher, we're kind of evaluating that

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Page 64

1 right now.

 Our sense is, like with the limited

archery permits, limited nonresident permits in

the state licenses, it seems to have stabilized

pretty good.

 If people from out of state want to

come to Montana and hunt the Breaks, there's

ample opportunity for them to find an outfitter

that can supply those services.

 And we kind of look at that as, you

know, reaching that whole audience. There are

some people who like to hunt that way, like the

opportunity to have somebody help them out with

the hunt, versus the individual who might come

in and do it on his own, so to speak.

 So, that's why we are at 11. We've got

no plans to increase that to 40 or set a cap,

but that will be something that's kind of

evaluated on a case-by-case basis.

 We've probably got 15 or 20 that have

asked if they could get a permit. If we sense

that there is a vacancy, for example, in a

hunting district where there's no outfitting

opportunities available for the general public,

it might be that we would go out and advertise

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Page 61

e that

l hunting

have a plan

be you put a cap

ld be, and

t 40 seems

happy now,

any

ight be coming

 your

w that that's

% of the

 the south side

'm sure that's a

d that in the

rtsman

t. If I

Page 62

probably

e Garfield

ers stand with

h-22,

of the fence

Page 63

1 MR. BERG: We'll start out with the

outfitting question.

 First of all, any commercial activity

on a National Wildlife Refuge requires special

authorization or a Special Use Permit.

 So whether it's outfitting, cattle

grazing, commercial paleo activities, those kind

of things all require a permit.

 Regarding the hunting outfitting on the

refuge, in 1988 -- up until 1988, we did not

permit any outfitting on the refuge, but we knew

it was going on.

 So what we did is open it up to people

that could historically show some use on the

refuge. And at that time, in '88, we issued 36

permits to hunting outfitting. Today, we have

11.

 Probably two-thirds of those have

dropped out because of game type violations

where we've canceled permits for inappropriate

hunting activities. The other third have

probably just gotten out of the business for one

reason or another, so we're down to 11.

 Whether or not that's the right number,

lower or higher, we're kind of evaluating that

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Page 64

1 right now.

 Our sense is, like with the limited

archery permits, limited nonresident permits in

the state licenses, it seems to have stabilized

pretty good.

If people from out of state want to

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 Also, I think I noted that 90% of the

suitable bighorn sheep habitat on the south side

in Garfield County is on CMR. I'm sure that's a

hot potato, but have you addressed that in the

plan?

 You know, strictly as a sportsman

and a hunter, I would like to see it. If I

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Page 62

1 was a rancher up on the Bench, I probably

wouldn't. So, I don't know where Garfield

County ranchers or Commissioners stand with

that.

 And the other one is a Catch-22,

depending literally on which side of the fence

you are on. Bison is either livestock, or it's

wildlife. And I think the courts are going to

take that into consideration.

 But, if you are issuing livestock

permits, then I think you need to be aware

somebody's going to say, well, I'm going to

bring my livestock bison down here and try and

get a grazing permit out of it.

 I don't know what -- what's Glenda? Is

she BLM? Is she wildlife or livestock or what?

 MR. CRAWFORD: She has a livestock

permit.

 MR. BRYANT: And before I spend a lot

of money on a jet boat, I'd like to know if you

guys are going to restrict the river use or

not.

 So, thank you.

 MR. CRAWFORD: Those are your

questions.

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dropped 

where w

hunting 

probably 

reason o

 W

lower or 

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25

1 right no

 Ou

archery 

the state 

pretty go

 If 

come to 

ample o

that can 

 An

know, re

some pe

opportu

the hunt

in and d

 So

no plans 

but that 

evaluate

 W

asked if 

that ther

hunting 

opportu

it might 

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BIG SKY REPORTING - FRANCES L. MOCK

16 (Pages 61 to 64)

Page 61

1 for you guys.

 In your Draft Plan, you state that

currently there are 11 commercial hunting

operations on CMR.

 And I'd like to know if you have a plan

in place, or recommend that maybe you put a cap

on it?

 I don't know what that would be, and

that's not up to me to decide. But 40 seems

like it might be too much.

 You know, 11, if we're all happy now,

that's fine.

 Also, I wonder if you have any

projection for what ecotourism might be coming

down the pike?

 In the next few years, APF, your

neighbor to the north, so we know that that's

going ramp up in some fashion.

 Also, I think I noted that 90% of the

suitable bighorn sheep habitat on the south side

in Garfield County is on CMR. I'm sure that's a

hot potato, but have you addressed that in the

plan?

 You know, strictly as a sportsman

and a hunter, I would like to see it. If I

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1 was a rancher up on the Bench, I probably

wouldn't. So, I don't know where Garfield

County ranchers or Commissioners stand with

that.

 And the other one is a Catch-22,

depending literally on which side of the fence

you are on. Bison is either livestock, or it's

wildlife. And I think the courts are going to

take that into consideration.

 But, if you are issuing livestock

permits, then I think you need to be aware

somebody's going to say, well, I'm going to

bring my livestock bison down here and try and

get a grazing permit out of it.

 I don't know what -- what's Glenda? Is

she BLM? Is she wildlife or livestock or what?

 MR. CRAWFORD: She has a livestock

permit.

 MR. BRYANT: And before I spend a lot

of money on a jet boat, I'd like to know if you

guys are going to restrict the river use or

not.

 So, thank you.

 MR. CRAWFORD: Those are your

questions.

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1 MR. BERG: We'll start out with the

outfitting question.

 First of all, any commercial activity

on a National Wildlife Refuge requires special

authorization or a Special Use Permit.

 So whether it's outfitting, cattle

grazing, commercial paleo activities, those kind

of things all require a permit.

 Regarding the hunting outfitting on the

refuge, in 1988 -- up until 1988, we did not

permit any outfitting on the refuge, but we knew

it was going on.

 So what we did is open it up to people

that could historically show some use on the

refuge. And at that time, in '88, we issued 36

permits to hunting outfitting. Today, we have

11.

 Probably two-thirds of those have

dropped out because of game type violations

where we've canceled permits for inappropriate

hunting activities. The other third have

probably just gotten out of the business for one

reason or another, so we're down to 11.

 Whether or not that's the right number,

lower or higher, we're kind of evaluating that

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1 right now.

 Our sense is, like with the limited

archery permits, limited nonresident permits in

the state licenses, it seems to have stabilized

pretty good.

 If people from out of state want to

come to Montana and hunt the Breaks, there's

ample opportunity for them to find an outfitter

that can supply those services.

 And we kind of look at that as, you

know, reaching that whole audience. There are

some people who like to hunt that way, like the

opportunity to have somebody help them out with

the hunt, versus the individual who might come

in and do it on his own, so to speak.

 So, that's why we are at 11. We've got

no plans to increase that to 40 or set a cap,

but that will be something that's kind of

evaluated on a case-by-case basis.

 We've probably got 15 or 20 that have

asked if they could get a permit. If we sense

that there is a vacancy, for example, in a

hunting district where there's no outfitting

opportunities available for the general public,

it might be that we would go out and advertise

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352 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

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BIG SKY REPORTING - FRANCES L. MOCK

17 (Pages 65 to 68)

Page 65

1 to see who be interested in that. But, that's

kind of in the future a little bit.

 We haven't addressed the fishing

outfitting. We're working with the Corps of

Engineers on that issue.

 Right now, it appears that they will be

the administrating agency regarding fishing on

the reservoir, which is getting to be a bigger

thing.

 They have similar rules and regulations

regarding commercial activities on the lake, so

we hope to address that in the near future from

a commercial standpoint.

 The question about sheep. You are

correct that there is extensive sheep habitat in

Garfield County.

 We went through a pretty lengthy

process here a couple years ago to evaluate that

and determined that it was suitable as probably

some of the better sheep habitat that we have on

CMR.

 We worked with the state, and at the

same time, the state was developing a Bighorn

Sheep Conservation Plan for the whole state.

They plugged in some criteria that suggested

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Page 66

1 that we not -- or anybody, whether it's them or

us -- not reintroduce sheep within approximately

14 to 15 miles of a domestic sheep operator.

 The reason for that is disease transfer

problems with wild sheep getting in with ewes

and stuff like that.

 The area we're looking at in Garfield

County historically has some sheep permit

holders close to that area. We did kind of a

cursory review of the sentiment in Garfield

County. Both us and the State talked to several

landowners over the course of a year, and it's

probably not the right time to do that, just

based on the current attitudes about putting

sheep in the refuge.

 Not to say that it won't happen in the

future. Our hope is that they get there on

their own, but they haven't done that yet.

Occasionally we'll see sheep east or south of

the river, but they haven't taken hold in that

area, so we're kind of on hold a little bit

there with that proposal.

 The comment about bison being livestock

or wildlife. Glenda Reynolds, an active

permittee in Garfield County, currently has a

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Page 67

1 permit on the refuge to run bison as livestock.

She's the only one. But that's just considered

a class of livestock, no different than what BLM

does in similar situations.

 MR. CRAWFORD: Should he buy a jet

boat?

 MR. BERG: Oh, a jet boat, yeah.

 That's been an off-and-on topic for

years. I question that, too, whether or not I

should buy one, because there's a lot of great

opportunities on the river.

 You know, there was a time when --

again, when permits for archery elk hunting,

there was no cap on them; they were unlimited.

 We started seeing some conflicts with

jet boats on that river; elk leaving islands,

being pushed out of those river bottoms because

of the dust bowl level of some of the boats that

were being used.

 We considered it based on what we were

seeing upstream with some of the wildlife use in

the river bottoms there. What we fell back to

here a couple years ago, because it was kind of

a hot button topic issue, and again because the

permits got limited, and we're not seeing the

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Page 68

1 negative impacts we saw earlier, is we're going

to monitor the use that goes on.

 We're doing that with both like at boat

ramps and cameras on the river itself to kind of

get a handle on what's actually occurring out

there.

 Personally, it's increased

significantly in the last 15 years, you know. I

have been the CMR for 20 years, and the first

couple of years I worked law enforcement on that

river, you'd maybe see three or four boats on

opening weekend. Now you're talking 30 to 40

boats on that same stretch of river.

 So, you know, it's an access tool for

hunters to get into those river bottoms.

Whether or not it's too much or not an issue,

that's something we will evaluate in the

future.

 MS. MATHER: Okay. Let me tell you the

next steps.

 We are taking this road show on this

road, or this show on the road. We go to

Bozeman tomorrow and then Great Falls on

Thursday, and then we come back two weeks from

now to hit Lewistown, Jordan, Glasgow and Malta.

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Page 65

that's

g

orps of

will be

shing on

bigger

ulations

e lake, so

ure from

are

abitat in

y

aluate that

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we have on

t the

 Bighorn

e state.

ggested

Page 66

 them or

roximately

erator.

nsfer

with ewes

Page 67

1 permit on the refuge to run bison as livestock.

She's the only one. But that's just considered

a class of livestock, no different than what BLM

does in similar situations.

 MR. CRAWFORD: Should he buy a jet

boat?

 MR. BERG: Oh, a jet boat, yeah.

 That's been an off-and-on topic for

years. I question that, too, whether or not I

should buy one, because there's a lot of great

opportunities on the river.

 You know, there was a time when --

again, when permits for archery elk hunting,

there was no cap on them; they were unlimited.

 We started seeing some conflicts with

jet boats on that river; elk leaving islands,

being pushed out of those river bottoms because

of the dust bowl level of some of the boats that

were being used.

 We considered it based on what we were

seeing upstream with some of the wildlife use in

the river bottoms there. What we fell back to

here a couple years ago, because it was kind of

a hot button topic issue, and again because the

permits got limited, and we're not seeing the

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Page 68

1 negative impacts we saw earlier, is we're going

to monitor the use that goes on.

 We're doing that with both like at boat

ramps and cameras on the river itself to kind of

get a handle on what's actually occurring out

there

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(406)248-4064 Fax:(406)256-5525 E-Mail:f

BIG SKY REPORTING - FRANCES L

and determined that it was suitable as probably

some of the better sheep habitat that we have on

CMR.

 We worked with the state, and at the

same time, the state was developing a Bighorn

Sheep Conservation Plan for the whole state.

They plugged in some criteria that suggested

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Page 66

1 that we not -- or anybody, whether it's them or

us -- not reintroduce sheep within approximately

14 to 15 miles of a domestic sheep operator.

 The reason for that is disease transfer

problems with wild sheep getting in with ewes

and stuff like that.

 The area we're looking at in Garfield

County historically has some sheep permit

holders close to that area. We did kind of a

cursory review of the sentiment in Garfield

County. Both us and the State talked to several

landowners over the course of a year, and it's

probably not the right time to do that, just

based on the current attitudes about putting

sheep in the refuge.

 Not to say that it won't happen in the

future. Our hope is that they get there on

their own, but they haven't done that yet.

Occasionally we'll see sheep east or south of

the river, but they haven't taken hold in that

area, so we're kind of on hold a little bit

there with that proposal.

 The comment about bison being livestock

or wildlife. Glenda Reynolds, an active

permittee in Garfield County, currently has a

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were being u

 We con

seeing upstre

the river bott

here a couple 

a hot button 

permits got l

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25

1 negative imp

to monitor th

 We're d

ramps and ca

get a handle 

there.

 Person

significantly 

have been th

couple of ye

river, you'd m

opening wee

boats on that 

 So, you 

hunters to ge

Whether or n

that's someth

future.

 MS. M

next steps.

 We are 

road, or this 

Bozeman tom

Thursday, an

now to hit L

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

17 (Pages 65 to 68)

Page 65

1 to see who be interested in that. But, that's

kind of in the future a little bit.

 We haven't addressed the fishing

outfitting. We're working with the Corps of

Engineers on that issue.

 Right now, it appears that they will be

the administrating agency regarding fishing on

the reservoir, which is getting to be a bigger

thing.

 They have similar rules and regulations

regarding commercial activities on the lake, so

we hope to address that in the near future from

a commercial standpoint.

 The question about sheep. You are

correct that there is extensive sheep habitat in

Garfield County.

 We went through a pretty lengthy

process here a couple years ago to evaluate that

and determined that it was suitable as probably

some of the better sheep habitat that we have on

CMR.

 We worked with the state, and at the

same time, the state was developing a Bighorn

Sheep Conservation Plan for the whole state.

They plugged in some criteria that suggested

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Page 66

1 that we not -- or anybody, whether it's them or

us -- not reintroduce sheep within approximately

14 to 15 miles of a domestic sheep operator.

 The reason for that is disease transfer

problems with wild sheep getting in with ewes

and stuff like that.

 The area we're looking at in Garfield

County historically has some sheep permit

holders close to that area. We did kind of a

cursory review of the sentiment in Garfield

County. Both us and the State talked to several

landowners over the course of a year, and it's

probably not the right time to do that, just

based on the current attitudes about putting

sheep in the refuge.

 Not to say that it won't happen in the

future. Our hope is that they get there on

their own, but they haven't done that yet.

Occasionally we'll see sheep east or south of

the river, but they haven't taken hold in that

area, so we're kind of on hold a little bit

there with that proposal.

 The comment about bison being livestock

or wildlife. Glenda Reynolds, an active

permittee in Garfield County, currently has a

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Page 67

1 permit on the refuge to run bison as livestock.

She's the only one. But that's just considered

a class of livestock, no different than what BLM

does in similar situations.

 MR. CRAWFORD: Should he buy a jet

boat?

 MR. BERG: Oh, a jet boat, yeah.

 That's been an off-and-on topic for

years. I question that, too, whether or not I

should buy one, because there's a lot of great

opportunities on the river.

 You know, there was a time when --

again, when permits for archery elk hunting,

there was no cap on them; they were unlimited.

 We started seeing some conflicts with

jet boats on that river; elk leaving islands,

being pushed out of those river bottoms because

of the dust bowl level of some of the boats that

were being used.

 We considered it based on what we were

seeing upstream with some of the wildlife use in

the river bottoms there. What we fell back to

here a couple years ago, because it was kind of

a hot button topic issue, and again because the

permits got limited, and we're not seeing the

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Page 68

1 negative impacts we saw earlier, is we're going

to monitor the use that goes on.

 We're doing that with both like at boat

ramps and cameras on the river itself to kind of

get a handle on what's actually occurring out

there.

 Personally, it's increased

significantly in the last 15 years, you know. I

have been the CMR for 20 years, and the first

couple of years I worked law enforcement on that

river, you'd maybe see three or four boats on

opening weekend. Now you're talking 30 to 40

boats on that same stretch of river.

 So, you know, it's an access tool for

hunters to get into those river bottoms.

Whether or not it's too much or not an issue,

that's something we will evaluate in the

future.

 MS. MATHER: Okay. Let me tell you the

next steps.

 We are taking this road show on this

road, or this show on the road. We go to

Bozeman tomorrow and then Great Falls on

Thursday, and then we come back two weeks from

now to hit Lewistown, Jordan, Glasgow and Malta.

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VOLUME 2, Chapter 4—Public Hearing Testimony 353

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

18 (Pages 69 to 70)

Page 69

1 And then we will be receiving comments,

as we mentioned, until November 16th. So, you

have plenty of time to review the document and

submit comments. Again, we encourage you to do

so.

 And then the winter will really be

spent with Laurie and her team compiling the

comments, responding to them, and then making

needed revisions to the plan.

 Anything else?

 (No response.)

 MS. MATHER: Thank you all very much

for coming, and thanks for the great comments.

 (Whereupon, the hearing was concluded

at 8:25 p.m.)

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Page 70

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Refuges

HEARING DATE: September 28, 2010

LOCATION: Billings, Montana

 I hereby certify that the proceedings

and evidence herein are contained fully and

accurately on the stenographic notes reported by

me at the hearing in the above matter before the

U.S. Fish & Wildlife Service, and that this is a

true and correct transcript of the same.

 DATE: October 5, 2010

 Frances L. Mock

 Big Sky Reporting

 2308 Interlachen Circle

 Billings, Montana 59105

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Page 69

ng comments,

r 16th. So, you

 document and

courage you to do

ally be

ompiling the

nd then making

u all very much

eat comments.

as concluded

Page 70

ATE

Refuges

010

dings

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BIG SKY REPORTING - FRANCE

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Page 70

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Refuges

HEARING DATE: September 28, 2010

LOCATION: Billings, Montana

 I hereby certify that the proceedings

and evidence herein are contained fully and

accurately on the stenographic notes reported by

me at the hearing in the above matter before the

U.S. Fish & Wildlife Service, and that this is a

true and correct transcript of the same.

 DATE: October 5, 2010

 Frances L. Mock

 Big Sky Reporting

 2308 Interlachen Circle

 Billings, Montana 59105

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BIG SKY REPORTING - FRANCES L. MOCK

18 (Pages 69 to 70)

Page 69

1 And then we will be receiving comments,

as we mentioned, until November 16th. So, you

have plenty of time to review the document and

submit comments. Again, we encourage you to do

so.

 And then the winter will really be

spent with Laurie and her team compiling the

comments, responding to them, and then making

needed revisions to the plan.

 Anything else?

 (No response.)

 MS. MATHER: Thank you all very much

for coming, and thanks for the great comments.

 (Whereupon, the hearing was concluded

at 8:25 p.m.)

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Page 70

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Refuges

HEARING DATE: September 28, 2010

LOCATION: Billings, Montana

 I hereby certify that the proceedings

and evidence herein are contained fully and

accurately on the stenographic notes reported by

me at the hearing in the above matter before the

U.S. Fish & Wildlife Service, and that this is a

true and correct transcript of the same.

 DATE: October 5, 2010

 Frances L. Mock

 Big Sky Reporting

 2308 Interlachen Circle

 Billings, Montana 59105

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354 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

 DRAFT COMPREHENSIVE CONSERVATION PLAN

 AND ENVIRONMENTAL IMPACT STATEMENT

 FOR THE CHARLES M. RUSSELL NATIONAL WILDLIFE REFUGE

 AND UL BEND NATIONAL WILDLIFE REFUGE

 TRANSCRIPT OF THE PUBLIC HEARING

 Held at the Holiday Inn

 5 East Baxter Lane

 Bozeman, Montana

 September 29, 2010

 5:42 p.m.

REPORTED BY: CHERYL ROMSA

 CHERYL ROMSA COURT REPORTING

 P. O. BOX 1278

 HELENA, MONTANA 59624

 (406) 449-6380

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

CHERYL ROMSA COURT REPORTING (406) 449-6380

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

CHERYL ROMSA COURT REPORTING (406) 449-6380

 I N D E X

 PAGE

Overview of alternatives by Barron Crawford........ 3

Public Comment/Questions:

 1. Roger Jenkins............................. 14

 2. Kerry White............................... 15

 3. Catherine Nelson.......................... 18

 4. Teri Ball................................. 18

 5. Janelle Holden............................ 19

 6. Larry Barnard............................. 20

 7. Mark Good................................. 21

 8. Ben Erickson.............................. 24

 9. Steven Hunts.............................. 26

 10. Glenn Hockett............................. 28

 11. Robert Bayley............................. 30

 12. Dave Stevens.............................. 32

 13. George Baldwin............................ 34

 14. Rod Jude.................................. 35

 15. Dawn Montanye............................. 36

 16. Lesley Robinson........................... 37

 17. Peter Aengst.............................. 38

 18. Kit Fischer............................... 40

 19. Nicki Stevens............................. 42

 20. Keith Aune................................ 43

 21. Paul Griffin.............................. 45

 22. Chip Gibbs................................ 47

Responses to questions by Barron Crawford and

Bill Berg.......................................... 47

 2

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 3

1 WHEREUPON, the following proceedings were had:

 (Mimi Mather opened the meeting and made

introductions.)

 MR. CRAWFORD: I'm just going to give you a brief

overview of the CCP process, how we've gotten to where

we're at today, hit the highlights of the alternatives,

and then we'll open it up to comments.

 So we started this back in January of 2007. We've

done 14 of these meetings. We've received about 24,000

comments during our public scoping, a couple hundred when

we went out and talked about the alternatives. We've had

numerous meetings with our cooperators. And we've taken

all that information and kind of thrown it together into

this draft CCP/EIS that has been turned out to the public.

 This is kind of the timeline that we've been through,

and we're right here (indicating), with the draft going

out onto the street. After the comment period, basically,

the staff will be sitting down and wading through all the

comments and addressing those comments for about the next,

oh, year and a half or so and then hopefully release the

final in the fall of 2012 --

 MS. SHANNON: No.

 MR. CRAWFORD: Oh, summer of 2012 -- spring,

summer, fall.

 MS. SHANNON: Winter of 2012, we'll have the

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1 final.

 MR. CRAWFORD: So why did we do a CCP?

Basically, the 1997 Refuge Improvement Act, that was one

of the provisions in the Act, that all refuges will have a

comprehensive conservation plan by 2012. And so that's

what we're shooting for, is to get the CMR and the UL Bend

plan finished by that time frame

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1 here (indicating) about step 5, with the draft document.

You know, after public scoping -- or after public

comments, there's a chance that we could go back to this

stage (indicating) and then go back through. Hopefully,

we've got some good alternatives out there that's covering

the full range of stuff that we've heard during our other

meetings and we've captured all that, and so we've got,

you know, four really good alternatives that cover all

that.

 So I'll give you a brief rundown on each of the

alternatives. We have Alternative A, which is basically

the no-action alternative. It's where we keep operating

like we're currently operating under the 1986 EIS. So

we'll have just a few changes. We'll continue to manage

the habitat on the Refuge within those 65 habitat units

that we currently have. We'll still gradually implement

prescriptive gazing like we've been doing. We're

currently prescriptively grazing about 35 percent of the

Refuge. We're doing that as ranchers sell that have

grazing permits on the refuge; if they sell to an outside

party, a non-family member, we hold those permits and

enroll those units into prescriptive grazing. We'll keep

managing big game under the population objectives that we

identified in the '86 EIS, 2.5 elk per square mile and

10 mule deer per square mile. We'll keep the 670 miles of

2

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Page 6

1 roads and we'll continue to protect the 155,000 acres of

proposed wilderness.

 Alternative B, we're calling this the wildlife

emphasis alternative. And this is where we're working in

partnership with our cooperators and partners to basically

provide this diversity of wildlife across the Refuge.

This is kind of like the wildlife species emphasiswhere

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (406

Page 3

1 WHEREUPON, the following proceedings were had:

 (Mimi Mather opened the meeting and made

introductions.)

 MR. CRAWFORD: I'm just going to give you a brief

overview of the CCP process, how we've gotten to where

we're at today, hit the highlights of the alternatives,

and then we'll open it up to comments.

 So we started this back in January of 2007. We've

done 14 of these meetings. We've received about 24,000

comments during our public scoping, a couple hundred when

we went out and talked about the alternatives. We've had

numerous meetings with our cooperators. And we've taken

all that information and kind of thrown it together into

this draft CCP/EIS that has been turned out to the public.

 This is kind of the timeline that we've been through,

and we're right here (indicating), with the draft going

out onto the street. After the comment period, basically,

the staff will be sitting down and wading through all the

comments and addressing those comments for about the next,

oh, year and a half or so and then hopefully release the

final in the fall of 2012 --

 MS. SHANNON: No.

 MR. CRAWFORD: Oh, summer of 2012 -- spring,

summer, fall.

 MS. SHANNON: Winter of 2012, we'll have the

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Page 4

1 final.

 MR. CRAWFORD: So why did we do a CCP?

Basically, the 1997 Refuge Improvement Act, that was one

of the provisions in the Act, that all refuges will have a

comprehensive conservation plan by 2012. And so that's

what we're shooting for, is to get the CMR and the UL Bend

plan finished by that time frame.

 But it also provides a management direction and

guidance that's based upon the refuge purposes and the

mission of the National Wildlife Refuge System. It

outlines the vision statement, goals, objectives, and

strategies for achieving those. It's accompanied by some

type of a NEPA document, either an environmental

assessment or an environmental impact statement. For CMR,

we did an environmental impact statement, just because of

the complexity of issues that we're dealing with. And

then it provides that long-term guidance, so basically as

managers come and go, there's basically a plan in place

that has already been through this public process that the

new manager can just pick up and continue to implement

instead of coming in and having their ideas as to how they

think the Refuge should be run. So it provides some of

that management consistency over that time period.

 So, again, this is just another chart showing how the

CCP process works. And, again, you know, we're right down

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1 here (indicating

You know, afte

comments, ther

stage (indicatin

we've got some 

the full range o

meetings and w

you know, four 

that.

 So I'll give y

alternatives. W

the no-action a

like we're curre

we'll have just 

the habitat on t

that we current

prescriptive gaz

currently presc

Refuge. We're 

grazing permits 

party, a non-fam

enroll those uni

managing big g

identified in the 

10 mule deer p

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1 roads and we'll 

proposed wilde

 Alternative B

emphasis altern

partnership with 

provide this div

This is kind of 

we'll be focusin

populations, ma

economic uses 

either those wil

support them.

 We've got th

various alternat

Alternative B, t

where we're exp

to possibly clos

of the Refuge.

 So kind of th

going to do a lo

that are out ther

food and cover

50 to 75 percen

years; get an ag

on the river bot

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VOLUME 2, Chapter 4—Public Hearing Testimony 355

EARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

SA COURT REPORTING (406) 449-6380

3 (Pages 3 to 6)

Page 3

oceedings were had:

ing and made

g to give you a brief

ve gotten to where

alternatives,

 2007. We've

ived about 24,000

 couple hundred when

atives. We've had

rs. And we've taken

 it together into

 out to the public.

e been through,

he draft going

period, basically,

ng through all the

ents for about the next,

fully release the

 of 2012 -- spring,

2, we'll have the

Page 4

we do a CCP?

nt Act, that was one

uges will have a

012. And so that's

MR and the UL Bend

irection and

urposes and the

e System. It

ectives, and

mpanied by some

vironmental

 statement. For CMR,

ent, just because of

ing with. And

e, so basically as

y a plan in place

c process that the

inue to implement

deas as to how they

rovides some of

 time period.

howing how the

now, we're right down

Page 5

1 here (indicating) about step 5, with the draft document.

You know, after public scoping -- or after public

comments, there's a chance that we could go back to this

stage (indicating) and then go back through. Hopefully,

we've got some good alternatives out there that's covering

the full range of stuff that we've heard during our other

meetings and we've captured all that, and so we've got,

you know, four really good alternatives that cover all

that.

 So I'll give you a brief rundown on each of the

alternatives. We have Alternative A, which is basically

the no-action alternative. It's where we keep operating

like we're currently operating under the 1986 EIS. So

we'll have just a few changes. We'll continue to manage

the habitat on the Refuge within those 65 habitat units

that we currently have. We'll still gradually implement

prescriptive gazing like we've been doing. We're

currently prescriptively grazing about 35 percent of the

Refuge. We're doing that as ranchers sell that have

grazing permits on the refuge; if they sell to an outside

party, a non-family member, we hold those permits and

enroll those units into prescriptive grazing. We'll keep

managing big game under the population objectives that we

identified in the '86 EIS, 2.5 elk per square mile and

10 mule deer per square mile. We'll keep the 670 miles of

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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Page 6

1 roads and we'll continue to protect the 155,000 acres of

proposed wilderness.

 Alternative B, we're calling this the wildlife

emphasis alternative. And this is where we're working in

partnership with our cooperators and partners to basically

provide this diversity of wildlife across the Refuge.

This is kind of like the wildlife species emphasis, where

we'll be focusing on big game, non-game, maximizing those

populations, maximizing diversity, and then we would limit

economic uses if they're having a negative impact on

either those wildlife populations or those habitats that

support them.

 We've got these maps scattered around the room of the

various alternatives. So this (indicating) is

Alternative B, the western part of the Refuge. We show

where we're expanding wilderness areas and proposed roads

to possibly close. This (indicating) is the eastern half

of the Refuge.

 So kind of the main themes of Alternative B are, we're

going to do a lot of active management of the habitats

that are out there to really produce that optimum wildlife

food and cover. Again, implement prescriptive grazing on

50 to 75 percent of the Refuge over the next four to seven

years; get an aggressive habitat restoration program going

on the river bottoms; work with Fish, Wildlife & Parks to

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CHERYL ROMSA COURT REPORTING (406) 449-6380

3 (Pages 3 to 6)

comments and addressing those comments for about the next,

oh, year and a half or so and then hopefully release the

final in the fall of 2012 --

 MS. SHANNON: No.

 MR. CRAWFORD: Oh, summer of 2012 -- spring,

summer, fall.

 MS. SHANNON: Winter of 2012, we'll have the

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25

Page 4

1 final.

 MR. CRAWFORD: So why did we do a CCP?

Basically, the 1997 Refuge Improvement Act, that was one

of the provisions in the Act, that all refuges will have a

comprehensive conservation plan by 2012. And so that's

what we're shooting for, is to get the CMR and the UL Bend

plan finished by that time frame.

 But it also provides a management direction and

guidance that's based upon the refuge purposes and the

mission of the National Wildlife Refuge System. It

outlines the vision statement, goals, objectives, and

strategies for achieving those. It's accompanied by some

type of a NEPA document, either an environmental

assessment or an environmental impact statement. For CMR,

we did an environmental impact statement, just because of

the complexity of issues that we're dealing with. And

then it provides that long-term guidance, so basically as

managers come and go, there's basically a plan in place

that has already been through this public process that the

new manager can just pick up and continue to implement

instead of coming in and having their ideas as to how they

think the Refuge should be run. So it provides some of

that management consistency over that time period.

 So, again, this is just another chart showing how the

CCP process works. And, again, you know, we're right down

2

3

4

5

6

7

8

9

10

11

12

13

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Refuge. We're doing that as ranchers sell that have

grazing permits on the refuge; if they sell to an outside

party, a non-family member, we hold those permits and

enroll those units into prescriptive grazing. We'll keep

managing big game under the population objectives that we

identified in the '86 EIS, 2.5 elk per square mile and

10 mule deer per square mile. We'll keep the 670 miles of

19

20

21

22

23

24

25

Page 6

1 roads and we'll continue to protect the 155,000 acres of

proposed wilderness.

 Alternative B, we're calling this the wildlife

emphasis alternative. And this is where we're working in

partnership with our cooperators and partners to basically

provide this diversity of wildlife across the Refuge.

This is kind of like the wildlife species emphasis, where

we'll be focusing on big game, non-game, maximizing those

populations, maximizing diversity, and then we would limit

economic uses if they're having a negative impact on

either those wildlife populations or those habitats that

support them.

 We've got these maps scattered around the room of the

various alternatives. So this (indicating) is

Alternative B, the western part of the Refuge. We show

where we're expanding wilderness areas and proposed roads

to possibly close. This (indicating) is the eastern half

of the Refuge.

 So kind of the main themes of Alternative B are, we're

going to do a lot of active management of the habitats

that are out there to really produce that optimum wildlife

food and cover. Again, implement prescriptive grazing on

50 to 75 percent of the Refuge over the next four to seven

years; get an aggressive habitat restoration program going

on the river bottoms; work with Fish, Wildlife & Parks to

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 7

1 provide a quality hunting program; sustain populations of

big game and habitat for non-game; close about 106 miles

of roads; and expand acreage in the proposed wilderness

areas by 25,000 acres.

 Then we move on to Alternative C, and this is the one

we kind of titled the public use and economic use

alternative. This is basically where, again, we're

managing the landscape in cooperation with our partners

and cooperators to promote maximum compatible wildlife

dependent uses. And wildlife dependent uses are hunting,

fishing, wildlife observation and wildlife photography,

environmental education and interpretation. And those

come straight out of the Improvement Act. We're still

going to still protect wildlife populations and habitats

to the extent possible. We're going to minimize damage

impacts to wildlife habitats by using a variety of

management tools to enhance diversity and to promote

public and economic opportunities.

 And, again, this is the map. You won't see any

expansion of wilderness and you won't see any proposed

roads to close under -- Well, excuse me. There are a

couple wilderness areas that will be closed. There is no

expansion of proposed wilderness areas.

 So kind of the main points of this alternative:

Again, provide opportunities to maximize those

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Page 8

1 recreational opportunities; maintain balance numbers of

big game and livestock on the Refuge; expand and maximize

hunting opportunities; improve access to the boat ramps;

and eliminate four of the proposed wilderness areas which

total about 35,000 acres.

 Then we move to Alternative D, and this is our

proposed action alternativeThis is what we're calling

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Page 9

1 will be limited when they're injurious to ecological

processes; apply those management practices that mimic and

restore that natural fire/grazing interaction that

occurred for thousands of years in the short-grass

prairie; using fire and wildland herbivory, elk and deer,

or prescriptive livestock grazing on 50 to 75 percent of

the Refuge, similar to Alternative B; again, maintain

health and diversity of all species; do some road closures

on about 23 miles of roads; and then the proposed

wilderness will expand six of those units for 18,000 acres

and eliminate three which totals 26,000.

 Some of the hot-button topics that have been a

recurring theme throughout this process is the

prescriptive grazing. We've gotten a lot of questions:

What is prescriptive grazing? And, basically, it's using

grazing as a management tool. So you're going into a unit

and you're saying that grazing naturally occurred in this

unit, and this is the benefits that you get from a habitat

standpoint for these species.

 A good example of that is mountain plovers. Mountain

plovers like to nest in prairie dog towns, and prairie

dogs like to occupy areas that have very short grass. And

so if we identified an area where we wanted to expand

mountain plover populations, we would write a management

plan that basically used fire and grazing that would allow

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Page 10

1 prairie dogs to hopefully expand into new areas, which

would then open up more habitat for mountain plovers. So

that's an example of how prescriptive grazing will be

used. It's basically used as a management tool to meet

very specific wildlife and/or habitat objectives.

 Prescriptive fire, the same thing, how will it be

used? We've been working with fire ecologists from around

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6

7

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING 

Page 7

1 provide a quality hunting program; sustain populations of

big game and habitat for non-game; close about 106 miles

of roads; and expand acreage in the proposed wilderness

areas by 25,000 acres.

 Then we move on to Alternative C, and this is the one

we kind of titled the public use and economic use

alternative. This is basically where, again, we're

managing the landscape in cooperation with our partners

and cooperators to promote maximum compatible wildlife

dependent uses. And wildlife dependent uses are hunting,

fishing, wildlife observation and wildlife photography,

environmental education and interpretation. And those

come straight out of the Improvement Act. We're still

going to still protect wildlife populations and habitats

to the extent possible. We're going to minimize damage

impacts to wildlife habitats by using a variety of

management tools to enhance diversity and to promote

public and economic opportunities.

 And, again, this is the map. You won't see any

expansion of wilderness and you won't see any proposed

roads to close under -- Well, excuse me. There are a

couple wilderness areas that will be closed. There is no

expansion of proposed wilderness areas.

 So kind of the main points of this alternative:

Again, provide opportunities to maximize those

2

3

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5

6

7

8

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10

11

12

13

14

15

16

17

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Page 8

1 recreational opportunities; maintain balance numbers of

big game and livestock on the Refuge; expand and maximize

hunting opportunities; improve access to the boat ramps;

and eliminate four of the proposed wilderness areas which

total about 35,000 acres.

 Then we move to Alternative D, and this is our

proposed action alternative. This is what we're calling

the natural process or the ecological processes

alternative. This is where we're going to, again, in

cooperation with our partners, kind of use natural dynamic

ecological processes. And when we say "ecological

processes," what we're referring to is fire, grazing,

flooding. Those are kind of the three things that shape

the habitats out there on the Refuge. We're also going to

do some active management to restore some of the degraded

habitats on the Refuge until we get them to the point

where we can let the natural processes take over. We're

going to promote, restore, and maintain biological

diversity, integrity, and environmental health. And then

once those processes are restored, then we're going to go

to more of a passive management approach. In this

alternative, we propose to close a few roads, propose to

eliminate a couple of wilderness areas, propose to expand

some others.

 The main points of this alternative are, economic uses

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1 will be lim

processes

restore th

occurred 

prairie; u

or prescri

the Refug

health and 

on about 

wildernes

and elimi

 Some o

recurring 

prescripti

What is p

grazing a

and you'r

unit, and 

standpoin

 A good 

plovers li

dogs like 

so if we i

mountain 

plan that 

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1 prairie do

would the

that's an e

used. It's 

very spec

 Prescri

used? W

the count

the Refug

informati

fire return 

grazing in

fire adapt

expand an

of differe

 As part 

all of our 

still meet

were set a

review of 

up with o

as to whic

recomme

 The sam

at the alte

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356 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

4 (Pages 7 to 10)

Page 7

 populations of

about 106 miles

ed wilderness

this is the one

mic use

 we're

h our partners

patible wildlife

ses are hunting,

hotography,

. And those

 We're still

nd habitats

mize damage

ety of

d to promote

ee any

 any proposed

here are a

 There is no

ative:

those

Page 8

numbers of

d and maximize

boat ramps;

s areas which

s our

re calling

s

ain, in

tural dynamic

logical

azing,

that shape

lso going to

of the degraded

he point

ver. We're

gical

. And then

 going to go

In this

propose to

se to expand

nomic uses

Page 9

1 will be limited when they're injurious to ecological

processes; apply those management practices that mimic and

restore that natural fire/grazing interaction that

occurred for thousands of years in the short-grass

prairie; using fire and wildland herbivory, elk and deer,

or prescriptive livestock grazing on 50 to 75 percent of

the Refuge, similar to Alternative B; again, maintain

health and diversity of all species; do some road closures

on about 23 miles of roads; and then the proposed

wilderness will expand six of those units for 18,000 acres

and eliminate three which totals 26,000.

 Some of the hot-button topics that have been a

recurring theme throughout this process is the

prescriptive grazing. We've gotten a lot of questions:

What is prescriptive grazing? And, basically, it's using

grazing as a management tool. So you're going into a unit

and you're saying that grazing naturally occurred in this

unit, and this is the benefits that you get from a habitat

standpoint for these species.

 A good example of that is mountain plovers. Mountain

plovers like to nest in prairie dog towns, and prairie

dogs like to occupy areas that have very short grass. And

so if we identified an area where we wanted to expand

mountain plover populations, we would write a management

plan that basically used fire and grazing that would allow

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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25

Page 10

1 prairie dogs to hopefully expand into new areas, which

would then open up more habitat for mountain plovers. So

that's an example of how prescriptive grazing will be

used. It's basically used as a management tool to meet

very specific wildlife and/or habitat objectives.

 Prescriptive fire, the same thing, how will it be

used? We've been working with fire ecologists from around

the country and looking at the historic fire frequency on

the Refuge. And what we would like to do is use that GIS

information that's been developed to restore that natural

fire return interval onto the landscape, restore that

grazing interaction, and so that these plants that are

fire adapted have the opportunity to grow, reproduce, and

expand and provide those important foods for a whole bunch

of different wildlife species.

 As part of the CCP process, we're mandated to evaluate

all of our proposed wilderness areas and make sure they're

still meeting those wilderness characteristics which they

were set aside for. And so we've done a comprehensive

review of those wilderness areas, and that's how we came

up with our recommendations under the various alternatives

as to which ones would be expanded and/or which ones we'd

recommend for eliminating.

 The same thing with the closing of roads. We looked

at the alternatives and kind of what the theme of that

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CHERYL ROMSA COURT REPORTING (406) 449-6380

4 (Pages 7 to 10)

 And, again, this is the map. You wont see any

expansion of wilderness and you won't see any proposed

roads to close under -- Well, excuse me. There are a

couple wilderness areas that will be closed. There is no

expansion of proposed wilderness areas.

 So kind of the main points of this alternative:

Again, provide opportunities to maximize those

19

20

21

22

23

24

25

Page 8

1 recreational opportunities; maintain balance numbers of

big game and livestock on the Refuge; expand and maximize

hunting opportunities; improve access to the boat ramps;

and eliminate four of the proposed wilderness areas which

total about 35,000 acres.

 Then we move to Alternative D, and this is our

proposed action alternative. This is what we're calling

the natural process or the ecological processes

alternative. This is where we're going to, again, in

cooperation with our partners, kind of use natural dynamic

ecological processes. And when we say "ecological

processes," what we're referring to is fire, grazing,

flooding. Those are kind of the three things that shape

the habitats out there on the Refuge. We're also going to

do some active management to restore some of the degraded

habitats on the Refuge until we get them to the point

where we can let the natural processes take over. We're

going to promote, restore, and maintain biological

diversity, integrity, and environmental health. And then

once those processes are restored, then we're going to go

to more of a passive management approach. In this

alternative, we propose to close a few roads, propose to

eliminate a couple of wilderness areas, propose to expand

some others.

 The main points of this alternative are, economic uses

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

standpoint for these species.

 A good example of that is mountain plovers. Mountain

plovers like to nest in prairie dog towns, and prairie

dogs like to occupy areas that have very short grass. And

so if we identified an area where we wanted to expand

mountain plover populations, we would write a management

plan that basically used fire and grazing that would allow

19

20

21

22

23

24

25

Page 10

1 prairie dogs to hopefully expand into new areas, which

would then open up more habitat for mountain plovers. So

that's an example of how prescriptive grazing will be

used. It's basically used as a management tool to meet

very specific wildlife and/or habitat objectives.

 Prescriptive fire, the same thing, how will it be

used? We've been working with fire ecologists from around

the country and looking at the historic fire frequency on

the Refuge. And what we would like to do is use that GIS

information that's been developed to restore that natural

fire return interval onto the landscape, restore that

grazing interaction, and so that these plants that are

fire adapted have the opportunity to grow, reproduce, and

expand and provide those important foods for a whole bunch

of different wildlife species.

 As part of the CCP process, we're mandated to evaluate

all of our proposed wilderness areas and make sure they're

still meeting those wilderness characteristics which they

were set aside for. And so we've done a comprehensive

review of those wilderness areas, and that's how we came

up with our recommendations under the various alternatives

as to which ones would be expanded and/or which ones we'd

recommend for eliminating.

 The same thing with the closing of roads. We looked

at the alternatives and kind of what the theme of that

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 11

1 alternative was; and, if we were wanting to meet a

specific wildlife objective in there, we looked at the

road densities and evaluated whether we felt they were

having an impact on those wildlife and if we could achieve

some different population objectives by maybe closing a

road permanently or closing it seasonally, and so that's

what we did there.

 And then another topic that we've heard quite a bit

about is bison restoration. Anybody that's been following

the news in Montana, as you know, there's quite an

interest in bison, both from a restoring of wild

population in another part of the state and also the

concerns that go along with that. And what we've said all

along for our planning process is that we recognize the

interest in bison. Bison are a Montana trust wildlife

resource species, they're not a federal trust resource

species at this time. Federal trust species are those

that are classified as threatened or endangered migratory

birds or anadromous fish.

 A lot of folks have asked, well, what happens if bison

become classified as threatened or endangered; does that

then change what you're proposing in your management plan?

And my response is, not really. You know, we've got gray

wolves and grizzly bears right now that are listed, and we

don't have any proposals in the plan to reintroduce those

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Page 12

1 species to the Refuge either. So I really don't see that

changing the bison classification would really have an

impact on what we're proposing to do in the plan at this

time. What we said in the plan is that we support Montana

Fish, Wildlife & Parks in moving forward with development

of a bison conservation plan or a bison restoration plan,

and if they choose to look at areas around the Refuge

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Page 13

1 might have overlooked in this planning process that will

2 help make this a better plan. The comment period is

scheduled to end November 16th.

 And that's about all I've got, so we'll open the floor

to comments. I appreciate everybody coming out today.

 MS. MATHER: So like I said, I'll be calling

folks up. I've got the list, we'll go in order. I'll

also call who is on deck so you can be ready to come up.

 Just a few rules: We'd like you to keep to three

minutes. I'm going to be kind of a strict timekeeper. I

have some cards when you're down to one minute,

20 seconds, and then when time is up. And then I just

come over and nudge you. But this wasn't a problem last

night; most people kept to under three minutes. Please,

we're recording all the comments, so if you wouldn't mind

stating your name, and, if it's a tricky spelling,

spelling it for us, that would help our court reporter.

And then finally, just in order to keep things running

smoothly and respect one another's opinion, we're asking

that you refrain from cheering or applauding someone's

comments.

 So I'll go through the list. Again, if you'd like to

sign up, there's another list in the back with Mike. And

like Barron mentioned, on the back of this sheet

(indicating), there's opportunities where you can write

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Page 14

1 comment. And, again, on the table with Mike back there,

there's a comment folder where you can stick that in.

 So first up is Roger Jenkins, with Kerry White on

deck.

 MR. JENKINS: I've never hardly ever needed a

microphone before, but that's fine. And having worked

with court reportersI have a great deal of respect for

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (40

Page 11

1 alternative was; and, if we were wanting to meet a

specific wildlife objective in there, we looked at the

road densities and evaluated whether we felt they were

having an impact on those wildlife and if we could achieve

some different population objectives by maybe closing a

road permanently or closing it seasonally, and so that's

what we did there.

 And then another topic that we've heard quite a bit

about is bison restoration. Anybody that's been following

the news in Montana, as you know, there's quite an

interest in bison, both from a restoring of wild

population in another part of the state and also the

concerns that go along with that. And what we've said all

along for our planning process is that we recognize the

interest in bison. Bison are a Montana trust wildlife

resource species, they're not a federal trust resource

species at this time. Federal trust species are those

that are classified as threatened or endangered migratory

birds or anadromous fish.

 A lot of folks have asked, well, what happens if bison

become classified as threatened or endangered; does that

then change what you're proposing in your management plan?

And my response is, not really. You know, we've got gray

wolves and grizzly bears right now that are listed, and we

don't have any proposals in the plan to reintroduce those

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Page 12

1 species to the Refuge either. So I really don't see that

changing the bison classification would really have an

impact on what we're proposing to do in the plan at this

time. What we said in the plan is that we support Montana

Fish, Wildlife & Parks in moving forward with development

of a bison conservation plan or a bison restoration plan,

and if they choose to look at areas around the Refuge,

we'll support and work with them in any way that the

Refuge can contribute to that proposal.

 So, we're here to hear from you guys, to hear your

comments on our plan. We ask that you address items that

are specifically in the plan. We ask that you speak

clearly and stick to your allotted time frame so that we

have an opportunity to hear from everyone. We have

numerous ways of commenting. You can give your public

testimony today, you can write your comments on the form

that we're handing out in the back and drop them off as

you go, you can send us an e-mail, you can send us a

letter. All of those, you know, are ways you can comment.

 There is no one comment that's weighted more than

another; we treat all comments the same. And it's not a

voting contest. So we're not going to sit there and keep

score of how many people support expanding wilderness and

how many people support eliminating wilderness. What

we're looking for are those succinct comments that we

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1 might have ov

2 help make this 

scheduled to e

 And that's a

to comments. 

 MS. MA

folks up. I've 

also call who i

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smoothly and r

that you refrain 

comments.

 So I'll go thr

sign up, there's 

like Barron me

(indicating), th

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1 comment. And

there's a comm

 So first up is 

deck.

 MR. JEN

microphone be

with court repo

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elimination of 

guess that wou

in and of yours

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VOLUME 2, Chapter 4—Public Hearing Testimony 357

ARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

A COURT REPORTING (406) 449-6380

5 (Pages 11 to 14)

Page 11

g to meet a

ooked at the

e felt they were

f we could achieve

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f wild

nd also the

what we've said all

e recognize the

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our management plan?

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are listed, and we

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Page 12

y don't see that

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n the plan at this

we support Montana

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restoration plan,

nd the Refuge,

y way that the

, to hear your

u address items that

t you speak

ame so that we

one. We have

an give your public

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drop them off as

can send us a

s you can comment.

hted more than

e. And it's not a

t there and keep

anding wilderness and

wilderness. What

mments that we

Page 13

1 might have overlooked in this planning process that will

2 help make this a better plan. The comment period is

scheduled to end November 16th.

 And that's about all I've got, so we'll open the floor

to comments. I appreciate everybody coming out today.

 MS. MATHER: So like I said, I'll be calling

folks up. I've got the list, we'll go in order. I'll

also call who is on deck so you can be ready to come up.

 Just a few rules: We'd like you to keep to three

minutes. I'm going to be kind of a strict timekeeper. I

have some cards when you're down to one minute,

20 seconds, and then when time is up. And then I just

come over and nudge you. But this wasn't a problem last

night; most people kept to under three minutes. Please,

we're recording all the comments, so if you wouldn't mind

stating your name, and, if it's a tricky spelling,

spelling it for us, that would help our court reporter.

And then finally, just in order to keep things running

smoothly and respect one another's opinion, we're asking

that you refrain from cheering or applauding someone's

comments.

 So I'll go through the list. Again, if you'd like to

sign up, there's another list in the back with Mike. And

like Barron mentioned, on the back of this sheet

(indicating), there's opportunities where you can write

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1 comment. And, again, on the table with Mike back there,

there's a comment folder where you can stick that in.

 So first up is Roger Jenkins, with Kerry White on

deck.

 MR. JENKINS: I've never hardly ever needed a

microphone before, but that's fine. And having worked

with court reporters, I have a great deal of respect for

your efforts.

 My name is Roger Jenkins, and I guess I have -- I have

some questions and some requests for clarification.

 In Montana here, we're blessed with all kinds of

different sorts of lands. I mean, we have national forest

land, national park land. My understanding is that the

U.S. Fish and Wildlife Service manages our wildlife

refuges. So I guess I'd really like to hear from the

staff, what sort of is the overriding management

philosophy of a wildlife refuge compared to, say, a

national forest, for example? That's one question I have.

 Another request for clarification is that when you

talk about elimination of wilderness or we want these new

wilderness areas, my understanding is that you're talking

about how you want to manage that land. There's really no

elimination of congressionally designated wilderness; I

guess that would be the case, right? Because you cannot,

in and of yourself, take away wilderness, you know, or

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CHERYL ROMSA COURT REPORTING (406) 449-6380

5 (Pages 11 to 14)

birds or anadromous fish.

 A lot of folks have asked, well, what happens if bison

become classified as threatened or endangered; does that

then change what you're proposing in your management plan?

And my response is, not really. You know, we've got gray

wolves and grizzly bears right now that are listed, and we

don't have any proposals in the plan to reintroduce those

19

20

21

22

23

24

25

Page 12

1 species to the Refuge either. So I really don't see that

changing the bison classification would really have an

impact on what we're proposing to do in the plan at this

time. What we said in the plan is that we support Montana

Fish, Wildlife & Parks in moving forward with development

of a bison conservation plan or a bison restoration plan,

and if they choose to look at areas around the Refuge,

we'll support and work with them in any way that the

Refuge can contribute to that proposal.

 So, we're here to hear from you guys, to hear your

comments on our plan. We ask that you address items that

are specifically in the plan. We ask that you speak

clearly and stick to your allotted time frame so that we

have an opportunity to hear from everyone. We have

numerous ways of commenting. You can give your public

testimony today, you can write your comments on the form

that we're handing out in the back and drop them off as

you go, you can send us an e-mail, you can send us a

letter. All of those, you know, are ways you can comment.

 There is no one comment that's weighted more than

another; we treat all comments the same. And it's not a

voting contest. So we're not going to sit there and keep

score of how many people support expanding wilderness and

how many people support eliminating wilderness. What

we're looking for are those succinct comments that we

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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18

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smoothly and respect one another's opinion, we're asking

that you refrain from cheering or applauding someone's

comments.

 So I'll go through the list. Again, if you'd like to

sign up, there's another list in the back with Mike. And

like Barron mentioned, on the back of this sheet

(indicating), there's opportunities where you can write

19

20

21

22

23

24

25

Page 14

1 comment. And, again, on the table with Mike back there,

there's a comment folder where you can stick that in.

 So first up is Roger Jenkins, with Kerry White on

deck.

 MR. JENKINS: I've never hardly ever needed a

microphone before, but that's fine. And having worked

with court reporters, I have a great deal of respect for

your efforts.

 My name is Roger Jenkins, and I guess I have -- I have

some questions and some requests for clarification.

 In Montana here, we're blessed with all kinds of

different sorts of lands. I mean, we have national forest

land, national park land. My understanding is that the

U.S. Fish and Wildlife Service manages our wildlife

refuges. So I guess I'd really like to hear from the

staff, what sort of is the overriding management

philosophy of a wildlife refuge compared to, say, a

national forest, for example? That's one question I have.

 Another request for clarification is that when you

talk about elimination of wilderness or we want these new

wilderness areas, my understanding is that you're talking

about how you want to manage that land. There's really no

elimination of congressionally designated wilderness; I

guess that would be the case, right? Because you cannot,

in and of yourself, take away wilderness, you know, or

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 15

1 pass -- you cannot make wilderness itself. So I guess

that would be some worthwhile clarifications.

 I think that's about a minute and 20 seconds.

 MS. MATHER: Thanks, Roger.

 And I should mention that if you do have a question

and not a comment, come on up and let us know the

question. Barron, Bill, and Laurie are taking notes, and

after everybody is done commenting, they'll respond to the

questions.

 MR. WHITE: My name is Kerry White, 4000

Blackwood Road in Bozeman.

 Is it then to write down our questions and hand them

in or can I verbally ask and then you could answer those?

 MS. MATHER: Verbally ask.

 MR. WHITE: Okay. The first question is, will

you be complying with the President's Council on

Environmental Quality and actually doing some economic

analysis on the effect of the loss of the grazing that

will be within those new areas?

 And, also, it's my understanding that there's going to

be roads and water containment facilities, fencing, and

that type of human structures within those new wilderness

areas that are going to be required to be removed. I

know, being up in that area, that 95 percent of the

prairie dog towns are next to the water containment

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1 facilities, those reservoirs. And I want to make sure

that if you're going to remove those water reservoirs,

you're going to consolidate or put more of that wildlife

down on the river in a more concentrated area and take

them away from those watering facilities, and along

with -- you know, it's going to be destructive to the

prairie dog habitat.

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Page 17

1 addressed that. Gray wolf, grizzly bear, Rocky Mountain

bighorn sheep. I just want to remind you that if you're

going to remove water containment facilities, concentrate

that wildlife down on the river, introduce grizzly bear

and gray wolf to the area, you'll probably end up like in

the Paradise, where we went from a 19,000 elk herd down to

maybe 2500. No more elk hunting in the Gallatin because

of the wolf depredation.

 So if you're going to start putting these predators in

there, keep that in mind. You've got predator management

in that list, and understand that with it on the federal

engaged species list, if the grizzly were ever to go back

on there, you have a real hard time, with our judges and

court system and the environmental groups tying this up in

litigation, to be able to deal with that. And I just hate

to see that healthy elk herd, you know, disappear up

there.

 You've got several roads in there on Preferred

Alternative D. I list here about 12 or 13. 23 or

26 miles closed, but these are all these little spur roads

that take you, you know, in to the water that last half

mile. And for those that have bad hips and the elderly

and stuff that want to hunt, that's quite an effort for

them to go that extra half a mile. So keep that under

consideration.

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1 And my last point is, under what process are we under

this for the appeal? Is this a 219, 215; what process are

we under for appeal on this?

 Thank you.

 MS. MATHER: Catherine Nelson, with Teri Ball on

deck.

MS. NELSON: Catherine Nelson, here in Bozeman.

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING (

Page 15

1 pass -- you cannot make wilderness itself. So I guess

that would be some worthwhile clarifications.

 I think that's about a minute and 20 seconds.

 MS. MATHER: Thanks, Roger.

 And I should mention that if you do have a question

and not a comment, come on up and let us know the

question. Barron, Bill, and Laurie are taking notes, and

after everybody is done commenting, they'll respond to the

questions.

 MR. WHITE: My name is Kerry White, 4000

Blackwood Road in Bozeman.

 Is it then to write down our questions and hand them

in or can I verbally ask and then you could answer those?

 MS. MATHER: Verbally ask.

 MR. WHITE: Okay. The first question is, will

you be complying with the President's Council on

Environmental Quality and actually doing some economic

analysis on the effect of the loss of the grazing that

will be within those new areas?

 And, also, it's my understanding that there's going to

be roads and water containment facilities, fencing, and

that type of human structures within those new wilderness

areas that are going to be required to be removed. I

know, being up in that area, that 95 percent of the

prairie dog towns are next to the water containment

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Page 16

1 facilities, those reservoirs. And I want to make sure

that if you're going to remove those water reservoirs,

you're going to consolidate or put more of that wildlife

down on the river in a more concentrated area and take

them away from those watering facilities, and along

with -- you know, it's going to be destructive to the

prairie dog habitat.

 I noticed in here, I don't think you've done any study

on air quality for your prescribed burns. And, also, you

know, the Federal Government doesn't have a real good

history on prescribed burns getting out of control. So

you might want to put something in there to -- you know,

justification on those prescribed burns versus grazing.

 Roads in the new wilderness, will they be removed?

Will roads that are in the old wilderness that's going to

be removed from wilderness, will they be reestablished?

Will we be able to have multiple-use access in there as in

the motorized? Because that's a big area, and to walk

around out there is quite a task without having some type

of motorized transportation.

 I noticed here on page -- I think it's page 17:

Habitat and wildlife. The draft CCP and EIS addresses the

following habitat and wildlife issues. It states in here:

Species reintroductions and management of species that

could move into, onto the Refuge. American bison, you

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1 addressed 

bighorn sh

going to r

that wildli

and gray w

the Paradi

maybe 25

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26 miles c

that take y

mile. And 

and stuff t

them to go 

considera

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1 And m

this for th

we under 

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 MS

deck.

 MS

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 MS

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 MS

baseball. 

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358 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

6 (Pages 15 to 18)

Page 15

So I guess

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Page 16

ake sure

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17:

S addresses the

es in here:

 species that

an bison, you

Page 17

1 addressed that. Gray wolf, grizzly bear, Rocky Mountain

bighorn sheep. I just want to remind you that if you're

going to remove water containment facilities, concentrate

that wildlife down on the river, introduce grizzly bear

and gray wolf to the area, you'll probably end up like in

the Paradise, where we went from a 19,000 elk herd down to

maybe 2500. No more elk hunting in the Gallatin because

of the wolf depredation.

 So if you're going to start putting these predators in

there, keep that in mind. You've got predator management

in that list, and understand that with it on the federal

engaged species list, if the grizzly were ever to go back

on there, you have a real hard time, with our judges and

court system and the environmental groups tying this up in

litigation, to be able to deal with that. And I just hate

to see that healthy elk herd, you know, disappear up

there.

 You've got several roads in there on Preferred

Alternative D. I list here about 12 or 13. 23 or

26 miles closed, but these are all these little spur roads

that take you, you know, in to the water that last half

mile. And for those that have bad hips and the elderly

and stuff that want to hunt, that's quite an effort for

them to go that extra half a mile. So keep that under

consideration.

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Page 18

1 And my last point is, under what process are we under

this for the appeal? Is this a 219, 215; what process are

we under for appeal on this?

 Thank you.

 MS. MATHER: Catherine Nelson, with Teri Ball on

deck.

 MS. NELSON: Catherine Nelson, here in Bozeman.

 I would like to follow up on some initial questions

that Roger raised, and they have to do with the

fundamental purpose of a wildlife refuge. And my

understanding is that the mission of a wildlife refuge is

to manage and restore fish, wildlife, and plant resources

and their habitats. In order to do that, it would seem to

me that wilderness areas -- designated wilderness areas

would be prime and critical to any kind of wildlife

refuge. And my concern is, as I understand it, that I

believe several proposed wilderness areas are going to be

eliminated. And I would really like to hear more to

explain how that meets the goals of a wildlife refuge.

 So that, I think, is my fundamental question.

 Thank you.

 MS. MATHER: Thank you, Katherine.

 So Teri, and Janelle on deck.

 MS. BALL: Hi, my name is Teri Ball, like a

baseball. And some of my questions have already been

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CHERYL ROMSA COURT REPORTING (406) 449-6380

6 (Pages 15 to 18)

will be within those new areas?

 And, also, it's my understanding that there's going to

be roads and water containment facilities, fencing, and

that type of human structures within those new wilderness

areas that are going to be required to be removed. I

know, being up in that area, that 95 percent of the

prairie dog towns are next to the water containment

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Page 16

1 facilities, those reservoirs. And I want to make sure

that if you're going to remove those water reservoirs,

you're going to consolidate or put more of that wildlife

down on the river in a more concentrated area and take

them away from those watering facilities, and along

with -- you know, it's going to be destructive to the

prairie dog habitat.

 I noticed in here, I don't think you've done any study

on air quality for your prescribed burns. And, also, you

know, the Federal Government doesn't have a real good

history on prescribed burns getting out of control. So

you might want to put something in there to -- you know,

justification on those prescribed burns versus grazing.

 Roads in the new wilderness, will they be removed?

Will roads that are in the old wilderness that's going to

be removed from wilderness, will they be reestablished?

Will we be able to have multiple-use access in there as in

the motorized? Because that's a big area, and to walk

around out there is quite a task without having some type

of motorized transportation.

 I noticed here on page -- I think it's page 17:

Habitat and wildlife. The draft CCP and EIS addresses the

following habitat and wildlife issues. It states in here:

Species reintroductions and management of species that

could move into, onto the Refuge. American bison, you

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Alternative D. I list here about 12 or 13. 23 or

26 miles closed, but these are all these little spur roads

that take you, you know, in to the water that last half

mile. And for those that have bad hips and the elderly

and stuff that want to hunt, that's quite an effort for

them to go that extra half a mile. So keep that under

consideration.

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1 And my last point is, under what process are we under

this for the appeal? Is this a 219, 215; what process are

we under for appeal on this?

 Thank you.

 MS. MATHER: Catherine Nelson, with Teri Ball on

deck.

 MS. NELSON: Catherine Nelson, here in Bozeman.

 I would like to follow up on some initial questions

that Roger raised, and they have to do with the

fundamental purpose of a wildlife refuge. And my

understanding is that the mission of a wildlife refuge is

to manage and restore fish, wildlife, and plant resources

and their habitats. In order to do that, it would seem to

me that wilderness areas -- designated wilderness areas

would be prime and critical to any kind of wildlife

refuge. And my concern is, as I understand it, that I

believe several proposed wilderness areas are going to be

eliminated. And I would really like to hear more to

explain how that meets the goals of a wildlife refuge.

 So that, I think, is my fundamental question.

 Thank you.

 MS. MATHER: Thank you, Katherine.

 So Teri, and Janelle on deck.

 MS. BALL: Hi, my name is Teri Ball, like a

baseball. And some of my questions have already been

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 19

1 asked, but I'd just like to ask a few more.

 One is, I would like to voice my support for

prescriptive burning within the Refuge for the benefit of

sage grouse, sharp-tail grouse, mountain plovers, and

hooved animals. I'd like to ask that the final plan

reduce or at least not increase the number of roads in the

refuge areas. And I'd also like to ask that it increase

the wilderness areas and not reduce. I think the plan

says now we actually are going to reduce the amount of

wilderness area.

 And then one other one is, I like birds a lot. I

understand there are about 236 species of birds on the

Refuge, and I'm wondering how you're planning to meet

their needs, since there's such a diversity, which we

would like to keep. And are there any conflicts that

exist in the plan for the birds?

 Thank you.

 MS. MATHER: Thank you.

 So Janelle Holden, and Larry Barnard on deck.

 MS. HOLDEN: Hi, my name is Janelle Holden. I

work for the Wilderness Society here in Bozeman.

 As I said last night, we're fairly happy with the

proposed alternative, except for the fact that there is

this decrease in wilderness acreage, which we think we

should be going the opposite direction, especially in our

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1 prairie ecosystems.

 But tonight I had a couple questions, one in

particular, about roads. It seems like Alternative B and

Alternative D have a pretty significant difference,

106 miles of road versus 23 miles of road. And I was

wondering if you could address sort of what criteria you

used in terms of ecological processes versus wildlife

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1 are and what we're doing.

 Alternative B -- I'm not a person with specifics.

Alternative B addresses the need for wilderness and

conservation. And if we look at it from an economic

standpoint, which you people have to, it's a lot easier to

manage a wilderness area or minimum impact criteria, you

know, such as off-road vehicles and whatnot, than it is --

You know, let's just make it simple. Wilderness is easier

to manage compared to all these other complicated

situations. This land belongs to everybody in the United

States, not to the people that were born here, like

myself. There's been a big change through the years. The

people interested in the public lands out in northeastern

Montana, certainly the people in Valley County, have a big

stake in it, but times are changing and they need to be

part of the change.

 Thank you.

 MS. MATHER: Ben Erickson, and Steve Hunts on

deck.

 Did I skip Mark?

 MR. GOOD: You did, yes.

 MS. MATHER: Okay. Sorry, Mark.

 MR. GOOD: That's all right.

 My name is Mark Good. I work with the Montana

Wilderness Association.

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1 I have not read through the entire EIS, and so some of

this stuff is, I'm sure, spelled out in that, and I

apologize for -- So I'm going to ask this more in terms of

questions, I think, than comments. I had several.

 One is looking at the couple of areas that, or the

three areas that are being proposed -- wilderness areas

that you're proposing to eliminateThe Beauchamp areaI

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (406

Page 19

1 asked, but I'd just like to ask a few more.

 One is, I would like to voice my support for

prescriptive burning within the Refuge for the benefit of

sage grouse, sharp-tail grouse, mountain plovers, and

hooved animals. I'd like to ask that the final plan

reduce or at least not increase the number of roads in the

refuge areas. And I'd also like to ask that it increase

the wilderness areas and not reduce. I think the plan

says now we actually are going to reduce the amount of

wilderness area.

 And then one other one is, I like birds a lot. I

understand there are about 236 species of birds on the

Refuge, and I'm wondering how you're planning to meet

their needs, since there's such a diversity, which we

would like to keep. And are there any conflicts that

exist in the plan for the birds?

 Thank you.

 MS. MATHER: Thank you.

 So Janelle Holden, and Larry Barnard on deck.

 MS. HOLDEN: Hi, my name is Janelle Holden. I

work for the Wilderness Society here in Bozeman.

 As I said last night, we're fairly happy with the

proposed alternative, except for the fact that there is

this decrease in wilderness acreage, which we think we

should be going the opposite direction, especially in our

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1 prairie ecosystems.

 But tonight I had a couple questions, one in

particular, about roads. It seems like Alternative B and

Alternative D have a pretty significant difference,

106 miles of road versus 23 miles of road. And I was

wondering if you could address sort of what criteria you

used in terms of ecological processes versus wildlife

habitat to come up with those numbers or what were some of

the reasons why you decided to reduce roads in each of

those alternatives, so that we can get a better

understanding of what our range of alternatives are.

 Then the other question I have is about Alternative B,

in terms of manipulating habitats. I'd like to know a

little bit more about what kind of crops you would plant

in Alternative B and synthetic methods for increasing

wildlife habitat and what that might look like

specifically to the CMR Refuge.

 That's it. Thanks.

 MS. MATHER: Larry Barnard, with Mark Good on

deck.

 MR. BARNARD: My name is Larry Barnard. I've

lived in Montana for 60 years, and I hope to live here

another 60 years. I love this place, and I want to remind

everybody in the room that this is not Nevada, this is a

very unique place. Everybody in the world knows who we

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1 are and what w

 Alternative B 

Alternative B a

conservation. A

standpoint, whi

manage a wilde

know, such as 

You know, let'

to manage com

situations. Thi

States, not to th

myself. There'

people intereste

Montana, certa

stake in it, but 

part of the chan

 Thank you.

 MS. MAT

deck.

 Did I skip M

 MR. GOO

 MS. MAT

 MR. GOO

 My name is 

Wilderness As

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1 I have not re

this stuff is, I'm 

apologize for -

questions, I thi

 One is looki

three areas that 

that you're prop

understand it's 

two-track that r

probably not as 

wilderness area

or even the rug

of its wildlife v

some of those o

of the criteria o

in terms of size

seems to me th

again -- I ment

that criteria and 

Hill Creek one

think that migh

wilderness doe

lands also shou

as a proposed w

 Another issu

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VOLUME 2, Chapter 4—Public Hearing Testimony 359

ARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

A COURT REPORTING (406) 449-6380

7 (Pages 19 to 22)

Page 19

more.

upport for

ge for the benefit of

tain plovers, and

he final plan

mber of roads in the

k that it increase

I think the plan

duce the amount of

irds a lot. I

es of birds on the

're planning to meet

rsity, which we

ny conflicts that

nard on deck.

is Janelle Holden. I

e in Bozeman.

ppy with the

fact that there is

which we think we

on, especially in our

Page 20

 one in

lternative B and

difference,

ad. And I was

what criteria you

ersus wildlife

or what were some of

roads in each of

better

rnatives are.

ut Alternative B,

ke to know a

you would plant

for increasing

k like

with Mark Good on

arry Barnard. I've

pe to live here

 I want to remind

Nevada, this is a

orld knows who we

Page 21

1 are and what we're doing.

 Alternative B -- I'm not a person with specifics.

Alternative B addresses the need for wilderness and

conservation. And if we look at it from an economic

standpoint, which you people have to, it's a lot easier to

manage a wilderness area or minimum impact criteria, you

know, such as off-road vehicles and whatnot, than it is --

You know, let's just make it simple. Wilderness is easier

to manage compared to all these other complicated

situations. This land belongs to everybody in the United

States, not to the people that were born here, like

myself. There's been a big change through the years. The

people interested in the public lands out in northeastern

Montana, certainly the people in Valley County, have a big

stake in it, but times are changing and they need to be

part of the change.

 Thank you.

 MS. MATHER: Ben Erickson, and Steve Hunts on

deck.

 Did I skip Mark?

 MR. GOOD: You did, yes.

 MS. MATHER: Okay. Sorry, Mark.

 MR. GOOD: That's all right.

 My name is Mark Good. I work with the Montana

Wilderness Association.

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1 I have not read through the entire EIS, and so some of

this stuff is, I'm sure, spelled out in that, and I

apologize for -- So I'm going to ask this more in terms of

questions, I think, than comments. I had several.

 One is looking at the couple of areas that, or the

three areas that are being proposed -- wilderness areas

that you're proposing to eliminate. The Beauchamp area, I

understand it's partly because of the -- there's a

two-track that runs through. And I know it's, again,

probably not as dramatic as what some people think

wilderness areas ought to look like in terms of mountains

or even the rugged Breaks, but I think probably in terms

of its wildlife value, it's probably more valuable than

some of those other areas. But it seems to me, in terms

of the criteria of wilderness, that it meets those, just

in terms of size, naturalness, sense of solitude, and it

seems to me the imprint of man is unnoticeable there. So,

again -- I mentioned this before, but if you would look at

that criteria and reconsider those areas. And I think the

Hill Creek one, I know there's an inholding in there. I

think that might be one of the issues, but, you know,

wilderness doesn't apply to that private land, but private

lands also shouldn't disqualify it from being considered

as a proposed wilderness area.

 Another issue that I wanted to bring up is just to

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CHERYL ROMSA COURT REPORTING (406) 449-6380

7 (Pages 19 to 22)

 So Janelle Holden, and Larry Barnard on deck.

 MS. HOLDEN: Hi, my name is Janelle Holden. I

work for the Wilderness Society here in Bozeman.

 As I said last night, we're fairly happy with the

proposed alternative, except for the fact that there is

this decrease in wilderness acreage, which we think we

should be going the opposite direction, especially in our

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Page 20

1 prairie ecosystems.

 But tonight I had a couple questions, one in

particular, about roads. It seems like Alternative B and

Alternative D have a pretty significant difference,

106 miles of road versus 23 miles of road. And I was

wondering if you could address sort of what criteria you

used in terms of ecological processes versus wildlife

habitat to come up with those numbers or what were some of

the reasons why you decided to reduce roads in each of

those alternatives, so that we can get a better

understanding of what our range of alternatives are.

 Then the other question I have is about Alternative B,

in terms of manipulating habitats. I'd like to know a

little bit more about what kind of crops you would plant

in Alternative B and synthetic methods for increasing

wildlife habitat and what that might look like

specifically to the CMR Refuge.

 That's it. Thanks.

 MS. MATHER: Larry Barnard, with Mark Good on

deck.

 MR. BARNARD: My name is Larry Barnard. I've

lived in Montana for 60 years, and I hope to live here

another 60 years. I love this place, and I want to remind

everybody in the room that this is not Nevada, this is a

very unique place. Everybody in the world knows who we

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deck.

 Did I skip Mark?

 MR. GOOD: You did, yes.

 MS. MATHER: Okay. Sorry, Mark.

 MR. GOOD: That's all right.

 My name is Mark Good. I work with the Montana

Wilderness Association.

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1 I have not read through the entire EIS, and so some of

this stuff is, I'm sure, spelled out in that, and I

apologize for -- So I'm going to ask this more in terms of

questions, I think, than comments. I had several.

 One is looking at the couple of areas that, or the

three areas that are being proposed -- wilderness areas

that you're proposing to eliminate. The Beauchamp area, I

understand it's partly because of the -- there's a

two-track that runs through. And I know it's, again,

probably not as dramatic as what some people think

wilderness areas ought to look like in terms of mountains

or even the rugged Breaks, but I think probably in terms

of its wildlife value, it's probably more valuable than

some of those other areas. But it seems to me, in terms

of the criteria of wilderness, that it meets those, just

in terms of size, naturalness, sense of solitude, and it

seems to me the imprint of man is unnoticeable there. So,

again -- I mentioned this before, but if you would look at

that criteria and reconsider those areas. And I think the

Hill Creek one, I know there's an inholding in there. I

think that might be one of the issues, but, you know,

wilderness doesn't apply to that private land, but private

lands also shouldn't disqualify it from being considered

as a proposed wilderness area.

 Another issue that I wanted to bring up is just to

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 23

1 clarify again the authority that you have in terms of

managing use on Fort Peck and the Missouri River and use

in some of the riparian areas and, you know, talk about

some of the trends in terms of jet boat use and its

potential impacts. And I don't know that that was real

well addressed in the Environmental Impact Statement.

 The other has to do with the economy. Again, this

might have been explained in the EIS, but there was a

study on wildlife refuges that came out a couple of years

ago. I think it's called Banking on Nature. And in

that -- you know, maybe I'm wrong, but I believe that it

said with the CMR, that it generated upwards of about

$14 million, and I think most of that from nonresidents,

but I assume a lot of it associated with hunting; and that

there was also -- created upwards of 200 jobs or more. So

I just wondered, is that correct, or if I misread that.

And, again, I don't know that that was included in there.

 The other thing, I think in the EIS, it would be

helpful to address kind of these indirect benefits of the

protected public lands. I think most of the comments

generally agree that protected public lands benefit local

communities and to look at that more closely, I think. In

areas where you're losing population, I think this is

something to consider and that these protected public

relations are features that make communities attractive

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1 and figure out how to benefit from that.

 Thanks.

 MS. MATHER: Thanks, Mark.

 Ben, with Steve on deck.

 MR. ERICKSON: Good evening, I'm Ben Erickson.

I currently reside in Belgrade, Montana. I spent my grade

school years in LewistownMontanaand my junior high and

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1 potential to cause user conflict. In other words, you're

going to have more people using the fewer roads. So what

you're going to have then is, you are going to have some

resource damage. In working with the Forest Service on

some of the travel management plans, we've coined a term

called the cram-down effect. When you cram enough people

down into a small enough area, you truly will damage the

resources there, and then that just opens the floodgate to

close that off permanently to people. So that's a big

concern of mine.

 The other concern I have, of course, is grazing. As I

said, some of my family has ranched, some of my family

still does, and some of my family farms. I know how

difficult it is for the ag producers to make it in today's

world. Part of the reason why federal grazing permits are

so important to the rancher, which I think is overlooked

way too often, is that due to past tax practices --

originally, we called it the estate tax, but now it's

commonly referred to as the death tax -- forces a farmer

or rancher to sell off part of his property to pay for his

taxes or his inheritance to pay for the land he inherited

from his father or to pay the inheritance tax his children

are going to have to come up with when he passes on. So

what that leaves the farmer or the rancher the alternative

with is picking up grazing leases from federal property.

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1 I think it's important that those grazing leases are

protected, and I think that these people have a right to

their way of life, too. Earlier, another gentleman said,

hey, these guys gotta get used to the changing times.

Well, it's true, times do change, but, at the same time,

it's never ceased to amaze me that with some of the things

that are going on in northeastern Montana right nowthat

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING (

Page 23

1 clarify again the authority that you have in terms of

managing use on Fort Peck and the Missouri River and use

in some of the riparian areas and, you know, talk about

some of the trends in terms of jet boat use and its

potential impacts. And I don't know that that was real

well addressed in the Environmental Impact Statement.

 The other has to do with the economy. Again, this

might have been explained in the EIS, but there was a

study on wildlife refuges that came out a couple of years

ago. I think it's called Banking on Nature. And in

that -- you know, maybe I'm wrong, but I believe that it

said with the CMR, that it generated upwards of about

$14 million, and I think most of that from nonresidents,

but I assume a lot of it associated with hunting; and that

there was also -- created upwards of 200 jobs or more. So

I just wondered, is that correct, or if I misread that.

And, again, I don't know that that was included in there.

 The other thing, I think in the EIS, it would be

helpful to address kind of these indirect benefits of the

protected public lands. I think most of the comments

generally agree that protected public lands benefit local

communities and to look at that more closely, I think. In

areas where you're losing population, I think this is

something to consider and that these protected public

relations are features that make communities attractive

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1 and figure out how to benefit from that.

 Thanks.

 MS. MATHER: Thanks, Mark.

 Ben, with Steve on deck.

 MR. ERICKSON: Good evening, I'm Ben Erickson.

I currently reside in Belgrade, Montana. I spent my grade

school years in Lewistown, Montana, and my junior high and

high school years in Miles City, so I'm a bit familiar

with the country you folks are talking about doing some

revisions to.

 I also happen to have had some great-uncles that lived

on the Fort Belknap Indian Reservation. My mother is a

Chippewa Cree Indian, and those were her uncles. If

anybody here is from the Hi-Line and you know any of the

Doneys, Richard or Clifford, those were my great-uncles.

So I've got a little bit of a stake in what's going on up

there, too, from a family viewpoint.

 A couple points of concern that I have with what's

going on: Any time we get into wanting to expand more

wilderness area, one of the things I noticed about

Alternative D was, several of the small roads, which I

think Kerry White pointed out, were slated for closure.

What concerns me about that is, those roads -- almost all

of those roads lead down to the water. The few roads that

are left remained open are going to cause -- or have the

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1 potential t

going to h

you're goi

resource d

some of th

called the 

down into 

resources 

close that 

concern o

 The oth

said, some 

still does, 

difficult it 

world. Pa

so importa

way too o

originally

commonly 

or rancher 

taxes or hi

from his f

are going 

what that 

with is pic

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1 I think 

protected

their way 

hey, these 

Well, it's 

it's never 

that are g

people in 

that are pr

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day-to-da

that these 

 So I gu

thanks for 

this, and I

this area.

 Thank 

 MS

 MR

a 15-year 

as well as 

 I'm goi

because I 

regards to 

concerned 

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360 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

8 (Pages 23 to 26)

Page 23

 terms of

uri River and use

w, talk about

and its

hat was real

ct Statement.

Again, this

there was a

ouple of years

And in

believe that it

rds of about

nonresidents,

ting; and that

bs or more. So

ead that.

uded in there.

uld be

nefits of the

comments

benefit local

ely, I think. In

nk this is

cted public

es attractive

Page 24

Ben Erickson.

pent my grade

y junior high and

familiar

doing some

es that lived

y mother is a

ncles. If

now any of the

 great-uncles.

ng on up

h what's

expand more

about

s, which I

or closure.

 -- almost all

few roads that

or have the

Page 25

1 potential to cause user conflict. In other words, you're

going to have more people using the fewer roads. So what

you're going to have then is, you are going to have some

resource damage. In working with the Forest Service on

some of the travel management plans, we've coined a term

called the cram-down effect. When you cram enough people

down into a small enough area, you truly will damage the

resources there, and then that just opens the floodgate to

close that off permanently to people. So that's a big

concern of mine.

 The other concern I have, of course, is grazing. As I

said, some of my family has ranched, some of my family

still does, and some of my family farms. I know how

difficult it is for the ag producers to make it in today's

world. Part of the reason why federal grazing permits are

so important to the rancher, which I think is overlooked

way too often, is that due to past tax practices --

originally, we called it the estate tax, but now it's

commonly referred to as the death tax -- forces a farmer

or rancher to sell off part of his property to pay for his

taxes or his inheritance to pay for the land he inherited

from his father or to pay the inheritance tax his children

are going to have to come up with when he passes on. So

what that leaves the farmer or the rancher the alternative

with is picking up grazing leases from federal property.

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1 I think it's important that those grazing leases are

protected, and I think that these people have a right to

their way of life, too. Earlier, another gentleman said,

hey, these guys gotta get used to the changing times.

Well, it's true, times do change, but, at the same time,

it's never ceased to amaze me that with some of the things

that are going on in northeastern Montana right now, that

people in southwestern and western Montana are the ones

that are proposing the changes in northeastern Montana.

They don't live there. They don't have to deal with the

day-to-day life, the day-to-day expenses and hardships

that these people do.

 So I guess in closing, I would just like to say,

thanks for letting us have an opportunity to comment on

this, and I'm not in favor of any additional wilderness in

this area.

 Thank you.

 MS. MATHER: Steve, with Glenn on deck.

 MR. HUNTS: Hello, my name is Steven Hunts. I'm

a 15-year resident of Bozeman, a hunter and a fisherman,

as well as a lifelong conservationist.

 I'm going to confine my comments to Alternative B,

because I consider that to be the best alternative. In

regards to evaluating habitat by target species, I'm

concerned with the way that this is being done right now,

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CHERYL ROMSA COURT REPORTING (406) 449-6380

8 (Pages 23 to 26)

helpful to address kind of these indirect benefits of the

protected public lands. I think most of the comments

generally agree that protected public lands benefit local

communities and to look at that more closely, I think. In

areas where you're losing population, I think this is

something to consider and that these protected public

relations are features that make communities attractive

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1 and figure out how to benefit from that.

 Thanks.

 MS. MATHER: Thanks, Mark.

 Ben, with Steve on deck.

 MR. ERICKSON: Good evening, I'm Ben Erickson.

I currently reside in Belgrade, Montana. I spent my grade

school years in Lewistown, Montana, and my junior high and

high school years in Miles City, so I'm a bit familiar

with the country you folks are talking about doing some

revisions to.

 I also happen to have had some great-uncles that lived

on the Fort Belknap Indian Reservation. My mother is a

Chippewa Cree Indian, and those were her uncles. If

anybody here is from the Hi-Line and you know any of the

Doneys, Richard or Clifford, those were my great-uncles.

So I've got a little bit of a stake in what's going on up

there, too, from a family viewpoint.

 A couple points of concern that I have with what's

going on: Any time we get into wanting to expand more

wilderness area, one of the things I noticed about

Alternative D was, several of the small roads, which I

think Kerry White pointed out, were slated for closure.

What concerns me about that is, those roads -- almost all

of those roads lead down to the water. The few roads that

are left remained open are going to cause -- or have the

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commonly referred to as the death tax -- forces a farmer

or rancher to sell off part of his property to pay for his

taxes or his inheritance to pay for the land he inherited

from his father or to pay the inheritance tax his children

are going to have to come up with when he passes on. So

what that leaves the farmer or the rancher the alternative

with is picking up grazing leases from federal property.

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Page 26

1 I think it's important that those grazing leases are

protected, and I think that these people have a right to

their way of life, too. Earlier, another gentleman said,

hey, these guys gotta get used to the changing times.

Well, it's true, times do change, but, at the same time,

it's never ceased to amaze me that with some of the things

that are going on in northeastern Montana right now, that

people in southwestern and western Montana are the ones

that are proposing the changes in northeastern Montana.

They don't live there. They don't have to deal with the

day-to-day life, the day-to-day expenses and hardships

that these people do.

 So I guess in closing, I would just like to say,

thanks for letting us have an opportunity to comment on

this, and I'm not in favor of any additional wilderness in

this area.

 Thank you.

 MS. MATHER: Steve, with Glenn on deck.

 MR. HUNTS: Hello, my name is Steven Hunts. I'm

a 15-year resident of Bozeman, a hunter and a fisherman,

as well as a lifelong conservationist.

 I'm going to confine my comments to Alternative B,

because I consider that to be the best alternative. In

regards to evaluating habitat by target species, I'm

concerned with the way that this is being done right now,

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

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1 the selection of these target species and lack of public

involvement. I understand that biologists are often used

as the primary source for picking target species. I think

the picking of target species has a great effect on

management practices down the road, and I think the public

involvement -- Some of these situations, I see target

species that I just don't quite understand why they're

being picked.

 I would like to see a greater emphasis in upland bird

species management. It seems like they always take a back

seat to big game management. I like habitat-based

wildlife management. I think all public lands should be

habitat-based managed. I think there should be a drop in

the prescriptive grazing to no more than 10 percent of the

Refuge. I think we can give grazers some opportunity. I

think that the recommended percentages are too high, 35 to

50 percent are too high. And I'd also like to see a study

and timeline for reintroducing bison. I think it's an

important wildlife species. I don't think it's a

livestock animal, and I think that it's time that we move

forward.

 And thank you very much for the opportunity.

 MS. MATHER: Glenn Hockett, with Corey on deck.

 MR. HOCKETT: Hi. My son's Corey, he won't be

talking.

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Page 28

1 MS. MATHER: Okay.

 MR. HOCKETT: I'm Glenn Hockett, and I volunteer

for the Gallatin Wildlife Association.

 First off, I'd like to say thank you for coming down

here, and well done, from what I've read so far, but with

the caveat that I would hope that you would extend the

idBiihiih

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Page 29

1 U.S. Fish and Wildlife Service is part of that. It just

seems like you guys are pointing fingers at each other,

saying, You go first, you go first. I mean, we realize --

everybody realizes it's a very controversial issue, but

somebody needs to step up and do this, and I think this is

the time for the Refuge to step up and do it and say, this

is a landscape that's suitable and we should seriously

consider it. It is interesting, I read that the domestic

bison can be grazed on the Refuge. I think that's sort of

ironic, that domestic bison can be grazed, but we can't

consider restoration of native wildlife; and that's not

appropriate.

 I do support the movement to prescriptive livestock

use on the Refuge, and I do think, to the degree you can,

you should remove fences and livestock water developments.

I've read a little bit in there where you did clearly

articulate that they do fragment habitat and significantly

affect different aspects of the Refuge, and I think that

would be a good idea, to the degree you can, to remove

those things and incorporate prescriptive grazing where it

is appropriate.

 As far as roads go, I'm concerned if -- It sounds like

there's roads across private property and then go onto the

Refuge, and sometimes those get closed. What I'm

wondering is, if any roads are exclusively to certain

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Page 30

1 private landowners that go onto the Refuge, those should

be closed or there should be open access for all, it seems

to me. And I don't know the situation, so maybe you could

clarify that.

 I've provided the wildlife biologist a paper on sage

grouse that I think will help with some of the concerns

b

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND 

CHERYL ROMSA COURT REPORTING (40

Page 27

1 the selection of these target species and lack of public

involvement. I understand that biologists are often used

as the primary source for picking target species. I think

the picking of target species has a great effect on

management practices down the road, and I think the public

involvement -- Some of these situations, I see target

species that I just don't quite understand why they're

being picked.

 I would like to see a greater emphasis in upland bird

species management. It seems like they always take a back

seat to big game management. I like habitat-based

wildlife management. I think all public lands should be

habitat-based managed. I think there should be a drop in

the prescriptive grazing to no more than 10 percent of the

Refuge. I think we can give grazers some opportunity. I

think that the recommended percentages are too high, 35 to

50 percent are too high. And I'd also like to see a study

and timeline for reintroducing bison. I think it's an

important wildlife species. I don't think it's a

livestock animal, and I think that it's time that we move

forward.

 And thank you very much for the opportunity.

 MS. MATHER: Glenn Hockett, with Corey on deck.

 MR. HOCKETT: Hi. My son's Corey, he won't be

talking.

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Page 28

1 MS. MATHER: Okay.

 MR. HOCKETT: I'm Glenn Hockett, and I volunteer

for the Gallatin Wildlife Association.

 First off, I'd like to say thank you for coming down

here, and well done, from what I've read so far, but with

the caveat that I would hope that you would extend the

comment period. Because it is hunting season right now

and we're right in the middle of it, and I have not been

able to immerse myself in this thing like I'd like to, so

I haven't been able to read it all, and I'd like a little

more time, if possible.

 I would also like to get a hard copy, if I could,

because the online version that I've been looking at is

missing a lot of figures and photographs and things. So

it would be nice if you could send me a hard copy.

 Regarding bison, I'm disappointed in the position that

the Refuge has taken, and I'm confused, too, because it

says that you guys are taking the position that you won't

consider reintroducing bison on the Refuge unless the

Fish, Wildlife & Parks initiates the effort to restore

bison as a wildlife species on a larger landscape, and,

indeed, they have done that with the U.S. Fish and

Wildlife Service in terms of the quarantined bison. They

had a committee asking for a home for these quarantined

bison that they quarantine from Yellowstone Park, and the

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1 U.S. Fish and W

seems like you 

saying, You go 

everybody real

somebody need

the time for the 

is a landscape t

consider it. It i

bison can be gr

ironic, that dom

consider restor

appropriate.

 I do support 

use on the Refu

you should rem

I've read a little 

articulate that t

affect different 

would be a goo

those things an

is appropriate.

 As far as roa

there's roads ac

Refuge, and so

wondering is, i

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1 private landow

be closed or the

to me. And I d

clarify that.

 I've provided 

grouse that I th

about sage grou

 And then at 

D, and I'm still 

towards B. Bu

your staff; in te

excellent.

 Thank you.

 MS. MAT

on deck.

 MR. BAY

Ennis. And it's 

group for comi

whole area can 

 From what I

don't know too 

good attention 

Alternative D s

was established 

things I did thi

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VOLUME 2, Chapter 4—Public Hearing Testimony 361

EARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

SA COURT REPORTING (406) 449-6380

9 (Pages 27 to 30)

Page 27

nd lack of public

gists are often used

et species. I think

at effect on

 and I think the public

ns, I see target

nd why they're

sis in upland bird

ey always take a back

habitat-based

ic lands should be

should be a drop in

an 10 percent of the

ome opportunity. I

ges are too high, 35 to

like to see a study

I think it's an

nk it's a

ime that we move

pportunity.

, with Corey on deck.

 Corey, he won't be

Page 28

ockett, and I volunteer

or coming down

ead so far, but with

would extend the

g season right now

d I have not been

ike I'd like to, so

'd like a little

, if I could,

een looking at is

phs and things. So

 a hard copy.

in the position that

ed, too, because it

tion that you won't

efuge unless the

fort to restore

 landscape, and,

U.S. Fish and

ntined bison. They

r these quarantined

wstone Park, and the

Page 29

1 U.S. Fish and Wildlife Service is part of that. It just

seems like you guys are pointing fingers at each other,

saying, You go first, you go first. I mean, we realize --

everybody realizes it's a very controversial issue, but

somebody needs to step up and do this, and I think this is

the time for the Refuge to step up and do it and say, this

is a landscape that's suitable and we should seriously

consider it. It is interesting, I read that the domestic

bison can be grazed on the Refuge. I think that's sort of

ironic, that domestic bison can be grazed, but we can't

consider restoration of native wildlife; and that's not

appropriate.

 I do support the movement to prescriptive livestock

use on the Refuge, and I do think, to the degree you can,

you should remove fences and livestock water developments.

I've read a little bit in there where you did clearly

articulate that they do fragment habitat and significantly

affect different aspects of the Refuge, and I think that

would be a good idea, to the degree you can, to remove

those things and incorporate prescriptive grazing where it

is appropriate.

 As far as roads go, I'm concerned if -- It sounds like

there's roads across private property and then go onto the

Refuge, and sometimes those get closed. What I'm

wondering is, if any roads are exclusively to certain

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Page 30

1 private landowners that go onto the Refuge, those should

be closed or there should be open access for all, it seems

to me. And I don't know the situation, so maybe you could

clarify that.

 I've provided the wildlife biologist a paper on sage

grouse that I think will help with some of the concerns

about sage grouse.

 And then at this point, I like both Alternative B and

D, and I'm still not sure which is best, but I'm leaning

towards B. But they're both very good. And I compliment

your staff; in terms of what I've read so far, it's

excellent.

 Thank you.

 MS. MATHER: Robert Bayley, and then Dave Stevens

on deck.

 MR. BAYLEY: My name is Bob Bayley, I live in

Ennis. And it's a pleasure to be here, and I thank the

group for coming to Bozeman so that those of us in this

whole area can come and comment.

 From what I've heard tonight -- And, unfortunately, I

don't know too much of the detail, but I did try to pay

good attention to what I heard tonight, and I think that

Alternative D speaks to the values that I think the Refuge

was established to make sure happen. And one of the

things I did this morning before I left home to come to

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CHERYL ROMSA COURT REPORTING (406) 449-6380

9 (Pages 27 to 30)

important wildlife species. I dont think its a

livestock animal, and I think that it's time that we move

forward.

 And thank you very much for the opportunity.

 MS. MATHER: Glenn Hockett, with Corey on deck.

 MR. HOCKETT: Hi. My son's Corey, he won't be

talking.

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Page 28

1 MS. MATHER: Okay.

 MR. HOCKETT: I'm Glenn Hockett, and I volunteer

for the Gallatin Wildlife Association.

 First off, I'd like to say thank you for coming down

here, and well done, from what I've read so far, but with

the caveat that I would hope that you would extend the

comment period. Because it is hunting season right now

and we're right in the middle of it, and I have not been

able to immerse myself in this thing like I'd like to, so

I haven't been able to read it all, and I'd like a little

more time, if possible.

 I would also like to get a hard copy, if I could,

because the online version that I've been looking at is

missing a lot of figures and photographs and things. So

it would be nice if you could send me a hard copy.

 Regarding bison, I'm disappointed in the position that

the Refuge has taken, and I'm confused, too, because it

says that you guys are taking the position that you won't

consider reintroducing bison on the Refuge unless the

Fish, Wildlife & Parks initiates the effort to restore

bison as a wildlife species on a larger landscape, and,

indeed, they have done that with the U.S. Fish and

Wildlife Service in terms of the quarantined bison. They

had a committee asking for a home for these quarantined

bison that they quarantine from Yellowstone Park, and the

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would be a good idea, to the degree you can, to remove

those things and incorporate prescriptive grazing where it

is appropriate.

 As far as roads go, I'm concerned if -- It sounds like

there's roads across private property and then go onto the

Refuge, and sometimes those get closed. What I'm

wondering is, if any roads are exclusively to certain

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Page 30

1 private landowners that go onto the Refuge, those should

be closed or there should be open access for all, it seems

to me. And I don't know the situation, so maybe you could

clarify that.

 I've provided the wildlife biologist a paper on sage

grouse that I think will help with some of the concerns

about sage grouse.

 And then at this point, I like both Alternative B and

D, and I'm still not sure which is best, but I'm leaning

towards B. But they're both very good. And I compliment

your staff; in terms of what I've read so far, it's

excellent.

 Thank you.

 MS. MATHER: Robert Bayley, and then Dave Stevens

on deck.

 MR. BAYLEY: My name is Bob Bayley, I live in

Ennis. And it's a pleasure to be here, and I thank the

group for coming to Bozeman so that those of us in this

whole area can come and comment.

 From what I've heard tonight -- And, unfortunately, I

don't know too much of the detail, but I did try to pay

good attention to what I heard tonight, and I think that

Alternative D speaks to the values that I think the Refuge

was established to make sure happen. And one of the

things I did this morning before I left home to come to

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 31

1 Bozeman was, I went quickly to the website. In the

history section, I read something that just resonated with

me so nicely, and I'm just repeating -- I'll just read one

line, or, actually, three lines, because I think it sums

up what I think the emphasis should be.

 This is from the Executive Order which established the

Refuge. And what you say on your website in the history

section is, you say that the natural forage resources

therein shall be first utilized for the purpose of

sustaining in a healthy condition a maximum of 400,000

sharp-tailed grouse and 1,500 antelope, the primary

species, and such non-predatory secondary species in such

numbers as may be necessary to maintain a balanced

wildlife population.

 Well, clearly, to do that, the land needs to be

preserved in as pristine and natural state as possible.

And the only way I see that really happening to its

fullest is to have the maximum amount of roadless area

designated wilderness and as few roads as possible. I

mean, most of us who love Montana and travel widely know

that roads are just about everywhere. And if you look

statistically at wilderness, we only have 3.7 percent of

the state designated wilderness. And in the eastern part

of Montana, where the Charlie Russell Wildlife Preserve

is, there is less than, I believe -- I wrote this down,

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1 it's just incredible. There is literally only

32,000 acres of wilderness. And with that in mind, it

just seems so obvious to me that what is needed in this

Refuge is the maximum amount of untraveled area that

wildlife can prosper in, and, as well, those who want to

hunt, fish, hike, horseback ride are free to do so.

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Page 33

1 small. I think all areas that qualify as wilderness

should be wilderness. I hate to see any being reduced.

The prairie ecosystem is not well represented in

wilderness, and it should be.

 The road networks are important to get people into

areas, but they also are very hard on wildlife species.

During hunting seasons, people patrol the roads, and the

wildlife, especially species like elk, it's very

detrimental to their population and existence.

 I think the grazing should be better managed. I think

that this prescribed grazing is a good idea, because I

think that does more or less represent what the bison did

in the early days, and I think that probably is good, and

I know prescribed burning is good, both of which should be

utilized to the greatest extent possible.

 I think fencing, and especially sheep-proof fencing,

should be eliminated. Some fencing is necessary as drift

fences to keep your livestock in the right places, but

that should be a minimum.

 I do support the restoration of bison. I think bison

need to be in a wild situation in some places, and CMR

seems to be one of the places it should be.

 So with that, I do have some questions as to why the

Fish and Wildlife Service is not concentrating on wildlife

like they are in Alternative B. I assume that you already

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1 have your preferred alternative, which is D, as I

gathered, and I hope that doesn't mean that you're on that

and there's not going to be any adjustments to it in the

future.

 Thank you.

 MS. MATHER: Thanks, Dave.

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING (

Page 31

1 Bozeman was, I went quickly to the website. In the

history section, I read something that just resonated with

me so nicely, and I'm just repeating -- I'll just read one

line, or, actually, three lines, because I think it sums

up what I think the emphasis should be.

 This is from the Executive Order which established the

Refuge. And what you say on your website in the history

section is, you say that the natural forage resources

therein shall be first utilized for the purpose of

sustaining in a healthy condition a maximum of 400,000

sharp-tailed grouse and 1,500 antelope, the primary

species, and such non-predatory secondary species in such

numbers as may be necessary to maintain a balanced

wildlife population.

 Well, clearly, to do that, the land needs to be

preserved in as pristine and natural state as possible.

And the only way I see that really happening to its

fullest is to have the maximum amount of roadless area

designated wilderness and as few roads as possible. I

mean, most of us who love Montana and travel widely know

that roads are just about everywhere. And if you look

statistically at wilderness, we only have 3.7 percent of

the state designated wilderness. And in the eastern part

of Montana, where the Charlie Russell Wildlife Preserve

is, there is less than, I believe -- I wrote this down,

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1 it's just incredible. There is literally only

32,000 acres of wilderness. And with that in mind, it

just seems so obvious to me that what is needed in this

Refuge is the maximum amount of untraveled area that

wildlife can prosper in, and, as well, those who want to

hunt, fish, hike, horseback ride are free to do so.

 I compare -- I use one example here which I'm very

familiar with, and that's the Red Rock Wildlife Refuge.

That refuge, which is in the very southern part of our

state on the Idaho border, the majority of the land in

that refuge is wilderness, and, yet, there's ample

hunting, there's canoeing, there's hiking, there are roads

that circle the refuge, and it works very well. I ask you

to think about that.

 Thank you.

 MS. MATHER: Thanks, Bob.

 Dave Stevens, and George Baldwin on deck.

 MR. STEVENS: I'm Dave Stevens. I'm a wildlife

biologist with Stevens Wildlife Consulting.

 I am very much concerned that the Fish and Wildlife

Service is losing their way in what the refuges are for.

Refuges are for the preservation of wildlife species and

management of wildlife species. I support Alternative B.

The CMR is a national treasure, and it should be

maintained like that. The proposed wilderness is too

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1 small. I t

should be 

The prair

wildernes

 The ro

areas, but 

During hu

wildlife, e

detriment

 I think 

that this p

think that 

in the ear

I know pr

utilized to 

 I think 

should be 

fences to 

that shou

 I do su

need to b

seems to 

 So with 

Fish and 

like they 

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1 have your 

gathered, 

and there'

future.

 Thank 

 MS. 

 Rod, an

 MR

drew my 

Charles M

Charles M

as long as 

father's na

Florence. 

Wildernes

tradition.

 I would 

very impo

through a 

has a mor

things tha

designate 

and get pe

Wildernes

wildernes

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362 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

10 (Pages 31 to 34)

Page 31

 In the

sonated with

t read one

 it sums

stablished the

in the history

ources

of

m of 400,000

primary

pecies in such

balanced

 be

ossible.

g to its

adless area

ossible. I

vel widely know

 you look

percent of

eastern part

life Preserve

down,

Page 32

t in mind, it

eeded in this

eled area that

 who want to

 do so.

ich I'm very

ldlife Refuge.

 part of our

the land in

ample

here are roads

ell. I ask you

deck.

 I'm a wildlife

g.

 and Wildlife

uges are for.

fe species and

t Alternative B.

ould be

rness is too

Page 33

1 small. I think all areas that qualify as wilderness

should be wilderness. I hate to see any being reduced.

The prairie ecosystem is not well represented in

wilderness, and it should be.

 The road networks are important to get people into

areas, but they also are very hard on wildlife species.

During hunting seasons, people patrol the roads, and the

wildlife, especially species like elk, it's very

detrimental to their population and existence.

 I think the grazing should be better managed. I think

that this prescribed grazing is a good idea, because I

think that does more or less represent what the bison did

in the early days, and I think that probably is good, and

I know prescribed burning is good, both of which should be

utilized to the greatest extent possible.

 I think fencing, and especially sheep-proof fencing,

should be eliminated. Some fencing is necessary as drift

fences to keep your livestock in the right places, but

that should be a minimum.

 I do support the restoration of bison. I think bison

need to be in a wild situation in some places, and CMR

seems to be one of the places it should be.

 So with that, I do have some questions as to why the

Fish and Wildlife Service is not concentrating on wildlife

like they are in Alternative B. I assume that you already

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Page 34

1 have your preferred alternative, which is D, as I

gathered, and I hope that doesn't mean that you're on that

and there's not going to be any adjustments to it in the

future.

 Thank you.

 MS. MATHER: Thanks, Dave.

 Rod, and then Dawn on deck.

 MR. BALDWIN: My name is George Baldwin. What

drew my interest in tonight's meeting, in part, was the

Charles M. Russell name. My father sat and watched

Charles M. Russell paint, which was okay with the painter

as long as the boys were quiet and behaved themselves. My

father's name is Kenneth Baldwin, my mother's name is

Florence. They were the founders of the Montana

Wilderness Association. So I stand here in that

tradition.

 I would like to say that some of the goals here seem

very important, and one of the goals is the preservation

through a refuge, but through wilderness; wilderness which

has a more distinct sense of heritage. And so one of the

things that my father especially emphasized was once you

designate a wilderness, find ways to do public education

and get people to use the wilderness. The Montana

Wilderness Association has an amazing program of

wilderness walks, all of which are educational. They have

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CHERYL ROMSA COURT REPORTING (406) 449-6380

10 (Pages 31 to 34)

designated wilderness and as few roads as possible. I

mean, most of us who love Montana and travel widely know

that roads are just about everywhere. And if you look

statistically at wilderness, we only have 3.7 percent of

the state designated wilderness. And in the eastern part

of Montana, where the Charlie Russell Wildlife Preserve

is, there is less than, I believe -- I wrote this down,

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Page 32

1 it's just incredible. There is literally only

32,000 acres of wilderness. And with that in mind, it

just seems so obvious to me that what is needed in this

Refuge is the maximum amount of untraveled area that

wildlife can prosper in, and, as well, those who want to

hunt, fish, hike, horseback ride are free to do so.

 I compare -- I use one example here which I'm very

familiar with, and that's the Red Rock Wildlife Refuge.

That refuge, which is in the very southern part of our

state on the Idaho border, the majority of the land in

that refuge is wilderness, and, yet, there's ample

hunting, there's canoeing, there's hiking, there are roads

that circle the refuge, and it works very well. I ask you

to think about that.

 Thank you.

 MS. MATHER: Thanks, Bob.

 Dave Stevens, and George Baldwin on deck.

 MR. STEVENS: I'm Dave Stevens. I'm a wildlife

biologist with Stevens Wildlife Consulting.

 I am very much concerned that the Fish and Wildlife

Service is losing their way in what the refuges are for.

Refuges are for the preservation of wildlife species and

management of wildlife species. I support Alternative B.

The CMR is a national treasure, and it should be

maintained like that. The proposed wilderness is too

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that should be a minimum.

 I do support the restoration of bison. I think bison

need to be in a wild situation in some places, and CMR

seems to be one of the places it should be.

 So with that, I do have some questions as to why the

Fish and Wildlife Service is not concentrating on wildlife

like they are in Alternative B. I assume that you already

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Page 34

1 have your preferred alternative, which is D, as I

gathered, and I hope that doesn't mean that you're on that

and there's not going to be any adjustments to it in the

future.

 Thank you.

 MS. MATHER: Thanks, Dave.

 Rod, and then Dawn on deck.

 MR. BALDWIN: My name is George Baldwin. What

drew my interest in tonight's meeting, in part, was the

Charles M. Russell name. My father sat and watched

Charles M. Russell paint, which was okay with the painter

as long as the boys were quiet and behaved themselves. My

father's name is Kenneth Baldwin, my mother's name is

Florence. They were the founders of the Montana

Wilderness Association. So I stand here in that

tradition.

 I would like to say that some of the goals here seem

very important, and one of the goals is the preservation

through a refuge, but through wilderness; wilderness which

has a more distinct sense of heritage. And so one of the

things that my father especially emphasized was once you

designate a wilderness, find ways to do public education

and get people to use the wilderness. The Montana

Wilderness Association has an amazing program of

wilderness walks, all of which are educational. They have

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 35

1 two guides which help people understand the territory

they're walking through, and these are always free. So I

would encourage the staff to look very carefully at how

you really intend to use this refuge and these wilderness

areas. I would second those who say the expansion of

wilderness seems like the right direction.

 Thank you for all your labor. I see you've been at it

for months. I will study this some more. Thank you.

 MS. MATHER: Thanks, George.

 Rod, and Dawn on deck.

 MR. JUDE: Rod Jude, Gallatin Canyon.

 I haven't waded through this entire document yet, but

I will do that and I will send you some written comments.

But I would like to come down on the side of this is all

about wildlife. And so I think more wilderness is a good

thing, less roads is a good thing, prescribed burns is a

good thing, prescriptive grazing is a good thing, and,

clearly, less fencing is a good thing.

 With that mind, I thank you for coming down here and

spending your time, and I think you're doing a pretty good

job. I think if you take all these comments at heart, we

can come up with a great, you know, piece of work. And

with that, thanks again for coming. I'll get those

comments to you.

 MS. MATHER: Thanks, Rod.

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Page 36

1 Dawn, and then Lesley Robinson on deck.

 MS. MONTANYE: I'm Dawn Montanye, with World

Wildlife Fund, based here in Bozeman. Thank you for the

opportunity to comment.

 We see, as I think many people in Montana, the CMR as

a treasure, not only for this region, but for the country

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5

6

Page 37

1 what that brings into local communities. And I think it's

important to also look at the -- what are the effects of

delivery of ecosystem services for keeping intact

resources, both for the region and then also for the

larger nation; for example, protecting water resources

that flow into the Gulf of Mexico from proper management.

And even those aspects could be looked into further. So I

think that's an important aspect to look at in more depth

and to also be explicit about when in some of these

meetings and talking to communities, as well.

 And then I would also echo the interest of extending

the comment period. I think that could be important for

people that, for whatever reason, whether they're hunting

or otherwise, might not be able to comment during the

period that's given. So if that's a possibility, I would

encourage that, as well.

 Thank you.

 MS. MATHER: Lesley, and Peter on deck.

 MS. ROBINSON: I'm Lesley Robinson, Phillips

County Commissioner, and I'm also the chairman of the

Montana Association of Counties Public Lands Committee.

 I just want to put into the record the policy that

MACo passed at our convention: Montana Association of

Counties supports livestock grazing on the Charles M.

Russell Wildlife Refuge at levels that sustain

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Page 38

1 economically sound livestock operations and maintain the

ecological health of the resource.

 Thanks.

 MS. MATHER: Thanks, Lesley.

 Peter, and then Kit on deck.

 MR. AENGST: Hi, Peter Aengst, with the

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (40

Page 35

1 two guides which help people understand the territory

they're walking through, and these are always free. So I

would encourage the staff to look very carefully at how

you really intend to use this refuge and these wilderness

areas. I would second those who say the expansion of

wilderness seems like the right direction.

 Thank you for all your labor. I see you've been at it

for months. I will study this some more. Thank you.

 MS. MATHER: Thanks, George.

 Rod, and Dawn on deck.

 MR. JUDE: Rod Jude, Gallatin Canyon.

 I haven't waded through this entire document yet, but

I will do that and I will send you some written comments.

But I would like to come down on the side of this is all

about wildlife. And so I think more wilderness is a good

thing, less roads is a good thing, prescribed burns is a

good thing, prescriptive grazing is a good thing, and,

clearly, less fencing is a good thing.

 With that mind, I thank you for coming down here and

spending your time, and I think you're doing a pretty good

job. I think if you take all these comments at heart, we

can come up with a great, you know, piece of work. And

with that, thanks again for coming. I'll get those

comments to you.

 MS. MATHER: Thanks, Rod.

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1 Dawn, and then Lesley Robinson on deck.

 MS. MONTANYE: I'm Dawn Montanye, with World

Wildlife Fund, based here in Bozeman. Thank you for the

opportunity to comment.

 We see, as I think many people in Montana, the CMR as

a treasure, not only for this region, but for the country

and the world. It is a globally significant protected

grassland area that is and has a high number of grassland

endemic species, entire grasslands and, in places, limited

road development, and, because of that, has been

determined as a really key and important grassland area

globally. So we support this effort. We're very much in

favor of the proposed alternative, the focus on

maintaining and supporting ecological processes and

looking at wildlife management and habitat management from

that perspective. Our interest is that we ensure this is

a place where native species do thrive and can thrive in

great numbers.

 There was a suggestion earlier for looking at some of

the economic issues related to the loss of grazing. I

don't think that that's a bad idea. I think some of the

economics have been looked at. But I would also encourage

the refuge managers and administration to talk about what

are the economic benefits that come from having abundant

wildlife, having people be able to come onto the Refuge,

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1 what that bring

important to al

delivery of eco

resources, both 

larger nation; f

that flow into t

And even those 

think that's an i

and to also be e

meetings and t

 And then I w

the comment p

people that, for 

or otherwise, m

period that's gi

encourage that

 Thank you.

 MS. MAT

 MS. ROB

County Comm

Montana Assoc

 I just want to 

MACo passed 

Counties suppo

Russell Wildlif

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1 economically s

ecological hea

 Thanks.

 MS. MA

 Peter, and th

 MR. AEN

Wilderness So

 Thanks for t

the draft.

 I had, I gues

think you've he

to the preferred 

8,000 acres in 

have a concern 

question is wh

analysis lookin

see how much 

as designated w

wilderness, to 

terms of its po

upping the rep

ecosystem type

System. So I w

not done, I gue

 The second 

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VOLUME 2, Chapter 4—Public Hearing Testimony 363

EARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

SA COURT REPORTING (406) 449-6380

11 (Pages 35 to 38)

Page 35

tand the territory

e always free. So I

y carefully at how

nd these wilderness

 the expansion of

ion.

e you've been at it

ore. Thank you.

ge.

n Canyon.

 document yet, but

me written comments.

e side of this is all

wilderness is a good

cribed burns is a

good thing, and,

ming down here and

e doing a pretty good

ments at heart, we

 piece of work. And

'll get those

Page 36

deck.

ontanye, with World

 Thank you for the

ontana, the CMR as

for the country

nt protected

mber of grassland

in places, limited

 has been

nt grassland area

e're very much in

cus on

processes and

bitat management from

 ensure this is

nd can thrive in

oking at some of

of grazing. I

k some of the

would also encourage

 to talk about what

m having abundant

 onto the Refuge,

Page 37

1 what that brings into local communities. And I think it's

important to also look at the -- what are the effects of

delivery of ecosystem services for keeping intact

resources, both for the region and then also for the

larger nation; for example, protecting water resources

that flow into the Gulf of Mexico from proper management.

And even those aspects could be looked into further. So I

think that's an important aspect to look at in more depth

and to also be explicit about when in some of these

meetings and talking to communities, as well.

 And then I would also echo the interest of extending

the comment period. I think that could be important for

people that, for whatever reason, whether they're hunting

or otherwise, might not be able to comment during the

period that's given. So if that's a possibility, I would

encourage that, as well.

 Thank you.

 MS. MATHER: Lesley, and Peter on deck.

 MS. ROBINSON: I'm Lesley Robinson, Phillips

County Commissioner, and I'm also the chairman of the

Montana Association of Counties Public Lands Committee.

 I just want to put into the record the policy that

MACo passed at our convention: Montana Association of

Counties supports livestock grazing on the Charles M.

Russell Wildlife Refuge at levels that sustain

2

3

4

5

6

7

8

9

10

11

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1 economically sound livestock operations and maintain the

ecological health of the resource.

 Thanks.

 MS. MATHER: Thanks, Lesley.

 Peter, and then Kit on deck.

 MR. AENGST: Hi, Peter Aengst, with the

Wilderness Society here in Bozeman.

 Thanks for the great work I've seen so far in terms of

the draft.

 I had, I guess, three questions. The first, as I

think you've heard from several speakers tonight, relates

to the preferred alternative and the net reduction of

8,000 acres in terms of recommended wilderness. And we

have a concern about that, and I guess my request or my

question is whether or not the Service did any sort of

analysis looking across prairie grassland ecosystems to

see how much wilderness is actually represented, whether

as designated wilderness or as recommended or potential

wilderness, to get a sense of how important the CMR is in

terms of its potential recommended wilderness in terms of

upping the representation of prairie and grassland

ecosystem types in the National Wilderness Preservation

System. So I would encourage you to do that if that was

not done, I guess.

 The second has to do with climate change. I'll admit

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CHERYL ROMSA COURT REPORTING (406) 449-6380

11 (Pages 35 to 38)

 With that mind, I thank you for coming down here and

spending your time, and I think you're doing a pretty good

job. I think if you take all these comments at heart, we

can come up with a great, you know, piece of work. And

with that, thanks again for coming. I'll get those

comments to you.

 MS. MATHER: Thanks, Rod.

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20

21

22

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25

Page 36

1 Dawn, and then Lesley Robinson on deck.

 MS. MONTANYE: I'm Dawn Montanye, with World

Wildlife Fund, based here in Bozeman. Thank you for the

opportunity to comment.

 We see, as I think many people in Montana, the CMR as

a treasure, not only for this region, but for the country

and the world. It is a globally significant protected

grassland area that is and has a high number of grassland

endemic species, entire grasslands and, in places, limited

road development, and, because of that, has been

determined as a really key and important grassland area

globally. So we support this effort. We're very much in

favor of the proposed alternative, the focus on

maintaining and supporting ecological processes and

looking at wildlife management and habitat management from

that perspective. Our interest is that we ensure this is

a place where native species do thrive and can thrive in

great numbers.

 There was a suggestion earlier for looking at some of

the economic issues related to the loss of grazing. I

don't think that that's a bad idea. I think some of the

economics have been looked at. But I would also encourage

the refuge managers and administration to talk about what

are the economic benefits that come from having abundant

wildlife, having people be able to come onto the Refuge,

2

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 MS. ROBINSON: I'm Lesley Robinson, Phillips

County Commissioner, and I'm also the chairman of the

Montana Association of Counties Public Lands Committee.

 I just want to put into the record the policy that

MACo passed at our convention: Montana Association of

Counties supports livestock grazing on the Charles M.

Russell Wildlife Refuge at levels that sustain

19

20

21

22

23

24

25

Page 38

1 economically sound livestock operations and maintain the

ecological health of the resource.

 Thanks.

 MS. MATHER: Thanks, Lesley.

 Peter, and then Kit on deck.

 MR. AENGST: Hi, Peter Aengst, with the

Wilderness Society here in Bozeman.

 Thanks for the great work I've seen so far in terms of

the draft.

 I had, I guess, three questions. The first, as I

think you've heard from several speakers tonight, relates

to the preferred alternative and the net reduction of

8,000 acres in terms of recommended wilderness. And we

have a concern about that, and I guess my request or my

question is whether or not the Service did any sort of

analysis looking across prairie grassland ecosystems to

see how much wilderness is actually represented, whether

as designated wilderness or as recommended or potential

wilderness, to get a sense of how important the CMR is in

terms of its potential recommended wilderness in terms of

upping the representation of prairie and grassland

ecosystem types in the National Wilderness Preservation

System. So I would encourage you to do that if that was

not done, I guess.

 The second has to do with climate change. I'll admit

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 39

1 I've only read the summary here and have not delved into

the EIS yet, but I'm not seeing much reference at all to

climate change. And, specifically, nationally the

Fish and Wildlife Service, of course, even I think as

recently as today, has announced whole initiatives dealing

with assessing climate change and planning on a large

landscape level, incorporating science more into kind of

thinking about adaptation. And so my question is -- with

the preferred alternative, which I certainly support its

goals of restoring greater biological integrity and

ecological processes and moving it first from an active

management to more of a passive management, my question

is, how is that being allied with these more national

goals and initiatives that the Fish and Wildlife Service

has around climate change? So I think it would be helpful

for the public to better understand the intersection

between these national climate change programs and

initiatives that are going on with the decisions being

made for management of the CMR.

 And third and last, I guess, is having to do with

roads. I guess not so much a question, but I think

there's some confusion that I think some people I've heard

voice: The areas that are being -- they've been kind of

combined or felt like the areas being recommended for

additional wilderness are happening because of roads being

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Page 40

1 closed. But when I read your map for the preferred

alternative, what I see is that, almost in every case, the

areas for road closures are not at all connected to where

you're talking about wilderness additions. So I think I

would just ask that you make that much more clear, that

the wilderness additions have nothing to do with any road

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Page 41

1 The first comment, relating to prescribed burning, I

am supportive, and our organizations are very supportive,

of Alternative D, and in terms of prescribed burning, we

are supportive of that. I have some questions in terms of

how that would work on the ground. I know that the costs

associated with prescribed burns are very high. It's a

fairly aggressive prescribed burning situation that looks

like it's how this would go in the plan, and exactly how

those costs in terms of -- I know that it's hard, even

now, to get the prescribed burns off the ground. I think

they are very important in terms of ecologically in

relation with prescriptive grazing. I think that is a

very good way to do it, but some specifics of how that

would work.

 Secondly, I haven't read completely through the plan,

but as far as sage grouse recovery areas, we'd like to see

those; you know, if they've been established and how are

they being addressed in relation to the current and

proposed grazing regime.

 Thirdly, I think it would be important to note in this

plan that the retirement of grazing leases through willing

seller/willing buyer agreements, providing an economic

incentive to ranchers to retire those leases, should be

noted as a primary means in shifting towards prescribed

grazing.

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Page 42

1 And lastly, in relation to bison, I would like to see

Fish and Wildlife Service as a proactive agency in

initiating and participating with the State in restoring

bison population with CMR.

 I would like to say I would like to see an extension

on this comment period. I have submitted an official

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING 

Page 39

1 I've only read the summary here and have not delved into

the EIS yet, but I'm not seeing much reference at all to

climate change. And, specifically, nationally the

Fish and Wildlife Service, of course, even I think as

recently as today, has announced whole initiatives dealing

with assessing climate change and planning on a large

landscape level, incorporating science more into kind of

thinking about adaptation. And so my question is -- with

the preferred alternative, which I certainly support its

goals of restoring greater biological integrity and

ecological processes and moving it first from an active

management to more of a passive management, my question

is, how is that being allied with these more national

goals and initiatives that the Fish and Wildlife Service

has around climate change? So I think it would be helpful

for the public to better understand the intersection

between these national climate change programs and

initiatives that are going on with the decisions being

made for management of the CMR.

 And third and last, I guess, is having to do with

roads. I guess not so much a question, but I think

there's some confusion that I think some people I've heard

voice: The areas that are being -- they've been kind of

combined or felt like the areas being recommended for

additional wilderness are happening because of roads being

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Page 40

1 closed. But when I read your map for the preferred

alternative, what I see is that, almost in every case, the

areas for road closures are not at all connected to where

you're talking about wilderness additions. So I think I

would just ask that you make that much more clear, that

the wilderness additions have nothing to do with any road

closures.

 And then the question, I guess, about road closures

is -- I think it was what, 23 or 28 miles of seasonal or

permanent miles of road closure. Maybe this is addressed

in the draft. How much -- if there's details provided in

terms of how you're going to be enforcing that, and for

those that are permanent road closures, is that just a

gate or is that ripping out and recontouring roads in

terms of how far you're going to go in terms of dealing

with those permanent road closures?

 So thanks, again.

 MS. MATHER: Thanks, Peter.

 Kit.

 MR. FISCHER: Hi, my name is Kit Fischer. I'm

representing National Wildlife Federation and the National

Wildlife Refuge Association. I just had a few short

comments.

 First, I'd like to thank the CMR staff and Fish and

Wildlife Service for this opportunity.

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1 The fir

am suppo

of Altern

are suppo

how that 

associate

fairly agg

like it's h

those cos

now, to g

they are v

relation w

very goo

would wo

 Second

but as far 

those; yo

they bein

proposed 

 Thirdly

plan that 

seller/wil

incentive 

noted as 

grazing.

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1 And la

Fish and W

initiating 

bison pop

 I would 

on this co

request fr

National W

Wildlife F

where tha

 Thank 

 MS

Before La

anybody 

 MS

through th

Alternativ

summary 

bighorn s

alternativ

wildlife m

bighorn s

important 

 In fact, 

summary 

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364 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

12 (Pages 39 to 42)

Page 39

ot delved into

ce at all to

y the

think as

atives dealing

on a large

 into kind of

ion is -- with

upport its

y and

m an active

ent, my question

national

fe Service

ould be helpful

ection

rams and

ns being

o with

 think

ople I've heard

en kind of

mended for

e of roads being

Page 40

preferred

ry case, the

cted to where

So I think I

ore clear, that

o with any road

ad closures

easonal or

his is addressed

provided in

that, and for

hat just a

 roads in

s of dealing

Fischer. I'm

and the National

ew short

 Fish and

Page 41

1 The first comment, relating to prescribed burning, I

am supportive, and our organizations are very supportive,

of Alternative D, and in terms of prescribed burning, we

are supportive of that. I have some questions in terms of

how that would work on the ground. I know that the costs

associated with prescribed burns are very high. It's a

fairly aggressive prescribed burning situation that looks

like it's how this would go in the plan, and exactly how

those costs in terms of -- I know that it's hard, even

now, to get the prescribed burns off the ground. I think

they are very important in terms of ecologically in

relation with prescriptive grazing. I think that is a

very good way to do it, but some specifics of how that

would work.

 Secondly, I haven't read completely through the plan,

but as far as sage grouse recovery areas, we'd like to see

those; you know, if they've been established and how are

they being addressed in relation to the current and

proposed grazing regime.

 Thirdly, I think it would be important to note in this

plan that the retirement of grazing leases through willing

seller/willing buyer agreements, providing an economic

incentive to ranchers to retire those leases, should be

noted as a primary means in shifting towards prescribed

grazing.

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Page 42

1 And lastly, in relation to bison, I would like to see

Fish and Wildlife Service as a proactive agency in

initiating and participating with the State in restoring

bison population with CMR.

 I would like to say I would like to see an extension

on this comment period. I have submitted an official

request from the National Wildlife Federation, the

National Wildlife Refuge Association, and the Montana

Wildlife Federation over a week ago and would like to see

where that stands.

 Thank you.

 MS. MATHER: So Kit was the last one on my list.

Before Laurie, Bill, and Barron answer the questions, does

anybody else -- Come on up.

 MS. STEVENS: I'm Nicki Stevens, and just reading

through the summary, I notice that only in the summary for

Alternative B are bighorn sheep mentioned. And that brief

summary indicates that there is suitable habitat for

bighorn sheep on the Refuge, and it would seem like any

alternative that really, truly wants to do a good job of

wildlife management should restore a species such as

bighorn sheep, which is valuable to hunters and is an

important ecosystem component and a very valuable species.

 In fact, basically, my impression, just reading the

summary and listening to the comments of people who have

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CHERYL ROMSA COURT REPORTING (406) 449-6380

12 (Pages 39 to 42)

made for management of the CMR.

 And third and last, I guess, is having to do with

roads. I guess not so much a question, but I think

there's some confusion that I think some people I've heard

voice: The areas that are being -- they've been kind of

combined or felt like the areas being recommended for

additional wilderness are happening because of roads being

19

20

21

22

23

24

25

Page 40

1 closed. But when I read your map for the preferred

alternative, what I see is that, almost in every case, the

areas for road closures are not at all connected to where

you're talking about wilderness additions. So I think I

would just ask that you make that much more clear, that

the wilderness additions have nothing to do with any road

closures.

 And then the question, I guess, about road closures

is -- I think it was what, 23 or 28 miles of seasonal or

permanent miles of road closure. Maybe this is addressed

in the draft. How much -- if there's details provided in

terms of how you're going to be enforcing that, and for

those that are permanent road closures, is that just a

gate or is that ripping out and recontouring roads in

terms of how far you're going to go in terms of dealing

with those permanent road closures?

 So thanks, again.

 MS. MATHER: Thanks, Peter.

 Kit.

 MR. FISCHER: Hi, my name is Kit Fischer. I'm

representing National Wildlife Federation and the National

Wildlife Refuge Association. I just had a few short

comments.

 First, I'd like to thank the CMR staff and Fish and

Wildlife Service for this opportunity.

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proposed grazing regime.

 Thirdly, I think it would be important to note in this

plan that the retirement of grazing leases through willing

seller/willing buyer agreements, providing an economic

incentive to ranchers to retire those leases, should be

noted as a primary means in shifting towards prescribed

grazing.

19

20

21

22

23

24

25

Page 42

1 And lastly, in relation to bison, I would like to see

Fish and Wildlife Service as a proactive agency in

initiating and participating with the State in restoring

bison population with CMR.

 I would like to say I would like to see an extension

on this comment period. I have submitted an official

request from the National Wildlife Federation, the

National Wildlife Refuge Association, and the Montana

Wildlife Federation over a week ago and would like to see

where that stands.

 Thank you.

 MS. MATHER: So Kit was the last one on my list.

Before Laurie, Bill, and Barron answer the questions, does

anybody else -- Come on up.

 MS. STEVENS: I'm Nicki Stevens, and just reading

through the summary, I notice that only in the summary for

Alternative B are bighorn sheep mentioned. And that brief

summary indicates that there is suitable habitat for

bighorn sheep on the Refuge, and it would seem like any

alternative that really, truly wants to do a good job of

wildlife management should restore a species such as

bighorn sheep, which is valuable to hunters and is an

important ecosystem component and a very valuable species.

 In fact, basically, my impression, just reading the

summary and listening to the comments of people who have

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 43

1 maybe read more, this is a very timid management document,

and it seems like it could be much bolder with respect to

actually doing what the mandate is as far as optimizing

wildlife management on a wildlife refuge. It should look

different than just a piece of BLM that's managed

primarily for cattle grazing. It should be different

management. It should really honestly emphasize wildlife.

 I think the distinction between B and D is political.

I think that in reality, if you maximize wildlife, you

optimize processes, natural processes. I don't see how

you can have one alternative that supposedly maximizes

wildlife habitat and another alternative that supposedly

optimizes natural processes. To me, those are the same if

you're a biologist, and I think that this is some kind of

political word use, where if you call it natural

processes, you can take out wilderness and leave in roads.

And I don't think you're really doing the job of a

wildlife refuge when you do that.

 Thank you.

 MS. MATHER: Thank you.

 Either of you guys.

 MR. AUNE: I guess I didn't sign the right sheet

there, so -- I'm Keith Aune. I'm with the Wildlife

Conservation Society, and the Wildlife Conservation

Society works worldwide to preserve wildlife and wild

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1 places. We work in 60 countries.

 I'm going to confine my comments, because I really do

want to say there's been some really good comment that I

can support here. But WCS, in looking at this, is really

supporting Alternative B. It's very consistent with our

mission, and we think it's consistent the title of

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Page 45

1 We should keep an open mind about that.

 The third thing I really want to emphasize is that if

you're thinking about ecological processes and really want

to really do a good job of restoring a fully functional

ecosystem, you have to be thinking about impending climate

change. And that was brought up once, but I want to

emphasize it again. From our perspective, bison in that

landscape operating as a keystone herbivore working to

create habitats for other species, building those

important community relationships, actually can enhance

resilience of this really critical landscape, and we can't

lose sight of that. There are very, very, very few places

like this left in the world; not just in North America, in

the world. So this is a very, very special place in that

regard.

 So I want to emphasize that we support Alternative B.

We think this is a really critical ecosystem that's still

intact, and you are the heart of that system and, as such,

should be brave and consistent in your messaging about

wildlife.

 Thank you.

 MS. MATHER: Yes.

 MR. GRIFFIN: My name is Paul Griffin. I live

here in Bozeman, and since it seems fashionable at times,

I'm fourth generation in the Gallatin Valley on my

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Page 46

1 mother's side.

 I could live with either B or D. I think you've done

really great, especially considering some work we've seen

at other times from other agencies.

 I wish you'd expand the socioeconomic data, because we

hear at these meetings that this could be devastating or

2

3

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6

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (40

Page 43

1 maybe read more, this is a very timid management document,

and it seems like it could be much bolder with respect to

actually doing what the mandate is as far as optimizing

wildlife management on a wildlife refuge. It should look

different than just a piece of BLM that's managed

primarily for cattle grazing. It should be different

management. It should really honestly emphasize wildlife.

 I think the distinction between B and D is political.

I think that in reality, if you maximize wildlife, you

optimize processes, natural processes. I don't see how

you can have one alternative that supposedly maximizes

wildlife habitat and another alternative that supposedly

optimizes natural processes. To me, those are the same if

you're a biologist, and I think that this is some kind of

political word use, where if you call it natural

processes, you can take out wilderness and leave in roads.

And I don't think you're really doing the job of a

wildlife refuge when you do that.

 Thank you.

 MS. MATHER: Thank you.

 Either of you guys.

 MR. AUNE: I guess I didn't sign the right sheet

there, so -- I'm Keith Aune. I'm with the Wildlife

Conservation Society, and the Wildlife Conservation

Society works worldwide to preserve wildlife and wild

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Page 44

1 places. We work in 60 countries.

 I'm going to confine my comments, because I really do

want to say there's been some really good comment that I

can support here. But WCS, in looking at this, is really

supporting Alternative B. It's very consistent with our

mission, and we think it's consistent the title of

national wildlife refuge. And so given that you are one

of the premier national wildlife refuges, I think the

wildlife emphasis makes sense.

 I do want to emphasize two other things. One is that

we're obviously very supportive of bison restoration. One

of the branches on our tree is the formation of the

American Bison Society over a hundred years ago. And we

are really working hard to look at the ecological

restoration of bison, which I think fits really well with

your theme of emphasizing ecological processes. But I

want to specifically say, I don't know how you can

emphasize ecological processes with the absence of a

keystone herbivore like bison, and so I really want to

encourage you to do that.

 The second thing is, I want you to really think about

bison and cattle. They are not necessarily an either/or

situation, and there's lots of places, lots of examples

across North America where agriculture and bison

conservation actually fit, and there are ways to do that.

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1 We should keep 

 The third thi

you're thinking 

to really do a g

ecosystem, you 

change. And th

emphasize it ag

landscape oper

create habitats 

important comm

resilience of thi

lose sight of tha

like this left in 

the world. So t

regard.

 So I want to 

We think this i

intact, and you 

should be brave 

wildlife.

 Thank you.

 MS. MAT

 MR. GRI

here in Bozema

I'm fourth gene

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1 mother's side.

 I could live 

really great, es

at other times f

 I wish you'd 

hear at these m

harmful. Well

42 permittees o

correctly. I'm 

the Chronicle, 

Phillips County

Government. B

would enlighte

going to be neg

there are. You

said, on your p

spend money. 

pouring money 

in 2009, the six 

property in the 

subsidies. So w

have any effec

 So I like B a

 Thank you.

 MS. MA

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VOLUME 2, Chapter 4—Public Hearing Testimony 365

ARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

A COURT REPORTING (406) 449-6380

13 (Pages 43 to 46)

Page 43

anagement document,

er with respect to

r as optimizing

ge. It should look

 managed

e different

emphasize wildlife.

D is political.

wildlife, you

 don't see how

sedly maximizes

hat supposedly

ose are the same if

s some kind of

atural

and leave in roads.

 job of a

the right sheet

e Wildlife

Conservation

ildlife and wild

Page 44

because I really do

ood comment that I

g at this, is really

sistent with our

e title of

 that you are one

s, I think the

ings. One is that

on restoration. One

ation of the

d years ago. And we

cological

really well with

processes. But I

how you can

he absence of a

 really want to

eally think about

rily an either/or

s of examples

re and bison

ways to do that.

Page 45

1 We should keep an open mind about that.

 The third thing I really want to emphasize is that if

you're thinking about ecological processes and really want

to really do a good job of restoring a fully functional

ecosystem, you have to be thinking about impending climate

change. And that was brought up once, but I want to

emphasize it again. From our perspective, bison in that

landscape operating as a keystone herbivore working to

create habitats for other species, building those

important community relationships, actually can enhance

resilience of this really critical landscape, and we can't

lose sight of that. There are very, very, very few places

like this left in the world; not just in North America, in

the world. So this is a very, very special place in that

regard.

 So I want to emphasize that we support Alternative B.

We think this is a really critical ecosystem that's still

intact, and you are the heart of that system and, as such,

should be brave and consistent in your messaging about

wildlife.

 Thank you.

 MS. MATHER: Yes.

 MR. GRIFFIN: My name is Paul Griffin. I live

here in Bozeman, and since it seems fashionable at times,

I'm fourth generation in the Gallatin Valley on my

2

3

4

5

6

7

8

9

10

11

12

13

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15

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Page 46

1 mother's side.

 I could live with either B or D. I think you've done

really great, especially considering some work we've seen

at other times from other agencies.

 I wish you'd expand the socioeconomic data, because we

hear at these meetings that this could be devastating or

harmful. Well, I think your plan mentions only

42 permittees on the whole Refuge, if I remember

correctly. I'm the Paul Griffin that wrote the letter to

the Chronicle, by the way, this morning outlining

Phillips County's economic connection to the Federal

Government. But I wish you would put that in, because it

would enlighten people about -- You said there wasn't

going to be negative effects, and I really don't think

there are. You've spent your money up there, like you

said, on your plans. Your people that live up there, they

spend money. But as a taxpayer, we federal taxpayers are

pouring money into a region of declining population. Just

in 2009, the six counties that border the Refuge or have

property in the Refuge received $54.4 million in USDA

subsidies. So what you guys do or don't do isn't going to

have any effect.

 So I like B and D, and have at it.

 Thank you.

 MS. MATHER: Thanks, Paul.

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CHERYL ROMSA COURT REPORTING (406) 449-6380

13 (Pages 43 to 46)

 Thank you.

 MS. MATHER: Thank you.

 Either of you guys.

 MR. AUNE: I guess I didn't sign the right sheet

there, so -- I'm Keith Aune. I'm with the Wildlife

Conservation Society, and the Wildlife Conservation

Society works worldwide to preserve wildlife and wild

19

20

21

22

23

24

25

Page 44

1 places. We work in 60 countries.

 I'm going to confine my comments, because I really do

want to say there's been some really good comment that I

can support here. But WCS, in looking at this, is really

supporting Alternative B. It's very consistent with our

mission, and we think it's consistent the title of

national wildlife refuge. And so given that you are one

of the premier national wildlife refuges, I think the

wildlife emphasis makes sense.

 I do want to emphasize two other things. One is that

we're obviously very supportive of bison restoration. One

of the branches on our tree is the formation of the

American Bison Society over a hundred years ago. And we

are really working hard to look at the ecological

restoration of bison, which I think fits really well with

your theme of emphasizing ecological processes. But I

want to specifically say, I don't know how you can

emphasize ecological processes with the absence of a

keystone herbivore like bison, and so I really want to

encourage you to do that.

 The second thing is, I want you to really think about

bison and cattle. They are not necessarily an either/or

situation, and there's lots of places, lots of examples

across North America where agriculture and bison

conservation actually fit, and there are ways to do that.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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25

should be brave and consistent in your messaging about

wildlife.

 Thank you.

 MS. MATHER: Yes.

 MR. GRIFFIN: My name is Paul Griffin. I live

here in Bozeman, and since it seems fashionable at times,

I'm fourth generation in the Gallatin Valley on my

19

20

21

22

23

24

25

Page 46

1 mother's side.

 I could live with either B or D. I think you've done

really great, especially considering some work we've seen

at other times from other agencies.

 I wish you'd expand the socioeconomic data, because we

hear at these meetings that this could be devastating or

harmful. Well, I think your plan mentions only

42 permittees on the whole Refuge, if I remember

correctly. I'm the Paul Griffin that wrote the letter to

the Chronicle, by the way, this morning outlining

Phillips County's economic connection to the Federal

Government. But I wish you would put that in, because it

would enlighten people about -- You said there wasn't

going to be negative effects, and I really don't think

there are. You've spent your money up there, like you

said, on your plans. Your people that live up there, they

spend money. But as a taxpayer, we federal taxpayers are

pouring money into a region of declining population. Just

in 2009, the six counties that border the Refuge or have

property in the Refuge received $54.4 million in USDA

subsidies. So what you guys do or don't do isn't going to

have any effect.

 So I like B and D, and have at it.

 Thank you.

 MS. MATHER: Thanks, Paul.

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 47

1 Anybody else?

 Yep.

 MR. GIBBS: My name is Chip Gibbs, and I've lived

in the Gallatin Valley for 22 years, but I'm from Malta,

and I think I can safely say that outside of maybe

Lesley Robinson, no one has spent more time in the Breaks

than me. I still have a lot of close ties there.

 I'm honestly opposed to B, C, and D. If it's not

broke, don't fix it. 3.7 percent of wilderness is plenty,

and I believe that if we put a vote to the state, people

would want more access to the public lands and not less.

 The Refuge has done a great job of preserving the

species. The amount of time that cattle are exposed on

the CMR isn't year around; I think that's a myth that's

out there. And no one is a better steward of the land

than those ranchers who have access to the CMR. And that

would be, I think, lost if it's put in the hands of

someone other than the people who are maintaining it

currently.

 MS. MATHER: Thanks, Chip.

 Anybody else?

 (No audible response.)

 MR. CRAWFORD: A lot of great comments and

questions. I'm sitting there jotting notes, going, Let's

see, which ones do Bill get? I'll answer the easy ones,

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Page 48

1 Bill can answer the tough ones.

 The first one we heard was the management philosophy

of the Fish and Wildlife Service compared to the other

agencies. And that's a great question. We got it last

night, as well.

 The Fish and Wildlife Service is the only federal

2

3

4

5

6

Page 49

1 It's basically -- you know, we're using our best hats, as

managers, as stewards of the land, to make a judgment call

as to are these areas still meeting those characteristics,

and sometimes it was a very difficult decision. We threw

some of those areas out there to get public comment from

folks and to get your thoughts on them, and I greatly

appreciate that. And from what we have heard these past

two nights, we definitely need to go back and look at some

of those areas closely.

 We did contract out the economic analysis. We

contracted with USGS out of Boulder. They've been used by

several national wildlife refuges and other federal

agencies to do economic analysis. They are economists.

They did look at the loss of grazing or the potential loss

of grazing, they looked at the potential revenue that

could be generated by expanding public use opportunities,

and they plugged it all into their computer models. And

I'm not an economist, so I don't understand all of it, but

I do feel that they did a very thorough job in looking at

the economic analysis of each of the alternatives.

 CMR provides less than one percent of the total

grazing that is found in the six counties that surround

the Refuge. Obviously, as we make changes to the grazing

programs, it could have an effect on the individual

rancher, that's no doubt. There are several ranchers that

2

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Page 50

1 do rely upon that CMR grazing permit for their ranching

operation.

 As we move forward, after the CCP is finalized, the

next step is developing the step-down management plans,

and one of the first ones that will be developed is called

the habitat management plan, and that's where the Refuge

2

3

4

5

6

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING (

Page 47

1 Anybody else?

 Yep.

 MR. GIBBS: My name is Chip Gibbs, and I've lived

in the Gallatin Valley for 22 years, but I'm from Malta,

and I think I can safely say that outside of maybe

Lesley Robinson, no one has spent more time in the Breaks

than me. I still have a lot of close ties there.

 I'm honestly opposed to B, C, and D. If it's not

broke, don't fix it. 3.7 percent of wilderness is plenty,

and I believe that if we put a vote to the state, people

would want more access to the public lands and not less.

 The Refuge has done a great job of preserving the

species. The amount of time that cattle are exposed on

the CMR isn't year around; I think that's a myth that's

out there. And no one is a better steward of the land

than those ranchers who have access to the CMR. And that

would be, I think, lost if it's put in the hands of

someone other than the people who are maintaining it

currently.

 MS. MATHER: Thanks, Chip.

 Anybody else?

 (No audible response.)

 MR. CRAWFORD: A lot of great comments and

questions. I'm sitting there jotting notes, going, Let's

see, which ones do Bill get? I'll answer the easy ones,

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Page 48

1 Bill can answer the tough ones.

 The first one we heard was the management philosophy

of the Fish and Wildlife Service compared to the other

agencies. And that's a great question. We got it last

night, as well.

 The Fish and Wildlife Service is the only federal

agency that's mandated to manage for fish, wildlife, and

their habitats, as compared to, say, the Forest Service or

the BLM, which has a multiple-use mandate, where they're

to try to balance all of the uses, economic uses, such as

grazing, mineral exploration, off-road vehicle travel,

hunting, fishing, you know, all that sort of stuff. So

that's basically the primary difference, is, we are here

for wildlife and wildlife habitats. It's a very clear,

distinct mission that we have, and it was emphasized or

strengthened with the passage of the National Wildlife

Refuge System Improvement Act in 1997. That's basically

our organic legislation.

 A clarification of wilderness elimination versus

proposed wilderness. As part of the CCP process, we are

to evaluate all of our proposed wilderness areas to make

sure that they still meet those wilderness characteristics

that were identified back when they were proposed, and so

that's what we did, and we also looked at them as compared

to the theme of the alternatives. And it is subjective.

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1 It's basica

managers

as to are t

and somet

some of th

folks and 

appreciate 

two night

of those a

 We did 

contracted 

several na

agencies t

They did 

of grazing

could be g

and they p

I'm not an 

I do feel t

the econo

 CMR p

grazing th

the Refug

programs

rancher, th

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1 do rely up

operation

 As we 

next step 

and one o

the habita

will look 

final plan

habitat ob

detailed p

permittee

program, 

still meet 

 When 

areas, we 

areas. W

eliminatin

did propo

call. It w

looking a

again, did 

 Let's se

would be 

alternativ

 We gav

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366 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

14 (Pages 47 to 50)

Page 47

s, and I've lived

from Malta,

maybe

me in the Breaks

.

t's not

s is plenty,

te, people

 and not less.

rving the

exposed on

myth that's

f the land

CMR. And that

s of

ntaining it

mments and

oing, Let's

 easy ones,

Page 48

ent philosophy

o the other

got it last

 federal

wildlife, and

st Service or

e, where they're

ses, such as

le travel,

tuff. So

e are here

 clear,

mphasized or

al Wildlife

That's basically

versus

rocess, we are

reas to make

aracteristics

oposed, and so

em as compared

ubjective.

Page 49

1 It's basically -- you know, we're using our best hats, as

managers, as stewards of the land, to make a judgment call

as to are these areas still meeting those characteristics,

and sometimes it was a very difficult decision. We threw

some of those areas out there to get public comment from

folks and to get your thoughts on them, and I greatly

appreciate that. And from what we have heard these past

two nights, we definitely need to go back and look at some

of those areas closely.

 We did contract out the economic analysis. We

contracted with USGS out of Boulder. They've been used by

several national wildlife refuges and other federal

agencies to do economic analysis. They are economists.

They did look at the loss of grazing or the potential loss

of grazing, they looked at the potential revenue that

could be generated by expanding public use opportunities,

and they plugged it all into their computer models. And

I'm not an economist, so I don't understand all of it, but

I do feel that they did a very thorough job in looking at

the economic analysis of each of the alternatives.

 CMR provides less than one percent of the total

grazing that is found in the six counties that surround

the Refuge. Obviously, as we make changes to the grazing

programs, it could have an effect on the individual

rancher, that's no doubt. There are several ranchers that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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Page 50

1 do rely upon that CMR grazing permit for their ranching

operation.

 As we move forward, after the CCP is finalized, the

next step is developing the step-down management plans,

and one of the first ones that will be developed is called

the habitat management plan, and that's where the Refuge

will look at the CCP and look at what was adopted as the

final plan. And in order to meet those wildlife and/or

habitat objectives, they will get down and develop a very

detailed plan, and working with those ranchers or current

permittees in order to implement a prescriptive grazing

program, so that we can fulfill our mission and hopefully

still meet the needs of our neighbors, as well.

 When we were looking at expanding at the wilderness

areas, we did not eliminate any roads to expand wilderness

areas. We basically confined them so that we wouldn't be

eliminating roads if we expanded areas. The roads that we

did propose to eliminate, again, it's another subjective

call. It was a best management looking at the area and

looking at fragmentation, looking at disturbance, and,

again, did it meet the overall theme of the alternative.

 Let's see, how did we come up with the roads that

would be eliminated and not eliminated between the

alternatives? Bill, you want that one?

 We gave Bill a red pen.

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CHERYL ROMSA COURT REPORTING (406) 449-6380

14 (Pages 47 to 50)

currently.

 MS. MATHER: Thanks, Chip.

 Anybody else?

 (No audible response.)

 MR. CRAWFORD: A lot of great comments and

questions. I'm sitting there jotting notes, going, Let's

see, which ones do Bill get? I'll answer the easy ones,

19

20

21

22

23

24

25

Page 48

1 Bill can answer the tough ones.

 The first one we heard was the management philosophy

of the Fish and Wildlife Service compared to the other

agencies. And that's a great question. We got it last

night, as well.

 The Fish and Wildlife Service is the only federal

agency that's mandated to manage for fish, wildlife, and

their habitats, as compared to, say, the Forest Service or

the BLM, which has a multiple-use mandate, where they're

to try to balance all of the uses, economic uses, such as

grazing, mineral exploration, off-road vehicle travel,

hunting, fishing, you know, all that sort of stuff. So

that's basically the primary difference, is, we are here

for wildlife and wildlife habitats. It's a very clear,

distinct mission that we have, and it was emphasized or

strengthened with the passage of the National Wildlife

Refuge System Improvement Act in 1997. That's basically

our organic legislation.

 A clarification of wilderness elimination versus

proposed wilderness. As part of the CCP process, we are

to evaluate all of our proposed wilderness areas to make

sure that they still meet those wilderness characteristics

that were identified back when they were proposed, and so

that's what we did, and we also looked at them as compared

to the theme of the alternatives. And it is subjective.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

I do feel that they did a very thorough job in looking at

the economic analysis of each of the alternatives.

 CMR provides less than one percent of the total

grazing that is found in the six counties that surround

the Refuge. Obviously, as we make changes to the grazing

programs, it could have an effect on the individual

rancher, that's no doubt. There are several ranchers that

19

20

21

22

23

24

25

Page 50

1 do rely upon that CMR grazing permit for their ranching

operation.

 As we move forward, after the CCP is finalized, the

next step is developing the step-down management plans,

and one of the first ones that will be developed is called

the habitat management plan, and that's where the Refuge

will look at the CCP and look at what was adopted as the

final plan. And in order to meet those wildlife and/or

habitat objectives, they will get down and develop a very

detailed plan, and working with those ranchers or current

permittees in order to implement a prescriptive grazing

program, so that we can fulfill our mission and hopefully

still meet the needs of our neighbors, as well.

 When we were looking at expanding at the wilderness

areas, we did not eliminate any roads to expand wilderness

areas. We basically confined them so that we wouldn't be

eliminating roads if we expanded areas. The roads that we

did propose to eliminate, again, it's another subjective

call. It was a best management looking at the area and

looking at fragmentation, looking at disturbance, and,

again, did it meet the overall theme of the alternative.

 Let's see, how did we come up with the roads that

would be eliminated and not eliminated between the

alternatives? Bill, you want that one?

 We gave Bill a red pen.

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 51

1 MR. BERG: It wasn't that easy.

 A couple things we looked at. Under B, you know, with

the wildlife emphasis that we had under that alternative,

we looked at roads more from a standpoint of creating

secure areas for populations or groups of elk, kind of

scattering them more across the landscape. And we've done

this to some extent already in a few areas on the Refuge,

but under Alternative B, we expanded on that to create the

security areas where they're not disturbed via motor

vehicles and things like that. So we took a real

aggressive approach to that management tool under B.

 Under D, we tried to compromise a little bit; still

closed some areas to provide more security habitat for

different species, including pronghorn antelope and elk

and deer. There's kind of a common theme out there that

if we can reduce the visual and traffic impacts, mainly

during hunting season, by closing some roads, create some

valleys or coulees in between where those animals aren't

getting disturbed, we can keep those animals spread out

over a larger landscape. So that was kind of what we

looked at. There's several studies, you know, nationwide

where that's been shown to impact use of certain areas, by

big game species especially.

 Again, some of the road closures were also dependent

on the type of land ownership that was involved. I'm

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Page 52

1 guessing about five miles was closed because of the fact

that the private land ownership that wasn't refuge lands

did create that exclusive use situation where a private

landowner closed that road. And that was one of the

questions Corey's dad had. We've tried to do that over

the past several years, not allow for an exclusive use,

2

3

4

5

6

Page 53

1 came up with the fact that those areas were not being used

as much as they should be because of that motorized use,

we could limit that activity in certain areas, no

different than we do a road. There's some joint

jurisdictional issues there that we would have to

coordinate with the other agencies, mainly the Corps of

Engineers, the State of Montana, not much unlike what's

being done on some of the rivers where they restrict

motorized use during certain times of the year. So that

would be a coordinated effort between several groups.

 What we chose to do after the scoping process was to

monitor some of the use on the river itself. We're in the

process of doing that, just to get a handle on it. Over

the years, we have noticed a pretty significant increase

in motorized use on the river, and also on the lake, but

mainly on the river where those river bottoms are so

important to wildlife, especially later on in the season.

 MR. CRAWFORD: Some of the other stuff that we

heard today.

 Glenn, make sure you see me before you leave.

 One thing that a couple of people resonated on was

Fish and Wildlife Service losing their way, species

management versus habitat management. And I can tell you

that as a staff, we wrestled in formulating Alternative B

and Alternative D. All of us went to school, got our

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Page 54

1 wildlife biology degree; you know, that's what it says,

wildlife biology. It doesn't say habitat biology. And

so, obviously, you go on to get an advanced degree,

99 percent of us study big critters with fur and teeth,

you know. I studied coyotes and wolves, okay? So I'm a

large carnivore guy. Very few of us go out and study

2

3

4

5

6

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (406

Page 51

1 MR. BERG: It wasn't that easy.

 A couple things we looked at. Under B, you know, with

the wildlife emphasis that we had under that alternative,

we looked at roads more from a standpoint of creating

secure areas for populations or groups of elk, kind of

scattering them more across the landscape. And we've done

this to some extent already in a few areas on the Refuge,

but under Alternative B, we expanded on that to create the

security areas where they're not disturbed via motor

vehicles and things like that. So we took a real

aggressive approach to that management tool under B.

 Under D, we tried to compromise a little bit; still

closed some areas to provide more security habitat for

different species, including pronghorn antelope and elk

and deer. There's kind of a common theme out there that

if we can reduce the visual and traffic impacts, mainly

during hunting season, by closing some roads, create some

valleys or coulees in between where those animals aren't

getting disturbed, we can keep those animals spread out

over a larger landscape. So that was kind of what we

looked at. There's several studies, you know, nationwide

where that's been shown to impact use of certain areas, by

big game species especially.

 Again, some of the road closures were also dependent

on the type of land ownership that was involved. I'm

2

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5

6

7

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10

11

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Page 52

1 guessing about five miles was closed because of the fact

that the private land ownership that wasn't refuge lands

did create that exclusive use situation where a private

landowner closed that road. And that was one of the

questions Corey's dad had. We've tried to do that over

the past several years, not allow for an exclusive use,

but where a road does access either state land or private

land, by law, we can't close that road; you know, we can't

deny historical access to that. So in some of those

situations, there is somewhat of an exclusive use. But,

say, where we had a road that was totally on the Refuge,

but there was a private parcel off the Refuge that created

that exclusive use, we then did close the road so that,

you know, it was the same for everybody, so to speak.

 I'm not sure that answered question.

 Should I go on here?

 MR. CRAWFORD: Give the authority for managing

the lake and the river and the jet boats.

 MR. BERG: A question came up last night also

about jet boat use and our authority to manage that on the

river, and it came up earlier during the scoping process

also, if we were to determine or evaluate the impacts of,

say, large jet boat use or large boats that have

high-decibel motors on them that affects the use of those

river bottoms by wildlife. If we were to determine or

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1 came up with th

as much as they 

we could limit 

different than w

jurisdictional is

coordinate with 

Engineers, the 

being done on s

motorized use d

would be a coo

 What we cho

monitor some o

process of doin

the years, we h

in motorized us

mainly on the r

important to wi

 MR. CRA

heard today.

 Glenn, make 

 One thing th

Fish and Wildli

management ve

that as a staff, w

and Alternative 

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1 wildlife biology 

wildlife biology

so, obviously, y

99 percent of u

you know. I stu

large carnivore 

plants. And so 

things with fur 

chokecherry an

Bob is the exce

 And so as we

okay, do we co

habitat? When 

if you increase 

are you doing g

should measure 

though those pl

a lot easier to c

 And so we k

decided on was

concentration tw

what Olaus Mu

1935 and did hi

the western par

elk and the Serv

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VOLUME 2, Chapter 4—Public Hearing Testimony 367

ARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

SA COURT REPORTING (406) 449-6380

15 (Pages 51 to 54)

Page 51

er B, you know, with

er that alternative,

point of creating

 of elk, kind of

ape. And we've done

eas on the Refuge,

 on that to create the

bed via motor

ok a real

ent tool under B.

little bit; still

urity habitat for

 antelope and elk

heme out there that

impacts, mainly

e roads, create some

hose animals aren't

nimals spread out

ind of what we

 know, nationwide

 of certain areas, by

ere also dependent

 involved. I'm

Page 52

because of the fact

asn't refuge lands

where a private

 was one of the

d to do that over

n exclusive use,

ate land or private

 you know, we can't

ome of those

clusive use. But,

ally on the Refuge,

Refuge that created

he road so that,

ody, so to speak.

.

uthority for managing

.

p last night also

 manage that on the

e scoping process

ate the impacts of,

hat have

cts the use of those

to determine or

Page 53

1 came up with the fact that those areas were not being used

as much as they should be because of that motorized use,

we could limit that activity in certain areas, no

different than we do a road. There's some joint

jurisdictional issues there that we would have to

coordinate with the other agencies, mainly the Corps of

Engineers, the State of Montana, not much unlike what's

being done on some of the rivers where they restrict

motorized use during certain times of the year. So that

would be a coordinated effort between several groups.

 What we chose to do after the scoping process was to

monitor some of the use on the river itself. We're in the

process of doing that, just to get a handle on it. Over

the years, we have noticed a pretty significant increase

in motorized use on the river, and also on the lake, but

mainly on the river where those river bottoms are so

important to wildlife, especially later on in the season.

 MR. CRAWFORD: Some of the other stuff that we

heard today.

 Glenn, make sure you see me before you leave.

 One thing that a couple of people resonated on was

Fish and Wildlife Service losing their way, species

management versus habitat management. And I can tell you

that as a staff, we wrestled in formulating Alternative B

and Alternative D. All of us went to school, got our

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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Page 54

1 wildlife biology degree; you know, that's what it says,

wildlife biology. It doesn't say habitat biology. And

so, obviously, you go on to get an advanced degree,

99 percent of us study big critters with fur and teeth,

you know. I studied coyotes and wolves, okay? So I'm a

large carnivore guy. Very few of us go out and study

plants. And so it's a lot easier for us to relate to

things with fur than it is to winterfat and saltbush and

chokecherry and buffaloberry, except for people like Bob.

Bob is the exception to the rule.

 And so as we're formulating this plan, it was like,

okay, do we concentrate on wildlife? Do we concentrate on

habitat? When you're forming objectives and strategies,

if you increase winterfat and buffaloberry on the Refuge,

are you doing good things for wildlife? Well, maybe we

should measure wildlife and make sure that by increasing

though those plants, we are doing good things. Well, it's

a lot easier to count plants than it is to count wildlife.

 And so we kept wrestling back and forth, and what we

decided on was, Alternative B would have this wildlife

concentration twist to it. And we were basically using

what Olaus Murie had identified when he came out here in

1935 and did his original biological survey, where he said

the western part of the Refuge was really important for

elk and the Service should concentrate on elk in this

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CHERYL ROMSA COURT REPORTING (406) 449-6380

15 (Pages 51 to 54)

getting disturbed, we can keep those animals spread out

over a larger landscape. So that was kind of what we

looked at. There's several studies, you know, nationwide

where that's been shown to impact use of certain areas, by

big game species especially.

 Again, some of the road closures were also dependent

on the type of land ownership that was involved. I'm

19

20

21

22

23

24

25

Page 52

1 guessing about five miles was closed because of the fact

that the private land ownership that wasn't refuge lands

did create that exclusive use situation where a private

landowner closed that road. And that was one of the

questions Corey's dad had. We've tried to do that over

the past several years, not allow for an exclusive use,

but where a road does access either state land or private

land, by law, we can't close that road; you know, we can't

deny historical access to that. So in some of those

situations, there is somewhat of an exclusive use. But,

say, where we had a road that was totally on the Refuge,

but there was a private parcel off the Refuge that created

that exclusive use, we then did close the road so that,

you know, it was the same for everybody, so to speak.

 I'm not sure that answered question.

 Should I go on here?

 MR. CRAWFORD: Give the authority for managing

the lake and the river and the jet boats.

 MR. BERG: A question came up last night also

about jet boat use and our authority to manage that on the

river, and it came up earlier during the scoping process

also, if we were to determine or evaluate the impacts of,

say, large jet boat use or large boats that have

high-decibel motors on them that affects the use of those

river bottoms by wildlife. If we were to determine or

2

3

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5

6

7

8

9

10

11

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heard today.

 Glenn, make sure you see me before you leave.

 One thing that a couple of people resonated on was

Fish and Wildlife Service losing their way, species

management versus habitat management. And I can tell you

that as a staff, we wrestled in formulating Alternative B

and Alternative D. All of us went to school, got our

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1 wildlife biology degree; you know, that's what it says,

wildlife biology. It doesn't say habitat biology. And

so, obviously, you go on to get an advanced degree,

99 percent of us study big critters with fur and teeth,

you know. I studied coyotes and wolves, okay? So I'm a

large carnivore guy. Very few of us go out and study

plants. And so it's a lot easier for us to relate to

things with fur than it is to winterfat and saltbush and

chokecherry and buffaloberry, except for people like Bob.

Bob is the exception to the rule.

 And so as we're formulating this plan, it was like,

okay, do we concentrate on wildlife? Do we concentrate on

habitat? When you're forming objectives and strategies,

if you increase winterfat and buffaloberry on the Refuge,

are you doing good things for wildlife? Well, maybe we

should measure wildlife and make sure that by increasing

though those plants, we are doing good things. Well, it's

a lot easier to count plants than it is to count wildlife.

 And so we kept wrestling back and forth, and what we

decided on was, Alternative B would have this wildlife

concentration twist to it. And we were basically using

what Olaus Murie had identified when he came out here in

1935 and did his original biological survey, where he said

the western part of the Refuge was really important for

elk and the Service should concentrate on elk in this

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 55

1 area; and the Mickey-Brandon Butte/Timber Creek area is

really good for bighorn sheep, and the Service should

concentrate on bighorn sheep management here; and the

southern part of the Refuge and the western part of the

Refuge is really good mule deer habitat, and the Service

should emphasize that; and the Service needs to expand

sharp-tail grouse management over on the eastern side. So

that was kind of the basis that we used to form

Alternative B.

 When we went to do Alternative D, we decided to take a

little different spin, saying, yes, wildlife is very

important, but what drives the wildlife species? You

know, it's those ecological processes and it's the

habitat. So we wanted to put more emphasis on habitat,

monitoring habitat, management, implementing processes,

and basically "build it, the wildlife will come" kind of

approach.

 So, you know, as biologists, we're conflicted between

those two, which one's best kind of a thing. And what we

tried to do was try to strike a balance. We went through

one phase of the plan, where we had no wildlife objectives

in Alternative D, it was all habitat objectives, and we

said, No, we really can't do that; we need some wildlife

objectives in D, we need some plant objectives in B. And

so that's kind of how we ended up at that point. So I

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1 hope that -- It's kind of a long, roundabout way to

address that point, but I hope that helps to clarify

B and D.

 Let's see, did we look at analysis of prairie

grassland ecosystems and wilderness and how much is

protected? No, we did not, to be perfectly honest. We

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1 a little bit of a summary as to where we're at.

 Approximately two years ago, we went through a pretty

in-depth analysis of sheep habitat in the Breaks on

CMR Refuge, looked at the slope, some of the grassy

knolls, the roughness characteristics of the area,

especially south of the river in Garfield County. At the

same time we were doing that, State Fish, Wildlife & Parks

was developing a conservation plan for bighorn sheep in

the state of Montana that put together some criteria for

reintroductions, things like proximity to domestic sheep,

potential impact to private lands, things like that. We

proposed to do a reintroduction in Garfield County, early

stages of that. There wasn't a formal proposal on the

table that was supported by all groups. We did a little

bit of an analysis with the landowners in the area. At

the same time, Fish, Wildlife & Parks conducted their own

analysis.

 At this time, it doesn't appear that there is support

for that from the landowners that live in that area. I

think potentially in the future that could happen. If

you'll look at the sheep industry -- domestic sheep

industry, it's kind of decreasing as far as numbers of

sheep in that part of Montana, so the potential is there.

If sheep were to move in there on their own, that would

probably be the best-case scenario, versus doing an actual

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1 reintroduction. But we're hopeful that that will occur at

some point in the future.

 There was also a question regarding, I believe,

selling or transferring grazing permits. And just so

people understand, one of the tools that we will use on

the Refuge in the future to manage habitat will be

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AN

CHERYL ROMSA COURT REPORTING (

Page 55

1 area; and the Mickey-Brandon Butte/Timber Creek area is

really good for bighorn sheep, and the Service should

concentrate on bighorn sheep management here; and the

southern part of the Refuge and the western part of the

Refuge is really good mule deer habitat, and the Service

should emphasize that; and the Service needs to expand

sharp-tail grouse management over on the eastern side. So

that was kind of the basis that we used to form

Alternative B.

 When we went to do Alternative D, we decided to take a

little different spin, saying, yes, wildlife is very

important, but what drives the wildlife species? You

know, it's those ecological processes and it's the

habitat. So we wanted to put more emphasis on habitat,

monitoring habitat, management, implementing processes,

and basically "build it, the wildlife will come" kind of

approach.

 So, you know, as biologists, we're conflicted between

those two, which one's best kind of a thing. And what we

tried to do was try to strike a balance. We went through

one phase of the plan, where we had no wildlife objectives

in Alternative D, it was all habitat objectives, and we

said, No, we really can't do that; we need some wildlife

objectives in D, we need some plant objectives in B. And

so that's kind of how we ended up at that point. So I

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1 hope that -- It's kind of a long, roundabout way to

address that point, but I hope that helps to clarify

B and D.

 Let's see, did we look at analysis of prairie

grassland ecosystems and wilderness and how much is

protected? No, we did not, to be perfectly honest. We

looked only at our areas inside the Refuge and based those

decisions on, in our minds, were those areas still meeting

their wilderness characteristics?

 Climate change, we heard that last night. We do have

in the document, on page 84 and 85, some objectives for

climate change. A lot of research-type projects, looking

at building resilience. Resilient habitats are better

adapted to dealing with climate change than habitats that

aren't resilient. We are looking at prescribed fire, the

effects of prescribed fire and smoke, what does that

contribute, versus wildfire and smoke. And there's a

couple of pretty good studies out there that shows that

through prescribed fire, you actually sequester quite a

bit of carbon. And so, yeah, you're putting smoke into

the air, but you're also sequestering lots of carbon into

the soil that it's bound up for a long time. And we would

like to expand that research and do more of it.

 MR. BERG: There was a question raised about

bighorn sheep, and I thought maybe I'd just give the group

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1 a little bit 

 Approx

in-depth a

CMR Ref

knolls, th

especially 

same time 

was deve

the state o

reintrodu

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table that 

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the same 

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 At this 

for that fr

think pote

you'll loo

industry, 

sheep in t

If sheep w

probably 

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1 reintrodu

some poi

 There 

selling or 

people un

the Refug

livestock

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choose to

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permit to 

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gives the

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opportun

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 Where 

where, sa

member 

more like

recreatio

are no di

rancher c

basically

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368 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

ING - DRAFT CCP AND EIS FOR CMR AND UL BEND

COURT REPORTING (406) 449-6380

16 (Pages 55 to 58)

Page 55

r Creek area is

ce should

here; and the

 part of the

d the Service

ds to expand

astern side. So

rm

ecided to take a

very

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Page 56

way to

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 We do have

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 smoke into

carbon into

And we would

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 give the group

Page 57

1 a little bit of a summary as to where we're at.

 Approximately two years ago, we went through a pretty

in-depth analysis of sheep habitat in the Breaks on

CMR Refuge, looked at the slope, some of the grassy

knolls, the roughness characteristics of the area,

especially south of the river in Garfield County. At the

same time we were doing that, State Fish, Wildlife & Parks

was developing a conservation plan for bighorn sheep in

the state of Montana that put together some criteria for

reintroductions, things like proximity to domestic sheep,

potential impact to private lands, things like that. We

proposed to do a reintroduction in Garfield County, early

stages of that. There wasn't a formal proposal on the

table that was supported by all groups. We did a little

bit of an analysis with the landowners in the area. At

the same time, Fish, Wildlife & Parks conducted their own

analysis.

 At this time, it doesn't appear that there is support

for that from the landowners that live in that area. I

think potentially in the future that could happen. If

you'll look at the sheep industry -- domestic sheep

industry, it's kind of decreasing as far as numbers of

sheep in that part of Montana, so the potential is there.

If sheep were to move in there on their own, that would

probably be the best-case scenario, versus doing an actual

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Page 58

1 reintroduction. But we're hopeful that that will occur at

some point in the future.

 There was also a question regarding, I believe,

selling or transferring grazing permits. And just so

people understand, one of the tools that we will use on

the Refuge in the future to manage habitat will be

livestock, so it's important that we have livestock

operators in and around CMR. For those permittees that

choose to, say, maintain a family ranch or continue to

keep the ranch in ownership, by policy, we transfer that

permit to a son, daughter, grandson, granddaughter,

spouse, or whatever, if that permittee so chooses. That

gives them the privilege of grazing on CMR when that

grazing is available. So that's one thing we're doing to

try to continue that tradition, but also provide that

opportunity for that family to basically stay on the

landscape.

 Where we don't transfer the permit is a situation

where, say, a longtime rancher doesn't have a family

member that wants to continue the business or, which is

more likely to happen, that ranch value is higher as a

recreational property, so the prices that are being paid

are no different than around this area. You know, a

rancher couldn't afford to buy it for that price,

basically. So in those cases where it sells to that third

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CHERYL ROMSA COURT REPORTING (406) 449-6380

16 (Pages 55 to 58)

those two, which ones best kind of a thing. And what we

tried to do was try to strike a balance. We went through

one phase of the plan, where we had no wildlife objectives

in Alternative D, it was all habitat objectives, and we

said, No, we really can't do that; we need some wildlife

objectives in D, we need some plant objectives in B. And

so that's kind of how we ended up at that point. So I

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1 hope that -- It's kind of a long, roundabout way to

address that point, but I hope that helps to clarify

B and D.

 Let's see, did we look at analysis of prairie

grassland ecosystems and wilderness and how much is

protected? No, we did not, to be perfectly honest. We

looked only at our areas inside the Refuge and based those

decisions on, in our minds, were those areas still meeting

their wilderness characteristics?

 Climate change, we heard that last night. We do have

in the document, on page 84 and 85, some objectives for

climate change. A lot of research-type projects, looking

at building resilience. Resilient habitats are better

adapted to dealing with climate change than habitats that

aren't resilient. We are looking at prescribed fire, the

effects of prescribed fire and smoke, what does that

contribute, versus wildfire and smoke. And there's a

couple of pretty good studies out there that shows that

through prescribed fire, you actually sequester quite a

bit of carbon. And so, yeah, you're putting smoke into

the air, but you're also sequestering lots of carbon into

the soil that it's bound up for a long time. And we would

like to expand that research and do more of it.

 MR. BERG: There was a question raised about

bighorn sheep, and I thought maybe I'd just give the group

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for that from the landowners that live in that area. I

think potentially in the future that could happen. If

you'll look at the sheep industry -- domestic sheep

industry, it's kind of decreasing as far as numbers of

sheep in that part of Montana, so the potential is there.

If sheep were to move in there on their own, that would

probably be the best-case scenario, versus doing an actual

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24

25

Page 58

1 reintroduction. But we're hopeful that that will occur at

some point in the future.

 There was also a question regarding, I believe,

selling or transferring grazing permits. And just so

people understand, one of the tools that we will use on

the Refuge in the future to manage habitat will be

livestock, so it's important that we have livestock

operators in and around CMR. For those permittees that

choose to, say, maintain a family ranch or continue to

keep the ranch in ownership, by policy, we transfer that

permit to a son, daughter, grandson, granddaughter,

spouse, or whatever, if that permittee so chooses. That

gives them the privilege of grazing on CMR when that

grazing is available. So that's one thing we're doing to

try to continue that tradition, but also provide that

opportunity for that family to basically stay on the

landscape.

 Where we don't transfer the permit is a situation

where, say, a longtime rancher doesn't have a family

member that wants to continue the business or, which is

more likely to happen, that ranch value is higher as a

recreational property, so the prices that are being paid

are no different than around this area. You know, a

rancher couldn't afford to buy it for that price,

basically. So in those cases where it sells to that third

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TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

Page 59

1 unrelated party and is used for a different purpose,

whether it's recreational or paleo or just the fact that

they want a scenic place to build a cabin, we do not

transfer that permit to the next owner. So what we would

do, then, is put it in the prescriptive grazing regime,

like we talked about. Then that pasture or that unit or

area would then be used as kind of a rotational system

with existing permittees.

 So a little bit different policy on how we handle

those kind of permits.

 MR. CRAWFORD: I think we had one more question

that was looking at possible food plots in some of our

river bottom restorations. In B, where we're talking

about synthetic methods, we're looking at using farming to

help restore those areas; basically, go in and clean them

up of weeds, and then after a couple of years we could go

in and plant native vegetation. So we'd consider some

type of alfalfa or cereal grain crop that refuge staff

would plant under Alternative B, basically so we could go

in there and clean up the weeds and then put it back to a

native grass/shrubland mix after that.

 Under Alternative C, we'd basically be doing the same

thing, except we'd use cooperative farmers. And,

basically, cooperative farmers are permittees that come in

under a special use permit, plant an identified crop that

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1 they then harvest, but they're putting all the time and

energy into planting and maintaining that crop. Their

return is basically harvesting that crop. And at the end

of the contract period, we have a field that's weed-free

that we can then go back and restore native plants to.

 In Alternative D, we're not proposing to use food

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Page 61

 COURT REPORTER'S CERTIFICATE

STATE OF MONTANA )

 ss.

COUNTY OF LEWIS AND CLARK )

 I, CHERYL ROMSA, Court Reporter, Notary Public in

and for the County of Lewis and Clark, State of Montana,

do hereby certify:

 That the foregoing proceedings were reported by

me in shorthand and later transcribed into typewriting;

and that the -60- pages contain a true record of the

proceedings to the best of my ability.

 DATED this 19th day of October 2010.

 s/Cheryl A. Romsa

 CHERYL A. ROMSA

TRANSCRIPT OF PUBLIC HEARING - DRAFT CCP AND E

CHERYL ROMSA COURT REPORTING (40

Page 59

1 unrelated party and is used for a different purpose,

whether it's recreational or paleo or just the fact that

they want a scenic place to build a cabin, we do not

transfer that permit to the next owner. So what we would

do, then, is put it in the prescriptive grazing regime,

like we talked about. Then that pasture or that unit or

area would then be used as kind of a rotational system

with existing permittees.

 So a little bit different policy on how we handle

those kind of permits.

 MR. CRAWFORD: I think we had one more question

that was looking at possible food plots in some of our

river bottom restorations. In B, where we're talking

about synthetic methods, we're looking at using farming to

help restore those areas; basically, go in and clean them

up of weeds, and then after a couple of years we could go

in and plant native vegetation. So we'd consider some

type of alfalfa or cereal grain crop that refuge staff

would plant under Alternative B, basically so we could go

in there and clean up the weeds and then put it back to a

native grass/shrubland mix after that.

 Under Alternative C, we'd basically be doing the same

thing, except we'd use cooperative farmers. And,

basically, cooperative farmers are permittees that come in

under a special use permit, plant an identified crop that

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1 they then harvest, but they're putting all the time and

energy into planting and maintaining that crop. Their

return is basically harvesting that crop. And at the end

of the contract period, we have a field that's weed-free

that we can then go back and restore native plants to.

 In Alternative D, we're not proposing to use food

plots. We'd just basically go in and, through the use of

fire and herbicides, reduce the weeds in those areas and

then go back in and follow up with a native planting.

 So that's the difference in B, C, and D in the river

bottom restorations.

 I think we've covered most of the questions.

 Again, we appreciate everybody coming out, and we'll

be here if you want to talk one-on-one with any of the

staff members. Several of our folks are in the back.

Randy is the wildlife biologist, Mike's the fire

management officer, Matt DeRosier is the station manager

at Sand Creek, Dan Harrell is the biologist out at

Sand Creek, and Bob Skinner is the habitat biologist in

Lewistown. So we're all here to address any questions

that you may have.

 Thanks.

 (The proceedings were concluded at 7:13 p.m.)

 * * * * * * *

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 COUR

STATE OF MO

 

COUNTY OF L

 I, CHERY

and for the Cou

do hereby certif

 That the f

me in shorthand 

and that the -60

proceedings to 

 DATED t

 

 
VOLUME 2, Chapter 4—Public Hearing Testimony 369

ARING - DRAFT CCP AND EIS FOR CMR AND UL BEND

A COURT REPORTING (406) 449-6380

17 (Pages 59 to 61)

Page 59

nt purpose,

 the fact that

n, we do not

So what we would

zing regime,

 or that unit or

tational system

 we handle

ad one more question

n some of our

we're talking

at using farming to

n and clean them

years we could go

 consider some

refuge staff

ally so we could go

n put it back to a

be doing the same

ers. And,

ittees that come in

ntified crop that

Page 60

ll the time and

hat crop. Their

. And at the end

 that's weed-free

ative plants to.

ng to use food

hrough the use of

n those areas and

native planting.

 D in the river

uestions.

ming out, and we'll

 with any of the

re in the back.

 the fire

 the station manager

ogist out at

abitat biologist in

ss any questions

t 7:13 p.m.)

Page 61

 COURT REPORTER'S CERTIFICATE

STATE OF MONTANA )

 ss.

COUNTY OF LEWIS AND CLARK )

 I, CHERYL ROMSA, Court Reporter, Notary Public in

and for the County of Lewis and Clark, State of Montana,

do hereby certify:

 That the foregoing proceedings were reported by

me in shorthand and later transcribed into typewriting;

and that the -60- pages contain a true record of the

proceedings to the best of my ability.

 DATED this 19th day of October 2010.

 s/Cheryl A. Romsa

 CHERYL A. ROMSA
370 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 1

 PUBLIC HEARING FOR THE CMR NATIONAL WILDLIFE REFUGE

 CONDUCTED BY THE US FISH AND WILDLIFE SERVICE

 Great Falls, Montana

 September 30, 2010

 7:00 o'clock p.m. 

PANEL:

Barron Crawford, Bill Berg, and Laurie Shannon 

PUBLIC SPEAKERS: 

Dyrek VanHyning, Dan Bennett, Wes Murray, Aart Dolman, Bob Nicholson

Mark Good, Laurie Riley, Janelle Holden, Jim McCollum, Randy Gray, 

Joanne Bernard 

1 (Pages 1 to 4) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 3 

 BE IT REMEMBERED that on Thursday, the 30th day of September, 

2010, at the hour of 7:00 o'clock p.m. of said day, at the Best Western 

Heritage Inn, 1700 Fox Farm Road, Great Falls, Montana, pursuant to 

notice, and before Anne Perron, RPR, Court Reporter and Notary Public 

for the State of Montana, the public hearing for the Charles M. Russell 

National Wildlife Refuge was had. 

 MIMI: We have a sign-up sheet. And there's a number who have 

signed up, and if you are inspired by somebody else's comments and 

you want to sign up later on. 

 Let me introduce Barron Crawford, the Project Leader, and also 

up at the front of the table is Bill Berg, the Deputy Project 

Leader, and Laurie Shannon, the Planning Team Leader. 

 MR. CRAWFORD: I feel like a rock star traveling around the 

state, and we're starting to get a following here, kind of like an 

entourage. See a lot of the same faces night after night, so, 

welcome everybody. Thanks for coming out tonight. 

 We'll start off here tonight with a brief overview of the CCP 

process where we started, how we got to where we're at today, and 

kind of what's going to happen in the future. 

 So we started basically in January of 2007. We held 14 public 

meetings. We received a little over 24,000 public comments during 

the scoping. We've held numerous meetings with our cooperators and 

partners, and that's pretty much how we've gotten to where we're at 

today. We released the draft CCP back on the 7th of September. 

 So this is right here. Open it up for public comment. We'll 

spend the next year and a half or so looking at those comments that 

we received during this period, and addressing those comments, and 

making changes to the document as appropriate. 

So why do we do this? Why do we spend years and years and years 

and thousands of dollars to go through this process? And the first 

is basically it's a requirement that was a part of the 1997 National 

Wildlife Refuge System Improvement Act that basically said all 

refuges will have a completed CCP by 2012. 

The next, it's just a very important document. It's set up to 

provide management, direction, and guidance that's based upon the 

refuge purpose and the mission of the National Refuge System. 

It also outlines the vision statement, goals, objectives and 

strategies to achieve those purposes of mission, and to guide that 

future management. 

It's accompanied by some type of NESA document, either an 

environmental assessment or Environmental Impact Statement. 

For CMR and UL Bend, just due to the complexity of issues that 

we're dealing with, we did an Environmental Impact Statement. 

And then, again, it provides that long-term guidance. Most 

plans are good for 15 years, and so as managers come and go, and the 

staffer changes, basically that road map has already been prepared 

for the future staff members that come on-board, and so instead of 

having a new manager come in and basically saying, Well, I don't 

like that. We're going to do something different. We've basically 

have got something in place for them to follow. 

,

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Page 4 

So, again, this is just another diagram of CCP process. And we 

started up here, public scoping, draft visions, developed 

alternatives, held more scoping. And that's how we got to the draft 

document.

After comments, there's a chance that we could go back here and 

revisit the alternatives. Hopefully, we have done a well enough job 

in selecting our four alternatives that we'll be able to move on to 

this next step here. 

So I'll give you a brief overview of each of the alternatives. 

We have Alternative A, which we call the no action. It's basically 

well, we're going to continue the management that we've been doing 

since the 1986 EIS was published. We'll have a few changes in 

there. We'll continue to manage the refuge based upon the 65 

habitat units that were established when the refuge was co-managed 

with the BLM up until 1976. 

We'll still gradually implement prescriptive grazing as those 

ranches sell to an outside family member or hold that permit and 

roll that unit into a prescriptive grazing program. 

And we'll talk a little bit more about that in a minute. 

We'll continue to manage big game to achieve the target levels 

that were identified in the '86 EIS, and we'll continue to keep the 

approximately 670 miles of roads open, and we'll continue to protect 

the 155,000 acres of proposed wilderness. 

Alternative B, we kind of call this one the wildlife and habitat 

emphasis alternative. And the basic theme behind it is manage the 

Page 2 

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ATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 3 

WILDLIFE REFUGE

FE SERVICE

lman, Bob Nicholson

m, Randy Gray, 

0th day of September, 

e Best Western 

ana, pursuant to 

and Notary Public 

arles M. Russell 

mber who have 

omments and 

spend the next year and a half or so looking at those comments that 

we received during this period, and addressing those comments, and 

making changes to the document as appropriate. 

So why do we do this? Why do we spend years and years and years 

and thousands of dollars to go through this process? And the first 

is basically it's a requirement that was a part of the 1997 National 

Wildlife Refuge System Improvement Act that basically said all 

refuges will have a completed CCP by 2012. 

The next, it's just a very important document. It's set up to 

provide management, direction, and guidance that's based upon the 

refuge purpose and the mission of the National Refuge System. 

It also outlines the vision statement, goals, objectives and 

strategies to achieve those purposes of mission, and to guide that 

future management. 

It's accompanied by some type of NESA document, either an 

environmental assessment or Environmental Impact Statement. 

For CMR and UL Bend, just due to the complexity of issues that 

we're dealing with, we did an Environmental Impact Statement. 

And then, again, it provides that long-term guidance. Most 

plans are good for 15 years, and so as managers come and go, and the 

staffer changes, basically that road map has already been prepared 

for the future staff members that come on-board, and so instead of 

having a new manager come in and basically saying, Well, I don't 

like that. We're going to do something different. We've basically 

have got something in place for them to follow. 

,

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Page 1

Page 4 

So, again, this is just another diagram of CCP process. And we 

started up here, public scoping, draft visions, developed 

alternatives, held more scoping. And that's how we got to the draft 

document.

After comments, there's a chance that we could go back here and 

revisit the alternatives. Hopefully, we have done a well enough job 

in selecting our four alternatives that we'll be able to move on to 

this next step here. 

Page 2 

1

2

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8

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

Dyrek VanHyning, Dan Bennett, Wes Murray, Aart Dolman, Bob Nicholson

Mark Good, Laurie Riley, Janelle Holden, Jim McCollum, Randy Gray, 

Joanne Bernard 

 BE IT REMEMBERED that on Thursday, the 30th day of September, 

2010, at the hour of 7:00 o'clock p.m. of said day, at the Best Western 

Heritage Inn, 1700 Fox Farm Road, Great Falls, Montana, pursuant to 

notice, and before Anne Perron, RPR, Court Reporter and Notary Public 

for the State of Montana, the public hearing for the Charles M. Russell 

National Wildlife Refuge was had. 

 MIMI: We have a sign-up sheet. And there's a number who have 

signed up, and if you are inspired by somebody else's comments and 

you want to sign up later on. 

 Let me introduce Barron Crawford, the Project Leader, and also 

up at the front of the table is Bill Berg, the Deputy Project 

Leader, and Laurie Shannon, the Planning Team Leader. 

 MR. CRAWFORD: I feel like a rock star traveling around the 

state, and we're starting to get a following here, kind of like an 

entourage. See a lot of the same faces night after night, so, 

welcome everybody. Thanks for coming out tonight. 

 We'll start off here tonight with a brief overview of the CCP 

process where we started, how we got to where we're at today, and 

kind of what's going to happen in the future. 

 So we started basically in January of 2007. We held 14 public 

meetings. We received a little over 24,000 public comments during 

the scoping. We've held numerous meetings with our cooperators and 

partners, and that's pretty much how we've gotten to where we're at 

today. We released the draft CCP back on the 7th of September. 

 So this is right here. Open it up for public comment. We'll 

And then, agai

plans are good fo

staffer changes, b

for the future staf

having a new ma

like that. We're g

have got somethi

,

1

2

2

9

0

1

2

2

2

2

3

4

52

So, again, this 

started up here, p

alternatives, held 

document.

After commen

revisit the alterna

in selecting our f

this next step her

So I'll give you 

We have Alterna

well, we're going 

since the 1986 E

there. We'll cont

habitat units that 

with the BLM up 

We'll still grad

ranches sell to an 

roll that unit into 

And we'll talk 

We'll continue 

that were identifi

approximately 67

the 155,000 acre

Alternative B, 

emphasis alterna

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1 (Pages 1 to 4) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 3 

 PUBLIC HEARING FOR THE CMR NATIONAL WILDLIFE REFUGE

 CONDUCTED BY THE US FISH AND WILDLIFE SERVICE

 Great Falls, Montana

 September 30, 2010

 7:00 o'clock p.m. 

PANEL:

Barron Crawford, Bill Berg, and Laurie Shannon 

PUBLIC SPEAKERS: 

Dyrek VanHyning, Dan Bennett, Wes Murray, Aart Dolman, Bob Nicholson

Mark Good, Laurie Riley, Janelle Holden, Jim McCollum, Randy Gray, 

Joanne Bernard 

 BE IT REMEMBERED that on Thursday, the 30th day of September, 

2010, at the hour of 7:00 o'clock p.m. of said day, at the Best Western 

Heritage Inn, 1700 Fox Farm Road, Great Falls, Montana, pursuant to 

notice, and before Anne Perron, RPR, Court Reporter and Notary Public 

for the State of Montana, the public hearing for the Charles M. Russell 

National Wildlife Refuge was had. 

 MIMI: We have a sign-up sheet. And there's a number who have 

signed up, and if you are inspired by somebody else's comments and 

you want to sign up later on. 

 Let me introduce Barron Crawford, the Project Leader, and also 

up at the front of the table is Bill Berg, the Deputy Project 

Leader, and Laurie Shannon, the Planning Team Leader. 

 MR. CRAWFORD: I feel like a rock star traveling around the 

state, and we're starting to get a following here, kind of like an 

entourage. See a lot of the same faces night after night, so, 

welcome everybody. Thanks for coming out tonight. 

 We'll start off here tonight with a brief overview of the CCP 

process where we started, how we got to where we're at today, and 

kind of what's going to happen in the future. 

 So we started basically in January of 2007. We held 14 public 

meetings. We received a little over 24,000 public comments during 

the scoping. We've held numerous meetings with our cooperators and 

partners, and that's pretty much how we've gotten to where we're at 

today. We released the draft CCP back on the 7th of September. 

 So this is right here. Open it up for public comment. We'll 

spend the next year and a half or so looking at those comments that 

we received during this period, and addressing those comments, and 

making changes to the document as appropriate. 

So why do we do this? Why do we spend years and years and years 

and thousands of dollars to go through this process? And the first 

is basically it's a requirement that was a part of the 1997 National 

Wildlife Refuge System Improvement Act that basically said all 

refuges will have a completed CCP by 2012. 

The next, it's just a very important document. It's set up to 

provide management, direction, and guidance that's based upon the 

refuge purpose and the mission of the National Refuge System. 

It also outlines the vision statement, goals, objectives and 

strategies to achieve those purposes of mission, and to guide that 

future management. 

It's accompanied by some type of NESA document, either an 

environmental assessment or Environmental Impact Statement. 

For CMR and UL Bend, just due to the complexity of issues that 

we're dealing with, we did an Environmental Impact Statement. 

And then, again, it provides that long-term guidance. Most 

plans are good for 15 years, and so as managers come and go, and the 

staffer changes, basically that road map has already been prepared 

for the future staff members that come on-board, and so instead of 

having a new manager come in and basically saying, Well, I don't 

like that. We're going to do something different. We've basically 

have got something in place for them to follow. 

,

1

1

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1

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Page 1

Page 4 

So, again, this is just another diagram of CCP process. And we 

started up here, public scoping, draft visions, developed 

alternatives, held more scoping. And that's how we got to the draft 

document.

After comments, there's a chance that we could go back here and 

revisit the alternatives. Hopefully, we have done a well enough job 

in selecting our four alternatives that we'll be able to move on to 

this next step here. 

So I'll give you a brief overview of each of the alternatives. 

We have Alternative A, which we call the no action. It's basically 

well, we're going to continue the management that we've been doing 

since the 1986 EIS was published. We'll have a few changes in 

there. We'll continue to manage the refuge based upon the 65 

habitat units that were established when the refuge was co-managed 

with the BLM up until 1976. 

We'll still gradually implement prescriptive grazing as those 

ranches sell to an outside family member or hold that permit and 

roll that unit into a prescriptive grazing program. 

And we'll talk a little bit more about that in a minute. 

We'll continue to manage big game to achieve the target levels 

that were identified in the '86 EIS, and we'll continue to keep the 

approximately 670 miles of roads open, and we'll continue to protect 

the 155,000 acres of proposed wilderness. 

Alternative B, we kind of call this one the wildlife and habitat 

emphasis alternative. And the basic theme behind it is manage the 

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VOLUME 2, Chapter 4—Public Hearing Testimony 371

2 (Pages 5 to 8) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 5 Page 7 

1 landscape in cooperation with our partners to emphasize abundance 

and diversity of wildlife using a combination of natural ecological 

processes, such as fire and grazing, but also some of those 

synthetic methods, such as farming, tree planting, flooding. 

 We'll encourage wildlife dependent public uses. And those are 

hunting and fishing and wildlife observation, wildlife photography, 

environmental education and interpretation. 

 And we'll limit economic uses when they compete for habitat. 

And economic uses are stuff like commercial outfitting, grazing, 

anything that generates kind of an income. 

 So we got some maps. Hopefully, people had an opportunity to 

look at them when they came in, but this is basically what the 

refuge would look at you under Alternative B with closing some 

roads, expanding some wilderness areas. 

 This is the west half of the refuge. This is the east half of 

the refuge. 

 Some of the common points that are in Alternative B is actively 

manage and manipulate habitats to create productive wildlife, food 

and cover. 

 Implement prescriptive grazing on 50 to 75 percent of the refuge 

within four to seven years. 

 Taking an aggressive approach to restoring the river bottoms. 

 Work with Montana Fish, Wildlife and Parks to provide quality 

hunting opportunities and sustain populations of big game and 

habitat for non game. 

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 And close approximately 106 miles of roads, and expand acreage 

of proposed wilderness by 25,000 acres in six existing units. 

 Alternative C, we call this the public use and the economic use. 

And this is basically, again, managing the landscape in cooperation 

with our partners to promote maximum compatible wildlife, 

dependant-public uses, and economic uses while still protecting 

wildlife populations in their habitats to the extent possible. 

 And we'll minimize damage to impacts, such as wildlife habitats, 

while using a variety of management tools to enhance and diversify 

public and economic opportunities. 

 So this is basically saying that we're going to continue running 

our grazing program very similar to what we're doing today. 

Gradually move to a prescriptive grazing program. Put more of an 

emphasis on range condition instead of habitat condition. 

 We'll touch on that a little bit more in a minute. 

 So this is the map for Alternative C. No road closures. Couple 

wilderness areas have been identified for recommendation to be 

removed.

 Main points of C: Manage habitats to provide more opportunities 

for recreation. Work with Montana Fish, Wildlife and Parks to 

maintain a balanced numbers of big game and livestock; expand and 

maximize hunting opportunities; improve access to boat ramps; and 

recommend eliminating four proposed wilderness areas that total 

about 35,000 acres. 

 And then we come to Alternative D. And this is our natural 

processes alternative. This is our proposed action as well. 

 And this is basically we're again working with our partners. 

We're going to use these natural ecological processes. And those 

ecological processes are primarily fire and grazing, and some active 

management. So we're mixing in a little bit of Alternative B to 

restore and/or maintain the biological diversity, biological 

integrity and biological health. And that comes right from the 

Improvement Act. 

 And then once these natural processes are restored, we'll take 

more of a passive management approach. And we'll still provide for 

a quality wildlife-dependent public uses and experience. And we're 

going to limit those economic uses when they're injurious to either 

the habitats or to the processes. 

 So this is what a map looks for Alternative D. And we've got 

some proposed expansion of some wilderness. We've got some proposed 

eliminating of some wilderness. We have some roads that we're 

proposing to close. 

 Again, on the east half, same thing. 

 The summary of Alternative D, economic uses will be limited when 

they're injurious to ecological processes. Apply management 

practices that mimic and restore natural process. Again, that's 

mostly fire and grazing. 

 Use fire and wild ungulate herbivory and/or prescriptive 

livestock grazing on 50 to 75 percent of the refuge to mimic that 

historic interaction; and work with Montana Fish, Wildlife and Parks 

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Page 6 Page 8 

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to maintain health and diversity of wildlife species; do some road 

closures on about 23 miles of roads; and expand six of the proposed 

wilderness areas for a total of 18,000 acres, and eliminate three 

for a total of 26,000. So we'll have a little bit of a net loss 

there in proposed wilderness. 

 So some of the hot button topics -- this is our third night as 

Mimi said. Some of the common themes that we've heard is 

prescriptive grazing, what is it? And basically when we're talking 

about preventative grazing, we're talking about using livestock in 

order to meet a very specific wildlife and/or habitat objective. 

 And an example that I like to use is, say, we go in and we 

identify an area that's got some prairie dogs. There's a potential 

that we could expand that prairie dog town. By expanding that 

prairie dog town, we could possibly get some more ferrets to move in 

there. We could create opportunities or burrowing owls and mountain 

clovers to nest. 

 And so we would want to go in there and graze that area heavily 

to reduce that overall grass cover to encourage those prairie dogs 

to expand. Once the prairie dogs expanded, then those other 

wildlife species are going to come, and then promote, you know, the 

expansion of the habitat for those species. 

 So that's one use where we would use prescriptive grazing to 

meet a specific wildlife and/or habitat objective. 

 Another could be to reduce the threat of wild fire. Might be a 

spot where we can't use prescribed fire due to in-holdings or very 

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 NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 5 Page 7 

o emphasize abundance 

n of natural ecological 

 some of those 

nting, flooding. 

c uses. And those are 

n, wildlife photography, 

 

 compete for habitat. 

al outfitting, grazing, 

 had an opportunity to 

basically what the 

B with closing some 

s the east half of 

lternative B is actively 

oductive wildlife, food 

75 percent of the refuge 

ng the river bottoms. 

arks to provide quality 

ns of big game and 

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ds, and expand acreage 

x existing units. 

and the economic use. 

ndscape in cooperation 

patible wildlife, 

while still protecting 

xtent possible

processes alternative. This is our proposed action as well. 

 And this is basically we're again working with our partners. 

We're going to use these natural ecological processes. And those 

ecological processes are primarily fire and grazing, and some active 

management. So we're mixing in a little bit of Alternative B to 

restore and/or maintain the biological diversity, biological 

integrity and biological health. And that comes right from the 

Improvement Act. 

 And then once these natural processes are restored, we'll take 

more of a passive management approach. And we'll still provide for 

a quality wildlife-dependent public uses and experience. And we're 

going to limit those economic uses when they're injurious to either 

the habitats or to the processes. 

 So this is what a map looks for Alternative D. And we've got 

some proposed expansion of some wilderness. We've got some proposed 

eliminating of some wilderness. We have some roads that we're 

proposing to close. 

 Again, on the east half, same thing. 

 The summary of Alternative D, economic uses will be limited when 

they're injurious to ecological processes. Apply management 

practices that mimic and restore natural process. Again, that's 

mostly fire and grazing. 

 Use fire and wild ungulate herbivory and/or prescriptive 

livestock grazing on 50 to 75 percent of the refuge to mimic that 

historic interaction; and work with Montana Fish, Wildlife and Parks 

Page 6 Page 8 

1

2

3

4

5

6

7

to maintain health and diversity of wildlife species; do some road 

closures on about 23 miles of roads; and expand six of the proposed 

wilderness areas for a total of 18,000 acres, and eliminate three 

for a total of 26,000. So we'll have a little bit of a net loss 

there in proposed wilderness. 

 So some of the hot button topics -- this is our third night as 

Mimi saidSome of the common themes that we've heard is 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

and cover. 

 Implement prescriptive grazing on 50 to 75 percent of the refuge 

within four to seven years. 

 Taking an aggressive approach to restoring the river bottoms. 

 Work with Montana Fish, Wildlife and Parks to provide quality 

hunting opportunities and sustain populations of big game and 

habitat for non game. 

19

20

21

22

23

24

25

 And close approximately 106 miles of roads, and expand acreage 

of proposed wilderness by 25,000 acres in six existing units. 

 Alternative C, we call this the public use and the economic use. 

And this is basically, again, managing the landscape in cooperation 

with our partners to promote maximum compatible wildlife, 

dependant-public uses, and economic uses while still protecting 

wildlife populations in their habitats to the extent possible. 

 And we'll minimize damage to impacts, such as wildlife habitats, 

while using a variety of management tools to enhance and diversify 

public and economic opportunities. 

 So this is basically saying that we're going to continue running 

our grazing program very similar to what we're doing today. 

Gradually move to a prescriptive grazing program. Put more of an 

emphasis on range condition instead of habitat condition. 

 We'll touch on that a little bit more in a minute. 

 So this is the map for Alternative C. No road closures. Couple 

wilderness areas have been identified for recommendation to be 

removed.

 Main points of C: Manage habitats to provide more opportunities 

for recreation. Work with Montana Fish, Wildlife and Parks to 

maintain a balanced numbers of big game and livestock; expand and 

maximize hunting opportunities; improve access to boat ramps; and 

recommend eliminating four proposed wilderness areas that total 

about 35,000 acres. 

 And then we come to Alternative D. And this is our natural 

 The summ

they're injur

practices tha

mostly fire 

 Use fire a

livestock gr

historic inte

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1 1

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to maintain 

closures on 

wilderness 

for a total o

there in pro

 So some 

Mimi said. 

prescriptive 

about preve

order to me

 And an e

identify an 

that we cou

prairie dog 

there. We c

clovers to n

 And so w

to reduce th

to expand. 

wildlife spe

expansion o

 So that's 

meet a spec

 Another 

spot where 

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2 (Pages 5 to 8) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 5 Page 7 

1 landscape in cooperation with our partners to emphasize abundance 

and diversity of wildlife using a combination of natural ecological 

processes, such as fire and grazing, but also some of those 

synthetic methods, such as farming, tree planting, flooding. 

 We'll encourage wildlife dependent public uses. And those are 

hunting and fishing and wildlife observation, wildlife photography, 

environmental education and interpretation. 

 And we'll limit economic uses when they compete for habitat. 

And economic uses are stuff like commercial outfitting, grazing, 

anything that generates kind of an income. 

 So we got some maps. Hopefully, people had an opportunity to 

look at them when they came in, but this is basically what the 

refuge would look at you under Alternative B with closing some 

roads, expanding some wilderness areas. 

 This is the west half of the refuge. This is the east half of 

the refuge. 

 Some of the common points that are in Alternative B is actively 

manage and manipulate habitats to create productive wildlife, food 

and cover. 

 Implement prescriptive grazing on 50 to 75 percent of the refuge 

within four to seven years. 

 Taking an aggressive approach to restoring the river bottoms. 

 Work with Montana Fish, Wildlife and Parks to provide quality 

hunting opportunities and sustain populations of big game and 

habitat for non game. 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

 And close approximately 106 miles of roads, and expand acreage 

of proposed wilderness by 25,000 acres in six existing units. 

 Alternative C, we call this the public use and the economic use. 

And this is basically, again, managing the landscape in cooperation 

with our partners to promote maximum compatible wildlife, 

dependant-public uses, and economic uses while still protecting 

wildlife populations in their habitats to the extent possible. 

 And we'll minimize damage to impacts, such as wildlife habitats, 

while using a variety of management tools to enhance and diversify 

public and economic opportunities. 

 So this is basically saying that we're going to continue running 

our grazing program very similar to what we're doing today. 

Gradually move to a prescriptive grazing program. Put more of an 

emphasis on range condition instead of habitat condition. 

 We'll touch on that a little bit more in a minute. 

 So this is the map for Alternative C. No road closures. Couple 

wilderness areas have been identified for recommendation to be 

removed.

 Main points of C: Manage habitats to provide more opportunities 

for recreation. Work with Montana Fish, Wildlife and Parks to 

maintain a balanced numbers of big game and livestock; expand and 

maximize hunting opportunities; improve access to boat ramps; and 

recommend eliminating four proposed wilderness areas that total 

about 35,000 acres. 

 And then we come to Alternative D. And this is our natural 

processes alternative. This is our proposed action as well. 

 And this is basically we're again working with our partners. 

We're going to use these natural ecological processes. And those 

ecological processes are primarily fire and grazing, and some active 

management. So we're mixing in a little bit of Alternative B to 

restore and/or maintain the biological diversity, biological 

integrity and biological health. And that comes right from the 

Improvement Act. 

 And then once these natural processes are restored, we'll take 

more of a passive management approach. And we'll still provide for 

a quality wildlife-dependent public uses and experience. And we're 

going to limit those economic uses when they're injurious to either 

the habitats or to the processes. 

 So this is what a map looks for Alternative D. And we've got 

some proposed expansion of some wilderness. We've got some proposed 

eliminating of some wilderness. We have some roads that we're 

proposing to close. 

 Again, on the east half, same thing. 

 The summary of Alternative D, economic uses will be limited when 

they're injurious to ecological processes. Apply management 

practices that mimic and restore natural process. Again, that's 

mostly fire and grazing. 

 Use fire and wild ungulate herbivory and/or prescriptive 

livestock grazing on 50 to 75 percent of the refuge to mimic that 

historic interaction; and work with Montana Fish, Wildlife and Parks 

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to maintain health and diversity of wildlife species; do some road 

closures on about 23 miles of roads; and expand six of the proposed 

wilderness areas for a total of 18,000 acres, and eliminate three 

for a total of 26,000. So we'll have a little bit of a net loss 

there in proposed wilderness. 

 So some of the hot button topics -- this is our third night as 

Mimi said. Some of the common themes that we've heard is 

prescriptive grazing, what is it? And basically when we're talking 

about preventative grazing, we're talking about using livestock in 

order to meet a very specific wildlife and/or habitat objective. 

 And an example that I like to use is, say, we go in and we 

identify an area that's got some prairie dogs. There's a potential 

that we could expand that prairie dog town. By expanding that 

prairie dog town, we could possibly get some more ferrets to move in 

there. We could create opportunities or burrowing owls and mountain 

clovers to nest. 

 And so we would want to go in there and graze that area heavily 

to reduce that overall grass cover to encourage those prairie dogs 

to expand. Once the prairie dogs expanded, then those other 

wildlife species are going to come, and then promote, you know, the 

expansion of the habitat for those species. 

 So that's one use where we would use prescriptive grazing to 

meet a specific wildlife and/or habitat objective. 

 Another could be to reduce the threat of wild fire. Might be a 

spot where we can't use prescribed fire due to in-holdings or very 

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372 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

3 (Pages 9 to 12) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 9 Page 11 

1 difficult to get into the area and control it. We could go in there 

and use livestock to graze that area and reduce the overall grass 

cover and reduce the threat of wild fire. 

 Prescriptive fire. We've had a lot of questions about that. 

How will it be used. We've talked a lot about the ecological 

processes of fire and grazing historically. 

 Fire would come through the area. As the plants burn, you've 

got that flush of lush growth. You have the bison and deer and the 

elk will kind of follow these fires and move from patch to patch to 

patch. So we've been working with some fire ecologists and doing 

quite a bit of research, looking at the historic fire frequency, and 

trying to restore that natural fire frequency back onto the 

landscape, and then restore that natural movement of those animals 

from patch to patch. 

 And to go there is to benefit those plants that are fire 

adaptive so that they have a chance to grow up, reach maturity, 

produce fruit, reproduce and expand. 

 Wilderness. As part of the CCP process, we're to look at 

evaluating our wilderness areas, and make sure that they still meet 

those wilderness characteristics which were identified when they 

were originally proposed. Our areas were proposed in around the mid

70s.

 And so as part of this process, we wanted to evaluate those 

areas and make sure they were still meeting those wilderness 

characteristics. It is subjective. You know, there's some things 

1

we can look at look. We can look at guidance in the actual 

wilderness law itself. We can look at our policy. But a lot of it 

is a subjective call. 

 And so that's why, you know, we throw these alternatives up 

there. We're talking about expanding and/or eliminating. And we'r

looking for comments from you, the public, to give us your input 

because I'm sure there's stuff that we missed when we were looking 

at those areas. 

 It's the same thing with the closing of roads. Some of the 

roads that we proposed to close are in areas where the public 

doesn't have access to those roads. And so it creates an exclusive 

use for the neighboring landowner to come in and use the refuge, 

which is not fair to the public. 

 And so some of our road closures are hoping to alleviate that 

situation. Others are to expand continuous blocks of habitat to 

allow wildlife to move freely from area to area. 

 And then the other comments we've heard quite a bit about is 

bison and bison restoration. 

 And what we chose to do in the plan is say that we would support

Montana Fish, Wildlife and Parks, if they brought forth a proposal 

to reintroduce bison somewhere in and around the refuge, that we 

work cooperatively with them in seeing in what role the Fish and 

Wildlife Service could assist in that process. But we weren't going 

to initiate a bison restoration project on our own. We feel that we 

need the State to step up and to do that as a State-managed wildlife 

species.

 So those are kind of what we've heard for the past couple of 

nights.

 Now we're going to turn it over to you guys. Let you guys give 

us some feedback. 

 We would ask that you address items that are specifically in the 

plan. Speak clearly. Stick to your allotted time frame. There are 

numerous ways to provide comments: Providing on oral comment is 

just one way tonight. You can also write down your comment on a 

piece of paper that was handed to you as you came in the door, and 

leave it on the table as you leave. You can send us a written 

comment to the address that is in the planning update. 

 Laurie said, please, do to the send them to her personal email 

account because it will get full in a hurry. There's a special 

email account to send those comments to. And that way, they will 

get properly cataloged and put in there. If you send it to Laurie's 

email, she'll probably delete it. 

 This is not a voting contest. There is no one form of comment 

that gets more weight than others. We consider all relevant 

comments the same. It doesn't matter whether we get one comment or 

we get a hundred thousand. They're all treated based upon their 

merit.

 The comment period is scheduled to end November 16. We have 

received numerous requests to extend that period. And we're taking 

that under consideration at this time. And we have not made any 

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Page 10 Page 12 

1 1 decisions. So I would please plan to have your comments submitted 

by that November 16th. 

 So that's it. We're going to take a few minutes and set up the 

podium here, and then turn to over to Mimi to call the speakers up. 

 (Recess taken.) 

 MIMI: So here's how Part Two is going to work. We're going to 

limit everybody to three minutes. I'm going to call folks off the 

list. We will go in order. I'll call the next person, and also 

announce who's on deck, so you can be ready to go. 

 We're going to be strict about the three minutes. I have some 

timecards here, so I will let you know when you have one minute 

left, 20 seconds left, and when time's up. 

 We just ask that you refrain from applause or cheering, so 

things can run smoothly and respect one other's opinions. 

 If you do just have a question, we urge you to come up and ask 

your question. These guys back here: Bill, Laurie and Barren will 

be taking notes. 

 And then we'll need about 15 minutes at the end and they will 

respond to all the questions that they have received. 

 So with that -- and the first name I can't read very well -- I 

think it's Derrick -- Dyrck VanHyning with Dan Bennett on deck. 

 One more thing, will you please state your name. And if it's a 

tricky spelling, spell it for our recorder. 

 MR. VanHYNING: My name is Dyrck VanHyning from Great Falls --

I'm a food broker -- spelled D-y-r-c-k VanHyning. 

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ATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 9 Page 11 

ld go in there 

overall grass 

bout that. 

cological 

 burn, you've 

and deer and the 

atch to patch to 

ogists and doing 

equency, and 

to the 

of those animals 

 fire 

ch maturity, 

o look at 

t they still meet 

ied when they 

d in around the mid

uate those 

wilderness 

 some things 

1

the actual 

But a lot of it 

lternatives up 

inating. And we'r

ve us your input 

n we were looking 

species.

 So those are kind of what we've heard for the past couple of 

nights.

 Now we're going to turn it over to you guys. Let you guys give 

us some feedback. 

 We would ask that you address items that are specifically in the 

plan. Speak clearly. Stick to your allotted time frame. There are 

numerous ways to provide comments: Providing on oral comment is 

just one way tonight. You can also write down your comment on a 

piece of paper that was handed to you as you came in the door, and 

leave it on the table as you leave. You can send us a written 

comment to the address that is in the planning update. 

 Laurie said, please, do to the send them to her personal email 

account because it will get full in a hurry. There's a special 

email account to send those comments to. And that way, they will 

get properly cataloged and put in there. If you send it to Laurie's 

email, she'll probably delete it. 

 This is not a voting contest. There is no one form of comment 

that gets more weight than others. We consider all relevant 

comments the same. It doesn't matter whether we get one comment or 

we get a hundred thousand. They're all treated based upon their 

merit.

 The comment period is scheduled to end November 16. We have 

received numerous requests to extend that period. And we're taking 

that under consideration at this time. And we have not made any 

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Page 10 Page 12 

1 decisions. So I would please plan to have your comments submitted 

by that November 16th. 

 So that's it. We're going to take a few minutes and set up the 

podium here, and then turn to over to Mimi to call the speakers up. 

 (Recess taken.) 

 MIMI: So here's how Part Two is going to work. We're going to 

limit everybody to three minutesI'm going to call folks off the 

2

3

4

e 5

6

7

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

evaluating our wilderness areas, and make sure that they still meet 

those wilderness characteristics which were identified when they 

were originally proposed. Our areas were proposed in around the mid

70s.

 And so as part of this process, we wanted to evaluate those 

areas and make sure they were still meeting those wilderness 

characteristics. It is subjective. You know, there's some things 

we can look at look. We can look at guidance in the actual 

wilderness law itself. We can look at our policy. But a lot of it 

is a subjective call. 

 And so that's why, you know, we throw these alternatives up 

there. We're talking about expanding and/or eliminating. And we'r

looking for comments from you, the public, to give us your input 

because I'm sure there's stuff that we missed when we were looking 

at those areas. 

 It's the same thing with the closing of roads. Some of the 

roads that we proposed to close are in areas where the public 

doesn't have access to those roads. And so it creates an exclusive 

use for the neighboring landowner to come in and use the refuge, 

which is not fair to the public. 

 And so some of our road closures are hoping to alleviate that 

situation. Others are to expand continuous blocks of habitat to 

allow wildlife to move freely from area to area. 

 And then the other comments we've heard quite a bit about is 

bison and bison restoration. 

 And what we chose to do in the plan is say that we would support

Montana Fish, Wildlife and Parks, if they brought forth a proposal 

to reintroduce bison somewhere in and around the refuge, that we 

work cooperatively with them in seeing in what role the Fish and 

Wildlife Service could assist in that process. But we weren't going 

to initiate a bison restoration project on our own. We feel that we 

need the State to step up and to do that as a State-managed wildlife 

that gets more we

comments the sam

we get a hundred 

merit.

 The comment p

received numerou

that under consid

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Page 10 

1 1 decisions. So I wo

by that November 

 So that's it. We

podium here, and t

 (Recess taken.) 

 MIMI: So here

limit everybody to 

list. We will go in 

announce who's on 

 We're going to b

timecards here, so 

left, 20 seconds lef

 We just ask that 

things can run smo

 If you do just ha

your question. Th

be taking notes. 

 And then we'll n

respond to all the q

 So with that -- a

think it's Derrick -

 One more thing

tricky spelling, spe

 MR. VanHYNI

I'm a food broker -

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3 (Pages 9 to 12) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 9 Page 11 

1 difficult to get into the area and control it. We could go in there 

and use livestock to graze that area and reduce the overall grass 

cover and reduce the threat of wild fire. 

 Prescriptive fire. We've had a lot of questions about that. 

How will it be used. We've talked a lot about the ecological 

processes of fire and grazing historically. 

 Fire would come through the area. As the plants burn, you've 

got that flush of lush growth. You have the bison and deer and the 

elk will kind of follow these fires and move from patch to patch to 

patch. So we've been working with some fire ecologists and doing 

quite a bit of research, looking at the historic fire frequency, and 

trying to restore that natural fire frequency back onto the 

landscape, and then restore that natural movement of those animals 

from patch to patch. 

 And to go there is to benefit those plants that are fire 

adaptive so that they have a chance to grow up, reach maturity, 

produce fruit, reproduce and expand. 

 Wilderness. As part of the CCP process, we're to look at 

evaluating our wilderness areas, and make sure that they still meet 

those wilderness characteristics which were identified when they 

were originally proposed. Our areas were proposed in around the mid

70s.

 And so as part of this process, we wanted to evaluate those 

areas and make sure they were still meeting those wilderness 

characteristics. It is subjective. You know, there's some things 

1

we can look at look. We can look at guidance in the actual 

wilderness law itself. We can look at our policy. But a lot of it 

is a subjective call. 

 And so that's why, you know, we throw these alternatives up 

there. We're talking about expanding and/or eliminating. And we'r

looking for comments from you, the public, to give us your input 

because I'm sure there's stuff that we missed when we were looking 

at those areas. 

 It's the same thing with the closing of roads. Some of the 

roads that we proposed to close are in areas where the public 

doesn't have access to those roads. And so it creates an exclusive 

use for the neighboring landowner to come in and use the refuge, 

which is not fair to the public. 

 And so some of our road closures are hoping to alleviate that 

situation. Others are to expand continuous blocks of habitat to 

allow wildlife to move freely from area to area. 

 And then the other comments we've heard quite a bit about is 

bison and bison restoration. 

 And what we chose to do in the plan is say that we would support

Montana Fish, Wildlife and Parks, if they brought forth a proposal 

to reintroduce bison somewhere in and around the refuge, that we 

work cooperatively with them in seeing in what role the Fish and 

Wildlife Service could assist in that process. But we weren't going 

to initiate a bison restoration project on our own. We feel that we 

need the State to step up and to do that as a State-managed wildlife 

species.

 So those are kind of what we've heard for the past couple of 

nights.

 Now we're going to turn it over to you guys. Let you guys give 

us some feedback. 

 We would ask that you address items that are specifically in the 

plan. Speak clearly. Stick to your allotted time frame. There are 

numerous ways to provide comments: Providing on oral comment is 

just one way tonight. You can also write down your comment on a 

piece of paper that was handed to you as you came in the door, and 

leave it on the table as you leave. You can send us a written 

comment to the address that is in the planning update. 

 Laurie said, please, do to the send them to her personal email 

account because it will get full in a hurry. There's a special 

email account to send those comments to. And that way, they will 

get properly cataloged and put in there. If you send it to Laurie's 

email, she'll probably delete it. 

 This is not a voting contest. There is no one form of comment 

that gets more weight than others. We consider all relevant 

comments the same. It doesn't matter whether we get one comment or 

we get a hundred thousand. They're all treated based upon their 

merit.

 The comment period is scheduled to end November 16. We have 

received numerous requests to extend that period. And we're taking 

that under consideration at this time. And we have not made any 

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Page 10 Page 12 

1 1 decisions. So I would please plan to have your comments submitted 

by that November 16th. 

 So that's it. We're going to take a few minutes and set up the 

podium here, and then turn to over to Mimi to call the speakers up. 

 (Recess taken.) 

 MIMI: So here's how Part Two is going to work. We're going to 

limit everybody to three minutes. I'm going to call folks off the 

list. We will go in order. I'll call the next person, and also 

announce who's on deck, so you can be ready to go. 

 We're going to be strict about the three minutes. I have some 

timecards here, so I will let you know when you have one minute 

left, 20 seconds left, and when time's up. 

 We just ask that you refrain from applause or cheering, so 

things can run smoothly and respect one other's opinions. 

 If you do just have a question, we urge you to come up and ask 

your question. These guys back here: Bill, Laurie and Barren will 

be taking notes. 

 And then we'll need about 15 minutes at the end and they will 

respond to all the questions that they have received. 

 So with that -- and the first name I can't read very well -- I 

think it's Derrick -- Dyrck VanHyning with Dan Bennett on deck. 

 One more thing, will you please state your name. And if it's a 

tricky spelling, spell it for our recorder. 

 MR. VanHYNING: My name is Dyrck VanHyning from Great Falls --

I'm a food broker -- spelled D-y-r-c-k VanHyning. 

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VOLUME 2, Chapter 4—Public Hearing Testimony 373

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 13 Page 15 

1 Now that will be your toughest name for the evening. So thank 

you for coming to Great Falls. I have basically two questions and 

they revolve around -- the first one prescriptive grazing and the 

second one is the wilderness study areas. 

 And I'm an interested public in the Upper Missouri River Breaks 

National Monument on grazing. And I -- in the monument, I work on

grazing issues and oil and gas. 

 And if I was a permitee, I guess, at this point, I do not 

understand prescriptive grazing because if I'm running so many head 

of cattle, and I have a plan -- this plan always will be changed 

based on the rainfall. But when I put cattle in a certain pasture 

and when I pull them out and so forth, and I know that long in 

advance, but it's still based on the rainfall. 

 But on prescriptive grazing, I understand your example, but I 

don't know that I'm going to put my cattle on a particular piece of 

land, I would think, until after the rainfall. 

 So that's my first question: How would I know in advance that 

I'm not going to have to find additional pasture. 

 And the second question is on the WSA's. And I have read 

through page 139. I think it's written well. I think it's very 

easy to understand. And I love your photos. 

 These WSA's were set by Congress. How is this process going to 

eliminate and add to certain areas? 

 And that's the end of my questions. 

 MIMI: Dan Bennett with Wes on deck. 

1

 MR. BENNETT: My name is Dan Bennett. Common spelling: two N's

and two T's. 

 I'm the conservation chair for the Upper Missouri Audubon 

Society in Great Falls. 

 I want to confine my comments tonight to the state of grassland 

birds which the whole world's become a population state for those, 

and they're starting to drop into the threatened and endangered 

process, which has gotten them nowhere because there's no room for 

them in that process. 

 So there's a couple of factors that look good to us in this 

plan, that will affect grasslands habitat. Those are the grazing 

and prescriptive burning, which we were thrilled to see those, and 

never thought we'd use a word like that in a place like this, but it 

is something new and just great. 

 The factors that bother us is that it doesn't seem like the 

preferred alternative is going to do much for rodent citizens. 

We're baffled by the lack of inclusion of all of the wilderness 

study areas. That seemed to be to us a no-brainer as far as keeping 

them as far as habitat goes. It's cheap and easy to keep 

fragmentation out of it. 

 And the last is oil and gas development, which would be a 

disaster. I know that that decision is not being made now. But 

we've been in enough places where that's gone through, and listened 

to all the mitigation stuff from the industry -- never yet have we 

seen any way to mitigate against the fragmentation that this causes. 

And for grassland birds, that would be about the last straw. 

 So I would appreciate if someone could address at the end of 

this what the thinking is on how we're going to benefit grasslands 

bird here and keep them alive. 

 Thank you. 

 MIMI: Wes and Art on deck. 

 MR. MURRAY: My name is Wes Murray, M-u-r-r-a-y. 

 And I come to you tonight as a sportsman who has been in the 

CM Russell for 40 years. I've been there when CM Russell cow range 

was administered by the BLM, and one of those individuals that 

fought hard to see that the US Fish and Wildlife Service would take 

control of it, and it would be manages as a wildlife area. And this 

is very important. 

 Also, one of those people that back in the 70's sat down with 

the maps and looked at it, came up with these wilderness areas, and 

I cannot support any proposal that would remove any of the areas. 

 I do really appreciate the additions that have been made. We 

looked and studied to see what would be the best. Part of that came 

from the tremendous pressure that has been put on the area. In the 

50's an elk herd was transferred from Glacier, from Seeley, from 

Yellowstone in the Gardiner area into the CM Russell. It was done 

by private individuals with the hope of -- it would flourish in that 

area.

 Today we have a flourishing elk herd, but that elk herd is 

seeing tremendous pressure off and on. And part of the reason we 

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Page 14 Page 16 

1 1 went with the wilderness study areas, trying to relieve some of the 

road pressure that was on there. 

 In the 70's in the early 70's there were 200 bow hunters in the 

state of Montana. And within a couple years that became 2,000. I 

think we have 14,000 bow hunters in the state of Montana now. 

 The pressure from the open roads -- prior to what the Fish and 

Wildlife Service -- has caused those elk herds to shift. There 

never used to be elk on the south side of the river. There was not 

a sustainable herd in the Bear Paws. Those elk were put out of the 

range by pressure. 

 So anything -- I totally support the road closures in Plan B. 

It's a tremendous asset to the wildlife range if we can continue and 

support that. 

 You know, prescriptive grazing is great if we can work it out. 

I know it's still an economical factor. And it will have an 

economical impact on the area. 

 I am very concerned on the issue of the prescriptive burning. 

There are certain pockets in the refuge that if you were to destroy 

that area and those travel ways, you would cut the movement of the 

elk.

 There was a fire in the early 2000's on the CK Ridge coming out 

the Nicholls Coulee. Prior to that fire, there were elk everywhere 

on that area. 

 Since that fire, there's no elk on that area -- never seen an 

elk in that ridge. 

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4 (Pages 13 to 16) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

 NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 13 Page 15 

he evening. So thank 

lly two questions and 

ve grazing and the 

Missouri River Breaks 

the monument, I work on

int, I do not 

m running so many head 

s will be changed 

n a certain pasture 

know that long in 

your example, but I 

n a particular piece of 

know in advance that 

ure. 

 And I have read 

 think it's very 

 

 is this process going to 

1

Common spelling: two N's

ouri Audubon 

e state of grassland 

tion state for those, 

nd endangered 

And for grassland birds, that would be about the last straw. 

 So I would appreciate if someone could address at the end of 

this what the thinking is on how we're going to benefit grasslands 

bird here and keep them alive. 

 Thank you. 

 MIMI: Wes and Art on deck. 

 MR. MURRAY: My name is Wes Murray, M-u-r-r-a-y. 

 And I come to you tonight as a sportsman who has been in the 

CM Russell for 40 years. I've been there when CM Russell cow range 

was administered by the BLM, and one of those individuals that 

fought hard to see that the US Fish and Wildlife Service would take 

control of it, and it would be manages as a wildlife area. And this 

is very important. 

 Also, one of those people that back in the 70's sat down with 

the maps and looked at it, came up with these wilderness areas, and 

I cannot support any proposal that would remove any of the areas. 

 I do really appreciate the additions that have been made. We 

looked and studied to see what would be the best. Part of that came 

from the tremendous pressure that has been put on the area. In the 

50's an elk herd was transferred from Glacier, from Seeley, from 

Yellowstone in the Gardiner area into the CM Russell. It was done 

by private individuals with the hope of -- it would flourish in that 

area.

 Today we have a flourishing elk herd, but that elk herd is 

seeing tremendous pressure off and on. And part of the reason we 

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1 went with the wilderness study areas, trying to relieve some of the 

road pressure that was on there. 

 In the 70's in the early 70's there were 200 bow hunters in the 

state of Montana. And within a couple years that became 2,000. I 

think we have 14,000 bow hunters in the state of Montana now. 

 The pressure from the open roads -- prior to what the Fish and 

Wildlife Service -- has caused those elk herds to shiftThere 

2

3

4

5

6

7

 And the second question is on the WSA's. And I have read 

through page 139. I think it's written well. I think it's very 

easy to understand. And I love your photos. 

 These WSA's were set by Congress. How is this process going to 

eliminate and add to certain areas? 

 And that's the end of my questions. 

 MIMI: Dan Bennett with Wes on deck. 

 MR. BENNETT: My name is Dan Bennett. Common spelling: two N's

and two T's. 

 I'm the conservation chair for the Upper Missouri Audubon 

Society in Great Falls. 

 I want to confine my comments tonight to the state of grassland 

birds which the whole world's become a population state for those, 

and they're starting to drop into the threatened and endangered 

process, which has gotten them nowhere because there's no room for 

them in that process. 

 So there's a couple of factors that look good to us in this 

plan, that will affect grasslands habitat. Those are the grazing 

and prescriptive burning, which we were thrilled to see those, and 

never thought we'd use a word like that in a place like this, but it 

is something new and just great. 

 The factors that bother us is that it doesn't seem like the 

preferred alternative is going to do much for rodent citizens. 

We're baffled by the lack of inclusion of all of the wilderness 

study areas. That seemed to be to us a no-brainer as far as keeping 

them as far as habitat goes. It's cheap and easy to keep 

fragmentation out of it. 

 And the last is oil and gas development, which would be a 

disaster. I know that that decision is not being made now. But 

we've been in enough places where that's gone through, and listened 

to all the mitigation stuff from the industry -- never yet have we 

seen any way to mitigate against the fragmentation that this causes. 

from the tre

50's an elk 

Yellowston

by private i

area.

 Today w

seeing trem

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Page 14 

1 1 went with 

road pressu

 In the 70

state of Mo

think we h

 The pres

Wildlife Se

never used 

a sustainab

range by p

 So anyth

It's a treme

support tha

 You kno

I know it's 

economica

 I am ver

There are c

that area an

elk.

 There w

the Nichol

on that are

 Since th

elk in that 

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Agamenoni & Frank Court Reporting

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CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 13 Page 15 

1 Now that will be your toughest name for the evening. So thank 

you for coming to Great Falls. I have basically two questions and 

they revolve around -- the first one prescriptive grazing and the 

second one is the wilderness study areas. 

 And I'm an interested public in the Upper Missouri River Breaks 

National Monument on grazing. And I -- in the monument, I work on

grazing issues and oil and gas. 

 And if I was a permitee, I guess, at this point, I do not 

understand prescriptive grazing because if I'm running so many head 

of cattle, and I have a plan -- this plan always will be changed 

based on the rainfall. But when I put cattle in a certain pasture 

and when I pull them out and so forth, and I know that long in 

advance, but it's still based on the rainfall. 

 But on prescriptive grazing, I understand your example, but I 

don't know that I'm going to put my cattle on a particular piece of 

land, I would think, until after the rainfall. 

 So that's my first question: How would I know in advance that 

I'm not going to have to find additional pasture. 

 And the second question is on the WSA's. And I have read 

through page 139. I think it's written well. I think it's very 

easy to understand. And I love your photos. 

 These WSA's were set by Congress. How is this process going to 

eliminate and add to certain areas? 

 And that's the end of my questions. 

 MIMI: Dan Bennett with Wes on deck. 

1

 MR. BENNETT: My name is Dan Bennett. Common spelling: two N's

and two T's. 

 I'm the conservation chair for the Upper Missouri Audubon 

Society in Great Falls. 

 I want to confine my comments tonight to the state of grassland 

birds which the whole world's become a population state for those, 

and they're starting to drop into the threatened and endangered 

process, which has gotten them nowhere because there's no room for 

them in that process. 

 So there's a couple of factors that look good to us in this 

plan, that will affect grasslands habitat. Those are the grazing 

and prescriptive burning, which we were thrilled to see those, and 

never thought we'd use a word like that in a place like this, but it 

is something new and just great. 

 The factors that bother us is that it doesn't seem like the 

preferred alternative is going to do much for rodent citizens. 

We're baffled by the lack of inclusion of all of the wilderness 

study areas. That seemed to be to us a no-brainer as far as keeping 

them as far as habitat goes. It's cheap and easy to keep 

fragmentation out of it. 

 And the last is oil and gas development, which would be a 

disaster. I know that that decision is not being made now. But 

we've been in enough places where that's gone through, and listened 

to all the mitigation stuff from the industry -- never yet have we 

seen any way to mitigate against the fragmentation that this causes. 

And for grassland birds, that would be about the last straw. 

 So I would appreciate if someone could address at the end of 

this what the thinking is on how we're going to benefit grasslands 

bird here and keep them alive. 

 Thank you. 

 MIMI: Wes and Art on deck. 

 MR. MURRAY: My name is Wes Murray, M-u-r-r-a-y. 

 And I come to you tonight as a sportsman who has been in the 

CM Russell for 40 years. I've been there when CM Russell cow range 

was administered by the BLM, and one of those individuals that 

fought hard to see that the US Fish and Wildlife Service would take 

control of it, and it would be manages as a wildlife area. And this 

is very important. 

 Also, one of those people that back in the 70's sat down with 

the maps and looked at it, came up with these wilderness areas, and 

I cannot support any proposal that would remove any of the areas. 

 I do really appreciate the additions that have been made. We 

looked and studied to see what would be the best. Part of that came 

from the tremendous pressure that has been put on the area. In the 

50's an elk herd was transferred from Glacier, from Seeley, from 

Yellowstone in the Gardiner area into the CM Russell. It was done 

by private individuals with the hope of -- it would flourish in that 

area.

 Today we have a flourishing elk herd, but that elk herd is 

seeing tremendous pressure off and on. And part of the reason we 

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1 1 went with the wilderness study areas, trying to relieve some of the 

road pressure that was on there. 

 In the 70's in the early 70's there were 200 bow hunters in the 

state of Montana. And within a couple years that became 2,000. I 

think we have 14,000 bow hunters in the state of Montana now. 

 The pressure from the open roads -- prior to what the Fish and 

Wildlife Service -- has caused those elk herds to shift. There 

never used to be elk on the south side of the river. There was not 

a sustainable herd in the Bear Paws. Those elk were put out of the 

range by pressure. 

 So anything -- I totally support the road closures in Plan B. 

It's a tremendous asset to the wildlife range if we can continue and 

support that. 

 You know, prescriptive grazing is great if we can work it out. 

I know it's still an economical factor. And it will have an 

economical impact on the area. 

 I am very concerned on the issue of the prescriptive burning. 

There are certain pockets in the refuge that if you were to destroy 

that area and those travel ways, you would cut the movement of the 

elk.

 There was a fire in the early 2000's on the CK Ridge coming out 

the Nicholls Coulee. Prior to that fire, there were elk everywhere 

on that area. 

 Since that fire, there's no elk on that area -- never seen an 

elk in that ridge. 

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com
374 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 17 Page 19 

1 So I would like to say if we can't, you know, go with something 

like Plan B, that we at least get to Plan A where we are right now. 

 Thank you. 

 MIMI: Aart and Bob Nicholson on deck. 

 MR. DOLMAN: Good evening. My name is Aart Dolman. A-a-r-t 

D-o-l-m-a-n. And that's -- I'm Dutch and an American citizen. 

 But, also, I'd like to have some questions because -- pertaining 

to water use and watercraft. I did not see too much of this in the 

plan.

 But I would like to be clear that I floated the Missouri River 

from Fort Peck all the way here into Great Falls and different parts 

since 1969. 

 And when I first came to this area, I was a young professor of 

history so I'd like to identify myself on that point. 

 And the question that I have pertaining to the uses of water 

craft is that I've noticed over the years the multiplication, you 

know, the tripling or quadrupling, what it is, of water usage and 

also boats that are getting faster and faster, and creating, 

therefore, a greater wake, and interferes certainly with not only 

with the river integrity, but also with the neighboring vegetation 

integrity of its shore. 

 So, therefore, my question is directed this way: Does the US 

Fish and Wildlife Service, you know, have a management 

responsibility on the river? 

 And if so, you know, where does it go from Fort Peck, and how is 

1

it related to the riparian areas. 

 My second question is are there any statistics that is recorded 

on the usage of river boats on the river? Do you keep a head count 

or watercraft count? Is that increasing or is that decreasing? 

 And my final question is Did the draft plan address the impacts 

from motorized watercraft? Because this is also the type of 

watercraft -- is also changing very drastically as our technology 

changes.

 And when I first started out, a person was really glad to do 

this with a screw propeller. And now we have jet boats, which not 

only increasing the speed, but also the size of the watercraft that 

they carry, ATV's on, and landing on the shore, and use that land, 

also. And that has a great impact. 

 I thank you very much for the time and for my questions. 

 MIMI: Bob and Mark on deck. 

 MR. NICHOLSON: I'm Bob Nicholson, N-i-c-h-o-l-s-o-n, and I'm 

a member of the Missouri Wilderness Association. 

 I didn't get a chance to read the environmental impact statement 

or the draft plan, but part of my question has been answered, but 

it's been mentioned in there about the road density in the refuge, 

which I gather is 670 miles. And then Plan B, I see they're going 

to eliminate 106 miles. 

 The rest of my question is How do you plan to manage off-road 

vehicle use. 

 Thank you. 

 MIMI: Mark with Leurie on deck. 

 MR. GOOD: My name is Mark Good. No E on the end, just plan 

Good -- not that Good. 

 Anyway, you know, I talk to people. It seems like there's 

always a lot of confusion about what -- how National Wildlife Refuge 

is different from other public lands, or how they're managed 

differently.

 And I think, in listening to you, and reading, it seems like it 

is pretty clear. The guiding principal, management, and that is 

that it's in about enhancement and protection of wildlife. And that 

mission seems pretty clear. 

 While commercial and recreational use is allowed on the refuge, 

prior uses include hunting, fishing, wildlife observation, 

photography, environmental education, and interpretation. 

 And other uses such as camping, outfitting, livestock grazing, 

bicycling, horseback riding, and motorized vehicle use are all 

secondary, and only allowed where they are compatible with the 

primary mission of the refuge. 

 Now I know that there are some who wish it were otherwise, who, 

I think, there's a few who probably wish the whole refuge would just 

go away. But that's not going to happen. And that's the way it is, 

so I think it's through that lens, that mission, that you've got 

that those decisions ought to follow. 

 So let me go on and say something about wilderness. I think 

it's often that our high plains are characterized as being boring or 

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1 1 no monotonous or empty, but I think anybody that spends time in the 

refuges, certainly knows that they're not boring, not monotonous, in 

fact, quite diverse. 

 And I know with the dam, certainly it is not the landscape that 

Lewis and Clark saw. And it's not teeming with wildlife in the same 

way it was when they came through, but that landscape is still vast 

and so impressive. And I think with the restoration of wildlife 

that has occurred over the years, decades, that there just isn't 

anything like it in, I think, the eastern half of the state. 

 And I know people generally don't associate wilderness areas 

with prairies, but -- and they are under-representative in the whole 

wilderness system. But I think as writer Wallace Stegner said, "The 

vanishing prairie is as good a place as any for the wilderness 

experience to happen;" and "is as worth preserving for the 

wilderness idea as the alpine forest." 

 So I just want to make the point that I think designating 

wilderness within the refuge reenforces that mission of the refuge 

by providing blocks of undisturbed land and quality of habitat. 

 And I think it also provided security for big game and helps to 

keep wildlife within the refuge. 

 I know there have been concerns by some of the landowners about 

the wildlife going outside the refuge. 

 I think all the areas that -- within the refuge that are 

proposed are -- they are all small, and they're all -- most all 

pretty equally accessible. At least the ones I have been to. 

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5 (Pages 17 to 20) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

ATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 17 Page 19 

with something 

are right now. 

art Dolman. A-a-r-t 

can citizen. 

e -- pertaining 

of this in the 

souri River 

d different parts 

 professor of 

s of water 

ation, you 

er usage and 

ting, 

ith not only 

g vegetation 

Does the US 

ement 

Peck, and how is 

1

t is recorded 

ep a head count 

reasing? 

ss the impacts 

 type of 

technology 

 MIMI: Mark with Leurie on deck. 

 MR. GOOD: My name is Mark Good. No E on the end, just plan 

Good -- not that Good. 

 Anyway, you know, I talk to people. It seems like there's 

always a lot of confusion about what -- how National Wildlife Refuge 

is different from other public lands, or how they're managed 

differently.

 And I think, in listening to you, and reading, it seems like it 

is pretty clear. The guiding principal, management, and that is 

that it's in about enhancement and protection of wildlife. And that 

mission seems pretty clear. 

 While commercial and recreational use is allowed on the refuge, 

prior uses include hunting, fishing, wildlife observation, 

photography, environmental education, and interpretation. 

 And other uses such as camping, outfitting, livestock grazing, 

bicycling, horseback riding, and motorized vehicle use are all 

secondary, and only allowed where they are compatible with the 

primary mission of the refuge. 

 Now I know that there are some who wish it were otherwise, who, 

I think, there's a few who probably wish the whole refuge would just 

go away. But that's not going to happen. And that's the way it is, 

so I think it's through that lens, that mission, that you've got 

that those decisions ought to follow. 

 So let me go on and say something about wilderness. I think 

it's often that our high plains are characterized as being boring or 

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

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20

21

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24

25

Page 18 Page 20 

1 no monotonous or empty, but I think anybody that spends time in the 

refuges, certainly knows that they're not boring, not monotonous, in 

fact, quite diverse. 

 And I know with the dam, certainly it is not the landscape that 

Lewis and Clark saw. And it's not teeming with wildlife in the same 

way it was when they came through, but that landscape is still vast 

and so impressiveAnd I think with the restoration of wildlife 

2

3

4

5

6

7

therefore, a greater wake, and interferes certainly with not only 

with the river integrity, but also with the neighboring vegetation 

integrity of its shore. 

 So, therefore, my question is directed this way: Does the US 

Fish and Wildlife Service, you know, have a management 

responsibility on the river? 

 And if so, you know, where does it go from Fort Peck, and how is 

it related to the riparian areas. 

 My second question is are there any statistics that is recorded 

on the usage of river boats on the river? Do you keep a head count 

or watercraft count? Is that increasing or is that decreasing? 

 And my final question is Did the draft plan address the impacts 

from motorized watercraft? Because this is also the type of 

watercraft -- is also changing very drastically as our technology 

changes.

 And when I first started out, a person was really glad to do 

this with a screw propeller. And now we have jet boats, which not 

only increasing the speed, but also the size of the watercraft that 

they carry, ATV's on, and landing on the shore, and use that land, 

also. And that has a great impact. 

 I thank you very much for the time and for my questions. 

 MIMI: Bob and Mark on deck. 

 MR. NICHOLSON: I'm Bob Nicholson, N-i-c-h-o-l-s-o-n, and I'm 

a member of the Missouri Wilderness Association. 

 I didn't get a chance to read the environmental impact statement 

or the draft plan, but part of my question has been answered, but 

it's been mentioned in there about the road density in the refuge, 

which I gather is 670 miles. And then Plan B, I see they're going 

to eliminate 106 miles. 

 The rest of my question is How do you plan to manage off-road 

vehicle use. 

 Thank you. 

 Now I know th

I think, there's a f

go away. But tha

so I think it's thro

that those decisio

 So let me go o

it's often that our 

19 19

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22 22

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Page 18 

1 1 no monotonous o

refuges, certainly 

fact, quite diverse

 And I know w

Lewis and Clark 

way it was when 

and so impressiv

that has occurred 

anything like it in

 And I know pe

with prairies, but 

wilderness system

vanishing prairie 

experience to hap

wilderness idea a

 So I just want 

wilderness within 

by providing bloc

 And I think it a

keep wildlife wit

 I know there h

the wildlife going 

 I think all the a

proposed are -- th

pretty equally acc

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Agamenoni & Frank Court Reporting

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CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 17 Page 19 

1 So I would like to say if we can't, you know, go with something 

like Plan B, that we at least get to Plan A where we are right now. 

 Thank you. 

 MIMI: Aart and Bob Nicholson on deck. 

 MR. DOLMAN: Good evening. My name is Aart Dolman. A-a-r-t 

D-o-l-m-a-n. And that's -- I'm Dutch and an American citizen. 

 But, also, I'd like to have some questions because -- pertaining 

to water use and watercraft. I did not see too much of this in the 

plan.

 But I would like to be clear that I floated the Missouri River 

from Fort Peck all the way here into Great Falls and different parts 

since 1969. 

 And when I first came to this area, I was a young professor of 

history so I'd like to identify myself on that point. 

 And the question that I have pertaining to the uses of water 

craft is that I've noticed over the years the multiplication, you 

know, the tripling or quadrupling, what it is, of water usage and 

also boats that are getting faster and faster, and creating, 

therefore, a greater wake, and interferes certainly with not only 

with the river integrity, but also with the neighboring vegetation 

integrity of its shore. 

 So, therefore, my question is directed this way: Does the US 

Fish and Wildlife Service, you know, have a management 

responsibility on the river? 

 And if so, you know, where does it go from Fort Peck, and how is 

1

it related to the riparian areas. 

 My second question is are there any statistics that is recorded 

on the usage of river boats on the river? Do you keep a head count 

or watercraft count? Is that increasing or is that decreasing? 

 And my final question is Did the draft plan address the impacts 

from motorized watercraft? Because this is also the type of 

watercraft -- is also changing very drastically as our technology 

changes.

 And when I first started out, a person was really glad to do 

this with a screw propeller. And now we have jet boats, which not 

only increasing the speed, but also the size of the watercraft that 

they carry, ATV's on, and landing on the shore, and use that land, 

also. And that has a great impact. 

 I thank you very much for the time and for my questions. 

 MIMI: Bob and Mark on deck. 

 MR. NICHOLSON: I'm Bob Nicholson, N-i-c-h-o-l-s-o-n, and I'm 

a member of the Missouri Wilderness Association. 

 I didn't get a chance to read the environmental impact statement 

or the draft plan, but part of my question has been answered, but 

it's been mentioned in there about the road density in the refuge, 

which I gather is 670 miles. And then Plan B, I see they're going 

to eliminate 106 miles. 

 The rest of my question is How do you plan to manage off-road 

vehicle use. 

 Thank you. 

 MIMI: Mark with Leurie on deck. 

 MR. GOOD: My name is Mark Good. No E on the end, just plan 

Good -- not that Good. 

 Anyway, you know, I talk to people. It seems like there's 

always a lot of confusion about what -- how National Wildlife Refuge 

is different from other public lands, or how they're managed 

differently.

 And I think, in listening to you, and reading, it seems like it 

is pretty clear. The guiding principal, management, and that is 

that it's in about enhancement and protection of wildlife. And that 

mission seems pretty clear. 

 While commercial and recreational use is allowed on the refuge, 

prior uses include hunting, fishing, wildlife observation, 

photography, environmental education, and interpretation. 

 And other uses such as camping, outfitting, livestock grazing, 

bicycling, horseback riding, and motorized vehicle use are all 

secondary, and only allowed where they are compatible with the 

primary mission of the refuge. 

 Now I know that there are some who wish it were otherwise, who, 

I think, there's a few who probably wish the whole refuge would just 

go away. But that's not going to happen. And that's the way it is, 

so I think it's through that lens, that mission, that you've got 

that those decisions ought to follow. 

 So let me go on and say something about wilderness. I think 

it's often that our high plains are characterized as being boring or 

2 2

3 3

4 4

5 5

6 6

7 7

8 8

9 9

10 10

11 11

12 12

13 13

14 14

15 15

16 16

17 17

18 18

19 19

20 20

21 21

22 22

23 23

24 24

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Page 18 Page 20 

1 1 no monotonous or empty, but I think anybody that spends time in the 

refuges, certainly knows that they're not boring, not monotonous, in 

fact, quite diverse. 

 And I know with the dam, certainly it is not the landscape that 

Lewis and Clark saw. And it's not teeming with wildlife in the same 

way it was when they came through, but that landscape is still vast 

and so impressive. And I think with the restoration of wildlife 

that has occurred over the years, decades, that there just isn't 

anything like it in, I think, the eastern half of the state. 

 And I know people generally don't associate wilderness areas 

with prairies, but -- and they are under-representative in the whole 

wilderness system. But I think as writer Wallace Stegner said, "The 

vanishing prairie is as good a place as any for the wilderness 

experience to happen;" and "is as worth preserving for the 

wilderness idea as the alpine forest." 

 So I just want to make the point that I think designating 

wilderness within the refuge reenforces that mission of the refuge 

by providing blocks of undisturbed land and quality of habitat. 

 And I think it also provided security for big game and helps to 

keep wildlife within the refuge. 

 I know there have been concerns by some of the landowners about 

the wildlife going outside the refuge. 

 I think all the areas that -- within the refuge that are 

proposed are -- they are all small, and they're all -- most all 

pretty equally accessible. At least the ones I have been to. 

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Agamenoni & Frank Court Reporting

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VOLUME 2, Chapter 4—Public Hearing Testimony 375

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 21 Page 23 

1 But I am concerned, though, as I mentioned this before about the 

three proposed areas that be being eliminated because I think they 

all fit the criteria, in size and naturalness and primitive 

character, and human activities are there -- are pretty negligible, 

and certainly want to provide that sense of solitude. 

 So I just ask you to reconsider, and I think it's -- think about 

how to make this plan work for the communities and for the people 

using them, but I think that the wilderness part of it fits that 

mission. Thanks. 

 MIMI: Laurie. Mel on deck. 

 MS. RILEY: My name is Laurie Riley. Laurie is spelled 

L-a-u-r-i-e. Riley is R-i-l-e-y. 

 I'm representing the Missouri River Conservation District 

Council.

 First of all, I'd like to say congratulations on a huge effort. 

It certainly is a very comprehensive document. And it's -- clearly 

has required thousands of hours of work and research. And we're 

very appreciative of the work that's gone into the plan. 

 I have not read the entire document. I'm only, I would say, 

well into Chapter Four. 

 And tonight I have more of a question than I do a comment. And 

it could be that the question is answered later in the document and 

I just haven't gotten there yet. 

 My question involves the discussion and use of sentinel plants 

and monitoring. And the Council has some concerns about monitoring 

1

using sentinel plants. And some of these concerns involve who 

developed the protocol and where else is it being used. Are there 

results of the protocol and are those results long-term. Has the 

system of using sentinel plants for monitoring been peer-reviewed. 

And is there a scientific basis for understanding the historical 

presence of the selective plants -- listed sentinel plants -- in the 

document.

 And there are widely accepted monitoring protocols and practices 

developed by the NRCS and the Society of Range Management. And I'm 

not familiar with whether or not the way sentinel plants are being 

used in those plan are consistent with those protocols. And I'm not 

a range specialist, and I could be wrong. 

 So these are questions more than comment. 

 And thank you for your time. 

 MIMI: Janelle with Jim on deck. 

 MS. HOLDEN: Janelle Holden, J-a-n-e-l-l-e H-o-l-d-e-n, 

Wilderness Society. 

 And I'm tour with these guys, too, so they've heard me -- this 

is the third time. So bear with me. 

 So today I had an editorial in the newspaper, and I'm a little 

worried that the headline might have confused some folks about oil 

and gas involvement in the refuge, so I want to make sure we 

understand that the mineral withdrawal until 2013 is a separate 

process and is not part of the CCP. 

 The point that I was trying to make, which I think is a 

legitimate comment here, is that the CMR is the only area of public 

land that are managed for wildlife in this region, and we don't want 

to see the CMR become an island. But it's a possibility that it 

could become an island because the BLM does manage for multiple 

uses, and it is possible that oil and gas development could come 

close to the CMR and affect the wildlife in the CMR. 

 So the point that I wanted to make is that the CMR is an 

absolute gem. It's a gem for Montana. It's a gem for the United 

States. And it's a gem world-wide in terms of prairie conservation. 

 And I hope that in your planning efforts you consider the 

impacts that other land management agencies and private landowners 

may make that would affect the resource down the line. 

 So, thanks again for all your efforts on this work and for 

bringing me to Great Falls. 

 MIMI: Thanks Janelle. Jim with Randy on deck. 

 MR. McCOLLUM: My name is Jim McCollum, M-c-C-o-l-l-u-m. 

 And like several of these folks, I don't have any comments. I 

have some questions. 

 I guess one comment, I think it would be good if you would 

address this oil and gas issue. Although it's not a part of the 

CCP, if you can explain to folks here what the status is of that 

because this article in the paper today made it look like it's 

something that needs to be worked on, and maybe you can clear that 

up.

 The other things I've got are sort of minor issues, but just in 

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Page 22 Page 24 

1 1 thumbing quickly through the EIS here the last few days -- I haven't 

had time to read it in detail -- but these are sort of technical 

details that I'm interested in finding out. 

 There's one place on page 153 where it talks about shed and/or 

collecting being prohibited under Alternative A, but is not 

mentioned in any of the other alternatives. 

 And I would like to know whether -- whether this is going to be 

continued as it is now. And if it is, what is the justification for 

prohibiting antler collecting on the refuge. 

 What advantage or -- for wildlife -- or disadvantage for 

wildlife do you garner by prohibiting antler collecting. 

 On page 155 there is a comment about the use of ATV's. And if 

their use becomes -- if there's increasing use, you'll begin 

monitoring that use for possible changes. 

 And I wasn't -- I'm interested in learning what your thinking is 

in that regard. ATV's are legal motor vehicles on public roads, on 

most public roads, in the state of Montana. And I'm wondering how 

you're talking about addressing some change possibly in the future 

regarding ATV's. 

 I didn't mark down the page number, but anyhow, in the section 

where you talk about refuge operations and how many staff you think 

you'll need in the future to carry out the plan, I didn't see any 

mention, like I said I haven't read the whole EIS, but didn't see 

any mention of the use of volunteers. 

 And this is a personal perspective. But I think that over the 

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6 (Pages 21 to 24) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

 NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 21 Page 23 

d this before about the 

 because I think they 

primitive 

e pretty negligible, 

litude. 

it's -- think about 

ties and for the people 

rt of it fits that 

aurie is spelled 

rvation District 

n a huge effort. 

t. And it's -- clearly 

research. And we're 

 the plan. 

nly, I would say, 

 I do a comment. And 

 in the document and 

se of sentinel plants 

oncerns about monitoring 

1

rns involve who 

g used. Are there 

g-term. Has the 

been peer-reviewed. 

 the historical 

l plants -- in the 

legitimate comment here, is that the CMR is the only area of public 

land that are managed for wildlife in this region, and we don't want 

to see the CMR become an island. But it's a possibility that it 

could become an island because the BLM does manage for multiple 

uses, and it is possible that oil and gas development could come 

close to the CMR and affect the wildlife in the CMR. 

 So the point that I wanted to make is that the CMR is an 

absolute gem. It's a gem for Montana. It's a gem for the United 

States. And it's a gem world-wide in terms of prairie conservation. 

 And I hope that in your planning efforts you consider the 

impacts that other land management agencies and private landowners 

may make that would affect the resource down the line. 

 So, thanks again for all your efforts on this work and for 

bringing me to Great Falls. 

 MIMI: Thanks Janelle. Jim with Randy on deck. 

 MR. McCOLLUM: My name is Jim McCollum, M-c-C-o-l-l-u-m. 

 And like several of these folks, I don't have any comments. I 

have some questions. 

 I guess one comment, I think it would be good if you would 

address this oil and gas issue. Although it's not a part of the 

CCP, if you can explain to folks here what the status is of that 

because this article in the paper today made it look like it's 

something that needs to be worked on, and maybe you can clear that 

up.

 The other things I've got are sort of minor issues, but just in 

2

3

4

5

6

7

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10

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25

Page 22 Page 24 

1 thumbing quickly through the EIS here the last few days -- I haven't 

had time to read it in detail -- but these are sort of technical 

details that I'm interested in finding out. 

 There's one place on page 153 where it talks about shed and/or 

collecting being prohibited under Alternative A, but is not 

mentioned in any of the other alternatives. 

And I would like to know whether whether this is going to be 

2

3

4

5

6

7

 I have not read the entire document. Im only, I would say, 

well into Chapter Four. 

 And tonight I have more of a question than I do a comment. And 

it could be that the question is answered later in the document and 

I just haven't gotten there yet. 

 My question involves the discussion and use of sentinel plants 

and monitoring. And the Council has some concerns about monitoring 

using sentinel plants. And some of these concerns involve who 

developed the protocol and where else is it being used. Are there 

results of the protocol and are those results long-term. Has the 

system of using sentinel plants for monitoring been peer-reviewed. 

And is there a scientific basis for understanding the historical 

presence of the selective plants -- listed sentinel plants -- in the 

document.

 And there are widely accepted monitoring protocols and practices 

developed by the NRCS and the Society of Range Management. And I'm 

not familiar with whether or not the way sentinel plants are being 

used in those plan are consistent with those protocols. And I'm not 

a range specialist, and I could be wrong. 

 So these are questions more than comment. 

 And thank you for your time. 

 MIMI: Janelle with Jim on deck. 

 MS. HOLDEN: Janelle Holden, J-a-n-e-l-l-e H-o-l-d-e-n, 

Wilderness Society. 

 And I'm tour with these guys, too, so they've heard me -- this 

is the third time. So bear with me. 

 So today I had an editorial in the newspaper, and I'm a little 

worried that the headline might have confused some folks about oil 

and gas involvement in the refuge, so I want to make sure we 

understand that the mineral withdrawal until 2013 is a separate 

process and is not part of the CCP. 

 The point that I was trying to make, which I think is a 

 I guess o

address thi

CCP, if you 

because thi

something 

up.

 The othe

19 19

20 20

21 21

22 22

23 23

24 24

25 25

Page 22 

1 1 thumbing q

had time to 

details that 

 There's o

collecting b

mentioned 

 And I w

continued a

prohibiting 

 What ad

wildlife do 

 On page 

their use be

monitoring 

 And I w

in that rega

most publi

you're talki

regarding A

 I didn't m

where you 

you'll need 

mention, li

any mentio

 And this 

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 21 Page 23 

1 But I am concerned, though, as I mentioned this before about the 

three proposed areas that be being eliminated because I think they 

all fit the criteria, in size and naturalness and primitive 

character, and human activities are there -- are pretty negligible, 

and certainly want to provide that sense of solitude. 

 So I just ask you to reconsider, and I think it's -- think about 

how to make this plan work for the communities and for the people 

using them, but I think that the wilderness part of it fits that 

mission. Thanks. 

 MIMI: Laurie. Mel on deck. 

 MS. RILEY: My name is Laurie Riley. Laurie is spelled 

L-a-u-r-i-e. Riley is R-i-l-e-y. 

 I'm representing the Missouri River Conservation District 

Council.

 First of all, I'd like to say congratulations on a huge effort. 

It certainly is a very comprehensive document. And it's -- clearly 

has required thousands of hours of work and research. And we're 

very appreciative of the work that's gone into the plan. 

 I have not read the entire document. I'm only, I would say, 

well into Chapter Four. 

 And tonight I have more of a question than I do a comment. And 

it could be that the question is answered later in the document and 

I just haven't gotten there yet. 

 My question involves the discussion and use of sentinel plants 

and monitoring. And the Council has some concerns about monitoring 

1

using sentinel plants. And some of these concerns involve who 

developed the protocol and where else is it being used. Are there 

results of the protocol and are those results long-term. Has the 

system of using sentinel plants for monitoring been peer-reviewed. 

And is there a scientific basis for understanding the historical 

presence of the selective plants -- listed sentinel plants -- in the 

document.

 And there are widely accepted monitoring protocols and practices 

developed by the NRCS and the Society of Range Management. And I'm 

not familiar with whether or not the way sentinel plants are being 

used in those plan are consistent with those protocols. And I'm not 

a range specialist, and I could be wrong. 

 So these are questions more than comment. 

 And thank you for your time. 

 MIMI: Janelle with Jim on deck. 

 MS. HOLDEN: Janelle Holden, J-a-n-e-l-l-e H-o-l-d-e-n, 

Wilderness Society. 

 And I'm tour with these guys, too, so they've heard me -- this 

is the third time. So bear with me. 

 So today I had an editorial in the newspaper, and I'm a little 

worried that the headline might have confused some folks about oil 

and gas involvement in the refuge, so I want to make sure we 

understand that the mineral withdrawal until 2013 is a separate 

process and is not part of the CCP. 

 The point that I was trying to make, which I think is a 

legitimate comment here, is that the CMR is the only area of public 

land that are managed for wildlife in this region, and we don't want 

to see the CMR become an island. But it's a possibility that it 

could become an island because the BLM does manage for multiple 

uses, and it is possible that oil and gas development could come 

close to the CMR and affect the wildlife in the CMR. 

 So the point that I wanted to make is that the CMR is an 

absolute gem. It's a gem for Montana. It's a gem for the United 

States. And it's a gem world-wide in terms of prairie conservation. 

 And I hope that in your planning efforts you consider the 

impacts that other land management agencies and private landowners 

may make that would affect the resource down the line. 

 So, thanks again for all your efforts on this work and for 

bringing me to Great Falls. 

 MIMI: Thanks Janelle. Jim with Randy on deck. 

 MR. McCOLLUM: My name is Jim McCollum, M-c-C-o-l-l-u-m. 

 And like several of these folks, I don't have any comments. I 

have some questions. 

 I guess one comment, I think it would be good if you would 

address this oil and gas issue. Although it's not a part of the 

CCP, if you can explain to folks here what the status is of that 

because this article in the paper today made it look like it's 

something that needs to be worked on, and maybe you can clear that 

up.

 The other things I've got are sort of minor issues, but just in 

2 2

3 3

4 4

5 5

6 6

7 7

8 8

9 9

10 10

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12 12

13 13

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15 15

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23 23

24 24

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Page 22 Page 24 

1 1 thumbing quickly through the EIS here the last few days -- I haven't 

had time to read it in detail -- but these are sort of technical 

details that I'm interested in finding out. 

 There's one place on page 153 where it talks about shed and/or 

collecting being prohibited under Alternative A, but is not 

mentioned in any of the other alternatives. 

 And I would like to know whether -- whether this is going to be 

continued as it is now. And if it is, what is the justification for 

prohibiting antler collecting on the refuge. 

 What advantage or -- for wildlife -- or disadvantage for 

wildlife do you garner by prohibiting antler collecting. 

 On page 155 there is a comment about the use of ATV's. And if 

their use becomes -- if there's increasing use, you'll begin 

monitoring that use for possible changes. 

 And I wasn't -- I'm interested in learning what your thinking is 

in that regard. ATV's are legal motor vehicles on public roads, on 

most public roads, in the state of Montana. And I'm wondering how 

you're talking about addressing some change possibly in the future 

regarding ATV's. 

 I didn't mark down the page number, but anyhow, in the section 

where you talk about refuge operations and how many staff you think 

you'll need in the future to carry out the plan, I didn't see any 

mention, like I said I haven't read the whole EIS, but didn't see 

any mention of the use of volunteers. 

 And this is a personal perspective. But I think that over the 

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6 (Pages 21 to 24) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com
376 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 25 Page 27 

1 next several years, the Fish and Wildlife Service, and all federal 

agencies, are going to be facing extraordinary pressures from a 

budgetary standpoint. 

 And I think you need to consider how you would use citizen 

volunteers to accomplish some of your work in the future, what kind 

of things the public could help you on, and to get more volunteer 

involvement on carrying out refuge programs. 

 And I may have some more questions once you start answering 

these that have been given to you. 

 Thanks. 

 MIMI: Thanks, Jim. Randy? 

 MR. GRAY: My name is Randy Gray. That's with a G-r-a-y as 

opposed to -e-y. 

 I'm a retired lawyer from Great Falls here. Was former mayor of 

the Great Falls. Served several terms on the BLM RAC for North 

Central Montana. I'm currently a member of the National Advisory 

Board for American Prairie Foundation. 

 Tonight I'm wearing a hat on behalf of myself and my kids. I 

don't represent any of the previous mentioned affiliations. And 

maybe representing my as yet unborn grandchildren if I'm lucky. 

 I guess I commend the Agency for coming up with the process 

you've come up with, and certainly the Preferred Plan B. 

 I echo Mark Good's comments about the importance to note that 

the Agency, this Agency, Fish and Wildlife Service, and the Refuge 

Service of the United States, the mission of that agency and those 

1

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refuges is to protect and enhance wildlife. And they're not 

conflicted with the problems that conflict the US Forest Service and 

BLM, which are multiple-use agencies. I think that's an important 

ground rule for the public to understand what's happening here. 

 I generally support the overarching concept of reintroducing 

prescriptive grazing, so long as it's coupled with prescriptive 

fire. And I think over time, that those two tools, used in 

conjunction, can mimic the process that occurred geologically and 

historically out there of the ungulate species of bison, a split 

hooved critter, in conjunction with fire, on that particular prairie 

landscape.

 So over time, I think as cattle are managed with more 

prescriptive use and as fire is managed with more prescriptive use, 

those two tools can be a proxy for what natural conditions were out 

there.

 And I mention that in particular because over time -- this plan 

will be in effect for 15 years -- but we have to look out beyond 15 

years, whatever the plan might be now -- over time I would encourage 

the reintroduction of bison species. I certainly agree that the 

state Fish, Wildlife and Parks should be principal involved with 

that, probably should be even the agency reintroducing those. 

 But over time, over the next four or five generations, or excuse 

me, decades, I think there should be bison back on that landscape, 

and using ungulates and cattle right now in conjunction with fire 

can proximate -- can be the proxy for preparing that landscape for 

more bison being on that landscape. 

 I think the importance of this whole concept here, as I think 

the Agency has it right, I see the refuge in this case using cattle 

rather than cattle using the refuge. And I think that should be a 

motto that you should take a look at your future management with 

because I think you're on the right track doing that. 

 I do note, and I've not gone through with a fine-tooth comb, but 

I would sure like there to be some comment about aggressive weed 

management should be part of what's being looked at in the overall 

management plan for the next 15 years. 

 And on a personal note, I do note that this last, well, about 

ten days ago, my wife and I went out to the Slippery End for the 

third year in a row, slept in my camper in the back of our pickup, 

and listened to that wonderful elk bugling occurring all night long. 

 Over the course of my time with the American Prairie Foundation, 

I have literally taken hundreds of visitors from this country and 

elsewhere to this landscape out there. And the gem that we have, 

the unbroken prairie that you are the heart of out there, is 

important for future generations of all Americans. 

 Thank you. 

 MIMI: Thanks, Randy. 

 Randy was the last one on my list, but does anybody else have a 

comment? Yeah, come on up. 

 MS. BERNARD: My name is Joanne, J-o-a-n-n-e Bernard, 

B-e-r-n-a-r-d.

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Page 26 Page 28 

1 1 And I'm a little short so I'll hold onto this. Anyway, I just 

want to thank you for coming, and putting so much effort into this, 

because it is, as many others have said, a gem. So I want to say 

that I am for Alternative B because of the very title of this 

management area, which is wildlife refuge. 

 I do have a question. And you did kind of touch on it a bit 

earlier, but most of us think of wildlife as the game animals or 

birds. And I know that the refuge is way more than that. 

 So I am hoping, as you have said, that we also include other 

species, other non-game species, in particular the prairie dog 

areas.

 I don't know how many of them are there now or how many there 

might be, but it would certainly contribute to the health of the 

wildlife refuge. 

 I also want to make a comment about the difference between 

cattle grazing and buffalo grazing. I'm not totally familiar with 

this on hand, but I have heard that buffalo do a whole lot more 

seeding of grass than cattle do, just because of their hoof shape, 

and also their activity. Cattle are very slow moving and buffalo 

can tear things up a bit, which seeds grass a lot easier. 

 So anyway, I just wanted you to know that I'm interested in both 

of those things. 

 Thank you. 

 MIMI: Anybody else? Okay. I'll turn it to Barron and Bill to 

respond to questions. 

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7 (Pages 25 to 28) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

ATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 25 Page 27 

and all federal 

ssures from a 

ld use citizen 

e future, what kind 

more volunteer 

u start answering 

 with a G-r-a-y as 

s former mayor of 

M RAC for North 

National Advisory 

and my kids. I 

iliations. And 

en if I'm lucky. 

with the process 

Plan B. 

tance to note that 

ce, and the Refuge 

gency and those 

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24

25

y're not 

orest Service and 

t's an important 

pening here. 

introducing 

escriptive 

ed in 

more bison being on that landscape. 

 I think the importance of this whole concept here, as I think 

the Agency has it right, I see the refuge in this case using cattle 

rather than cattle using the refuge. And I think that should be a 

motto that you should take a look at your future management with 

because I think you're on the right track doing that. 

 I do note, and I've not gone through with a fine-tooth comb, but 

I would sure like there to be some comment about aggressive weed 

management should be part of what's being looked at in the overall 

management plan for the next 15 years. 

 And on a personal note, I do note that this last, well, about 

ten days ago, my wife and I went out to the Slippery End for the 

third year in a row, slept in my camper in the back of our pickup, 

and listened to that wonderful elk bugling occurring all night long. 

 Over the course of my time with the American Prairie Foundation, 

I have literally taken hundreds of visitors from this country and 

elsewhere to this landscape out there. And the gem that we have, 

the unbroken prairie that you are the heart of out there, is 

important for future generations of all Americans. 

 Thank you. 

 MIMI: Thanks, Randy. 

 Randy was the last one on my list, but does anybody else have a 

comment? Yeah, come on up. 

 MS. BERNARD: My name is Joanne, J-o-a-n-n-e Bernard, 

B-e-r-n-a-r-d.

Page 26 Page 28 

1 And I'm a little short so I'll hold onto this. Anyway, I just 

want to thank you for coming, and putting so much effort into this, 

because it is, as many others have said, a gem. So I want to say 

that I am for Alternative B because of the very title of this 

management area, which is wildlife refuge. 

 I do have a question. And you did kind of touch on it a bit 

earlier, but most of us think of wildlife as the game animals or 

2

3

4

5

6

7

dont represent any of the previous mentioned affiliations. And 

maybe representing my as yet unborn grandchildren if I'm lucky. 

 I guess I commend the Agency for coming up with the process 

you've come up with, and certainly the Preferred Plan B. 

 I echo Mark Good's comments about the importance to note that 

the Agency, this Agency, Fish and Wildlife Service, and the Refuge 

Service of the United States, the mission of that agency and those 

19

20

21

22

23

24

25

refuges is to protect and enhance wildlife. And they're not 

conflicted with the problems that conflict the US Forest Service and 

BLM, which are multiple-use agencies. I think that's an important 

ground rule for the public to understand what's happening here. 

 I generally support the overarching concept of reintroducing 

prescriptive grazing, so long as it's coupled with prescriptive 

fire. And I think over time, that those two tools, used in 

conjunction, can mimic the process that occurred geologically and 

historically out there of the ungulate species of bison, a split 

hooved critter, in conjunction with fire, on that particular prairie 

landscape.

 So over time, I think as cattle are managed with more 

prescriptive use and as fire is managed with more prescriptive use, 

those two tools can be a proxy for what natural conditions were out 

there.

 And I mention that in particular because over time -- this plan 

will be in effect for 15 years -- but we have to look out beyond 15 

years, whatever the plan might be now -- over time I would encourage 

the reintroduction of bison species. I certainly agree that the 

state Fish, Wildlife and Parks should be principal involved with 

that, probably should be even the agency reintroducing those. 

 But over time, over the next four or five generations, or excuse 

me, decades, I think there should be bison back on that landscape, 

and using ungulates and cattle right now in conjunction with fire 

can proximate -- can be the proxy for preparing that landscape for 

important for fut

 Thank you. 

 MIMI: Thank

 Randy was the 

comment? Yeah

 MS. BERNAR

B-e-r-n-a-r-d.

19

20

21

22

23

24

25

Page 26 

1 1 And I'm a littl

want to thank yo

because it is, as m

that I am for Alte

management are

 I do have a qu

earlier, but most 

birds. And I kno

 So I am hopin

species, other no

areas.

 I don't know h

might be, but it w

wildlife refuge. 

 I also want to 

cattle grazing an

this on hand, but 

seeding of grass 

and also their ac

can tear things u

 So anyway, I j

of those things. 

 Thank you. 

 MIMI: Anyb

respond to quest

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Agamenoni & Frank Court Reporting

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CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 25 Page 27 

1 next several years, the Fish and Wildlife Service, and all federal 

agencies, are going to be facing extraordinary pressures from a 

budgetary standpoint. 

 And I think you need to consider how you would use citizen 

volunteers to accomplish some of your work in the future, what kind 

of things the public could help you on, and to get more volunteer 

involvement on carrying out refuge programs. 

 And I may have some more questions once you start answering 

these that have been given to you. 

 Thanks. 

 MIMI: Thanks, Jim. Randy? 

 MR. GRAY: My name is Randy Gray. That's with a G-r-a-y as 

opposed to -e-y. 

 I'm a retired lawyer from Great Falls here. Was former mayor of 

the Great Falls. Served several terms on the BLM RAC for North 

Central Montana. I'm currently a member of the National Advisory 

Board for American Prairie Foundation. 

 Tonight I'm wearing a hat on behalf of myself and my kids. I 

don't represent any of the previous mentioned affiliations. And 

maybe representing my as yet unborn grandchildren if I'm lucky. 

 I guess I commend the Agency for coming up with the process 

you've come up with, and certainly the Preferred Plan B. 

 I echo Mark Good's comments about the importance to note that 

the Agency, this Agency, Fish and Wildlife Service, and the Refuge 

Service of the United States, the mission of that agency and those 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

18

19

20

21

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24

25

refuges is to protect and enhance wildlife. And they're not 

conflicted with the problems that conflict the US Forest Service and 

BLM, which are multiple-use agencies. I think that's an important 

ground rule for the public to understand what's happening here. 

 I generally support the overarching concept of reintroducing 

prescriptive grazing, so long as it's coupled with prescriptive 

fire. And I think over time, that those two tools, used in 

conjunction, can mimic the process that occurred geologically and 

historically out there of the ungulate species of bison, a split 

hooved critter, in conjunction with fire, on that particular prairie 

landscape.

 So over time, I think as cattle are managed with more 

prescriptive use and as fire is managed with more prescriptive use, 

those two tools can be a proxy for what natural conditions were out 

there.

 And I mention that in particular because over time -- this plan 

will be in effect for 15 years -- but we have to look out beyond 15 

years, whatever the plan might be now -- over time I would encourage 

the reintroduction of bison species. I certainly agree that the 

state Fish, Wildlife and Parks should be principal involved with 

that, probably should be even the agency reintroducing those. 

 But over time, over the next four or five generations, or excuse 

me, decades, I think there should be bison back on that landscape, 

and using ungulates and cattle right now in conjunction with fire 

can proximate -- can be the proxy for preparing that landscape for 

more bison being on that landscape. 

 I think the importance of this whole concept here, as I think 

the Agency has it right, I see the refuge in this case using cattle 

rather than cattle using the refuge. And I think that should be a 

motto that you should take a look at your future management with 

because I think you're on the right track doing that. 

 I do note, and I've not gone through with a fine-tooth comb, but 

I would sure like there to be some comment about aggressive weed 

management should be part of what's being looked at in the overall 

management plan for the next 15 years. 

 And on a personal note, I do note that this last, well, about 

ten days ago, my wife and I went out to the Slippery End for the 

third year in a row, slept in my camper in the back of our pickup, 

and listened to that wonderful elk bugling occurring all night long. 

 Over the course of my time with the American Prairie Foundation, 

I have literally taken hundreds of visitors from this country and 

elsewhere to this landscape out there. And the gem that we have, 

the unbroken prairie that you are the heart of out there, is 

important for future generations of all Americans. 

 Thank you. 

 MIMI: Thanks, Randy. 

 Randy was the last one on my list, but does anybody else have a 

comment? Yeah, come on up. 

 MS. BERNARD: My name is Joanne, J-o-a-n-n-e Bernard, 

B-e-r-n-a-r-d.

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1 1 And I'm a little short so I'll hold onto this. Anyway, I just 

want to thank you for coming, and putting so much effort into this, 

because it is, as many others have said, a gem. So I want to say 

that I am for Alternative B because of the very title of this 

management area, which is wildlife refuge. 

 I do have a question. And you did kind of touch on it a bit 

earlier, but most of us think of wildlife as the game animals or 

birds. And I know that the refuge is way more than that. 

 So I am hoping, as you have said, that we also include other 

species, other non-game species, in particular the prairie dog 

areas.

 I don't know how many of them are there now or how many there 

might be, but it would certainly contribute to the health of the 

wildlife refuge. 

 I also want to make a comment about the difference between 

cattle grazing and buffalo grazing. I'm not totally familiar with 

this on hand, but I have heard that buffalo do a whole lot more 

seeding of grass than cattle do, just because of their hoof shape, 

and also their activity. Cattle are very slow moving and buffalo 

can tear things up a bit, which seeds grass a lot easier. 

 So anyway, I just wanted you to know that I'm interested in both 

of those things. 

 Thank you. 

 MIMI: Anybody else? Okay. I'll turn it to Barron and Bill to 

respond to questions. 

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com
VOLUME 2, Chapter 4—Public Hearing Testimony 377

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 29 Page 31 

1 MR. CRAWFORD: We tag team these question and answers. I take 

the softball ones, and Bill takes the hard ones. So that's the 

privilege the being manager. 

 Prescriptive grazing. Do not understand how it could impact 

permitees need to know in advance. 

 That is something that we're definitely aware of. And as part 

of this CCP process, we're going to be developing kind of this 

umbrella document that introduces this broad concept for how we're 

going to manage the landscape. And we actually get down to putting 

actions on the ground. We spell that out in what's called a Habitat 

Management Plan. And right now under the '86 EIS, we have 65 

individual habitat management plans. And those management plans 

were developed in concert with the permitees that were grazing on 

those 65 habitat units. So basically the refuge sat down with those 

permitees and said, you know, the reductions that we feel we need to 

make in order to benefit wildlife, how can we fit this into your 

operation, or how can we accommodate you in your operation. 

 We will go through this same provides once this CCP is finalized 

and we start developing those individual habitat management plans. 

We'll sit down. We'll look at the area -- it won't be 65 units. It 

will be something larger. So we'll have multiple permitees that 

we'll be working with. And we'll basically say, you know, in this 

area, this is what we want to do. This is how we see using cattle 

as a management tool to accomplish that. How can you guys help us 

do that. 

1

 And there's going to be some folks that are very locked into 

that cow/calf operation that are going to have a very hard time 

adapting and meeting, you know, maybe our needs. And there's going 

to be other folks that are going to have the flexibility that may be 

running a yearling herd that can have a lot more flexibility and 

bring animals in for some period of time and take them out. 

 So that's going to be a real challenge for the staff as we start 

developing those HMP's to be working with those individuals and 

making sure that we're not impacting them. 

 The one method that we have been using here for the past ten 

years, as those ranches sell to a non-family member, we're holding 

those permits, so we have about 35 percent of the refuge right now 

that we have enrolled in a prescriptive grazing program. 

 And we're using that to move some permitees around to help 

benefit the habitat in those areas that have been grazed the same 

way year after year after year. 

 And so that's probably a strategy that we'll continue to employ 

as these ranchers sell to a non-family member. We'll be holding 

those permits, creating those vacate habitat units, rolling those 

into prescriptive grazing. And so it won't be so much of an impact 

on the current permitee -- that we'll have areas available. 

 Heard a comment or question how are we going to benefit 

grasslands birds. 

 We have a new position on the refuge. We have an individual 

that has moved into kind of a bird biologist's position. She has 

done quite a bit of bird work in Alaska, is very interested in 

birds, works with the Audubon group quite often. Is kind of 

formulating how she's going to fulfill her new role. We did look at 

grassland bird species as being an important part of this plan. 

 A lot of the fire and grazing was developed to try to restore 

biological diversity, not only of the plants, but also the insects 

that rely upon those plants, and then they will also attract the 

various bird species. 

 You got a whole suite out there. You've got birds that prefer, 

you know, bare ground to birds that prefer very thick cover. 

 And so the idea is to try to create that gradient of habitat 

types across the refuge so you meet the needs of all the various 

bird species. 

 We're also going to look at not only the breeding birds, but the 

migrant birds as well. That river corridor provides important 

habitat for a lot of migratory bird species. We don't have a lot of 

information on that, so we're going to spend quite a bit of time 

looking at those corridors and determining, you know, how important 

they are to birds moving up and down that river. 

 Management responsibility on the river, how it relates to 

riparian. Does the plan address impact on boat use. 

 MR. BERG: I told you. I could use a little forewarning. 

 This came up during our scoping meeting. And it's one of the 

things we considered as part of this plan. We're not quite to the 

stage where we can flat out say that there are impacts occurring 

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from boat use on the river. 

 But we have seen that same increase that the one gentleman 

referred to in the last 15, 20 years. The boat size has increased 

significantly. The river is not any kind of a deterrent anymore to 

boat use. It used to be upper end of reservoir was kind of a delta, 

where it was shallow and things. Now with the jet boats that they 

have, it's not a deterrent. 

 So what our plan is to do, and we'll probably have to do a 

little bit better job of explaining this in the document, is not 

having the data to make that determination, not only from a use 

standpoint, but also the impacts it might have an wildlife. 

 We're proposing in the future to adopt a monitoring system to 

see what kind of use we do have. We've done some preliminary work 

with cameras, trying to put those in strategic locations so we can 

identify not only the numbers of boats, but the size, and things 

like that. 

 We've heard a few complaints from hunters that hunt the river 

bottoms, camp on the river bottoms, those kind of things, where 

these big jet boats will actually disturb game at times when they're 

being hunted, that they notice. So it's a use that we're going to 

look into so -- we're just not there yet as far as documented impact 

so --

 MR. CRAWFORD: Page 232 talks about boat use if you're 

interested in the plan. 

 MR. BERG: I thought I'd go right on to the mineral withdrawal. 

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8 (Pages 29 to 32) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

 NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 29 Page 31 

estion and answers. I take 

 So that's the 

w it could impact 

re of. And as part 

ping kind of this 

concept for how we're 

ally get down to putting 

hat's called a Habitat 

86 EIS, we have 65 

ose management plans 

that were grazing on 

 sat down with those 

that we feel we need to 

fit this into your 

n your operation. 

e this CCP is finalized 

at management plans. 

n't be 65 units. It 

ple permitees that 

y, you know, in this 

we see using cattle 

w can you guys help us 

1

 very locked into 

 a very hard time 

needs. And there's going 

xibility that may be 

ore flexibility and 

take them out. 

e staff as we start 

done quite a bit of bird work in Alaska, is very interested in 

birds, works with the Audubon group quite often. Is kind of 

formulating how she's going to fulfill her new role. We did look at 

grassland bird species as being an important part of this plan. 

 A lot of the fire and grazing was developed to try to restore 

biological diversity, not only of the plants, but also the insects 

that rely upon those plants, and then they will also attract the 

various bird species. 

 You got a whole suite out there. You've got birds that prefer, 

you know, bare ground to birds that prefer very thick cover. 

 And so the idea is to try to create that gradient of habitat 

types across the refuge so you meet the needs of all the various 

bird species. 

 We're also going to look at not only the breeding birds, but the 

migrant birds as well. That river corridor provides important 

habitat for a lot of migratory bird species. We don't have a lot of 

information on that, so we're going to spend quite a bit of time 

looking at those corridors and determining, you know, how important 

they are to birds moving up and down that river. 

 Management responsibility on the river, how it relates to 

riparian. Does the plan address impact on boat use. 

 MR. BERG: I told you. I could use a little forewarning. 

 This came up during our scoping meeting. And it's one of the 

things we considered as part of this plan. We're not quite to the 

stage where we can flat out say that there are impacts occurring 

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Page 30 Page 32 

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from boat use on the river. 

 But we have seen that same increase that the one gentleman 

referred to in the last 15, 20 years. The boat size has increased 

significantly. The river is not any kind of a deterrent anymore to 

boat use. It used to be upper end of reservoir was kind of a delta, 

where it was shallow and things. Now with the jet boats that they 

haveit's not a deterrent

and we start developing those individual habitat management plans. 

We'll sit down. We'll look at the area -- it won't be 65 units. It 

will be something larger. So we'll have multiple permitees that 

we'll be working with. And we'll basically say, you know, in this 

area, this is what we want to do. This is how we see using cattle 

as a management tool to accomplish that. How can you guys help us 

do that. 

 And there's going to be some folks that are very locked into 

that cow/calf operation that are going to have a very hard time 

adapting and meeting, you know, maybe our needs. And there's going 

to be other folks that are going to have the flexibility that may be 

running a yearling herd that can have a lot more flexibility and 

bring animals in for some period of time and take them out. 

 So that's going to be a real challenge for the staff as we start 

developing those HMP's to be working with those individuals and 

making sure that we're not impacting them. 

 The one method that we have been using here for the past ten 

years, as those ranches sell to a non-family member, we're holding 

those permits, so we have about 35 percent of the refuge right now 

that we have enrolled in a prescriptive grazing program. 

 And we're using that to move some permitees around to help 

benefit the habitat in those areas that have been grazed the same 

way year after year after year. 

 And so that's probably a strategy that we'll continue to employ 

as these ranchers sell to a non-family member. We'll be holding 

those permits, creating those vacate habitat units, rolling those 

into prescriptive grazing. And so it won't be so much of an impact 

on the current permitee -- that we'll have areas available. 

 Heard a comment or question how are we going to benefit 

grasslands birds. 

 We have a new position on the refuge. We have an individual 

that has moved into kind of a bird biologist's position. She has 

they are to 

 Managem

riparian. D

 MR. BE

 This cam

things we c

stage where 

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from boat u

 But we h

referred to 

significantl

boat use. It 

where it wa

have, it's no

 So what 

little bit bet

having the 

standpoint, 

 We're pr

see what ki

with camer

identify not 

like that. 

 We've he

bottoms, ca

these big je

being hunte

look into so 

so --

 MR. CR

interested i

 MR. BE

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 29 Page 31 

1 MR. CRAWFORD: We tag team these question and answers. I take 

the softball ones, and Bill takes the hard ones. So that's the 

privilege the being manager. 

 Prescriptive grazing. Do not understand how it could impact 

permitees need to know in advance. 

 That is something that we're definitely aware of. And as part 

of this CCP process, we're going to be developing kind of this 

umbrella document that introduces this broad concept for how we're 

going to manage the landscape. And we actually get down to putting 

actions on the ground. We spell that out in what's called a Habitat 

Management Plan. And right now under the '86 EIS, we have 65 

individual habitat management plans. And those management plans 

were developed in concert with the permitees that were grazing on 

those 65 habitat units. So basically the refuge sat down with those 

permitees and said, you know, the reductions that we feel we need to 

make in order to benefit wildlife, how can we fit this into your 

operation, or how can we accommodate you in your operation. 

 We will go through this same provides once this CCP is finalized 

and we start developing those individual habitat management plans. 

We'll sit down. We'll look at the area -- it won't be 65 units. It 

will be something larger. So we'll have multiple permitees that 

we'll be working with. And we'll basically say, you know, in this 

area, this is what we want to do. This is how we see using cattle 

as a management tool to accomplish that. How can you guys help us 

do that. 

1

 And there's going to be some folks that are very locked into 

that cow/calf operation that are going to have a very hard time 

adapting and meeting, you know, maybe our needs. And there's going 

to be other folks that are going to have the flexibility that may be 

running a yearling herd that can have a lot more flexibility and 

bring animals in for some period of time and take them out. 

 So that's going to be a real challenge for the staff as we start 

developing those HMP's to be working with those individuals and 

making sure that we're not impacting them. 

 The one method that we have been using here for the past ten 

years, as those ranches sell to a non-family member, we're holding 

those permits, so we have about 35 percent of the refuge right now 

that we have enrolled in a prescriptive grazing program. 

 And we're using that to move some permitees around to help 

benefit the habitat in those areas that have been grazed the same 

way year after year after year. 

 And so that's probably a strategy that we'll continue to employ 

as these ranchers sell to a non-family member. We'll be holding 

those permits, creating those vacate habitat units, rolling those 

into prescriptive grazing. And so it won't be so much of an impact 

on the current permitee -- that we'll have areas available. 

 Heard a comment or question how are we going to benefit 

grasslands birds. 

 We have a new position on the refuge. We have an individual 

that has moved into kind of a bird biologist's position. She has 

done quite a bit of bird work in Alaska, is very interested in 

birds, works with the Audubon group quite often. Is kind of 

formulating how she's going to fulfill her new role. We did look at 

grassland bird species as being an important part of this plan. 

 A lot of the fire and grazing was developed to try to restore 

biological diversity, not only of the plants, but also the insects 

that rely upon those plants, and then they will also attract the 

various bird species. 

 You got a whole suite out there. You've got birds that prefer, 

you know, bare ground to birds that prefer very thick cover. 

 And so the idea is to try to create that gradient of habitat 

types across the refuge so you meet the needs of all the various 

bird species. 

 We're also going to look at not only the breeding birds, but the 

migrant birds as well. That river corridor provides important 

habitat for a lot of migratory bird species. We don't have a lot of 

information on that, so we're going to spend quite a bit of time 

looking at those corridors and determining, you know, how important 

they are to birds moving up and down that river. 

 Management responsibility on the river, how it relates to 

riparian. Does the plan address impact on boat use. 

 MR. BERG: I told you. I could use a little forewarning. 

 This came up during our scoping meeting. And it's one of the 

things we considered as part of this plan. We're not quite to the 

stage where we can flat out say that there are impacts occurring 

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from boat use on the river. 

 But we have seen that same increase that the one gentleman 

referred to in the last 15, 20 years. The boat size has increased 

significantly. The river is not any kind of a deterrent anymore to 

boat use. It used to be upper end of reservoir was kind of a delta, 

where it was shallow and things. Now with the jet boats that they 

have, it's not a deterrent. 

 So what our plan is to do, and we'll probably have to do a 

little bit better job of explaining this in the document, is not 

having the data to make that determination, not only from a use 

standpoint, but also the impacts it might have an wildlife. 

 We're proposing in the future to adopt a monitoring system to 

see what kind of use we do have. We've done some preliminary work 

with cameras, trying to put those in strategic locations so we can 

identify not only the numbers of boats, but the size, and things 

like that. 

 We've heard a few complaints from hunters that hunt the river 

bottoms, camp on the river bottoms, those kind of things, where 

these big jet boats will actually disturb game at times when they're 

being hunted, that they notice. So it's a use that we're going to 

look into so -- we're just not there yet as far as documented impact 

so --

 MR. CRAWFORD: Page 232 talks about boat use if you're 

interested in the plan. 

 MR. BERG: I thought I'd go right on to the mineral withdrawal. 

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com
378 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 33 Page 35 

1 MR. CRAWFORD: Management of ATV's and then oil and gas. 

 MR. BERG: Currently on the refuge, ORV's are allowed on 

numbered routes only. And they have to be street legal. So it's no 

different than in the town of Great Falls here. And I assume that's 

a legitimate or similar law where if it's street legal, as a 

motorcycle would be, with a license plate, brake lights, I think 

some form of signal for left and right, and I think rearview mirror, 

those vehicles are also allowed on numbered routes, as are pickups, 

two-wheel drive and four-wheel drive, and so forth. 

 Fifteen years ago or so, we saw a tremendous amount of off-road 

use, not only from ATV's but pickups. Over the years we've been 

fairly aggressive at managing that kind of use. We enforce our 

off-road regulations pretty hard. And we think it's in check pretty 

good right now. We don't have any areas where ATV's or ORV's can be 

used anywhere off-road. It's all the numbered trail system. 

 The only exception to that is on the ice at Fort Peck Lake in 

the wintertime. We do allow snowmobiles and four-wheelers to travel 

anywhere on that lake surface, and most of it's related to ice 

fishing.

 So even though we see an increase in number of ATV's that 

hunter's and recreationists use in the Breaks, most of it's 

replacing what they would have used in a pickup or, you know, in the 

past. So we haven't seen the impact from it like some of the other 

agencies have, you know, in the mountains, or, like, off-road use on 

BLM.

1

 But the thing that we're seeing, even with those agencies, you 

know, they're realizing or starting to see the impact of unregulated 

use and, for example, the ORV regs that the BLM is enforcing in the 

state here now is kind of addressing a similar problem to what we 

had 15 years ago so --

 And the next one I had down was the mineral withdrawal issue or 

the oil and gas development that Janelle brought up. 

 In 1992, we went through a formal mineral withdrawal process. 

And that addressed locatable minerals specifically, which aren't oil 

and gas. It's more like mining type operations: Gold, diamonds, 

gravel, things like that. That's a formal process that agencies 

have to go through to withdraw the availability of those public 

domain lands to somebody coming in and developing those minerals. 

 It basically takes the refuge off the table when it comes to 

somebody applying for a mineral withdrawal permit on the refuge. We 

are going through the renewal process as we speak, and my thought is 

it isn't as much of an issue as some people would think it is. 

 It's a process we went through before and didn't have a whole 

lot of controversy with it. And bottom line is there isn't a whole 

lot of potential locatable minerals in those soil types out there --

even way deep in the horizon. So we don't think that's going to be 

an issue in the future. 

 In regards to oil and gas, my understanding of the policy today 

is if the federal government determines that there's drainage 

occurring on federal minerals, that we own oil and gas, the decision 

will be made whether or not from a government agency standpoint we 

should go in and develop those minerals so they're not being taken 

by a private entity on the outside. 

 And we have that occurring on some refuges, especially in 

Louisiana, North Dakota, and some of those places. But one of the 

things that's helping us is the ability to indirect drill nowadays, 

so there's a potential if, say, for example, somebody came right up 

to our boundary and sunk a well on a private land that was tapping 

an oil field that extended out onto the refuge, but they were 

actually draining federal minerals off the federal estate, the 

potential or the technology is there to where we could probably 

develop those same federal minerals off-site and not impact the 

refuge itself. 

 But getting back to Janelle's comment that the BLM is 

considering leasing federal minerals immediately adjacent to CMR and 

the surrounding area, you know, that's a valid concern. 

 If you look at Phillips County, it's probably the hottest gas 

and natural gas field in Montana right now. Huge number of wells. 

It's not in the southern part of the county where it affects the 

refuges as much as it is in the north. But it could come that way. 

 The one thing we have seen is probably five years ago, the BLM 

was proposing to lease several thousands acres in Garfield County. 

There's kind of a potential vein that runs northwest/southeast, kind 

of towards Hacksbee Point/Hell Creek to the southeast. And at that 

time, the BLM chose not to lease those potential minerals because of 

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1 1 the proximity to the refuge, and some of the other resource values 

that are there, paleo, the Breaks habitat, things like that, so --

 Once in a while we have an ability to influence those decisions, 

even know it doesn't directly affect the lands we manage. 

 So I think that kind of hit where you are coming from. 

 MR. CRAWFORD: Do the shed antlers. 

 MR. BERG: Shed antlers. All right. I wasn't where you're 

coming from there, Jim, but --

 MR. McCOLLUM: I'm not an antler picker, but I know a lot of 

people who are. 

 MR. BERG: Yeah, It was our mistake not putting it in all the 

alternatives.

 If you're familiar with refuges, they're more restrictive than 

other public lands. And part of the reason is because we've got a 

real definitive mission. There isn't anything that you can pick up 

on a refuge legally, whether it's a piece of driftwood, an antler, 

paleo, you know, dinosaur bone, or something like that. 

 On refuges, all those things are owned by the government. And 

it's not legally -- legal to pick those up, unless specifically 

authorized.

 We treat antlers the same way. Why do we think antlers are 

important to the ecosystem out there? And I'm sure a lot of you 

have seen it, but it's one of those things that's hard to quantify, 

but you ever find an antler that's been on the ground for a year or 

two, pretty obvious what's going on with that antler. Critters are 

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9 (Pages 33 to 36) 

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ATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 33 Page 35 

hen oil and gas. 

allowed on 

gal. So it's no 

 assume that's 

s a 

ts, I think 

arview mirror, 

as are pickups, 

unt of off-road 

rs we've been 

nforce our 

n check pretty 

V's or ORV's can be 

ystem. 

k Lake in 

wheelers to travel 

d to ice 

ATV's that 

 it's 

you know, in the 

e of the other 

off-road use on 

1

gencies, you 

of unregulated 

s enforcing in the 

em to what we 

hdrawal issue or 

. 

will be made whether or not from a government agency standpoint we 

should go in and develop those minerals so they're not being taken 

by a private entity on the outside. 

 And we have that occurring on some refuges, especially in 

Louisiana, North Dakota, and some of those places. But one of the 

things that's helping us is the ability to indirect drill nowadays, 

so there's a potential if, say, for example, somebody came right up 

to our boundary and sunk a well on a private land that was tapping 

an oil field that extended out onto the refuge, but they were 

actually draining federal minerals off the federal estate, the 

potential or the technology is there to where we could probably 

develop those same federal minerals off-site and not impact the 

refuge itself. 

 But getting back to Janelle's comment that the BLM is 

considering leasing federal minerals immediately adjacent to CMR and 

the surrounding area, you know, that's a valid concern. 

 If you look at Phillips County, it's probably the hottest gas 

and natural gas field in Montana right now. Huge number of wells. 

It's not in the southern part of the county where it affects the 

refuges as much as it is in the north. But it could come that way. 

 The one thing we have seen is probably five years ago, the BLM 

was proposing to lease several thousands acres in Garfield County. 

There's kind of a potential vein that runs northwest/southeast, kind 

of towards Hacksbee Point/Hell Creek to the southeast. And at that 

time, the BLM chose not to lease those potential minerals because of 

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1 the proximity to the refuge, and some of the other resource values 

that are there, paleo, the Breaks habitat, things like that, so --

 Once in a while we have an ability to influence those decisions, 

even know it doesn't directly affect the lands we manage. 

 So I think that kind of hit where you are coming from. 

 MR. CRAWFORD: Do the shed antlers. 

 MR. BERG: Shed antlers. All right. I wasn't where you're 

2

3

4

5

6

7

fishing.

 So even though we see an increase in number of ATV's that 

hunter's and recreationists use in the Breaks, most of it's 

replacing what they would have used in a pickup or, you know, in the 

past. So we haven't seen the impact from it like some of the other 

agencies have, you know, in the mountains, or, like, off-road use on 

BLM.

 But the thing that we're seeing, even with those agencies, you 

know, they're realizing or starting to see the impact of unregulated 

use and, for example, the ORV regs that the BLM is enforcing in the 

state here now is kind of addressing a similar problem to what we 

had 15 years ago so --

 And the next one I had down was the mineral withdrawal issue or 

the oil and gas development that Janelle brought up. 

 In 1992, we went through a formal mineral withdrawal process. 

And that addressed locatable minerals specifically, which aren't oil 

and gas. It's more like mining type operations: Gold, diamonds, 

gravel, things like that. That's a formal process that agencies 

have to go through to withdraw the availability of those public 

domain lands to somebody coming in and developing those minerals. 

 It basically takes the refuge off the table when it comes to 

somebody applying for a mineral withdrawal permit on the refuge. We 

are going through the renewal process as we speak, and my thought is 

it isn't as much of an issue as some people would think it is. 

 It's a process we went through before and didn't have a whole 

lot of controversy with it. And bottom line is there isn't a whole 

lot of potential locatable minerals in those soil types out there --

even way deep in the horizon. So we don't think that's going to be 

an issue in the future. 

 In regards to oil and gas, my understanding of the policy today 

is if the federal government determines that there's drainage 

occurring on federal minerals, that we own oil and gas, the decision 

Its not in the sou

refuges as much 

 The one thing 

was proposing to 

There's kind of a 

of towards Hacks

time, the BLM ch

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Page 34 

1 1 the proximity to 

that are there, pa

 Once in a whi

even know it do

 So I think tha

 MR. CRAWF

 MR. BERG: 

coming from the

 MR. McCOL

people who are. 

 MR. BERG: 

alternatives.

 If you're fami

other public land

real definitive m

on a refuge lega

paleo, you know

 On refuges, a

it's not legally -- 

authorized.

 We treat antle

important to the 

have seen it, but 

but you ever fin

two, pretty obvi

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CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 33 Page 35 

1 MR. CRAWFORD: Management of ATV's and then oil and gas. 

 MR. BERG: Currently on the refuge, ORV's are allowed on 

numbered routes only. And they have to be street legal. So it's no 

different than in the town of Great Falls here. And I assume that's 

a legitimate or similar law where if it's street legal, as a 

motorcycle would be, with a license plate, brake lights, I think 

some form of signal for left and right, and I think rearview mirror, 

those vehicles are also allowed on numbered routes, as are pickups, 

two-wheel drive and four-wheel drive, and so forth. 

 Fifteen years ago or so, we saw a tremendous amount of off-road 

use, not only from ATV's but pickups. Over the years we've been 

fairly aggressive at managing that kind of use. We enforce our 

off-road regulations pretty hard. And we think it's in check pretty 

good right now. We don't have any areas where ATV's or ORV's can be 

used anywhere off-road. It's all the numbered trail system. 

 The only exception to that is on the ice at Fort Peck Lake in 

the wintertime. We do allow snowmobiles and four-wheelers to travel 

anywhere on that lake surface, and most of it's related to ice 

fishing.

 So even though we see an increase in number of ATV's that 

hunter's and recreationists use in the Breaks, most of it's 

replacing what they would have used in a pickup or, you know, in the 

past. So we haven't seen the impact from it like some of the other 

agencies have, you know, in the mountains, or, like, off-road use on 

BLM.

1

 But the thing that we're seeing, even with those agencies, you 

know, they're realizing or starting to see the impact of unregulated 

use and, for example, the ORV regs that the BLM is enforcing in the 

state here now is kind of addressing a similar problem to what we 

had 15 years ago so --

 And the next one I had down was the mineral withdrawal issue or 

the oil and gas development that Janelle brought up. 

 In 1992, we went through a formal mineral withdrawal process. 

And that addressed locatable minerals specifically, which aren't oil 

and gas. It's more like mining type operations: Gold, diamonds, 

gravel, things like that. That's a formal process that agencies 

have to go through to withdraw the availability of those public 

domain lands to somebody coming in and developing those minerals. 

 It basically takes the refuge off the table when it comes to 

somebody applying for a mineral withdrawal permit on the refuge. We 

are going through the renewal process as we speak, and my thought is 

it isn't as much of an issue as some people would think it is. 

 It's a process we went through before and didn't have a whole 

lot of controversy with it. And bottom line is there isn't a whole 

lot of potential locatable minerals in those soil types out there --

even way deep in the horizon. So we don't think that's going to be 

an issue in the future. 

 In regards to oil and gas, my understanding of the policy today 

is if the federal government determines that there's drainage 

occurring on federal minerals, that we own oil and gas, the decision 

will be made whether or not from a government agency standpoint we 

should go in and develop those minerals so they're not being taken 

by a private entity on the outside. 

 And we have that occurring on some refuges, especially in 

Louisiana, North Dakota, and some of those places. But one of the 

things that's helping us is the ability to indirect drill nowadays, 

so there's a potential if, say, for example, somebody came right up 

to our boundary and sunk a well on a private land that was tapping 

an oil field that extended out onto the refuge, but they were 

actually draining federal minerals off the federal estate, the 

potential or the technology is there to where we could probably 

develop those same federal minerals off-site and not impact the 

refuge itself. 

 But getting back to Janelle's comment that the BLM is 

considering leasing federal minerals immediately adjacent to CMR and 

the surrounding area, you know, that's a valid concern. 

 If you look at Phillips County, it's probably the hottest gas 

and natural gas field in Montana right now. Huge number of wells. 

It's not in the southern part of the county where it affects the 

refuges as much as it is in the north. But it could come that way. 

 The one thing we have seen is probably five years ago, the BLM 

was proposing to lease several thousands acres in Garfield County. 

There's kind of a potential vein that runs northwest/southeast, kind 

of towards Hacksbee Point/Hell Creek to the southeast. And at that 

time, the BLM chose not to lease those potential minerals because of 

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Page 34 Page 36 

1 1 the proximity to the refuge, and some of the other resource values 

that are there, paleo, the Breaks habitat, things like that, so --

 Once in a while we have an ability to influence those decisions, 

even know it doesn't directly affect the lands we manage. 

 So I think that kind of hit where you are coming from. 

 MR. CRAWFORD: Do the shed antlers. 

 MR. BERG: Shed antlers. All right. I wasn't where you're 

coming from there, Jim, but --

 MR. McCOLLUM: I'm not an antler picker, but I know a lot of 

people who are. 

 MR. BERG: Yeah, It was our mistake not putting it in all the 

alternatives.

 If you're familiar with refuges, they're more restrictive than 

other public lands. And part of the reason is because we've got a 

real definitive mission. There isn't anything that you can pick up 

on a refuge legally, whether it's a piece of driftwood, an antler, 

paleo, you know, dinosaur bone, or something like that. 

 On refuges, all those things are owned by the government. And 

it's not legally -- legal to pick those up, unless specifically 

authorized.

 We treat antlers the same way. Why do we think antlers are 

important to the ecosystem out there? And I'm sure a lot of you 

have seen it, but it's one of those things that's hard to quantify, 

but you ever find an antler that's been on the ground for a year or 

two, pretty obvious what's going on with that antler. Critters are 

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VOLUME 2, Chapter 4—Public Hearing Testimony 379

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 37 Page 39 

1 chewing on it, whether it's mice or squirrels, or whatever. So 

we've kind of taken the position that that stuff cycles back through 

into the ecosystem, and it's good for it. 

 But the other, probably bigger reason we don't allow it, is the 

timing of the year when most of that activity occurs. Springtime, 

the animals are stressed already, coming out of the winter. You've 

got some calving going on or fawns being born, so it's something we 

don't allow, and don't plan to in the future. 

 Some refuges do. Some game management areas allow it, as we 

all know. But they time it so it doesn't impact, you know, the main 

purpose of the place. 

 MR. CRAWFORD: Bob, I'm going to put you on notice and I'm 

giving the microphone to you next, you're going to answer sentinel 

plant questions, so get your thinking cap on. 

 We had one other comment concerning proposed wilderness areas 

set by Congress, and how can we add and eliminate. 

 There's two types of wilderness on CMR. We have designated 

wilderness, which is the UL Bend, and that's designated by Congress. 

Congress passed a law that says this area will be set aside as 

wilderness and brought into the wilderness preservation system. 

 The remaining 15 areas on the refuge are called proposed 

wilderness areas. Okay. Proposed wilderness areas are those areas 

that have been identified by the Agency, in this case the Fish and 

Wildlife Service, that they meet the wilderness characteristics as 

outlined by the Wilderness Act. 

1

 We went ahead and we proposed them to our agency in 

Washington, D.C., our director said, yes, I concur these areas 

should be considered for adding into the wilderness preservation 

system.

 It then went to the Secretary of the Interior, the Secretary 

then said, yes, I concur these areas should be added into the 

wilderness preservation system. 

 And that's where they sit until Congress then acts on it by 

passing a law, bringing them into the wilderness system. 

 So during that time when they've been approved by our Agency 

and by the Secretary's office, they're to be evaluated every now and 

then. And what the Service has decided is we'll evaluate those 

areas every 15 years when you do a CCP to make sure they're still 

meeting those wilderness characteristics. 

 So these areas that we're proposing to add, we'll have to go 

through that process again, and we'll send the recommendation to our 

director; our director will either say yes, I approve, or, no, I 

deny; if they say that they approve, it then goes to the Secretary's 

desk; the secretary will then say, yes, I agree or I disagree; if 

they agree, then they sit there as proposed wilderness waiting on 

Congress to take action. 

 The same process will be used if we decide to eliminate a 

proposed wilderness of the area. We'll send that recommendation to 

the director; the director will say yes, I agree, or I disagree; if 

they disagree, then it stays as proposed wilderness. If they agree, 

then it goes to the Secretary; and the Secretary again says, I agree 

or I disagree. 

 So that's how the process works. Congressionally designated 

wilderness, only Congress can take that away. 

 Proposed wilderness, the Agency the makes recommendations, and 

the Secretary has the final say. So I hope that clears up that 

point.

 The other question that we had was concerning sentinel plant 

monitoring, the peer-review, the science behind it, and its relation 

to some of the other range monitoring techniques. 

 And so this is Bob Skinner. Bob's our habitat biologist, and 

has been working on this for the past several years, so --

 MR. SKINNER: I guess the first thing to clear up about that 

would be that we are a single-purpose agency, and it is wildlife 

habitat and management. And so, we aren't necessarily -- don't feel 

like we should manage the land the same way a multiple-use agency in 

range lands or ranch managed lands for. 

 So we are looking at plants. We called them sentinel plants --

was our name -- they are also called indicator plants and other 

terms for these. 

 But these are plants that are first to vanish when ecological 

processes change from their evolutionary combination. 

 So this is like the historic fire/grazing interaction that 

occurred, and this has changed. And certain plants are among the 

first to vanish. And they're sentinels or indicators. 

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1 1 And if you can restore those processes to the point they're 

doing well again, then other plants tend to follow. 

 And so we don't necessarily feel that range practices are 

appropriate in all cases for us. And we are working on this with a 

team of people that includes some range folks to publish our 

particular version of this indicator plant. 

 It is an old concept. Alda Leopold called them diagnosis plants, 

said every area has plants that are diagnostic. And that would be 

another good name for them. And this is a long topic so that's all 

I can say at the moment. 

 MR. CRAWFORD: I think we covered all the questions. I will 

turn it back to Mimi. 

 We'll be sticking around if folks want to come up and talk to us 

one-on-one.

 You heard from Bob, our habitat biologist. We've got Randy 

Matchett in the back. He's our senior wildlife biologist. Dan 

Harold's next to him. He's a biologist out of Sand Creek. Matt 

deRosier is a station manager at Sand Creek. Nathan Hawkaluk is a 

station manager at Jordan. 

 Who else is here? Joanne, in cognito. Joanne is a biologist in 

our Lewistown office. So quite a few folks here. Grab one of them 

if you've got questions. 

 And thanks again for everybody coming out. 

 MIMI: That's all I have, too. 

 (Meeting adjourned) 

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10 (Pages 37 to 40)

Agamenoni & Frank Court Reporting

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 NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

Page 37 Page 39 

or whatever. So 

f cycles back through 

on't allow it, is the 

occurs. Springtime, 

of the winter. You've 

rn, so it's something we 

nt areas allow it, as we 

ct, you know, the main 

t you on notice and I'm 

ing to answer sentinel 

oposed wilderness areas 

minate. 

We have designated 

designated by Congress. 

l be set aside as 

reservation system. 

alled proposed 

s areas are those areas 

his case the Fish and 

ss characteristics as 

1

our agency in 

ncur these areas 

derness preservation 

r, the Secretary 

 added into the 

then it goes to the Secretary; and the Secretary again says, I agree 

or I disagree. 

 So that's how the process works. Congressionally designated 

wilderness, only Congress can take that away. 

 Proposed wilderness, the Agency the makes recommendations, and 

the Secretary has the final say. So I hope that clears up that 

point.

 The other question that we had was concerning sentinel plant 

monitoring, the peer-review, the science behind it, and its relation 

to some of the other range monitoring techniques. 

 And so this is Bob Skinner. Bob's our habitat biologist, and 

has been working on this for the past several years, so --

 MR. SKINNER: I guess the first thing to clear up about that 

would be that we are a single-purpose agency, and it is wildlife 

habitat and management. And so, we aren't necessarily -- don't feel 

like we should manage the land the same way a multiple-use agency in 

range lands or ranch managed lands for. 

 So we are looking at plants. We called them sentinel plants --

was our name -- they are also called indicator plants and other 

terms for these. 

 But these are plants that are first to vanish when ecological 

processes change from their evolutionary combination. 

 So this is like the historic fire/grazing interaction that 

occurred, and this has changed. And certain plants are among the 

first to vanish. And they're sentinels or indicators. 

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Page 38 Page 40 

1 And if you can restore those processes to the point they're 

doing well again, then other plants tend to follow. 

 And so we don't necessarily feel that range practices are 

appropriate in all cases for us. And we are working on this with a 

team of people that includes some range folks to publish our 

particular version of this indicator plant. 

It is an old conceptAlda Leopold called them diagnosis plants

2

3

4

5

6

7

Congress passed a law that says this area will be set aside as 

wilderness and brought into the wilderness preservation system. 

 The remaining 15 areas on the refuge are called proposed 

wilderness areas. Okay. Proposed wilderness areas are those areas 

that have been identified by the Agency, in this case the Fish and 

Wildlife Service, that they meet the wilderness characteristics as 

outlined by the Wilderness Act. 

 We went ahead and we proposed them to our agency in 

Washington, D.C., our director said, yes, I concur these areas 

should be considered for adding into the wilderness preservation 

system.

 It then went to the Secretary of the Interior, the Secretary 

then said, yes, I concur these areas should be added into the 

wilderness preservation system. 

 And that's where they sit until Congress then acts on it by 

passing a law, bringing them into the wilderness system. 

 So during that time when they've been approved by our Agency 

and by the Secretary's office, they're to be evaluated every now and 

then. And what the Service has decided is we'll evaluate those 

areas every 15 years when you do a CCP to make sure they're still 

meeting those wilderness characteristics. 

 So these areas that we're proposing to add, we'll have to go 

through that process again, and we'll send the recommendation to our 

director; our director will either say yes, I approve, or, no, I 

deny; if they say that they approve, it then goes to the Secretary's 

desk; the secretary will then say, yes, I agree or I disagree; if 

they agree, then they sit there as proposed wilderness waiting on 

Congress to take action. 

 The same process will be used if we decide to eliminate a 

proposed wilderness of the area. We'll send that recommendation to 

the director; the director will say yes, I agree, or I disagree; if 

they disagree, then it stays as proposed wilderness. If they agree, 

was our nam

terms for th

 But these 

processes c

 So this is 

occurred, a

first to vani

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Page 38 

1 1 And if y

doing well 

 And so w

appropriate 

team of peo

particular v

 It is an o

said every 

another go

I can say at 

 MR. CR

turn it back 

 We'll be 

one-on-one

 You hea

Matchett in 

Harold's ne

deRosier is 

station man

 Who els

our Lewist

if you've g

 And than

 MIMI: 

 (Meetin

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CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010

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1 chewing on it, whether it's mice or squirrels, or whatever. So 

we've kind of taken the position that that stuff cycles back through 

into the ecosystem, and it's good for it. 

 But the other, probably bigger reason we don't allow it, is the 

timing of the year when most of that activity occurs. Springtime, 

the animals are stressed already, coming out of the winter. You've 

got some calving going on or fawns being born, so it's something we 

don't allow, and don't plan to in the future. 

 Some refuges do. Some game management areas allow it, as we 

all know. But they time it so it doesn't impact, you know, the main 

purpose of the place. 

 MR. CRAWFORD: Bob, I'm going to put you on notice and I'm 

giving the microphone to you next, you're going to answer sentinel 

plant questions, so get your thinking cap on. 

 We had one other comment concerning proposed wilderness areas 

set by Congress, and how can we add and eliminate. 

 There's two types of wilderness on CMR. We have designated 

wilderness, which is the UL Bend, and that's designated by Congress. 

Congress passed a law that says this area will be set aside as 

wilderness and brought into the wilderness preservation system. 

 The remaining 15 areas on the refuge are called proposed 

wilderness areas. Okay. Proposed wilderness areas are those areas 

that have been identified by the Agency, in this case the Fish and 

Wildlife Service, that they meet the wilderness characteristics as 

outlined by the Wilderness Act. 

1

 We went ahead and we proposed them to our agency in 

Washington, D.C., our director said, yes, I concur these areas 

should be considered for adding into the wilderness preservation 

system.

 It then went to the Secretary of the Interior, the Secretary 

then said, yes, I concur these areas should be added into the 

wilderness preservation system. 

 And that's where they sit until Congress then acts on it by 

passing a law, bringing them into the wilderness system. 

 So during that time when they've been approved by our Agency 

and by the Secretary's office, they're to be evaluated every now and 

then. And what the Service has decided is we'll evaluate those 

areas every 15 years when you do a CCP to make sure they're still 

meeting those wilderness characteristics. 

 So these areas that we're proposing to add, we'll have to go 

through that process again, and we'll send the recommendation to our 

director; our director will either say yes, I approve, or, no, I 

deny; if they say that they approve, it then goes to the Secretary's 

desk; the secretary will then say, yes, I agree or I disagree; if 

they agree, then they sit there as proposed wilderness waiting on 

Congress to take action. 

 The same process will be used if we decide to eliminate a 

proposed wilderness of the area. We'll send that recommendation to 

the director; the director will say yes, I agree, or I disagree; if 

they disagree, then it stays as proposed wilderness. If they agree, 

then it goes to the Secretary; and the Secretary again says, I agree 

or I disagree. 

 So that's how the process works. Congressionally designated 

wilderness, only Congress can take that away. 

 Proposed wilderness, the Agency the makes recommendations, and 

the Secretary has the final say. So I hope that clears up that 

point.

 The other question that we had was concerning sentinel plant 

monitoring, the peer-review, the science behind it, and its relation 

to some of the other range monitoring techniques. 

 And so this is Bob Skinner. Bob's our habitat biologist, and 

has been working on this for the past several years, so --

 MR. SKINNER: I guess the first thing to clear up about that 

would be that we are a single-purpose agency, and it is wildlife 

habitat and management. And so, we aren't necessarily -- don't feel 

like we should manage the land the same way a multiple-use agency in 

range lands or ranch managed lands for. 

 So we are looking at plants. We called them sentinel plants --

was our name -- they are also called indicator plants and other 

terms for these. 

 But these are plants that are first to vanish when ecological 

processes change from their evolutionary combination. 

 So this is like the historic fire/grazing interaction that 

occurred, and this has changed. And certain plants are among the 

first to vanish. And they're sentinels or indicators. 

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1 1 And if you can restore those processes to the point they're 

doing well again, then other plants tend to follow. 

 And so we don't necessarily feel that range practices are 

appropriate in all cases for us. And we are working on this with a 

team of people that includes some range folks to publish our 

particular version of this indicator plant. 

 It is an old concept. Alda Leopold called them diagnosis plants, 

said every area has plants that are diagnostic. And that would be 

another good name for them. And this is a long topic so that's all 

I can say at the moment. 

 MR. CRAWFORD: I think we covered all the questions. I will 

turn it back to Mimi. 

 We'll be sticking around if folks want to come up and talk to us 

one-on-one.

 You heard from Bob, our habitat biologist. We've got Randy 

Matchett in the back. He's our senior wildlife biologist. Dan 

Harold's next to him. He's a biologist out of Sand Creek. Matt 

deRosier is a station manager at Sand Creek. Nathan Hawkaluk is a 

station manager at Jordan. 

 Who else is here? Joanne, in cognito. Joanne is a biologist in 

our Lewistown office. So quite a few folks here. Grab one of them 

if you've got questions. 

 And thanks again for everybody coming out. 

 MIMI: That's all I have, too. 

 (Meeting adjourned) 

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Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com
380 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

11 (Page 41) 

Agamenoni & Frank Court Reporting

406-727-7272 courtreporting@strainbld.com

CMR NATIONAL WILDLIFE REFUGE TAKEN 9/30/2010 

Page 41 

1 CERTIFICATE OF REPORTER 

 BE IT KNOWN that I, Anne Perron, RPR, a duly appointed, qualified and 

acting Court Reporter and Notary Public in and for the State of Montana, 

do hereby attest as follows: 

 That I was duly authorized to and did report the public hearing of in 

Great Falls for the CM Russell Refuge CCP; 

 That the foregoing pages of this transcript constitute a true and 

 accurate transcription of my stenotype notes of the comments of said 

meeting.

 IN WITNESS WHEREOF, I have hereunto set my hand this 19th day of 

October, 2010. 

 _______________________________

 Anne Perron, RPR 

 Agamenoni & Frank

 603 Strain Building 

 Great Falls, MT 59401

 (406) 727-7272 

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390 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
VOLUME 2, Chapter 4—Public Hearing Testimony 391
392 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
VOLUME 2, Chapter 4—Public Hearing Testimony 393
394 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
VOLUME 2, Chapter 4—Public Hearing Testimony 395

Page 1

 TRANSCRIPT OF PROCEEDINGS

 U.S. DEPARTMENT OF THE INTERIOR

 U.S. Fish & Wildlife Service

 Charles M. Russell and UL Bend

 National Wildlife Refuges

 The TRANSCRIPT OF PROCEEDINGS at VFW, 11

South Main Street, Jordan, Montana, on the 13th

day of October, 2010, beginning at 2:00 p.m.

PANEL:

BARRON CRAWFORD Project Leader

BILL BERG Deputy Project Leader

LAURIE SHANNON Planner

MIMI MATHER Speaker Facilitator

Page 1

DINGS

 INTERIOR

nd

DINGS at VFW, 11

 on the 13th

:00 p.m.

eader

eader

tator

Page 2

PAGE

21

24

26

28

32

Page 3

1 P R O C E E D I N G S

 2:00 p.m.

 MS. MATHER: Okay, folks, let's get

started in a timely start. Please have a seat.

Plenty of room up front.

 Well, thanks, everybody, for coming

this afternoon. This is our second meeting this

week, and we have two others after today.

 The purpose of the meeting is for the

Fish & Wildlife Service to collect your input on

the draft CCP, the Comprehensive Conservation

Plan.

 My name is Mimi. I'll be facilitating

this meeting.

 And I'm up here with Barron Crawford,

CMR's Project Leader; Bill Berg, the Deputy

Project Leader; and, Laurie Shannon, who is the

CCP Planning Team Leader.

 The way the next two hours are going to

work is, Barron will give a brief presentation

on the CCP and describe the alternatives and the

highlight points of the plan.

 Then we'll turn it to you and open the

floor for public comments.

 Keep in mind that we want to make sure

2

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Page 4

1 we give everybody enough time to speak, so we're

2 going to limit the time of your comments to

three minutes.

 So, if you all have a lot to say, start

thinking about how you can narrow your comments

down to three minutes. There's plenty of other

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

1 (Pages 1 to 4)

Page 1

 TRANSCRIPT OF PROCEEDINGS

 U.S. DEPARTMENT OF THE INTERIOR

 U.S. Fish & Wildlife Service

 Charles M. Russell and UL Bend

 National Wildlife Refuges

 The TRANSCRIPT OF PROCEEDINGS at VFW, 11

South Main Street, Jordan, Montana, on the 13th

day of October, 2010, beginning at 2:00 p.m.

PANEL:

BARRON CRAWFORD Project Leader

BILL BERG Deputy Project Leader

LAURIE SHANNON Planner

MIMI MATHER Speaker Facilitator

Page 2

1 SPEAKERS PAGE

KAREN TAYLOR 21

JACK MURNION 24

EDLA McKERLICK 26

MIKE McKEEVER 28

NORMAN "SKIP" OLSON 32

KARLA CHRISTENSEN 37

JERRY COLDWELL 38

ERIC MILLER 39

DEAN ROGGE 40

MARK GOOD 41

JANELLE HOLDEN 44

JEANNE KIRKEGARD 46

JANET GUPTILL 48

RALPH GRIINK 49

FLOSSIE PHIPPS 50

JOAN D. WATSON 51

LAYNE MURNION 54

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Page 3

1 P R O C E E D I N G S

 2:00 p.m.

 MS. MATHER: Okay, folks, let's get

started in a timely start. Please have a seat.

Plenty of room up front.

 Well, thanks, everybody, for coming

this afternoon. This is our second meeting this

week, and we have two others after today.

 The purpose of the meeting is for the

Fish & Wildlife Service to collect your input on

the draft CCP, the Comprehensive Conservation

Plan.

 My name is Mimi. I'll be facilitating

this meeting.

 And I'm up here with Barron Crawford,

CMR's Project Leader; Bill Berg, the Deputy

Project Leader; and, Laurie Shannon, who is the

CCP Planning Team Leader.

 The way the next two hours are going to

work is, Barron will give a brief presentation

on the CCP and describe the alternatives and the

highlight points of the plan.

 Then we'll turn it to you and open the

floor for public comments.

 Keep in mind that we want to make sure

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 4

1 we give everybody enough time to speak, so we're

2 going to limit the time of your comments to

three minutes.

 So, if you all have a lot to say, start

thinking about how you can narrow your comments

down to three minutes. There's plenty of other

ways that you could submit your comments other

than up here at the mic.

 So, with that, I'll turn it to Barron,

and then I'll give you an explanation of how the

comments are going to run afterwards.

 MR. CRAWFORD: Thanks, Mimi.

 Steve, can you maybe get the first

couple of rows of lights and figure that out.

Maybe this will show up a little bit better.

 I'm going to give a brief overview of

what we have been doing for the past three

years. Talk a little bit about the CCP process,

where we're at and where we're going.

 So, we started basically in January of

2007. That's when we held the first public

scoping meetings. We did 14 of those all

together. We got about 24,000 public comments

did during that time.

 We've had numerous meetings with our

3

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7

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

1 (Pages 1 to 4)

Page 2

1 SPEAKERS PAGE

KAREN TAYLOR 21

JACK MURNION 24

EDLA McKERLICK 26

MIKE McKEEVER 28

NORMAN "SKIP" OLSON 32

KARLA CHRISTENSEN 37

JERRY COLDWELL 38

ERIC MILLER 39

DEAN ROGGE 40

MARK GOOD 41

JANELLE HOLDEN 44

JEANNE KIRKEGARD 46

JANET GUPTILL 48

RALPH GRIINK 49

FLOSSIE PHIPPS 50

JOAN D. WATSON 51

LAYNE MURNION 54

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3

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Page 3

1 P R O C E E D I N G S

 2:00 p.m.

 MS. MATHER: Okay, folks, let's get

started in a timely start. Please have a seat.

Plenty of room up front.

 Well, thanks, everybody, for coming

this afternoon. This is our second meeting this

week, and we have two others after today.

 The purpose of the meeting is for the

Fish & Wildlife Service to collect your input on

the draft CCP, the Comprehensive Conservation

Plan.

 My name is Mimi. I'll be facilitating

this meeting.

 And I'm up here with Barron Crawford,

CMR's Project Leader; Bill Berg, the Deputy

Project Leader; and, Laurie Shannon, who is the

CCP Planning Team Leader.

 The way the next two hours are going to

work is, Barron will give a brief presentation

on the CCP and describe the alternatives and the

highlight points of the plan.

 Then we'll turn it to you and open the

floor for public comments.

 Keep in mind that we want to make sure

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 4

1 we give everybody enough time to speak, so we're

2 going to limit the time of your comments to

three minutes.

 So, if you all have a lot to say, start

thinking about how you can narrow your comments

down to three minutes. There's plenty of other

ways that you could submit your comments other

than up here at the mic.

 So, with that, I'll turn it to Barron,

and then I'll give you an explanation of how the

comments are going to run afterwards.

 MR. CRAWFORD: Thanks, Mimi.

 Steve, can you maybe get the first

couple of rows of lights and figure that out.

Maybe this will show up a little bit better.

 I'm going to give a brief overview of

what we have been doing for the past three

years. Talk a little bit about the CCP process,

where we're at and where we're going.

 So, we started basically in January of

2007. That's when we held the first public

scoping meetings. We did 14 of those all

together. We got about 24,000 public comments

did during that time.

 We've had numerous meetings with our

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCES 

Page 2

1 SPEAKERS PAGE

KAREN TAYLOR 21

JACK MURNION 24

EDLA McKERLICK 26

MIKE McKEEVER 28

NORMAN "SKIP" OLSON 32

KARLA CHRISTENSEN 37

JERRY COLDWELL 38

ERIC MILLER 39

DEAN ROGGE 40

MARK GOOD 41

JANELLE HOLDEN 44

JEANNE KIRKEGARD 46

JANET GUPTILL 48

RALPH GRIINK 49

FLOSSIE PHIPPS 50

JOAN D. WATSON 51

LAYNE MURNION 54

2

3

4

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8

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 Th

work is, 

on the C

highligh

 Th

floor for 

 Ke

19

20

21

22

23

24

25

1 we give 

2 going to 

three mi

 So

thinking 

down to 

ways tha

than up h

 So

and then 

commen

 MR

 Ste

couple o

Maybe t

 I'm 

what we 

years. T

where w

 So

2007. T

scoping 

together

did durin

 We

3

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396 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 5

ll of that

nt.

of

ning, public

d then the

ully

use, for

Wildlife

basically

2015.

 in the

So the

to make

P does,

uidance

 and the

m.

or

 past, as a

uld have new

Page 6

mplement

uld go one

ave, and a

y would go

was a lot

Page 7

1 we're down here at the bottom with the Draft

Plan and NEPA document. Hopefully we can move

into this next step, prepare and adopt a Final

Plan.

 But there's nothing to say that based

upon the comments that we receive during this

period, that we might not go back to this step

right here (indicating), and go with an all new

alternative and start back again with another

round of scoping meetings.

 So, that's kind of how this works. It

doesn't always flow like this. Sometimes you go

back and then go forward.

 Hopefully we've thought this through

enough, and we've covered everything, and maybe

we just have to do a little modification to the

alternative that ends up in the Final Plan.

 So we came up with four alternatives.

Basically we have the Alternative A, which is

"No Action", which is basically continue doing

what we have been doing since 1986, when the

last EIS was developed.

 There would be a few changes. You

know, some of those changes we've been doing

here along the way.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 8

1 But the basic concepts of this

alternative is you continue to manage the refuge

under the 65 habitat units that are out there

that where established when the refuge was

co-managed with BLM.

We continue to move towards this

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

2 (Pages 5 to 8)

Page 5

1 cooperators, and we've kind of taken all of that

and rolled it up into this Draft document.

 So this is kind of just an outline of

the CCP timeline. You know, preplanning, public

involvement, scoping, alternatives, and then the

Draft.

 And then from here, we'll hopefully

move on to a Final CCP and EIS.

 So, basically we do a CCP because, for

one, we're mandated by the National Wildlife

Refuge System Improvement Act. It basically

says all refuges will have a completed

Comprehensive Conservation Plan by 2015.

 And so there's about 548 refuges in the

United States, and a little over, what,

two-thirds of those are already done. So the

rest of the refuges are working trying to make

that deadline.

 But the main point of what a CCP does,

is it provides management direction, guidance

that is based upon the refuge purposes and the

mission of the Wildlife Refuge System.

 It kind of provides a road map for

managers as they come and go. In the past, as a

new manager would come in, they would have new

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 6

1 ideas, and so they would take off and implement

those, and the refuge management would go one

direction. And that manager would leave, and a

new manager would come in, and they would go

back the other direction, and so there was a lot

of inconsistency in management.

 With this plan in place, it will

hopefully provide the stable, long-term

guidance. So it outlines a vision statement,

goals, objectives and strategies for that future

management.

 It's accompanied by some type of NEPA

document. Most of the time it's an

Environmental Assessment for the CMR. Due to

the complexity of issues that we're addressing,

we did do an EIS. That's why the document is so

large. Sorry about that.

 And again, it provides the long-term

guidance for the management over that 15-year

period.

 So they are 15-year plans. They have

to be updated, renewed, revisited at the end of

that 15-year period.

 So, this is just kind of a flow chart

as to the steps that are involved in a CCP. And

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 7

1 we're down here at the bottom with the Draft

Plan and NEPA document. Hopefully we can move

into this next step, prepare and adopt a Final

Plan.

 But there's nothing to say that based

upon the comments that we receive during this

period, that we might not go back to this step

right here (indicating), and go with an all new

alternative and start back again with another

round of scoping meetings.

 So, that's kind of how this works. It

doesn't always flow like this. Sometimes you go

back and then go forward.

 Hopefully we've thought this through

enough, and we've covered everything, and maybe

we just have to do a little modification to the

alternative that ends up in the Final Plan.

 So we came up with four alternatives.

Basically we have the Alternative A, which is

"No Action", which is basically continue doing

what we have been doing since 1986, when the

last EIS was developed.

 There would be a few changes. You

know, some of those changes we've been doing

here along the way.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 8

1 But the basic concepts of this

alternative is you continue to manage the refuge

under the 65 habitat units that are out there

that where established when the refuge was

co-managed with BLM.

 We continue to move towards this

gradual implementation of prescriptive grazing,

and as a ranch sells to a nonfamily member,

holding that permit and enrolling that unit into

a prescriptive program.

 We would still manage big game to

achieve those target levels that were identified

in '86 of 2.5 elk per square mile, and 10 mule

deer per square mile.

 We'd keep open the 670 miles of roads

or so that are out there, and we'd continue with

protecting the 155,000 acres of proposed

wilderness.

 So then we came to our action

alternatives, and the first one was what we

coined the "Wildlife and Habitat Emphasis", and

threw a bunch of big biological words in here

just to make us look smart.

 But it's basically to manage the

landscape in cooperation with our partners to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

2 (Pages 5 to 8)

Page 5

1 cooperators, and we've kind of taken all of that

and rolled it up into this Draft document.

 So this is kind of just an outline of

the CCP timeline. You know, preplanning, public

involvement, scoping, alternatives, and then the

Draft.

 And then from here, we'll hopefully

move on to a Final CCP and EIS.

 So, basically we do a CCP because, for

one, we're mandated by the National Wildlife

Refuge System Improvement Act. It basically

says all refuges will have a completed

Comprehensive Conservation Plan by 2015.

 And so there's about 548 refuges in the

United States, and a little over, what,

two-thirds of those are already done. So the

rest of the refuges are working trying to make

that deadline.

 But the main point of what a CCP does,

is it provides management direction, guidance

that is based upon the refuge purposes and the

mission of the Wildlife Refuge System.

 It kind of provides a road map for

managers as they come and go. In the past, as a

new manager would come in, they would have new

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 6

1 ideas, and so they would take off and implement

those, and the refuge management would go one

direction. And that manager would leave, and a

new manager would come in, and they would go

back the other direction, and so there was a lot

of inconsistency in management.

 With this plan in place, it will

hopefully provide the stable, long-term

guidance. So it outlines a vision statement,

goals, objectives and strategies for that future

management.

 It's accompanied by some type of NEPA

document. Most of the time it's an

Environmental Assessment for the CMR. Due to

the complexity of issues that we're addressing,

we did do an EIS. That's why the document is so

large. Sorry about that.

 And again, it provides the long-term

guidance for the management over that 15-year

period.

 So they are 15-year plans. They have

to be updated, renewed, revisited at the end of

that 15-year period.

 So, this is just kind of a flow chart

as to the steps that are involved in a CCP. And

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 7

1 we're down here at the bottom with the Draft

Plan and NEPA document. Hopefully we can move

into this next step, prepare and adopt a Final

Plan.

 But there's nothing to say that based

upon the comments that we receive during this

period, that we might not go back to this step

right here (indicating), and go with an all new

alternative and start back again with another

round of scoping meetings.

 So, that's kind of how this works. It

doesn't always flow like this. Sometimes you go

back and then go forward.

 Hopefully we've thought this through

enough, and we've covered everything, and maybe

we just have to do a little modification to the

alternative that ends up in the Final Plan.

 So we came up with four alternatives.

Basically we have the Alternative A, which is

"No Action", which is basically continue doing

what we have been doing since 1986, when the

last EIS was developed.

 There would be a few changes. You

know, some of those changes we've been doing

here along the way.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 8

1 But the basic concepts of this

alternative is you continue to manage the refuge

under the 65 habitat units that are out there

that where established when the refuge was

co-managed with BLM.

 We continue to move towards this

gradual implementation of prescriptive grazing,

and as a ranch sells to a nonfamily member,

holding that permit and enrolling that unit into

a prescriptive program.

 We would still manage big game to

achieve those target levels that were identified

in '86 of 2.5 elk per square mile, and 10 mule

deer per square mile.

 We'd keep open the 670 miles of roads

or so that are out there, and we'd continue with

protecting the 155,000 acres of proposed

wilderness.

 So then we came to our action

alternatives, and the first one was what we

coined the "Wildlife and Habitat Emphasis", and

threw a bunch of big biological words in here

just to make us look smart.

 But it's basically to manage the

landscape in cooperation with our partners to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

 But the main point of what a CCP does,

is it provides management direction, guidance

that is based upon the refuge purposes and the

mission of the Wildlife Refuge System.

 It kind of provides a road map for

managers as they come and go. In the past, as a

new manager would come in, they would have new

19

20

21

22

23

24

25

Page 6

1 ideas, and so they would take off and implement

those, and the refuge management would go one

direction. And that manager would leave, and a

new manager would come in, and they would go

back the other direction, and so there was a lot

of inconsistency in management.

 With this plan in place, it will

hopefully provide the stable, long-term

guidance. So it outlines a vision statement,

goals, objectives and strategies for that future

management.

 It's accompanied by some type of NEPA

document. Most of the time it's an

Environmental Assessment for the CMR. Due to

the complexity of issues that we're addressing,

we did do an EIS. That's why the document is so

large. Sorry about that.

 And again, it provides the long-term

guidance for the management over that 15-year

period.

 So they are 15-year plans. They have

to be updated, renewed, revisited at the end of

that 15-year period.

 So, this is just kind of a flow chart

as to the steps that are involved in a CCP. And

2

3

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Basically we 

"No Action", 

what we have 

last EIS was 

 There w

know, some o

here along th

19

20

21

22

23

24

25

1 But the 

alternative is 

under the 65 

that where es

co-managed 

 We con

gradual impl

and as a ranc

holding that p

a prescriptive 

 We wo

achieve those 

in '86 of 2.5 e

deer per squa

 We'd k

or so that are 

protecting th

wilderness.

 So then 

alternatives, 

coined the "W

threw a bunc

just to make 

 But it's 

landscape in 

2

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VOLUME 2, Chapter 4—Public Hearing Testimony 397

Page 9

ersity of

alanced,

ological

at the

and flooding.

ynthetic

 are like

me pumping to

for cottonwood

And those are

rvation and

ntal education

 got several

s

ke a closer

welcome to.

rnative,

of the proposed

ed in the light

proposing to

The same thing

Page 10

s is, we'd

n about 50 to

e're

e would get a

ng towards a

Page 11

1 And we've minimized damaging impacts to

habitats while using a variety of management

tools that would enhance and diversify public

and economic opportunities.

 So, out of this proposal, we're not

going to close any roads. We are proposing to

eliminate a couple of proposed wilderness

areas.

 And then some of the highlights of

this, is we'd work with Fish, Wildlife & Parks

to maintain that balance between big game and

livestock; work to provide more opportunities

for recreation; expand some hunting

opportunities. We're looking to hopefully

expand some youth hunting opportunities in

particular.

 We'd recommend eliminating about four

proposed wilderness areas, for a total of 35,000

acres.

 And then we move to our last

alternative, Alternative D, and this one is

called the "Natural Processes", or the

"Ecological Processes". And this is our

proposed action. Okay, this is the one that we

think best fits our mission of the Refuge

2

3

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7

8

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10

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13

14

15

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Page 12

1 System.

 And for this one, again, we're going to

use those natural ecological processes of fire,

grazing and flooding and active management -

farming, tree planting - to restore and/or

maintain the biological diversity and integrity

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

3 (Pages 9 to 12)

Page 9

1 emphasize the abundance and diversity of

wildlife populations using both balanced,

natural ecological processes.

 And when we talk about ecological

processes, the three big ones out at the

Missouri branch are fire, grazing and flooding.

 Then we're also looking at synthetic

methods. And synthetic methods are like

farming, tree planting, maybe some pumping to

recreate some of those floodings for cottonwood

regeneration.

 We'd continue to encourage

wildlife-dependent public uses. And those are

hunting and fishing, wildlife observation and

wildlife photography, environmental education

and interpretation.

 And back in the back, we've got several

maps set up that depict the various

alternatives, and if you want to take a closer

look at those, you are more than welcome to.

 But basically under this alternative,

we would be expanding a couple of the proposed

wilderness areas. These are shaded in the light

orange. We would be closing -- proposing to

close several cherry stem roads. The same thing

2

3

4

5

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7

8

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10

11

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13

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15

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Page 10

1 over here on the east half.

 So, kind of a synopsis of this is, we'd

implement prescriptive grazing on about 50 to

75% of the refuge. Right now, we're

prescriptively grazing 35%, so we would get a

little bit more aggressive in moving towards a

prescriptive grazing program. We would do that

within about a four- to seven-year time period.

 We'd do some active restoration of the

river bottoms. We'd continue to work with the

State to provide quality hunting opportunities

for big game, and then we'd also look more to

strive for providing habitat for nongame.

 The big one for this alternative is

we'd close about 106 miles of roads, and we'd

increase proposed wilderness areas by 25,000

acres in six units.

 The next alternative we came up with

was Alternative C, and we're calling this one

the "Public Use and the Economic Emphasis".

 And basically this one is to promote

maximum compatible wildlife-dependent public

uses and economic uses while protecting wildlife

populations and habitats, to the extent

possible.

2

3

4

5

6

7

8

9

10

11

12

13

14

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25

Page 11

1 And we've minimized damaging impacts to

habitats while using a variety of management

tools that would enhance and diversify public

and economic opportunities.

 So, out of this proposal, we're not

going to close any roads. We are proposing to

eliminate a couple of proposed wilderness

areas.

 And then some of the highlights of

this, is we'd work with Fish, Wildlife & Parks

to maintain that balance between big game and

livestock; work to provide more opportunities

for recreation; expand some hunting

opportunities. We're looking to hopefully

expand some youth hunting opportunities in

particular.

 We'd recommend eliminating about four

proposed wilderness areas, for a total of 35,000

acres.

 And then we move to our last

alternative, Alternative D, and this one is

called the "Natural Processes", or the

"Ecological Processes". And this is our

proposed action. Okay, this is the one that we

think best fits our mission of the Refuge

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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21

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Page 12

1 System.

 And for this one, again, we're going to

use those natural ecological processes of fire,

grazing and flooding and active management -

farming, tree planting - to restore and/or

maintain the biological diversity and integrity

and environmental health.

 And then once we have those processes

restored to the best of our abilities, we'll

take more of a passive management approach.

 We're still going to provide that

quality wildlife-dependent public uses. But the

big one here, is we would limit economic uses

when they are causing injury to either our

ecological processes or to those plants that

we're trying to get to going in a positive

direction.

 So again, last map, a couple of

proposed expansions of wilderness areas. Not as

much as in B. A couple of eliminations of some

proposed wilderness. A couple of proposed road

closures. Same thing here.

 So this one is economic uses will be

limited when they are injurious to our

ecological processes.

2

3

4

5

6

7

8

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

3 (Pages 9 to 12)

Page 9

1 emphasize the abundance and diversity of

wildlife populations using both balanced,

natural ecological processes.

 And when we talk about ecological

processes, the three big ones out at the

Missouri branch are fire, grazing and flooding.

 Then we're also looking at synthetic

methods. And synthetic methods are like

farming, tree planting, maybe some pumping to

recreate some of those floodings for cottonwood

regeneration.

 We'd continue to encourage

wildlife-dependent public uses. And those are

hunting and fishing, wildlife observation and

wildlife photography, environmental education

and interpretation.

 And back in the back, we've got several

maps set up that depict the various

alternatives, and if you want to take a closer

look at those, you are more than welcome to.

 But basically under this alternative,

we would be expanding a couple of the proposed

wilderness areas. These are shaded in the light

orange. We would be closing -- proposing to

close several cherry stem roads. The same thing

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 10

1 over here on the east half.

 So, kind of a synopsis of this is, we'd

implement prescriptive grazing on about 50 to

75% of the refuge. Right now, we're

prescriptively grazing 35%, so we would get a

little bit more aggressive in moving towards a

prescriptive grazing program. We would do that

within about a four- to seven-year time period.

 We'd do some active restoration of the

river bottoms. We'd continue to work with the

State to provide quality hunting opportunities

for big game, and then we'd also look more to

strive for providing habitat for nongame.

 The big one for this alternative is

we'd close about 106 miles of roads, and we'd

increase proposed wilderness areas by 25,000

acres in six units.

 The next alternative we came up with

was Alternative C, and we're calling this one

the "Public Use and the Economic Emphasis".

 And basically this one is to promote

maximum compatible wildlife-dependent public

uses and economic uses while protecting wildlife

populations and habitats, to the extent

possible.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 11

1 And we've minimized damaging impacts to

habitats while using a variety of management

tools that would enhance and diversify public

and economic opportunities.

 So, out of this proposal, we're not

going to close any roads. We are proposing to

eliminate a couple of proposed wilderness

areas.

 And then some of the highlights of

this, is we'd work with Fish, Wildlife & Parks

to maintain that balance between big game and

livestock; work to provide more opportunities

for recreation; expand some hunting

opportunities. We're looking to hopefully

expand some youth hunting opportunities in

particular.

 We'd recommend eliminating about four

proposed wilderness areas, for a total of 35,000

acres.

 And then we move to our last

alternative, Alternative D, and this one is

called the "Natural Processes", or the

"Ecological Processes". And this is our

proposed action. Okay, this is the one that we

think best fits our mission of the Refuge

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 12

1 System.

 And for this one, again, we're going to

use those natural ecological processes of fire,

grazing and flooding and active management -

farming, tree planting - to restore and/or

maintain the biological diversity and integrity

and environmental health.

 And then once we have those processes

restored to the best of our abilities, we'll

take more of a passive management approach.

 We're still going to provide that

quality wildlife-dependent public uses. But the

big one here, is we would limit economic uses

when they are causing injury to either our

ecological processes or to those plants that

we're trying to get to going in a positive

direction.

 So again, last map, a couple of

proposed expansions of wilderness areas. Not as

much as in B. A couple of eliminations of some

proposed wilderness. A couple of proposed road

closures. Same thing here.

 So this one is economic uses will be

limited when they are injurious to our

ecological processes.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

alternatives, and if you want to take a closer

look at those, you are more than welcome to.

 But basically under this alternative,

we would be expanding a couple of the proposed

wilderness areas. These are shaded in the light

orange. We would be closing -- proposing to

close several cherry stem roads. The same thing

19

20

21

22

23

24

25

Page 10

1 over here on the east half.

 So, kind of a synopsis of this is, we'd

implement prescriptive grazing on about 50 to

75% of the refuge. Right now, we're

prescriptively grazing 35%, so we would get a

little bit more aggressive in moving towards a

prescriptive grazing program. We would do that

within about a four- to seven-year time period.

 We'd do some active restoration of the

river bottoms. We'd continue to work with the

State to provide quality hunting opportunities

for big game, and then we'd also look more to

strive for providing habitat for nongame.

 The big one for this alternative is

we'd close about 106 miles of roads, and we'd

increase proposed wilderness areas by 25,000

acres in six units.

 The next alternative we came up with

was Alternative C, and we're calling this one

the "Public Use and the Economic Emphasis".

 And basically this one is to promote

maximum compatible wildlife-dependent public

uses and economic uses while protecting wildlife

populations and habitats, to the extent

possible.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

acres.

 An

alternati

called th

"Ecolog

propose

think be

19

20

21

22

23

24

25

1 System.

 An

use thos

grazing 

farming

maintain 

and envi

 An

restored 

take mo

 W

quality w

big one 

when th

ecologic

we're try

direction

 So 

propose

much as 

propose

closures

 So 

limited w

ecologic

2

3

4

5

6

7

8

9

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398 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 13

actices

rocesses

 grazing,

e

refuge.

grazing

r about a

.

h,

nd

nd we'd

 areas, for

ating three

ng?

.

ng.

nts. Some

rd,

tion

I found

Page 14

 it.

order to

ut

Page 15

1 protect that area from wildfire.

 So, those are two examples of how you

use prescriptive grazing to manage specific

wildlife or habitat objective.

 The other one is prescribed fire. How

will it be used?

 We've been working with fire ecologists

for the past five years now that have been

looking at mapping the historic fire frequency

occurrence on the refuge. Starting to get a

pretty good map in some places as to what that

occurrence was.

 It's highly variable, as you can

imagine, based upon the soils, based upon the

topography, based upon the slope. It ranges

anywhere from about every seven years to several

hundred years.

 So, the idea is to go into those places

that have frequent fire and put it back on the

ground. Several of those spots haven't seen

fire in 60 or 70 years.

 So the challenge is, is to go in and

put a light, cool fire through there to reduce

some of that fuel load, reduce the risk of a

catastrophic wildfire, but yet also keep it to a

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 16

1 point where it's manageable so you keep it

within this designated area.

 We touched on wilderness. You know,

basically as part of the CCP process, we're

mandated to look at our proposed wilderness

areas and to make recommendations as to whether

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

4 (Pages 13 to 16)

Page 13

1 We would apply management practices

that mimic and restore those natural processes

of fire and grazing. We'd use fire and grazing,

both wild ungulates and/or prescriptive

livestock grazing on 50 to 75% of the refuge.

 We would move to prescriptive grazing

at a slower pace. We would do it over about a

9- to 10-year period versus a four- to

seven-year period under Alternative B.

 Again, we would work with Fish,

Wildlife & Parks to maintain health and

diversity of all wildlife species.

 Close about 23 miles of roads, and we'd

expand six of the proposed wilderness areas, for

18,000 acres, but we'd propose eliminating three

from a reduction of 26.

 So, this is about the fourth meeting?

Fifth?

 MS. SHANNON: Fifth meeting.

 MR. CRAWFORD: Fifth meeting.

 We've heard quite a few comments. Some

of the hot button topics that we've heard,

prescriptive grazing, what is it?

 I had a gentleman ask me a question

last night about conservation grazing. I found

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 14

1 that a very unique term. Kind of liked it.

2 What we define as "prescriptive

grazing" is basically using grazing in order to

meet a specific wildlife and/or habitat

management objective.

 So basically we're going to go out

there. We're going to look at an area. And the

example that I like to use, is let's say we have

an area that's got a prairie dog town. It's got

some mountain plovers nesting on it. We want to

expand habitat for nesting mountain plovers.

 Mountain plovers like bare areas with

very little vegetation. So that's a case where

we could go in, graze an area really heavily.

Hopefully get the prairie dogs to expand. That

would then open up areas for mountain plovers to

then occupy new nesting areas.

 Another example is where you have sage

grouse lex, or you have wintering habitat for

sage grouse, and it has a high field buildup in

that area.

 And we obviously don't want to go in

there with fire and ruin the habitat for sage

grouse. We could use livestock to go in there

and reduce that hazardous fuel load, and then

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 15

1 protect that area from wildfire.

 So, those are two examples of how you

use prescriptive grazing to manage specific

wildlife or habitat objective.

 The other one is prescribed fire. How

will it be used?

 We've been working with fire ecologists

for the past five years now that have been

looking at mapping the historic fire frequency

occurrence on the refuge. Starting to get a

pretty good map in some places as to what that

occurrence was.

 It's highly variable, as you can

imagine, based upon the soils, based upon the

topography, based upon the slope. It ranges

anywhere from about every seven years to several

hundred years.

 So, the idea is to go into those places

that have frequent fire and put it back on the

ground. Several of those spots haven't seen

fire in 60 or 70 years.

 So the challenge is, is to go in and

put a light, cool fire through there to reduce

some of that fuel load, reduce the risk of a

catastrophic wildfire, but yet also keep it to a

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 16

1 point where it's manageable so you keep it

within this designated area.

 We touched on wilderness. You know,

basically as part of the CCP process, we're

mandated to look at our proposed wilderness

areas and to make recommendations as to whether

those areas still meet those wilderness

characteristics in which they were set aside

for.

 It is subjective. You know, we

basically look at the Act and look at the

reasons that those areas where set aside for

proposed wilderness, and we make a judgment

call.

 And that's why you see under

Alternative B no areas proposed for elimination,

and under Alternative C, you see more areas

proposed for elimination.

 We looked at it as to what was

kind of the emphasis of that alternative,

and then could we say, okay, yeah, this area

may not fit well under this alternative.

There's a possibility that, you know, maybe

we should consider dropping it from proposed

wilderness.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

4 (Pages 13 to 16)

Page 13

1 We would apply management practices

that mimic and restore those natural processes

of fire and grazing. We'd use fire and grazing,

both wild ungulates and/or prescriptive

livestock grazing on 50 to 75% of the refuge.

 We would move to prescriptive grazing

at a slower pace. We would do it over about a

9- to 10-year period versus a four- to

seven-year period under Alternative B.

 Again, we would work with Fish,

Wildlife & Parks to maintain health and

diversity of all wildlife species.

 Close about 23 miles of roads, and we'd

expand six of the proposed wilderness areas, for

18,000 acres, but we'd propose eliminating three

from a reduction of 26.

 So, this is about the fourth meeting?

Fifth?

 MS. SHANNON: Fifth meeting.

 MR. CRAWFORD: Fifth meeting.

 We've heard quite a few comments. Some

of the hot button topics that we've heard,

prescriptive grazing, what is it?

 I had a gentleman ask me a question

last night about conservation grazing. I found

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 14

1 that a very unique term. Kind of liked it.

2 What we define as "prescriptive

grazing" is basically using grazing in order to

meet a specific wildlife and/or habitat

management objective.

 So basically we're going to go out

there. We're going to look at an area. And the

example that I like to use, is let's say we have

an area that's got a prairie dog town. It's got

some mountain plovers nesting on it. We want to

expand habitat for nesting mountain plovers.

 Mountain plovers like bare areas with

very little vegetation. So that's a case where

we could go in, graze an area really heavily.

Hopefully get the prairie dogs to expand. That

would then open up areas for mountain plovers to

then occupy new nesting areas.

 Another example is where you have sage

grouse lex, or you have wintering habitat for

sage grouse, and it has a high field buildup in

that area.

 And we obviously don't want to go in

there with fire and ruin the habitat for sage

grouse. We could use livestock to go in there

and reduce that hazardous fuel load, and then

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 15

1 protect that area from wildfire.

 So, those are two examples of how you

use prescriptive grazing to manage specific

wildlife or habitat objective.

 The other one is prescribed fire. How

will it be used?

 We've been working with fire ecologists

for the past five years now that have been

looking at mapping the historic fire frequency

occurrence on the refuge. Starting to get a

pretty good map in some places as to what that

occurrence was.

 It's highly variable, as you can

imagine, based upon the soils, based upon the

topography, based upon the slope. It ranges

anywhere from about every seven years to several

hundred years.

 So, the idea is to go into those places

that have frequent fire and put it back on the

ground. Several of those spots haven't seen

fire in 60 or 70 years.

 So the challenge is, is to go in and

put a light, cool fire through there to reduce

some of that fuel load, reduce the risk of a

catastrophic wildfire, but yet also keep it to a

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 16

1 point where it's manageable so you keep it

within this designated area.

 We touched on wilderness. You know,

basically as part of the CCP process, we're

mandated to look at our proposed wilderness

areas and to make recommendations as to whether

those areas still meet those wilderness

characteristics in which they were set aside

for.

 It is subjective. You know, we

basically look at the Act and look at the

reasons that those areas where set aside for

proposed wilderness, and we make a judgment

call.

 And that's why you see under

Alternative B no areas proposed for elimination,

and under Alternative C, you see more areas

proposed for elimination.

 We looked at it as to what was

kind of the emphasis of that alternative,

and then could we say, okay, yeah, this area

may not fit well under this alternative.

There's a possibility that, you know, maybe

we should consider dropping it from proposed

wilderness.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

 MS. SHANNON: Fifth meeting.

 MR. CRAWFORD: Fifth meeting.

 We've heard quite a few comments. Some

of the hot button topics that we've heard,

prescriptive grazing, what is it?

 I had a gentleman ask me a question

last night about conservation grazing. I found

19

20

21

22

23

24

25

Page 14

1 that a very unique term. Kind of liked it.

2 What we define as "prescriptive

grazing" is basically using grazing in order to

meet a specific wildlife and/or habitat

management objective.

 So basically we're going to go out

there. We're going to look at an area. And the

example that I like to use, is let's say we have

an area that's got a prairie dog town. It's got

some mountain plovers nesting on it. We want to

expand habitat for nesting mountain plovers.

 Mountain plovers like bare areas with

very little vegetation. So that's a case where

we could go in, graze an area really heavily.

Hopefully get the prairie dogs to expand. That

would then open up areas for mountain plovers to

then occupy new nesting areas.

 Another example is where you have sage

grouse lex, or you have wintering habitat for

sage grouse, and it has a high field buildup in

that area.

 And we obviously don't want to go in

there with fire and ruin the habitat for sage

grouse. We could use livestock to go in there

and reduce that hazardous fuel load, and then

3

4

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9

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that have freq

ground. Sev

fire in 60 or 7

 So the 

put a light, co

some of that 

catastrophic 

19

20

21

22

23

24

25

1 point where i

within this de

 We tou

basically as p

mandated to 

areas and to m

those areas s

characteristic

for.

 It is sub

basically loo

reasons that t

proposed wil

call.

 And tha

Alternative B 

and under Al

proposed for 

 We loo

kind of the em

and then cou

may not fit w

There's a pos

we should co

wilderness.

2

3

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VOLUME 2, Chapter 4—Public Hearing Testimony 399

Page 17

We looked

ided -- or

ination as to,

lity to manage

essary access

the area, or

r a hunting

 -- the

holding.

 that we

ds should be

ich ones

a lot of

y that as

e will not be

uge, which is

 you is

e to

kay? That is a

he time

Page 18

 proposing,

f proposing

e refuge.

was that if

proposal, that

aluate the refuge

Page 19

1 the table when you leave. You can mail that

in. You can send Laurie a nice letter. You can

send her an email.

 There's no one comment form that's

weighted more heavily than the other one. We

treat all the comments the same, whether they

are written, whether they're emailed, whether

they're spoken.

 And it's not a voting contest. So, you

know, it doesn't matter if one person says

something, and 1,000 people say something

totally opposite. We look at the value of that

comment, and we weigh it on that value alone.

 So, that's all I've got. I appreciate

everybody taking time out of your very busy

schedules today to come out here. It's been

great working with everybody. Thanks.

 MS. MATHER: Okay, it's your turn. So,

let me explain how the comments will work.

 I have got a list of everybody that

signed up. I'll call folks off the list. I

will call who's next as well as who's on deck so

that person can be ready. Feel free to come sit

in our on-deck seats.

 Again, you have three minutes. We're

2

3

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7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 20

1 going to be strict about that time frame so we

can ensure that everybody has a chance to

comment.

 Once you've spoken for two minutes, and

you are down to one minute, Brad will hold up

the "one minute" sign. He's also got one for

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

5 (Pages 17 to 20)

Page 17

1 The same thing with roads. We looked

at the roads on the refuge and decided -- or

tried to make a subjective determination as to,

are those roads impacting our ability to manage

wildlife? Are they providing necessary access

for the public to get in and enjoy the area, or

to access a favorite fishing hole or a hunting

area?

 You know, it doesn't lead to -- the

lake doesn't lead that a private in-holding.

 Those are the sorts of things that we

looked at in determining what roads should be

proposed for elimination, and which ones

shouldn't.

 And then the final one was a lot of

comments on bison.

 And I can stand here and say that as

long as I'm manager of CFR, there will not be

any free-ranging bison on the refuge, which is

two more days.

 But, what I can honestly tell you is

that in the plan, we do not propose to

reintroduce free-ranging bison, okay? That is a

State-managed wildlife species.

 It is in the plan, because at the time

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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22

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25

Page 18

1 of our developing it, the State was proposing,

or was looking at the possibility of proposing

bison restoration in and around the refuge.

 So what we put in the plan was that if

the State brought forward such a proposal, that

we would work with them and evaluate the refuge

to see what role the refuge may play in

fulfilling that State plan.

 And it's no different than what we do

working with the State to fulfill their Bighorn

Sheep Management Plan, or their Elk Management

Plan or their Prairie Dog Management Plan. So,

that's the same thing there.

 So, as Mimi said, we're here to take

your comments today. We ask that you come and

use this microphone so everybody in the room can

hear you.

 This other microphone goes to our

recorder up here so she captures everything.

 We ask that you state your name; spell

it if it's not a common spelling, and go ahead

and give your comment.

 There are other ways that you can also

comment. There was comment sheets handed out in

the back. You can write on that and drop it at

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 19

1 the table when you leave. You can mail that

in. You can send Laurie a nice letter. You can

send her an email.

 There's no one comment form that's

weighted more heavily than the other one. We

treat all the comments the same, whether they

are written, whether they're emailed, whether

they're spoken.

 And it's not a voting contest. So, you

know, it doesn't matter if one person says

something, and 1,000 people say something

totally opposite. We look at the value of that

comment, and we weigh it on that value alone.

 So, that's all I've got. I appreciate

everybody taking time out of your very busy

schedules today to come out here. It's been

great working with everybody. Thanks.

 MS. MATHER: Okay, it's your turn. So,

let me explain how the comments will work.

 I have got a list of everybody that

signed up. I'll call folks off the list. I

will call who's next as well as who's on deck so

that person can be ready. Feel free to come sit

in our on-deck seats.

 Again, you have three minutes. We're

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 20

1 going to be strict about that time frame so we

can ensure that everybody has a chance to

comment.

 Once you've spoken for two minutes, and

you are down to one minute, Brad will hold up

the "one minute" sign. He's also got one for

when you have "20 seconds left". At that point,

we really need to start wrapping up.

 And then there's a "time is up", at

which case, we would like for you to hand the

mic back to me, and I'll call up the next

person.

 Some of you have said that you just

have a question. That's fine. Come on up to

the mic and just ask your question.

 We're going to break -- we're going to

stop at 3:45 so that Barron has an opportunity

to address a number of the questions and

comments as a way to close the meeting.

 So, one other thing I ask, just to

respect one another's opinion.

 And to allow things to move quickly and

smoothly, please don't interrupt one another as

people are giving comments, and please hold back

on applause and cheering.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

5 (Pages 17 to 20)

Page 17

1 The same thing with roads. We looked

at the roads on the refuge and decided -- or

tried to make a subjective determination as to,

are those roads impacting our ability to manage

wildlife? Are they providing necessary access

for the public to get in and enjoy the area, or

to access a favorite fishing hole or a hunting

area?

 You know, it doesn't lead to -- the

lake doesn't lead that a private in-holding.

 Those are the sorts of things that we

looked at in determining what roads should be

proposed for elimination, and which ones

shouldn't.

 And then the final one was a lot of

comments on bison.

 And I can stand here and say that as

long as I'm manager of CFR, there will not be

any free-ranging bison on the refuge, which is

two more days.

 But, what I can honestly tell you is

that in the plan, we do not propose to

reintroduce free-ranging bison, okay? That is a

State-managed wildlife species.

 It is in the plan, because at the time

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 18

1 of our developing it, the State was proposing,

or was looking at the possibility of proposing

bison restoration in and around the refuge.

 So what we put in the plan was that if

the State brought forward such a proposal, that

we would work with them and evaluate the refuge

to see what role the refuge may play in

fulfilling that State plan.

 And it's no different than what we do

working with the State to fulfill their Bighorn

Sheep Management Plan, or their Elk Management

Plan or their Prairie Dog Management Plan. So,

that's the same thing there.

 So, as Mimi said, we're here to take

your comments today. We ask that you come and

use this microphone so everybody in the room can

hear you.

 This other microphone goes to our

recorder up here so she captures everything.

 We ask that you state your name; spell

it if it's not a common spelling, and go ahead

and give your comment.

 There are other ways that you can also

comment. There was comment sheets handed out in

the back. You can write on that and drop it at

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 19

1 the table when you leave. You can mail that

in. You can send Laurie a nice letter. You can

send her an email.

 There's no one comment form that's

weighted more heavily than the other one. We

treat all the comments the same, whether they

are written, whether they're emailed, whether

they're spoken.

 And it's not a voting contest. So, you

know, it doesn't matter if one person says

something, and 1,000 people say something

totally opposite. We look at the value of that

comment, and we weigh it on that value alone.

 So, that's all I've got. I appreciate

everybody taking time out of your very busy

schedules today to come out here. It's been

great working with everybody. Thanks.

 MS. MATHER: Okay, it's your turn. So,

let me explain how the comments will work.

 I have got a list of everybody that

signed up. I'll call folks off the list. I

will call who's next as well as who's on deck so

that person can be ready. Feel free to come sit

in our on-deck seats.

 Again, you have three minutes. We're

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 20

1 going to be strict about that time frame so we

can ensure that everybody has a chance to

comment.

 Once you've spoken for two minutes, and

you are down to one minute, Brad will hold up

the "one minute" sign. He's also got one for

when you have "20 seconds left". At that point,

we really need to start wrapping up.

 And then there's a "time is up", at

which case, we would like for you to hand the

mic back to me, and I'll call up the next

person.

 Some of you have said that you just

have a question. That's fine. Come on up to

the mic and just ask your question.

 We're going to break -- we're going to

stop at 3:45 so that Barron has an opportunity

to address a number of the questions and

comments as a way to close the meeting.

 So, one other thing I ask, just to

respect one another's opinion.

 And to allow things to move quickly and

smoothly, please don't interrupt one another as

people are giving comments, and please hold back

on applause and cheering.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

any free-ranging bison on the refuge, which is

two more days.

 But, what I can honestly tell you is

that in the plan, we do not propose to

reintroduce free-ranging bison, okay? That is a

State-managed wildlife species.

 It is in the plan, because at the time

19

20

21

22

23

24

25

Page 18

1 of our developing it, the State was proposing,

or was looking at the possibility of proposing

bison restoration in and around the refuge.

 So what we put in the plan was that if

the State brought forward such a proposal, that

we would work with them and evaluate the refuge

to see what role the refuge may play in

fulfilling that State plan.

 And it's no different than what we do

working with the State to fulfill their Bighorn

Sheep Management Plan, or their Elk Management

Plan or their Prairie Dog Management Plan. So,

that's the same thing there.

 So, as Mimi said, we're here to take

your comments today. We ask that you come and

use this microphone so everybody in the room can

hear you.

 This other microphone goes to our

recorder up here so she captures everything.

 We ask that you state your name; spell

it if it's not a common spelling, and go ahead

and give your comment.

 There are other ways that you can also

comment. There was comment sheets handed out in

the back. You can write on that and drop it at

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

let me e

 I h

signed u

will call 

that pers

in our on

 Ag

19

20

21

22

23

24

25

1 going to 

can ensu

commen

 On

you are 

the "one 

when yo

we reall

 An

which c

mic back 

person.

 So

have a q

the mic 

 W

stop at 3

to addre

commen

 So

respect o

 An

smoothl

people a

on appla

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
400 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 21

ot

ps on deck.

oing to be

're

ave a

lease".

ons

blic

 grazing,

at because

d the

hers that

ced them.

erything,

e people

wolves.

uffalo

 of the

ow come the

to destroy

ng

Page 22

hey

d wildlife,

uff.

yet

Page 23

1 agencies call them "wild horses", and they're

using them to take the grazing rights away. But

those horses where turned loose by the people

that went broke in this area from the Dirty

Thirties. They are not true wild horses.

 Prairie dogs totally ruin the land, as

all of us know, but yet these guys want a lot

more of them.

 And a little bit ago, there was

something about limiting the fuel. Well, how

come we're going to have so much fuel. If we

had a little more grazing, we wouldn't have that

fuel, would we?

 Okay, you're probably not going to like

me for what I'm going to say here, but our

president, legislators, representatives, public

servants swear an oath to the Constitution, and

are supposed to be tried for treason when they

pass legislation that violates the Constitution

or allow the takings of private property.

 It's a fact that laws contrary to the

Constitution are supposed to be null and void

from the time of their inception. Imminent

domain is not to be used to take a person's

means of making a living or their homes, except

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 24

1 for the public good, and wildlife and habitat is

not what the law was meant for.

 Okay, I guess I'm getting limited here,

so I'm just going to say, "United we stand.

Divided we fall."

MS. MATHER: Thank you, Karen.

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

6 (Pages 21 to 24)

Page 21

1 So with that, we can start. I've got

Karen Taylor up first, and Tony Phipps on deck.

 KAREN TAYLOR: This isn't going to be

easy in that time limit, but anyway.

 These agencies keep saying they're

going to involve the public, yet they have a

release out that says "not for public release".

 They keep doing all these decisions

with no scientific data, without the public

input. They've eliminated all kinds of grazing,

put people out of business. I know that because

we just lost our ranch.

 Okay. The government poisoned the

wolves. Now it's the fault of the ranchers that

we don't have wolves. They reintroduced them.

They keep saying they want native everything,

but that's not native wolves. There are people

who can prove that they are not true wolves.

 The government still have the buffalo

slaughtered. Somehow that's the fault of the

ranchers. But I would like to know how come the

buffalo can graze, but cows just seem to destroy

the habitat?

 They have been taking the grazing

rights and, like I say, putting us out of

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 22

1 business.

 They plan on burning things. They

wanted to have cover for the birds and wildlife,

but yet they're going to burn all this stuff.

And they call this nature.

 They're closing more roads, but yet

they say they want the public to be able to use

it.

 Take a look at those maps really close,

because how in the devil with all those roads

closed are we going to get to our, quote,

"favorite fishing hole"?

 They had no public hearings to close

these roads. That's illegal, just the same as

when they're doing all this stuff behind our

backs.

 And they limit fishing and hunting, and

yet they say it's your public land, and you can

use it.

 They're limiting us to voice our

concerns. And if you voice your concerns,

believe me, you will be put out of business and

threatened.

 Okay, they protected what they called

wild horses. Wild Horse Annie and the federal

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 23

1 agencies call them "wild horses", and they're

using them to take the grazing rights away. But

those horses where turned loose by the people

that went broke in this area from the Dirty

Thirties. They are not true wild horses.

 Prairie dogs totally ruin the land, as

all of us know, but yet these guys want a lot

more of them.

 And a little bit ago, there was

something about limiting the fuel. Well, how

come we're going to have so much fuel. If we

had a little more grazing, we wouldn't have that

fuel, would we?

 Okay, you're probably not going to like

me for what I'm going to say here, but our

president, legislators, representatives, public

servants swear an oath to the Constitution, and

are supposed to be tried for treason when they

pass legislation that violates the Constitution

or allow the takings of private property.

 It's a fact that laws contrary to the

Constitution are supposed to be null and void

from the time of their inception. Imminent

domain is not to be used to take a person's

means of making a living or their homes, except

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 24

1 for the public good, and wildlife and habitat is

not what the law was meant for.

 Okay, I guess I'm getting limited here,

so I'm just going to say, "United we stand.

Divided we fall."

 MS. MATHER: Thank you, Karen.

 Tony Phipps?

 MR. PHIPPS: I'll pass.

 MS. MATHER: You'll pass.

 Okay, Jack Murnion, and Edla on deck.

 And again, Jack, if you could spell

your name for the court reporter.

 MR. MURNION: I got to get my glasses.

 I was one of the Garfield County

Commissioners. I will confine my statement to

the economic impact of Preferred Plan D to the

taxpayers of Garfield County.

 Page 316, Part 5 of this Draft CCP

states that I believe in '07, there where 1800

 -- 18,872 AUMs in the refuge, at a rate of 1720

an AUM for an income to CMR from grazing of

$324,598.40.

 When this income to the CMR ends under

Preferred Plan D, and I quote from Page 5 --

from Part 5, Page 330,

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

6 (Pages 21 to 24)

Page 21

1 So with that, we can start. I've got

Karen Taylor up first, and Tony Phipps on deck.

 KAREN TAYLOR: This isn't going to be

easy in that time limit, but anyway.

 These agencies keep saying they're

going to involve the public, yet they have a

release out that says "not for public release".

 They keep doing all these decisions

with no scientific data, without the public

input. They've eliminated all kinds of grazing,

put people out of business. I know that because

we just lost our ranch.

 Okay. The government poisoned the

wolves. Now it's the fault of the ranchers that

we don't have wolves. They reintroduced them.

They keep saying they want native everything,

but that's not native wolves. There are people

who can prove that they are not true wolves.

 The government still have the buffalo

slaughtered. Somehow that's the fault of the

ranchers. But I would like to know how come the

buffalo can graze, but cows just seem to destroy

the habitat?

 They have been taking the grazing

rights and, like I say, putting us out of

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 22

1 business.

 They plan on burning things. They

wanted to have cover for the birds and wildlife,

but yet they're going to burn all this stuff.

And they call this nature.

 They're closing more roads, but yet

they say they want the public to be able to use

it.

 Take a look at those maps really close,

because how in the devil with all those roads

closed are we going to get to our, quote,

"favorite fishing hole"?

 They had no public hearings to close

these roads. That's illegal, just the same as

when they're doing all this stuff behind our

backs.

 And they limit fishing and hunting, and

yet they say it's your public land, and you can

use it.

 They're limiting us to voice our

concerns. And if you voice your concerns,

believe me, you will be put out of business and

threatened.

 Okay, they protected what they called

wild horses. Wild Horse Annie and the federal

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 23

1 agencies call them "wild horses", and they're

using them to take the grazing rights away. But

those horses where turned loose by the people

that went broke in this area from the Dirty

Thirties. They are not true wild horses.

 Prairie dogs totally ruin the land, as

all of us know, but yet these guys want a lot

more of them.

 And a little bit ago, there was

something about limiting the fuel. Well, how

come we're going to have so much fuel. If we

had a little more grazing, we wouldn't have that

fuel, would we?

 Okay, you're probably not going to like

me for what I'm going to say here, but our

president, legislators, representatives, public

servants swear an oath to the Constitution, and

are supposed to be tried for treason when they

pass legislation that violates the Constitution

or allow the takings of private property.

 It's a fact that laws contrary to the

Constitution are supposed to be null and void

from the time of their inception. Imminent

domain is not to be used to take a person's

means of making a living or their homes, except

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 24

1 for the public good, and wildlife and habitat is

not what the law was meant for.

 Okay, I guess I'm getting limited here,

so I'm just going to say, "United we stand.

Divided we fall."

 MS. MATHER: Thank you, Karen.

 Tony Phipps?

 MR. PHIPPS: I'll pass.

 MS. MATHER: You'll pass.

 Okay, Jack Murnion, and Edla on deck.

 And again, Jack, if you could spell

your name for the court reporter.

 MR. MURNION: I got to get my glasses.

 I was one of the Garfield County

Commissioners. I will confine my statement to

the economic impact of Preferred Plan D to the

taxpayers of Garfield County.

 Page 316, Part 5 of this Draft CCP

states that I believe in '07, there where 1800

 -- 18,872 AUMs in the refuge, at a rate of 1720

an AUM for an income to CMR from grazing of

$324,598.40.

 When this income to the CMR ends under

Preferred Plan D, and I quote from Page 5 --

from Part 5, Page 330,

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

 The government still have the buffalo

slaughtered. Somehow that's the fault of the

ranchers. But I would like to know how come the

buffalo can graze, but cows just seem to destroy

the habitat?

 They have been taking the grazing

rights and, like I say, putting us out of

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Page 22

1 business.

 They plan on burning things. They

wanted to have cover for the birds and wildlife,

but yet they're going to burn all this stuff.

And they call this nature.

 They're closing more roads, but yet

they say they want the public to be able to use

it.

 Take a look at those maps really close,

because how in the devil with all those roads

closed are we going to get to our, quote,

"favorite fishing hole"?

 They had no public hearings to close

these roads. That's illegal, just the same as

when they're doing all this stuff behind our

backs.

 And they limit fishing and hunting, and

yet they say it's your public land, and you can

use it.

 They're limiting us to voice our

concerns. And if you voice your concerns,

believe me, you will be put out of business and

threatened.

 Okay, they protected what they called

wild horses. Wild Horse Annie and the federal

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pass legislati

or allow the 

 It's a fa

Constitution 

from the tim

domain is no

means of ma

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25

1 for the public 

not what the 

 Okay, I 

so I'm just go

Divided we f

 MS. M

 Tony P

 MR. PH

 MS. M

 Okay, J

 And ag

your name fo

 MR. M

 I was o

Commission

the economic 

taxpayers of 

 Page 3

states that I b

 -- 18,872 AU

an AUM for 

$324,598.40

 When t

Preferred Pla

from Part 5, 

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VOLUME 2, Chapter 4—Public Hearing Testimony 401

Page 25

mpact data

ce any

hat could give

d promise over

hinking that

debt?

Page 14 in

r

s

Page 26

nk you.

on deck.

o you want us to

Page 27

1 that are going to get up and talk -- I'm just

going to say I've been here 26 years in the

county, and we are all practitioners. None of

us get to be a theoretical person.

 So when you talk about roads and all

the things that go into a piece of property,

we're the ones that are falling in a hole or

digging some hunter out of a hole. We deal with

the real situation. We have real animals that

need something to eat and water to drink.

 So, these papers and charts and

computers that the theoretician people work

with, the bureaucracy people work with, they're

all very neat and tidy, and everything is done

in three minutes, of course.

 And we are put in the situation of

three minutes to defend what we think would be

best, but we're living out here a lifetime.

Everybody in these nice outfits and nice

salaries will drive away, and then people can

talk. We go home to the real.

 So I would say of the alternatives that

we're looking at, let's go with Alternative A

that we can maybe deal with.

 The people that are sitting in some big

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Page 28

1 city in a basement with a computer and can be as

odd as a $3 bill ought not to have a word to say

about the things that affect us, like

predators. If they want one, come and get one.

Take them home. Put it in a cage. Look at it.

But the people that have been part of

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6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

7 (Pages 25 to 28)

Page 25

1 "Alternative D will

 generate 2.1 million more

 in local output, 25

 additional jobs, and 569.6

 thousand more in agri

 income as compared to

 Alternative A."

 I submit that the economic impact data

in this study book is flawed.

 I submit that I would embrace any

business in our part of Montana that could give

up all revenue of $324,598.40, and promise over

$2 million in local output.

 Is this the same economic thinking that

has our great country trillions in debt?

 And one further comment. Page 14 in

this book.

 "All the issues excluded

 on Page 14 as outside of

 this Draft CCP and EIS

 should be addressed, as our

 information from Congress

 suggests that this plan

 cannot further destroy our

 rural economy."

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Page 26

1 Thank you.

 MS. MATHER: And Edla?

 EDLA McKERLICK: Thank you.

 MS. MATHER: And Mike on deck.

 MS. McKERLICK: How do you want us to

hold this thing?

 MS. MATHER: We want you to just stand

right there. This is the one you speak into.

 MS. McKERLICK: That's awkward.

 We're going to turn to the audience,

though.

 MS. MATHER: But it's actually better

for the court reporter if you face her and face

these guys. These guys can hear you because you

are mic'd.

 MS. McKERLICK: Well, that's odd.

 I'm going to turn to the public.

 MS. MATHER: Can you just spell your

name real quick?

 MS. McKERLICK: Edla, E-D-L-A;

McKerlick, M-c-K-E-R-L-I-C-K.

 I didn't prepare anything ahead of

time, but -- can you hear me?

 I'll just speak -- Karen spoke with

practical facts, and I'm sure the other people

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8

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Page 27

1 that are going to get up and talk -- I'm just

going to say I've been here 26 years in the

county, and we are all practitioners. None of

us get to be a theoretical person.

 So when you talk about roads and all

the things that go into a piece of property,

we're the ones that are falling in a hole or

digging some hunter out of a hole. We deal with

the real situation. We have real animals that

need something to eat and water to drink.

 So, these papers and charts and

computers that the theoretician people work

with, the bureaucracy people work with, they're

all very neat and tidy, and everything is done

in three minutes, of course.

 And we are put in the situation of

three minutes to defend what we think would be

best, but we're living out here a lifetime.

Everybody in these nice outfits and nice

salaries will drive away, and then people can

talk. We go home to the real.

 So I would say of the alternatives that

we're looking at, let's go with Alternative A

that we can maybe deal with.

 The people that are sitting in some big

2

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5

6

7

8

9

10

11

12

13

14

15

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24

25

Page 28

1 city in a basement with a computer and can be as

odd as a $3 bill ought not to have a word to say

about the things that affect us, like

predators. If they want one, come and get one.

Take them home. Put it in a cage. Look at it.

 But the people that have been part of

the history, and most of us have been from the

time of so many generations, we're not just

people that have come out here to get away from

the city.

 And we have it a lot better than our

ancestors had it. But for heaven's sakes, when

you say "partnering up", listen to what the

partners have to say, if we are the partners.

Maybe we aren't.

 So it's a very difficult topic, but I

would say, please pay attention to the people

that actually live here.

 MS. MATHER: Mike, and I believe it's

Skip Olson on deck.

 MIKE McKEEVER: My name is Mike

McKeever, M-c-K-E-E-V-E-R.

 I've three questions or five questions,

whatever I have to ask.

 And first I would like to say, Edla, we

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

7 (Pages 25 to 28)

Page 25

1 "Alternative D will

 generate 2.1 million more

 in local output, 25

 additional jobs, and 569.6

 thousand more in agri

 income as compared to

 Alternative A."

 I submit that the economic impact data

in this study book is flawed.

 I submit that I would embrace any

business in our part of Montana that could give

up all revenue of $324,598.40, and promise over

$2 million in local output.

 Is this the same economic thinking that

has our great country trillions in debt?

 And one further comment. Page 14 in

this book.

 "All the issues excluded

 on Page 14 as outside of

 this Draft CCP and EIS

 should be addressed, as our

 information from Congress

 suggests that this plan

 cannot further destroy our

 rural economy."

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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17

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Page 26

1 Thank you.

 MS. MATHER: And Edla?

 EDLA McKERLICK: Thank you.

 MS. MATHER: And Mike on deck.

 MS. McKERLICK: How do you want us to

hold this thing?

 MS. MATHER: We want you to just stand

right there. This is the one you speak into.

 MS. McKERLICK: That's awkward.

 We're going to turn to the audience,

though.

 MS. MATHER: But it's actually better

for the court reporter if you face her and face

these guys. These guys can hear you because you

are mic'd.

 MS. McKERLICK: Well, that's odd.

 I'm going to turn to the public.

 MS. MATHER: Can you just spell your

name real quick?

 MS. McKERLICK: Edla, E-D-L-A;

McKerlick, M-c-K-E-R-L-I-C-K.

 I didn't prepare anything ahead of

time, but -- can you hear me?

 I'll just speak -- Karen spoke with

practical facts, and I'm sure the other people

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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20

21

22

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24

25

Page 27

1 that are going to get up and talk -- I'm just

going to say I've been here 26 years in the

county, and we are all practitioners. None of

us get to be a theoretical person.

 So when you talk about roads and all

the things that go into a piece of property,

we're the ones that are falling in a hole or

digging some hunter out of a hole. We deal with

the real situation. We have real animals that

need something to eat and water to drink.

 So, these papers and charts and

computers that the theoretician people work

with, the bureaucracy people work with, they're

all very neat and tidy, and everything is done

in three minutes, of course.

 And we are put in the situation of

three minutes to defend what we think would be

best, but we're living out here a lifetime.

Everybody in these nice outfits and nice

salaries will drive away, and then people can

talk. We go home to the real.

 So I would say of the alternatives that

we're looking at, let's go with Alternative A

that we can maybe deal with.

 The people that are sitting in some big

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 28

1 city in a basement with a computer and can be as

odd as a $3 bill ought not to have a word to say

about the things that affect us, like

predators. If they want one, come and get one.

Take them home. Put it in a cage. Look at it.

 But the people that have been part of

the history, and most of us have been from the

time of so many generations, we're not just

people that have come out here to get away from

the city.

 And we have it a lot better than our

ancestors had it. But for heaven's sakes, when

you say "partnering up", listen to what the

partners have to say, if we are the partners.

Maybe we aren't.

 So it's a very difficult topic, but I

would say, please pay attention to the people

that actually live here.

 MS. MATHER: Mike, and I believe it's

Skip Olson on deck.

 MIKE McKEEVER: My name is Mike

McKeever, M-c-K-E-E-V-E-R.

 I've three questions or five questions,

whatever I have to ask.

 And first I would like to say, Edla, we

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 on Page 14 as outside of

 this Draft CCP and EIS

 should be addressed, as our

 information from Congress

 suggests that this plan

 cannot further destroy our

 rural economy."

19

20

21

22

23

24

25

Page 26

1 Thank you.

 MS. MATHER: And Edla?

 EDLA McKERLICK: Thank you.

 MS. MATHER: And Mike on deck.

 MS. McKERLICK: How do you want us to

hold this thing?

 MS. MATHER: We want you to just stand

right there. This is the one you speak into.

 MS. McKERLICK: That's awkward.

 We're going to turn to the audience,

though.

 MS. MATHER: But it's actually better

for the court reporter if you face her and face

these guys. These guys can hear you because you

are mic'd.

 MS. McKERLICK: Well, that's odd.

 I'm going to turn to the public.

 MS. MATHER: Can you just spell your

name real quick?

 MS. McKERLICK: Edla, E-D-L-A;

McKerlick, M-c-K-E-R-L-I-C-K.

 I didn't prepare anything ahead of

time, but -- can you hear me?

 I'll just speak -- Karen spoke with

practical facts, and I'm sure the other people

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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25

Everybo

salaries 

talk. W

 So 

we're lo

that we 

 Th

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22

23

24

25

1 city in a 

odd as a 

about th

predator

Take the

 Bu

the histo

time of s

people t

the city.

 An

ancestor

you say 

partners 

Maybe w

 So 

would s

that actu

 M

Skip Ols

 MI

McKeev

 I'v

whateve

 An

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402 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 29

seem

and it

are in

o you propose

he

reational

ed to

ent private

hree

eck Lake,

ple of

s and

inate

e limited

tively

 will be

m

lanning

dlife

 tapped

Page 30

g if

Because

mething

nning.

ay a

Page 31

1 Are we, as individuals and private

landowners, going to get a buy like this from

the state, or is this just a special perk for

the CMR at the school's expense?

 And water rights. I guess I'd like to

know who will end up with the rights when the

impoundments are removed? I think this is

Page 75. I would like an explanation of that --

Page 175.

 I guess a real brief comment here.

 As I read over these preferred

alternatives, A is the one I would prefer, of

course. But there's lots and lots of

consideration for private property rights of the

adjacent landowners.

 We got prescribed fires out of control;

normal annual grazing permits, but prescribed

grazing as well as introduction of native

species by the partners, and, of course,

increased predator populations. These changes

make for a very unfriendly neighbor relations to

the adjacent landowners.

 My solution to this would to be fence

the entire refuge.

 Predator type, pay a recreation tax to

2

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Page 32

1 the counties, and then you can study it; you can

burn it; you can let the predators have what's

in there, but you won't be bothering us.

 Thank you.

 MS. MATHER: Thank you.

Skip, with Karla Christensen on deck.

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

8 (Pages 29 to 32)

Page 29

1 agree.

2 One of my questions that I can't seem

to get this straight, I look in the book, and it

says if you're not going to pay your share in

the county with PELT funding, how do you propose

to pay your fair share of the taxes in the

counties affected by your existence?

 The CMR should be taxed as recreational

land. That's, I guess a question.

 The second one would be, we need to

address the negative impacts on adjacent private

lands.

 For example, our place is about three

miles from the Big Dry Arm of Fort Peck Lake,

and as Alternative D, and I think a couple of

the others say, if we take out the fences and

the water impoundments, and we eliminate

predator control as we have it now, the limited

amount we have now, we will be negatively

affected by the additional wildlife that will be

seeking food, water and protection from

predators.

 Is the CMR or the government planning

to pay a trespass fee for additional wildlife

that we have to support? We're nearly tapped

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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25

Page 30

1 out running the livestock right now.

 So, I guess I'm kind of wondering if

we're going to be compensated for it? Because

we will have to -- we'll have to do something

for the additional livestock we'll be running.

 I'm sure that we would have to pay a

trespass fee in the event that our livestock

strayed out to CMR lands and took up residence.

 Also, another thing, State lands. I

think there's 36,000 acres within the boundary

of the CMR of State lands. I think this is what

I read. And I'm wondering if this is just

another takings?

 Your proposal to protect State lands.

What is your proposal to protect these State

lands for the schools without the bidding

process?

 You say on Page -- I think it's 329,

 "If permittees no longer

 retained their grazing

 permits, the Service will

 work with the DNRC to

 assume these permits."

 And part of it says "providing the CMR

has the funding to do it".

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 31

1 Are we, as individuals and private

landowners, going to get a buy like this from

the state, or is this just a special perk for

the CMR at the school's expense?

 And water rights. I guess I'd like to

know who will end up with the rights when the

impoundments are removed? I think this is

Page 75. I would like an explanation of that --

Page 175.

 I guess a real brief comment here.

 As I read over these preferred

alternatives, A is the one I would prefer, of

course. But there's lots and lots of

consideration for private property rights of the

adjacent landowners.

 We got prescribed fires out of control;

normal annual grazing permits, but prescribed

grazing as well as introduction of native

species by the partners, and, of course,

increased predator populations. These changes

make for a very unfriendly neighbor relations to

the adjacent landowners.

 My solution to this would to be fence

the entire refuge.

 Predator type, pay a recreation tax to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 32

1 the counties, and then you can study it; you can

burn it; you can let the predators have what's

in there, but you won't be bothering us.

 Thank you.

 MS. MATHER: Thank you.

 Skip, with Karla Christensen on deck.

 SKIP OLSON: Olson, O-L-S-O-N. First

name Norman, N-O-R-M-A-N.

 This is going to be short, as they

say. I'm going to read just a couple of things

directly from this magazine.

 Would you hold that, please.

 MS. MATHER: Yes.

 MR. OLSON: Just to get your

attention.

 This is the "Effect on Riparian Areas",

Page 276, Alternative B.

 "If wolves where to

 naturally recolonize the

 refuge, the presence and

 management of wolves on the

 refuge would provide

 predational pressure on

 wild ungulates, which would

 benefit riparian health by

2

3

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

8 (Pages 29 to 32)

Page 29

1 agree.

2 One of my questions that I can't seem

to get this straight, I look in the book, and it

says if you're not going to pay your share in

the county with PELT funding, how do you propose

to pay your fair share of the taxes in the

counties affected by your existence?

 The CMR should be taxed as recreational

land. That's, I guess a question.

 The second one would be, we need to

address the negative impacts on adjacent private

lands.

 For example, our place is about three

miles from the Big Dry Arm of Fort Peck Lake,

and as Alternative D, and I think a couple of

the others say, if we take out the fences and

the water impoundments, and we eliminate

predator control as we have it now, the limited

amount we have now, we will be negatively

affected by the additional wildlife that will be

seeking food, water and protection from

predators.

 Is the CMR or the government planning

to pay a trespass fee for additional wildlife

that we have to support? We're nearly tapped

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 30

1 out running the livestock right now.

 So, I guess I'm kind of wondering if

we're going to be compensated for it? Because

we will have to -- we'll have to do something

for the additional livestock we'll be running.

 I'm sure that we would have to pay a

trespass fee in the event that our livestock

strayed out to CMR lands and took up residence.

 Also, another thing, State lands. I

think there's 36,000 acres within the boundary

of the CMR of State lands. I think this is what

I read. And I'm wondering if this is just

another takings?

 Your proposal to protect State lands.

What is your proposal to protect these State

lands for the schools without the bidding

process?

 You say on Page -- I think it's 329,

 "If permittees no longer

 retained their grazing

 permits, the Service will

 work with the DNRC to

 assume these permits."

 And part of it says "providing the CMR

has the funding to do it".

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 31

1 Are we, as individuals and private

landowners, going to get a buy like this from

the state, or is this just a special perk for

the CMR at the school's expense?

 And water rights. I guess I'd like to

know who will end up with the rights when the

impoundments are removed? I think this is

Page 75. I would like an explanation of that --

Page 175.

 I guess a real brief comment here.

 As I read over these preferred

alternatives, A is the one I would prefer, of

course. But there's lots and lots of

consideration for private property rights of the

adjacent landowners.

 We got prescribed fires out of control;

normal annual grazing permits, but prescribed

grazing as well as introduction of native

species by the partners, and, of course,

increased predator populations. These changes

make for a very unfriendly neighbor relations to

the adjacent landowners.

 My solution to this would to be fence

the entire refuge.

 Predator type, pay a recreation tax to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 32

1 the counties, and then you can study it; you can

burn it; you can let the predators have what's

in there, but you won't be bothering us.

 Thank you.

 MS. MATHER: Thank you.

 Skip, with Karla Christensen on deck.

 SKIP OLSON: Olson, O-L-S-O-N. First

name Norman, N-O-R-M-A-N.

 This is going to be short, as they

say. I'm going to read just a couple of things

directly from this magazine.

 Would you hold that, please.

 MS. MATHER: Yes.

 MR. OLSON: Just to get your

attention.

 This is the "Effect on Riparian Areas",

Page 276, Alternative B.

 "If wolves where to

 naturally recolonize the

 refuge, the presence and

 management of wolves on the

 refuge would provide

 predational pressure on

 wild ungulates, which would

 benefit riparian health by

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

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(406)248-4064 Fax:(406)256-5525 E-Mail:f

BIG SKY REPORTING - FRANCES L

amount we have now, we will be negatively

affected by the additional wildlife that will be

seeking food, water and protection from

predators.

 Is the CMR or the government planning

to pay a trespass fee for additional wildlife

that we have to support? We're nearly tapped

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Page 30

1 out running the livestock right now.

 So, I guess I'm kind of wondering if

we're going to be compensated for it? Because

we will have to -- we'll have to do something

for the additional livestock we'll be running.

 I'm sure that we would have to pay a

trespass fee in the event that our livestock

strayed out to CMR lands and took up residence.

 Also, another thing, State lands. I

think there's 36,000 acres within the boundary

of the CMR of State lands. I think this is what

I read. And I'm wondering if this is just

another takings?

 Your proposal to protect State lands.

What is your proposal to protect these State

lands for the schools without the bidding

process?

 You say on Page -- I think it's 329,

 "If permittees no longer

 retained their grazing

 permits, the Service will

 work with the DNRC to

 assume these permits."

 And part of it says "providing the CMR

has the funding to do it".

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species by th

increased pre

make for a v

the adjacent 

 My sol

the entire ref

 Predato

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25

1 the counties, 

burn it; you c

in there, but 

 Thank 

 MS. M

 Skip, w

 SKIP O

name Norma

 This is 

say. I'm goin

directly from 

 Would 

 MS. M

 MR. O

attention.

 This is 

Page 276, Al

 "If w

 natura

 refuge

 manag

 refuge 

 preda

 wild u

 benef

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VOLUME 2, Chapter 4—Public Hearing Testimony 403

Page 33

t

ld

r

d

Page 34

dget,

ave a budget

ut costs to

1 million acres

Page 35

1 sheet, be reminded that these are in thousands

of dollars.

 The bottom of the page of Alternative A

runs from 49 million. Alternative D goes 76

million. This is over a 15-year plan.

 I'd like to highlight a couple of

things. The biggest enemy that we have on this

is range and invasive species.

 We are getting covered up from the

north by thousands of acres of weeds. And you

guys that aren't familiar with that, I have

extensive experience with weeds on the CMR. I

don't know if I have time to talk about them.

 You know, if you look at them

proposals, they're going to spend $8 million

building a building. I'm sure you're going to

want to jump right out and help them pay for

this.

 There's $4 million in there to buy

land.

 And I'll give you some comparisons.

The highest amount on any of those proposals is

to take care of the range with native species is

120,000 over 15 years. Compare that to spending

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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25 425,000 taking pictures.

Page 36

1 Compare that to spending 400, 500, 400,

200 millions of dollars letting people hunt.

Why the hell does it cost 338,000 to let

somebody go hunting on the refuge?

 MS. MATHER: Skip, you're about out of

time.

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

9 (Pages 33 to 36)

Page 33

1 potentially reducing

 wildlife ungulate grazing

 pressure in some areas.

 "If wolves where

 reintroduced to the refuge,

 their presence as another

 large ungulate would result

 in negligible to minor

 effects on riparian health.

 "Alternative B, the

 elimination of active

 predator removal and the

 incorporation of wolf

 management objectives on

 the refuge would provide

 predational pressure on

 wild ungulates, which would

 benefit riparian health by

 potentially reducing wild

 ungulate grazing pressure

 in some areas.

 "The effects of

 management objectives for

 bison and fur bearers would

 be the same."

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3

4

5

6

7

8

9

10

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Page 34

1 I would like to go to the budget,

expense, income. Some of you have a budget

sheet.

 Quick costs. They talk about costs to

this community on the refuge. 1.1 million acres

minus, say, 250,000 for the lake.

 An AUM in this country is worth 50

bucks, at least. That's costing you 8 to $10

million a year in income for this -- for the

surrounding communities of the lake.

 They said 8 to 10 million. That's at

50 bucks an AUM. That's what it's costing you

to let the cattle come off of that.

 We're a broke nation. We even try to

permit -- create something are becoming a

minority in this country, as you know.

 Some of you have a budget sheet. I

hope I can find mine before I run out of time.

 Hang on to that, would you? That might

give me time to get my glasses out.

 MS. MATHER: Well, we'll pause for a

minute.

 MR. OLSON: Thank you.

 MS. MATHER: Yes.

 MR. OLSON: If you look in the budget

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13

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15

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17

18

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22

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24

25

Page 35

1 sheet, be reminded that these are in thousands

of dollars.

 The bottom of the page of Alternative A

runs from 49 million. Alternative D goes 76

million. This is over a 15-year plan.

 I'd like to highlight a couple of

things. The biggest enemy that we have on this

is range and invasive species.

 We are getting covered up from the

north by thousands of acres of weeds. And you

guys that aren't familiar with that, I have

extensive experience with weeds on the CMR. I

don't know if I have time to talk about them.

 You know, if you look at them

proposals, they're going to spend $8 million

building a building. I'm sure you're going to

want to jump right out and help them pay for

this.

 There's $4 million in there to buy

land.

 And I'll give you some comparisons.

The highest amount on any of those proposals is

to take care of the range with native species is

120,000 over 15 years. Compare that to spending

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 425,000 taking pictures.

Page 36

1 Compare that to spending 400, 500, 400,

200 millions of dollars letting people hunt.

Why the hell does it cost 338,000 to let

somebody go hunting on the refuge?

 MS. MATHER: Skip, you're about out of

time.

 MR. OLSON: Okay.

 I don't know where to go with this

budget thing. It amazes me.

 Their number one responsibility, as

anybody is, has, that's a caretaker of range of

the land that we're hearing being used is to

take care of the range. That is not their

priority. And when they don't take care of the

range, they won't have a refuge.

 Look at the numbers. I guess that's

where I'll stop on the budget. It's astounding

to see.

 25 new employees for Alternative D.

There's new buildings proposed for Jordan,

Fort Peck.

 MS. MATHER: Time's up, Skip.

 Want that back?

 MR. OLSON: Sure.

 MS. MATHER: Thanks, Skip.

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

9 (Pages 33 to 36)

Page 33

1 potentially reducing

 wildlife ungulate grazing

 pressure in some areas.

 "If wolves where

 reintroduced to the refuge,

 their presence as another

 large ungulate would result

 in negligible to minor

 effects on riparian health.

 "Alternative B, the

 elimination of active

 predator removal and the

 incorporation of wolf

 management objectives on

 the refuge would provide

 predational pressure on

 wild ungulates, which would

 benefit riparian health by

 potentially reducing wild

 ungulate grazing pressure

 in some areas.

 "The effects of

 management objectives for

 bison and fur bearers would

 be the same."

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 34

1 I would like to go to the budget,

expense, income. Some of you have a budget

sheet.

 Quick costs. They talk about costs to

this community on the refuge. 1.1 million acres

minus, say, 250,000 for the lake.

 An AUM in this country is worth 50

bucks, at least. That's costing you 8 to $10

million a year in income for this -- for the

surrounding communities of the lake.

 They said 8 to 10 million. That's at

50 bucks an AUM. That's what it's costing you

to let the cattle come off of that.

 We're a broke nation. We even try to

permit -- create something are becoming a

minority in this country, as you know.

 Some of you have a budget sheet. I

hope I can find mine before I run out of time.

 Hang on to that, would you? That might

give me time to get my glasses out.

 MS. MATHER: Well, we'll pause for a

minute.

 MR. OLSON: Thank you.

 MS. MATHER: Yes.

 MR. OLSON: If you look in the budget

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 35

1 sheet, be reminded that these are in thousands

of dollars.

 The bottom of the page of Alternative A

runs from 49 million. Alternative D goes 76

million. This is over a 15-year plan.

 I'd like to highlight a couple of

things. The biggest enemy that we have on this

is range and invasive species.

 We are getting covered up from the

north by thousands of acres of weeds. And you

guys that aren't familiar with that, I have

extensive experience with weeds on the CMR. I

don't know if I have time to talk about them.

 You know, if you look at them

proposals, they're going to spend $8 million

building a building. I'm sure you're going to

want to jump right out and help them pay for

this.

 There's $4 million in there to buy

land.

 And I'll give you some comparisons.

The highest amount on any of those proposals is

to take care of the range with native species is

120,000 over 15 years. Compare that to spending

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25 425,000 taking pictures.

Page 36

1 Compare that to spending 400, 500, 400,

200 millions of dollars letting people hunt.

Why the hell does it cost 338,000 to let

somebody go hunting on the refuge?

 MS. MATHER: Skip, you're about out of

time.

 MR. OLSON: Okay.

 I don't know where to go with this

budget thing. It amazes me.

 Their number one responsibility, as

anybody is, has, that's a caretaker of range of

the land that we're hearing being used is to

take care of the range. That is not their

priority. And when they don't take care of the

range, they won't have a refuge.

 Look at the numbers. I guess that's

where I'll stop on the budget. It's astounding

to see.

 25 new employees for Alternative D.

There's new buildings proposed for Jordan,

Fort Peck.

 MS. MATHER: Time's up, Skip.

 Want that back?

 MR. OLSON: Sure.

 MS. MATHER: Thanks, Skip.

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 potentially reducing wild

 ungulate grazing pressure

 in some areas.

 "The effects of

 management objectives for

 bison and fur bearers would

 be the same."

19

20

21

22

23

24

25

Page 34

1 I would like to go to the budget,

expense, income. Some of you have a budget

sheet.

 Quick costs. They talk about costs to

this community on the refuge. 1.1 million acres

minus, say, 250,000 for the lake.

 An AUM in this country is worth 50

bucks, at least. That's costing you 8 to $10

million a year in income for this -- for the

surrounding communities of the lake.

 They said 8 to 10 million. That's at

50 bucks an AUM. That's what it's costing you

to let the cattle come off of that.

 We're a broke nation. We even try to

permit -- create something are becoming a

minority in this country, as you know.

 Some of you have a budget sheet. I

hope I can find mine before I run out of time.

 Hang on to that, would you? That might

give me time to get my glasses out.

 MS. MATHER: Well, we'll pause for a

minute.

 MR. OLSON: Thank you.

 MS. MATHER: Yes.

 MR. OLSON: If you look in the budget

2

3

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5

6

7

8

9

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25

 Th

land.

 An

The high

to take c

120,000 

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20

21

22

23

24

25 425,000 

1 Co

200 mill

Why the 

somebod

 M

time.

 MR

 I d

budget t

 Th

anybody 

the land 

take care 

priority. 

range, th

 Lo

where I'

to see.

 25 

There's n

Fort Pec

 M

 W

 MR

 M

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404 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 37

name is Karla

Christensen,

meday

a couple of

ered at

als

And if

e

he refuge

stated in

they

n raised

 when they

o

ng

here are

bison

Page 38

k.

well,

Commissioner.

s like

Page 39

1 Where are the bison going to come from?

Do we bring them out of the Park, which was

suggested, and have to fight with BANGS,

brucellosis for the next -- until we are all out

of business?

 I don't think so. We don't like that

situation.

 And that's my comments for now.

 MS. MATHER: Thanks, Jerry.

 JERRY COLDWELL: Thank you.

 MS. MATHER: Eric, with Dean.

 ERIC MILLER: Good afternoon. My name

is Eric Miller. It's E-R-I-C; M-I-L-L-E-R, and

I am from Jordan, though not originally.

 This is going to be pretty

straightforward.

 In your introduction -- or in your

vision statement -- and I'm going to paraphrase

this -- you state that you will use adaptive

management rooted in science to protect and

improve the health of the refuge, wildlife and

habitat.

 So my question to you today, you're

talking about making significant wildlife and

habitat changes through all four of your

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 40

1 proposed actions that will alter five regimes,

livestock grazing and water dispersal systems.

 So, with those comments, do you have

any local or regional short grass parent

prairie-based research documentation from

unbiased articles or university research

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

10 (Pages 37 to 40)

Page 37

1 Karla's up, with Jerry on deck.

 KARLA CHRISTENSEN: My name is Karla

Christensen. Karla, K-A-R-L-A, and Christensen,

C-H-R-I-S-T-E-N-S-E-N.

 My concern is the bison that someday

may be running on our range. I have a couple of

questions that I would like to be answered at

sometime today.

 One of them is, all of the proposals

that are in this book talk about bison. And if

they are restored to areas outside of the

refuge, and the animals migrate onto the refuge

as State-managed wildlife species, as stated in

the book on Page 92 and Page 93.

 Now, my question is, where are they

expected to migrate from?

 My second question is, can bison raised

as domestic livestock become wildlife when they

wander onto the CMR?

 And then my third question is, do

domestic bison as livestock have grazing

allotments on the CMR? And if so, where are

those grazing allotments located?

 Okay, I'm really concerned that bison

are going to slip in the back door.

2

3

4

5

6

7

8

9

10

11

12

13

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15

16

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Page 38

1 Thank you.

 MS. MATHER: Thanks, Karla.

 Jerry, and then Eric Miller on deck.

 JERRY COLDWELL: Jerry Coldwell,

C-O-L-D-W-E-L-L. Rancher, County Commissioner.

 How are you guys doing? It sounds like

you've had a pretty rough go part of the time.

 What I've got to say is in the last

10 years, this county has lost over almost half

its population since the CMR was changed from a

range to a refuge and permits were cut down.

 I have some questions. Number one,

I'll go with the bison, too.

 Are you going -- if they are on the

game range, are you going to fence them into it?

And if not, who's going to -- how are we going

to manage these to keep these bison out of our

cattle herds, or are we going to be able to?

 Another question I have, with your

prescriptive grazing, you're talking about

taking these fences out and impoundments of

water out of the range, or refuge.

 How will the people be able to catch up

with their cattle on the prescriptive grazing if

the fences are gone, okay?

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 39

1 Where are the bison going to come from?

Do we bring them out of the Park, which was

suggested, and have to fight with BANGS,

brucellosis for the next -- until we are all out

of business?

 I don't think so. We don't like that

situation.

 And that's my comments for now.

 MS. MATHER: Thanks, Jerry.

 JERRY COLDWELL: Thank you.

 MS. MATHER: Eric, with Dean.

 ERIC MILLER: Good afternoon. My name

is Eric Miller. It's E-R-I-C; M-I-L-L-E-R, and

I am from Jordan, though not originally.

 This is going to be pretty

straightforward.

 In your introduction -- or in your

vision statement -- and I'm going to paraphrase

this -- you state that you will use adaptive

management rooted in science to protect and

improve the health of the refuge, wildlife and

habitat.

 So my question to you today, you're

talking about making significant wildlife and

habitat changes through all four of your

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 40

1 proposed actions that will alter five regimes,

livestock grazing and water dispersal systems.

 So, with those comments, do you have

any local or regional short grass parent

prairie-based research documentation from

unbiased articles or university research

professionals that has been refereed and peer

reviewed journal publications that you can

provide to this community and the surrounding

communities that you're going to impact by these

changes?

 Thank you.

 MS. MATHER: Thanks, Eric.

 ERIC MILLER: Mm-hmm.

 MS. MATHER: Dean, with Mark Good on

deck.

 DEAN ROGGE: Has the community

referenced the Garfield County Growth Policy as

required by the state of Montana, or any of the

other five counties' policies surrounding the

state of Montana?

 THE REPORTER: Can you please spell

your last name for me.

 MR. ROGGE: R-O-G-G-E.

 And regarding the use of sentinel plant

2

3

4

5

6

7

8

9

10

11

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13

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

10 (Pages 37 to 40)

Page 37

1 Karla's up, with Jerry on deck.

 KARLA CHRISTENSEN: My name is Karla

Christensen. Karla, K-A-R-L-A, and Christensen,

C-H-R-I-S-T-E-N-S-E-N.

 My concern is the bison that someday

may be running on our range. I have a couple of

questions that I would like to be answered at

sometime today.

 One of them is, all of the proposals

that are in this book talk about bison. And if

they are restored to areas outside of the

refuge, and the animals migrate onto the refuge

as State-managed wildlife species, as stated in

the book on Page 92 and Page 93.

 Now, my question is, where are they

expected to migrate from?

 My second question is, can bison raised

as domestic livestock become wildlife when they

wander onto the CMR?

 And then my third question is, do

domestic bison as livestock have grazing

allotments on the CMR? And if so, where are

those grazing allotments located?

 Okay, I'm really concerned that bison

are going to slip in the back door.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 38

1 Thank you.

 MS. MATHER: Thanks, Karla.

 Jerry, and then Eric Miller on deck.

 JERRY COLDWELL: Jerry Coldwell,

C-O-L-D-W-E-L-L. Rancher, County Commissioner.

 How are you guys doing? It sounds like

you've had a pretty rough go part of the time.

 What I've got to say is in the last

10 years, this county has lost over almost half

its population since the CMR was changed from a

range to a refuge and permits were cut down.

 I have some questions. Number one,

I'll go with the bison, too.

 Are you going -- if they are on the

game range, are you going to fence them into it?

And if not, who's going to -- how are we going

to manage these to keep these bison out of our

cattle herds, or are we going to be able to?

 Another question I have, with your

prescriptive grazing, you're talking about

taking these fences out and impoundments of

water out of the range, or refuge.

 How will the people be able to catch up

with their cattle on the prescriptive grazing if

the fences are gone, okay?

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 39

1 Where are the bison going to come from?

Do we bring them out of the Park, which was

suggested, and have to fight with BANGS,

brucellosis for the next -- until we are all out

of business?

 I don't think so. We don't like that

situation.

 And that's my comments for now.

 MS. MATHER: Thanks, Jerry.

 JERRY COLDWELL: Thank you.

 MS. MATHER: Eric, with Dean.

 ERIC MILLER: Good afternoon. My name

is Eric Miller. It's E-R-I-C; M-I-L-L-E-R, and

I am from Jordan, though not originally.

 This is going to be pretty

straightforward.

 In your introduction -- or in your

vision statement -- and I'm going to paraphrase

this -- you state that you will use adaptive

management rooted in science to protect and

improve the health of the refuge, wildlife and

habitat.

 So my question to you today, you're

talking about making significant wildlife and

habitat changes through all four of your

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 40

1 proposed actions that will alter five regimes,

livestock grazing and water dispersal systems.

 So, with those comments, do you have

any local or regional short grass parent

prairie-based research documentation from

unbiased articles or university research

professionals that has been refereed and peer

reviewed journal publications that you can

provide to this community and the surrounding

communities that you're going to impact by these

changes?

 Thank you.

 MS. MATHER: Thanks, Eric.

 ERIC MILLER: Mm-hmm.

 MS. MATHER: Dean, with Mark Good on

deck.

 DEAN ROGGE: Has the community

referenced the Garfield County Growth Policy as

required by the state of Montana, or any of the

other five counties' policies surrounding the

state of Montana?

 THE REPORTER: Can you please spell

your last name for me.

 MR. ROGGE: R-O-G-G-E.

 And regarding the use of sentinel plant

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

wander onto the CMR?

 And then my third question is, do

domestic bison as livestock have grazing

allotments on the CMR? And if so, where are

those grazing allotments located?

 Okay, I'm really concerned that bison

are going to slip in the back door.

19

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Page 38

1 Thank you.

 MS. MATHER: Thanks, Karla.

 Jerry, and then Eric Miller on deck.

 JERRY COLDWELL: Jerry Coldwell,

C-O-L-D-W-E-L-L. Rancher, County Commissioner.

 How are you guys doing? It sounds like

you've had a pretty rough go part of the time.

 What I've got to say is in the last

10 years, this county has lost over almost half

its population since the CMR was changed from a

range to a refuge and permits were cut down.

 I have some questions. Number one,

I'll go with the bison, too.

 Are you going -- if they are on the

game range, are you going to fence them into it?

And if not, who's going to -- how are we going

to manage these to keep these bison out of our

cattle herds, or are we going to be able to?

 Another question I have, with your

prescriptive grazing, you're talking about

taking these fences out and impoundments of

water out of the range, or refuge.

 How will the people be able to catch up

with their cattle on the prescriptive grazing if

the fences are gone, okay?

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this -- you st

management 

improve the 

habitat.

 So my 

talking abou

habitat chang

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20

21

22

23

24

25

1 proposed act

livestock gra

 So, wit

any local or 

prairie-based 

unbiased arti

professionals 

reviewed jou

provide to th

communities 

changes?

 Thank 

 MS. M

 ERIC M

 MS. M

deck.

 DEAN 

referenced th

required by t

other five co

state of Mon

 THE R

your last nam

 MR. R

 And re

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VOLUME 2, Chapter 4—Public Hearing Testimony 405

Page 41

th, who

e else has this

 are the

s for

e historical

ted plants?

d, with Janelle on

s Mark Good. I'm

Montana

s a

nds are managed

and Management

 that the

t on the refuge

n of wildlife.

 don't like

but I don't

Maybe not

icans across

Montanans.

 across the

Page 42

h eastern part

e state, move

th the west

by most measures,

nk there's

s you have seen

Page 43

1 about 100,000. I might be wrong about that.

But, you know, that's a significant number, and

I haven't seen any economical calculations, but

I bet it would be more than what most people

think.

 But I also want to talk about some of

the other uses that I don't think get a lot of

talk for which our refuge is supposed be

managed, and that's things like wildlife viewing

and environmental education and interpretation.

 I mean, you can look at a place like

Slippery Ann, where you do get a lot of people

showing up.

 Wildlife viewing is increasingly

popular. I think things like -- which is

increasing interest in like history, prehistory,

paleontology, and even hiking. And I think that

more could be done to attract people to some of

these gateway communities which would help

them.

 And I know that that's, you know, maybe

in a small way, but maybe that's an important

way, too, to help stabilize local communities so

that they can keep schools and other things and

other services.

2

3

4

5

6

7

8

9

10

11

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13

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24

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Page 44

1 We put out a book every year called

"Wilderness Walks". We're trying to attract

people to places across the state.

 And what I keep finding when -- we're

also making presentations around. Particularly

I know some people in the eastern part of the

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

11 (Pages 41 to 44)

Page 41

1 surveys for monitoring range health, who

developed the protocol, and where else has this

protocol been followed, and what are the

results, and are they long-term?

 And is there a scientific basis for

understanding and determining the historical

presence and absence of the selected plants?

 MS. MATHER: Mark Good, with Janelle on

deck.

 MARK GOOD: My name is Mark Good. I'm

from Great Falls. I work for the Montana

Wilderness Association.

 It's my understanding that as a

National Wildlife Refuge, that lands are managed

differently from, say, Bureau of Land Management

lands or Forest Service lands, and that the

guiding principle for management on the refuge

is the enhancement and protection of wildlife.

 Now, I know a lot of people don't like

that; they wish it where different, but I don't

think that's going to change.

 Refuges are pretty popular. Maybe not

here, but they're popular by Americans across

the country, and I think by most Montanans.

 What I have also noticed, is across the

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 42

1 state, it seems the economies, both eastern part

of the state and western part of the state, move

in kind of divergent directions with the west

growing; the economy's growing by most measures,

and the east declining. I don't think there's

anything mysterious about that, as you have seen

agricultural getting -- farms and ranches

getting bigger and bigger, more mechanized,

hiring fewer and fewer people; easier access to

commercial places like Billings and so on. I

don't think that's a trend that's going to

change.

 Now, that's not to suggest that

agriculture's not important. It is, and it will

continue to be, and it's not to be insensitive

to those who will use this refuge for which it's

important.

 But I do want to make the point that

the refuge also contributes, makes an economic

contribution to local communities.

 First, their staff. And it's kind of

direct through employment and surfaces in

products they purchase.

 Indirect, you could look at things like

hunting. I think they're figuring, the EIS was

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 43

1 about 100,000. I might be wrong about that.

But, you know, that's a significant number, and

I haven't seen any economical calculations, but

I bet it would be more than what most people

think.

 But I also want to talk about some of

the other uses that I don't think get a lot of

talk for which our refuge is supposed be

managed, and that's things like wildlife viewing

and environmental education and interpretation.

 I mean, you can look at a place like

Slippery Ann, where you do get a lot of people

showing up.

 Wildlife viewing is increasingly

popular. I think things like -- which is

increasing interest in like history, prehistory,

paleontology, and even hiking. And I think that

more could be done to attract people to some of

these gateway communities which would help

them.

 And I know that that's, you know, maybe

in a small way, but maybe that's an important

way, too, to help stabilize local communities so

that they can keep schools and other things and

other services.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 44

1 We put out a book every year called

"Wilderness Walks". We're trying to attract

people to places across the state.

 And what I keep finding when -- we're

also making presentations around. Particularly

I know some people in the eastern part of the

state are surprised to learn about some the

prairie landscapes that we have, and that

they're much more diverse and interesting than

what they thought.

 So I just offer -- make an offer to

work with the refuge or anybody else who's

interested in trying to help encourage that kind

of use of this refuge and, again, as a way to I

think help local communities.

 MS. MATHER: Thanks, Mark.

 Janelle, with Jeanne Kilegard on deck.

 JANELLE HOLDEN: Janelle Holden.

J-A-N-E-L-L-E; H-O-L-D-E-N. I'm with the

Wilderness Society.

 It's good to hear so many people here

today who are very passionate about public

lands. I'm very passionate about public lands

myself, as is the organization that I work for.

 So, I'm going to say something that's

2

3

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

11 (Pages 41 to 44)

Page 41

1 surveys for monitoring range health, who

developed the protocol, and where else has this

protocol been followed, and what are the

results, and are they long-term?

 And is there a scientific basis for

understanding and determining the historical

presence and absence of the selected plants?

 MS. MATHER: Mark Good, with Janelle on

deck.

 MARK GOOD: My name is Mark Good. I'm

from Great Falls. I work for the Montana

Wilderness Association.

 It's my understanding that as a

National Wildlife Refuge, that lands are managed

differently from, say, Bureau of Land Management

lands or Forest Service lands, and that the

guiding principle for management on the refuge

is the enhancement and protection of wildlife.

 Now, I know a lot of people don't like

that; they wish it where different, but I don't

think that's going to change.

 Refuges are pretty popular. Maybe not

here, but they're popular by Americans across

the country, and I think by most Montanans.

 What I have also noticed, is across the

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 42

1 state, it seems the economies, both eastern part

of the state and western part of the state, move

in kind of divergent directions with the west

growing; the economy's growing by most measures,

and the east declining. I don't think there's

anything mysterious about that, as you have seen

agricultural getting -- farms and ranches

getting bigger and bigger, more mechanized,

hiring fewer and fewer people; easier access to

commercial places like Billings and so on. I

don't think that's a trend that's going to

change.

 Now, that's not to suggest that

agriculture's not important. It is, and it will

continue to be, and it's not to be insensitive

to those who will use this refuge for which it's

important.

 But I do want to make the point that

the refuge also contributes, makes an economic

contribution to local communities.

 First, their staff. And it's kind of

direct through employment and surfaces in

products they purchase.

 Indirect, you could look at things like

hunting. I think they're figuring, the EIS was

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 43

1 about 100,000. I might be wrong about that.

But, you know, that's a significant number, and

I haven't seen any economical calculations, but

I bet it would be more than what most people

think.

 But I also want to talk about some of

the other uses that I don't think get a lot of

talk for which our refuge is supposed be

managed, and that's things like wildlife viewing

and environmental education and interpretation.

 I mean, you can look at a place like

Slippery Ann, where you do get a lot of people

showing up.

 Wildlife viewing is increasingly

popular. I think things like -- which is

increasing interest in like history, prehistory,

paleontology, and even hiking. And I think that

more could be done to attract people to some of

these gateway communities which would help

them.

 And I know that that's, you know, maybe

in a small way, but maybe that's an important

way, too, to help stabilize local communities so

that they can keep schools and other things and

other services.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 44

1 We put out a book every year called

"Wilderness Walks". We're trying to attract

people to places across the state.

 And what I keep finding when -- we're

also making presentations around. Particularly

I know some people in the eastern part of the

state are surprised to learn about some the

prairie landscapes that we have, and that

they're much more diverse and interesting than

what they thought.

 So I just offer -- make an offer to

work with the refuge or anybody else who's

interested in trying to help encourage that kind

of use of this refuge and, again, as a way to I

think help local communities.

 MS. MATHER: Thanks, Mark.

 Janelle, with Jeanne Kilegard on deck.

 JANELLE HOLDEN: Janelle Holden.

J-A-N-E-L-L-E; H-O-L-D-E-N. I'm with the

Wilderness Society.

 It's good to hear so many people here

today who are very passionate about public

lands. I'm very passionate about public lands

myself, as is the organization that I work for.

 So, I'm going to say something that's

2

3

4

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7

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 Now, I know a lot of people dont like

that; they wish it where different, but I don't

think that's going to change.

 Refuges are pretty popular. Maybe not

here, but they're popular by Americans across

the country, and I think by most Montanans.

 What I have also noticed, is across the

19

20

21

22

23

24

25

Page 42

1 state, it seems the economies, both eastern part

of the state and western part of the state, move

in kind of divergent directions with the west

growing; the economy's growing by most measures,

and the east declining. I don't think there's

anything mysterious about that, as you have seen

agricultural getting -- farms and ranches

getting bigger and bigger, more mechanized,

hiring fewer and fewer people; easier access to

commercial places like Billings and so on. I

don't think that's a trend that's going to

change.

 Now, that's not to suggest that

agriculture's not important. It is, and it will

continue to be, and it's not to be insensitive

to those who will use this refuge for which it's

important.

 But I do want to make the point that

the refuge also contributes, makes an economic

contribution to local communities.

 First, their staff. And it's kind of

direct through employment and surfaces in

products they purchase.

 Indirect, you could look at things like

hunting. I think they're figuring, the EIS was

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

these ga

them.

 An

in a sma

way, too

that they 

other ser

19

20

21

22

23

24

25

1 W

"Wilder

people t

 An

also mak

I know s

state are 

prairie l

they're m

what the

 So 

work wi

intereste

of use o

think he

 M

 Jan

 JA

J-A-N-E

Wildern

 It's 

today w

lands. I

myself, 

 So

2

3

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23

24

25
406 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 45

een

ublic

r me to

he 1.1

are

ou own,

nd that's a

ntire CCP

k the

excellent

e of

 of the

ness, the

 proposed

o keep

d perhaps

areas are

em in the

na.

orld.

Page 46

.

e.

Page 47

1 records for the past 6,000 years that says what

these lands looked like?

 You know, as we go, progress comes

change. And if we're going to go backwards in

time, I don't see how any of us are going to

benefit from that.

 And another thing, too, you didn't

address climate change 6,000 years ago, or even

back in 1935, so I would like to see some more

research or some more current monitoring to help

with this CCP.

 And then there's another one in

Chapter 3. It says 50% of the plants species

you are to maintain, and I was wondering how you

were going to have these plant species increase

in size when you don't have any control of your

wildlife?

 I work for a Conservation District, and

we just did a planting in a creek bottom of over

1,000 trees, and we did not fence this out

except for the cattle were not allowed to graze

in this, and we're lucky we got two trees left

because of the wildlife damage. So, I just

don't see no emphasis on any of that.

 The other thing, I notice wolves are

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 48

1 listed on both the endangered species and also

the reintroduced species, and I was wondering

how come both? Either they are endangered, or

that was just a reintroduction of species.

 And I have lots and lots of other

comments, but I'll send them in writing.

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

12 (Pages 45 to 48)

Page 45

1 fairly different from what folks have been

saying here today.

 I feel fairly wealthy because of public

lands. I live in town, and it's a way for me to

feel like I own a piece of America. The 1.1

million acres of the CMR is a pretty rare

treasure, and it's one that I own and you own,

and everyone else in America owns, and that's a

pretty amazing concept.

 So, I wanted to say today that, I

haven't been able to get through the entire CCP

yet, but what I have read so far, I think the

Fish & Wildlife Services has done an excellent

job. I think they provided a good range of

alternatives to consider.

 We're not very happy with some of the

proposals that they made about wilderness, the

boundaries that they've changed in the proposed

alternative, so we're asking for them to keep

the proposal that they have already and perhaps

expand it, because prairie wilderness areas are

very rare. There's not very many of them in the

country.

 And this is a real gem for Montana.

It's a gem for the nation, and for the world.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 46

1 So, that's why I'm here today. Thanks.

 MS. MATHER: Thanks, Janelle.

 Jeanne Kilegard.

 JEANNE KIRKEGARD: It's

K-I-R-K-E-G-A-R-D.

 I just have a couple of questions.

 On Page 24, and then there's other --

on Page 24 through 25, and there's several other

places, it states that you have a lot of

emphasis on the assessment that was done by

Murray of 1935.

 And I was just wondering why you do not

use more recent assessments or monitoring that

you have done and were dating clear back to

1935?

 Then also in Chapter 3 on Page 67, it

says that,

 "This alternative, which

 is D, the preferred, calls

 strongly for evolutionary

 forces of fire and grazing

 by wildlife that shaped

 this landscape during the

 past 6,000 years."

 And I was wondering, do we have any

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 47

1 records for the past 6,000 years that says what

these lands looked like?

 You know, as we go, progress comes

change. And if we're going to go backwards in

time, I don't see how any of us are going to

benefit from that.

 And another thing, too, you didn't

address climate change 6,000 years ago, or even

back in 1935, so I would like to see some more

research or some more current monitoring to help

with this CCP.

 And then there's another one in

Chapter 3. It says 50% of the plants species

you are to maintain, and I was wondering how you

were going to have these plant species increase

in size when you don't have any control of your

wildlife?

 I work for a Conservation District, and

we just did a planting in a creek bottom of over

1,000 trees, and we did not fence this out

except for the cattle were not allowed to graze

in this, and we're lucky we got two trees left

because of the wildlife damage. So, I just

don't see no emphasis on any of that.

 The other thing, I notice wolves are

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 48

1 listed on both the endangered species and also

the reintroduced species, and I was wondering

how come both? Either they are endangered, or

that was just a reintroduction of species.

 And I have lots and lots of other

comments, but I'll send them in writing.

 Thank you.

 MS. MATHER: I'm having trouble reading

the last one. Somebody from the "Jordan

Tribune". Is that you?

 You can just state your name and spell

it.

 JANET GUPTILL: Janet Guptill with

"Jordan Tribune".

 I would like to ask the question, that

most of you people that are here from Wilderness

Society and from the U.S. Fish Wildlife are on

payroll. The rest of us are here as

volunteers.

 And there's quite a difference in the

time and the effort that can be put forth from

people who are on payroll versus people who are

trying to make a living out here.

 I concur with the ranchers and those

who have got up and stated that we should have

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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19

20

21

22

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24

25

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

12 (Pages 45 to 48)

Page 45

1 fairly different from what folks have been

saying here today.

 I feel fairly wealthy because of public

lands. I live in town, and it's a way for me to

feel like I own a piece of America. The 1.1

million acres of the CMR is a pretty rare

treasure, and it's one that I own and you own,

and everyone else in America owns, and that's a

pretty amazing concept.

 So, I wanted to say today that, I

haven't been able to get through the entire CCP

yet, but what I have read so far, I think the

Fish & Wildlife Services has done an excellent

job. I think they provided a good range of

alternatives to consider.

 We're not very happy with some of the

proposals that they made about wilderness, the

boundaries that they've changed in the proposed

alternative, so we're asking for them to keep

the proposal that they have already and perhaps

expand it, because prairie wilderness areas are

very rare. There's not very many of them in the

country.

 And this is a real gem for Montana.

It's a gem for the nation, and for the world.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 46

1 So, that's why I'm here today. Thanks.

 MS. MATHER: Thanks, Janelle.

 Jeanne Kilegard.

 JEANNE KIRKEGARD: It's

K-I-R-K-E-G-A-R-D.

 I just have a couple of questions.

 On Page 24, and then there's other --

on Page 24 through 25, and there's several other

places, it states that you have a lot of

emphasis on the assessment that was done by

Murray of 1935.

 And I was just wondering why you do not

use more recent assessments or monitoring that

you have done and were dating clear back to

1935?

 Then also in Chapter 3 on Page 67, it

says that,

 "This alternative, which

 is D, the preferred, calls

 strongly for evolutionary

 forces of fire and grazing

 by wildlife that shaped

 this landscape during the

 past 6,000 years."

 And I was wondering, do we have any

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 47

1 records for the past 6,000 years that says what

these lands looked like?

 You know, as we go, progress comes

change. And if we're going to go backwards in

time, I don't see how any of us are going to

benefit from that.

 And another thing, too, you didn't

address climate change 6,000 years ago, or even

back in 1935, so I would like to see some more

research or some more current monitoring to help

with this CCP.

 And then there's another one in

Chapter 3. It says 50% of the plants species

you are to maintain, and I was wondering how you

were going to have these plant species increase

in size when you don't have any control of your

wildlife?

 I work for a Conservation District, and

we just did a planting in a creek bottom of over

1,000 trees, and we did not fence this out

except for the cattle were not allowed to graze

in this, and we're lucky we got two trees left

because of the wildlife damage. So, I just

don't see no emphasis on any of that.

 The other thing, I notice wolves are

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 48

1 listed on both the endangered species and also

the reintroduced species, and I was wondering

how come both? Either they are endangered, or

that was just a reintroduction of species.

 And I have lots and lots of other

comments, but I'll send them in writing.

 Thank you.

 MS. MATHER: I'm having trouble reading

the last one. Somebody from the "Jordan

Tribune". Is that you?

 You can just state your name and spell

it.

 JANET GUPTILL: Janet Guptill with

"Jordan Tribune".

 I would like to ask the question, that

most of you people that are here from Wilderness

Society and from the U.S. Fish Wildlife are on

payroll. The rest of us are here as

volunteers.

 And there's quite a difference in the

time and the effort that can be put forth from

people who are on payroll versus people who are

trying to make a living out here.

 I concur with the ranchers and those

who have got up and stated that we should have

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

alternative, so were asking for them to keep

the proposal that they have already and perhaps

expand it, because prairie wilderness areas are

very rare. There's not very many of them in the

country.

 And this is a real gem for Montana.

It's a gem for the nation, and for the world.

19

20

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Page 46

1 So, that's why I'm here today. Thanks.

 MS. MATHER: Thanks, Janelle.

 Jeanne Kilegard.

 JEANNE KIRKEGARD: It's

K-I-R-K-E-G-A-R-D.

 I just have a couple of questions.

 On Page 24, and then there's other --

on Page 24 through 25, and there's several other

places, it states that you have a lot of

emphasis on the assessment that was done by

Murray of 1935.

 And I was just wondering why you do not

use more recent assessments or monitoring that

you have done and were dating clear back to

1935?

 Then also in Chapter 3 on Page 67, it

says that,

 "This alternative, which

 is D, the preferred, calls

 strongly for evolutionary

 forces of fire and grazing

 by wildlife that shaped

 this landscape during the

 past 6,000 years."

 And I was wondering, do we have any

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we just did a 

1,000 trees, a

except for th

in this, and w

because of th

don't see no e

 The oth

19

20

21

22

23

24

25

1 listed on both 

the reintrodu

how come bo

that was just 

 And I h

comments, b

 Thank 

 MS. M

the last one. 

Tribune". Is 

 You ca

it.

 JANET 

"Jordan Trib

 I would 

most of you p

Society and f

payroll. The 

volunteers.

 And the

time and the 

people who a

trying to mak

 I concu

who have go

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VOLUME 2, Chapter 4—Public Hearing Testimony 407

Page 49

e A, or less

 to do is

tten comments,

n Tribune" so

ent.

.

list.

omment?

riink,

at hasn't

the left

e

Page 50

 to grab all

ll make note of

ou.

Page 51

1 We need those roads left open so we can

continue to use them. And as a rancher, we do

need them open for going out and riding for our

cattle and using the horse trailer to haul our

horses and things,. And so it's very important

that we keep the public roads open to the

public.

 MS. MATHER: Okay.

 One more?

 JEANNE KIRKEGARD: I just have a

request.

 I was just going to request if we could

have an extension of 30 days on this CCP to

review it? I received mine like a month late

compared to everybody else in my area that

received it, and that's --

 MS. MATHER: Any other comments or

questions?

 Oh, one more.

 JOAN D. WATSON: My name of is Joan D.

Watson, W-A-T-S-O-N.

 My only comment is in reading the

scoping results from quite a long time ago after

they had the scoping meetings, and Barron

referred to this a little bit in his opening

2

3

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5

6

7

8

9

10

11

12

13

14

15

16

17

18

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21

22

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24

25

Page 52

1 comments about the 24,000 responses that were

received in writing.

 There where 23,867 of them. 81 of them

came from individuals. So, that is the Earl

Isaacs, the Leo Coles, the Joan Gibsons that

took time to sit and write a letter.

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

13 (Pages 49 to 52)

Page 49

1 no change and go with Alternative A, or less

than that.

 The other thing I would like to do is

ask that those who have made written comments,

please bring a copy by the "Jordan Tribune" so

that we can get your exact comment.

 Thank you.

 MS. MATHER: Thank you.

 Okay, that is the end of my list.

 Does anybody else have a comment?

 Come on up.

 RALPH GRIINK: Ralph Griink,

G-R-I-I-N-K.

 I only have one question that hasn't

been asked.

 On Page 66, halfway down the left

column, it says,

 "Prescriptive Livestock

 Grazing."

 "We will construct

 boundary fences where

 absent, potentially expand

 boundary fences to include

 partner lands that share

 the objective and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 50

1 strategies."

 So, this means you're going to grab all

the BLM land there?

 MR. CRAWFORD: We will make note of

that and answer it here in a bit.

 RALPH GRIINK: Thank you.

 MS. MATHER: Thanks, Ralph.

 Anybody else want to comment?

 Come on up.

 FLOSSIE PHIPPS: Flossie,

F-L-O-S-S-I-E; P-H-I-P-P-S.

 My concern is the public land need a

lot of roads and needs the roads left open so

the public can use them.

 If it goes through private property,

the private property owner should remember he

got to his place on the roads -- on these roads,

and he knew that it was public land beyond the

road before he ever bought his place.

 So, I think they have no right to close

those roads going through their land into public

land because that is for the public to use.

 The roads have been there long before

the landowner was, or before any of us ever

were, these roads have been there.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 51

1 We need those roads left open so we can

continue to use them. And as a rancher, we do

need them open for going out and riding for our

cattle and using the horse trailer to haul our

horses and things,. And so it's very important

that we keep the public roads open to the

public.

 MS. MATHER: Okay.

 One more?

 JEANNE KIRKEGARD: I just have a

request.

 I was just going to request if we could

have an extension of 30 days on this CCP to

review it? I received mine like a month late

compared to everybody else in my area that

received it, and that's --

 MS. MATHER: Any other comments or

questions?

 Oh, one more.

 JOAN D. WATSON: My name of is Joan D.

Watson, W-A-T-S-O-N.

 My only comment is in reading the

scoping results from quite a long time ago after

they had the scoping meetings, and Barron

referred to this a little bit in his opening

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 52

1 comments about the 24,000 responses that were

received in writing.

 There where 23,867 of them. 81 of them

came from individuals. So, that is the Earl

Isaacs, the Leo Coles, the Joan Gibsons that

took time to sit and write a letter.

 23 of those comments came from public

agencies. Five of those where the surrounding

counties.

 There where three Conservation District

groups involved in that. Our own was the only

local one.

 So that's 8 out of the 23 that had

local community interest at heart.

 The other 23,753, I believe is the

number, was a single form letter sent out by

members of the Wilderness Society.

 So, I'm encouraging every one locally

here to write a letter or have some input into a

public letter and get as many people to sign it

as we can. That apparently stood out in their

mind, and obviously it would.

 And guess where the weight is going to

go? It is going to go to the squeaky wheel.

 So, I would encourage every one of you

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

13 (Pages 49 to 52)

Page 49

1 no change and go with Alternative A, or less

than that.

 The other thing I would like to do is

ask that those who have made written comments,

please bring a copy by the "Jordan Tribune" so

that we can get your exact comment.

 Thank you.

 MS. MATHER: Thank you.

 Okay, that is the end of my list.

 Does anybody else have a comment?

 Come on up.

 RALPH GRIINK: Ralph Griink,

G-R-I-I-N-K.

 I only have one question that hasn't

been asked.

 On Page 66, halfway down the left

column, it says,

 "Prescriptive Livestock

 Grazing."

 "We will construct

 boundary fences where

 absent, potentially expand

 boundary fences to include

 partner lands that share

 the objective and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 50

1 strategies."

 So, this means you're going to grab all

the BLM land there?

 MR. CRAWFORD: We will make note of

that and answer it here in a bit.

 RALPH GRIINK: Thank you.

 MS. MATHER: Thanks, Ralph.

 Anybody else want to comment?

 Come on up.

 FLOSSIE PHIPPS: Flossie,

F-L-O-S-S-I-E; P-H-I-P-P-S.

 My concern is the public land need a

lot of roads and needs the roads left open so

the public can use them.

 If it goes through private property,

the private property owner should remember he

got to his place on the roads -- on these roads,

and he knew that it was public land beyond the

road before he ever bought his place.

 So, I think they have no right to close

those roads going through their land into public

land because that is for the public to use.

 The roads have been there long before

the landowner was, or before any of us ever

were, these roads have been there.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 51

1 We need those roads left open so we can

continue to use them. And as a rancher, we do

need them open for going out and riding for our

cattle and using the horse trailer to haul our

horses and things,. And so it's very important

that we keep the public roads open to the

public.

 MS. MATHER: Okay.

 One more?

 JEANNE KIRKEGARD: I just have a

request.

 I was just going to request if we could

have an extension of 30 days on this CCP to

review it? I received mine like a month late

compared to everybody else in my area that

received it, and that's --

 MS. MATHER: Any other comments or

questions?

 Oh, one more.

 JOAN D. WATSON: My name of is Joan D.

Watson, W-A-T-S-O-N.

 My only comment is in reading the

scoping results from quite a long time ago after

they had the scoping meetings, and Barron

referred to this a little bit in his opening

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 52

1 comments about the 24,000 responses that were

received in writing.

 There where 23,867 of them. 81 of them

came from individuals. So, that is the Earl

Isaacs, the Leo Coles, the Joan Gibsons that

took time to sit and write a letter.

 23 of those comments came from public

agencies. Five of those where the surrounding

counties.

 There where three Conservation District

groups involved in that. Our own was the only

local one.

 So that's 8 out of the 23 that had

local community interest at heart.

 The other 23,753, I believe is the

number, was a single form letter sent out by

members of the Wilderness Society.

 So, I'm encouraging every one locally

here to write a letter or have some input into a

public letter and get as many people to sign it

as we can. That apparently stood out in their

mind, and obviously it would.

 And guess where the weight is going to

go? It is going to go to the squeaky wheel.

 So, I would encourage every one of you

2

3

4

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6

7

8

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10

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 Grazing.

 "We will construct

 boundary fences where

 absent, potentially expand

 boundary fences to include

 partner lands that share

 the objective and

19

20

21

22

23

24

25

Page 50

1 strategies."

 So, this means you're going to grab all

the BLM land there?

 MR. CRAWFORD: We will make note of

that and answer it here in a bit.

 RALPH GRIINK: Thank you.

 MS. MATHER: Thanks, Ralph.

 Anybody else want to comment?

 Come on up.

 FLOSSIE PHIPPS: Flossie,

F-L-O-S-S-I-E; P-H-I-P-P-S.

 My concern is the public land need a

lot of roads and needs the roads left open so

the public can use them.

 If it goes through private property,

the private property owner should remember he

got to his place on the roads -- on these roads,

and he knew that it was public land beyond the

road before he ever bought his place.

 So, I think they have no right to close

those roads going through their land into public

land because that is for the public to use.

 The roads have been there long before

the landowner was, or before any of us ever

were, these roads have been there.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

 Oh

 JO

Watson, 

 My 

scoping 

they had 

referred 

19

20

21

22

23

24

25

1 commen

received 

 Th

came fro

Isaacs, t

took tim

 23 

agencies

counties

 Th

groups i

local on

 So 

local com

 Th

number, 

member

 So

here to w

public le

as we ca

mind, an

 An

go? It is 

 So

2

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408 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 53

A". Sign

how

ies. And

n the ball,

Make

ough

l state

e can get

up with a

e

d every

ive them to

 off on

Board,

 those

n

hn

les, the

Page 54

nput.

an get a

. Voice

e you to

Page 55

1 But if you want to, I'd say go with

Alternative R. Let the ranchers run it. We'd

be a lot cheaper. Hell, we have do. We can't

afford these millions. We don't make that

much.

 That's all I have.

 MS. MATHER: Thank you.

 Okay, I'm going to turn it over to

Barron to respond to questions you've heard.

 MR. CRAWFORD: Bill and I have this

range of activities. He takes the hard ones.

I'm just trying to figure out which ones Bill's

going to get.

 Let's see. I was trying read through

my notes here real quick and see what kind of

questions we got.

 State lands. Are we going to protect?

Page 329.

 Basically when we met with the DNRC,

and we were talking about limited prescriptive

grazing, there was a comment from the State that

there's a possibility that those State lands

could become unattractive then to the current

permittee, would have the impact on the local

school district, what was the refuge willing to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

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24

25

Page 56

1 do to ensure that there wasn't an impact on that

school?

 And what we said is that we would be

willing to pick up of those leases, and as we

put on the statement, "depending upon budgets".

As everybody knows, our budget is year

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

14 (Pages 53 to 56)

Page 53

1 to write a letter. I don't care if it's one

sentence, "I am in favor of Alternate A". Sign

your name and send it in.

 It doesn't take much to at least show

where your support and your interest lies. And

obviously the Wilderness Society is on the ball,

and we are not. So, let's get in gear. Make

some comments.

 We're going to try maybe to, through

the Chamber of Commerce, get a local state

corner meeting together, and maybe we can get

some input, and maybe we can come up with a

letter that has some clout and has some

meaning.

 And so I'm encouraging each and every

one of you, make some comments. Give them to

Dean Rogge.

 Dean Rogge has worked his butt off on

this project. The local Conservation Board,

Monte Billing is here as well. Talk to those

people. They're knowledgeable.

 Talk to the people that have been

permit holders for a long time. The John

McKerlicks, the Harold Isaacs, the Coles, the

Phippses.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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22

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Page 54

1 AUDIENCE: Snooks.

 MS. WATSON: Snooks.

 Talk to those people. Get their input.

 And write a comment, or if we can get a

meeting together, come to the meeting. Voice

your comments today. But I encourage you to

make a statement.

 They're making a statement. We need to

make a statement.

 Thank you.

 MS. MATHER: Anything else?

 Yes.

 LAYNE MURNION: Layne Murnion.

L-A-Y-N-E; M-U-R-N-I-O-N.

 Well, I'd like to say that I'm kind of

disappointed. We had such a good hearing. I

haven't seen these guys bailing hay to feed

their wildlife this winter. I guess that's our

job again.

 Every year when we get some snow or

something, and it gets tough, everybody wants to

see the wildlife live.

 The Phippses, I'm sure they got

thousands of elk eating on them. We have lots

of deer and stuff like that.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 55

1 But if you want to, I'd say go with

Alternative R. Let the ranchers run it. We'd

be a lot cheaper. Hell, we have do. We can't

afford these millions. We don't make that

much.

 That's all I have.

 MS. MATHER: Thank you.

 Okay, I'm going to turn it over to

Barron to respond to questions you've heard.

 MR. CRAWFORD: Bill and I have this

range of activities. He takes the hard ones.

I'm just trying to figure out which ones Bill's

going to get.

 Let's see. I was trying read through

my notes here real quick and see what kind of

questions we got.

 State lands. Are we going to protect?

Page 329.

 Basically when we met with the DNRC,

and we were talking about limited prescriptive

grazing, there was a comment from the State that

there's a possibility that those State lands

could become unattractive then to the current

permittee, would have the impact on the local

school district, what was the refuge willing to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 56

1 do to ensure that there wasn't an impact on that

school?

 And what we said is that we would be

willing to pick up of those leases, and as we

put on the statement, "depending upon budgets".

 As everybody knows, our budget is year

to year. We're not guaranteed any old funding.

You know, it's pretty much Congress passes a

funding bill. Sometimes it's passed before

October. Sometimes it's passed after December.

 But the bottom line is, we don't know

how much funding we're going to get. So we had

to put that statement in there that says

"depending upon current funding".

 Now, come reality, is the CMR ever not

going to be funded out of the federal budget?

 There's a possibility if they decide to

abolish the National Wildlife Refuge System. If

they did that, I'm sure this land would probably

be turned over to some other agency, such as the

BLM. So that then, you know, it would fall upon

the BLM; it would fall upon a different

management strategy.

 The bottom line is, we made the best

assurance to the State that we could make given

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13

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

14 (Pages 53 to 56)

Page 53

1 to write a letter. I don't care if it's one

sentence, "I am in favor of Alternate A". Sign

your name and send it in.

 It doesn't take much to at least show

where your support and your interest lies. And

obviously the Wilderness Society is on the ball,

and we are not. So, let's get in gear. Make

some comments.

 We're going to try maybe to, through

the Chamber of Commerce, get a local state

corner meeting together, and maybe we can get

some input, and maybe we can come up with a

letter that has some clout and has some

meaning.

 And so I'm encouraging each and every

one of you, make some comments. Give them to

Dean Rogge.

 Dean Rogge has worked his butt off on

this project. The local Conservation Board,

Monte Billing is here as well. Talk to those

people. They're knowledgeable.

 Talk to the people that have been

permit holders for a long time. The John

McKerlicks, the Harold Isaacs, the Coles, the

Phippses.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 54

1 AUDIENCE: Snooks.

 MS. WATSON: Snooks.

 Talk to those people. Get their input.

 And write a comment, or if we can get a

meeting together, come to the meeting. Voice

your comments today. But I encourage you to

make a statement.

 They're making a statement. We need to

make a statement.

 Thank you.

 MS. MATHER: Anything else?

 Yes.

 LAYNE MURNION: Layne Murnion.

L-A-Y-N-E; M-U-R-N-I-O-N.

 Well, I'd like to say that I'm kind of

disappointed. We had such a good hearing. I

haven't seen these guys bailing hay to feed

their wildlife this winter. I guess that's our

job again.

 Every year when we get some snow or

something, and it gets tough, everybody wants to

see the wildlife live.

 The Phippses, I'm sure they got

thousands of elk eating on them. We have lots

of deer and stuff like that.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 55

1 But if you want to, I'd say go with

Alternative R. Let the ranchers run it. We'd

be a lot cheaper. Hell, we have do. We can't

afford these millions. We don't make that

much.

 That's all I have.

 MS. MATHER: Thank you.

 Okay, I'm going to turn it over to

Barron to respond to questions you've heard.

 MR. CRAWFORD: Bill and I have this

range of activities. He takes the hard ones.

I'm just trying to figure out which ones Bill's

going to get.

 Let's see. I was trying read through

my notes here real quick and see what kind of

questions we got.

 State lands. Are we going to protect?

Page 329.

 Basically when we met with the DNRC,

and we were talking about limited prescriptive

grazing, there was a comment from the State that

there's a possibility that those State lands

could become unattractive then to the current

permittee, would have the impact on the local

school district, what was the refuge willing to

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 56

1 do to ensure that there wasn't an impact on that

school?

 And what we said is that we would be

willing to pick up of those leases, and as we

put on the statement, "depending upon budgets".

 As everybody knows, our budget is year

to year. We're not guaranteed any old funding.

You know, it's pretty much Congress passes a

funding bill. Sometimes it's passed before

October. Sometimes it's passed after December.

 But the bottom line is, we don't know

how much funding we're going to get. So we had

to put that statement in there that says

"depending upon current funding".

 Now, come reality, is the CMR ever not

going to be funded out of the federal budget?

 There's a possibility if they decide to

abolish the National Wildlife Refuge System. If

they did that, I'm sure this land would probably

be turned over to some other agency, such as the

BLM. So that then, you know, it would fall upon

the BLM; it would fall upon a different

management strategy.

 The bottom line is, we made the best

assurance to the State that we could make given

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

this project. The local Conservation Board,

Monte Billing is here as well. Talk to those

people. They're knowledgeable.

 Talk to the people that have been

permit holders for a long time. The John

McKerlicks, the Harold Isaacs, the Coles, the

Phippses.

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Page 54

1 AUDIENCE: Snooks.

 MS. WATSON: Snooks.

 Talk to those people. Get their input.

 And write a comment, or if we can get a

meeting together, come to the meeting. Voice

your comments today. But I encourage you to

make a statement.

 They're making a statement. We need to

make a statement.

 Thank you.

 MS. MATHER: Anything else?

 Yes.

 LAYNE MURNION: Layne Murnion.

L-A-Y-N-E; M-U-R-N-I-O-N.

 Well, I'd like to say that I'm kind of

disappointed. We had such a good hearing. I

haven't seen these guys bailing hay to feed

their wildlife this winter. I guess that's our

job again.

 Every year when we get some snow or

something, and it gets tough, everybody wants to

see the wildlife live.

 The Phippses, I'm sure they got

thousands of elk eating on them. We have lots

of deer and stuff like that.

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 Basical

and we were 

grazing, ther

there's a poss

could becom

permittee, wo

school distric

19

20

21

22

23

24

25

1 do to ensure 

school?

 And wh

willing to pic

put on the sta

 As ever

to year. We'

You know, it

funding bill. 

October. Som

 But the 

how much fu

to put that sta

"depending u

 Now, c

going to be f

 There's 

abolish the N

they did that

be turned ove

BLM. So tha

the BLM; it w

management 

 The bo

assurance to 

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VOLUME 2, Chapter 4—Public Hearing Testimony 409

Page 57

al with.

with that.

of the dilemma

ctful of that,

adequately

te on the

 we're talking

with their

fe & Parks

 to reintroduce

mewhere in the

d onto the

d how we

naging those

now, how

ock together?

Mountains area

e there.

cent to

da. So there

on herds and

Page 58

ame area.

, where

n.

d, there's

quarantine

f the state

Page 59

1 are coming out of the quarantine facility. And

it was my understanding that was one of the

reasons why they started talking about

developing this bison restoration plan.

 Domestic bison convert to wild bison

that wander on the CMR?

 No, domestic bison that wander around

on the CMR are trespass livestock and are dealt

with as trespass livestock.

 Domestic bison grazing on CMR?

 Yes, we had one long-standing permittee

in Garfield County that's been grazing bison for

20 years.

 MR. BERG: 20-plus, yeah.

 MR. CRAWFORD: 20-plus years, and that

is it.

 I'm at the point where I need

bifocals. It is driving me crazy, because I

refuse to buy them. I'm not that old.

 Bison. Fence bison. How we keep from

cattle herds?

 Again, we're not proposing to do

anything with bison, so we are not going to

create a fenced bison herd. We have no interest

in maintaining a fenced bison herd. The two we

2

3

4

5

6

7

8

9

10

11

12

13

14

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Page 60

1 have in Lewistown is plenty.

 Taking fences out and reducing water.

How are we going to manage livestock? That's a

great question.

 And obviously this hasn't been thought

out all the way. You know, we're throwing stuff

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

15 (Pages 57 to 60)

Page 57

1 the constraints that we have to deal with.

 The State was comfortable with that.

So, I think they understood kind of the dilemma

that we're in, and they were respectful of that,

and they felt that we addressed it adequately

from their standpoint.

 Some of the bison issues.

 Talk about bison that migrate on the

refuge. Okay. Again, you know, we're talking

about if the State moved forward with their

proposal, okay, State Fish, Wildlife & Parks

moved forward with the proposal to reintroduce

bison somewhere in the state, somewhere in the

local area, and those bison moved onto the

refuge.

 So in the plan, we addressed how we

would work with the State for managing those

animals, okay.

 It is a valid concern. You know, how

do you deal with bison and livestock together?

It's been done down in the Henry Mountains area

of Utah. So, there is one example there.

 It's being done up in -- adjacent to

Grasslands National Park in Canada. So there

are examples out there of how bison herds and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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21

22

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24

25

Page 58

1 cattle herds can get along in the same area.

 Let's see. State land species, where

they come from? A great question.

 Obviously everybody's heard, there's

quite a bit of talk about the bison quarantine

facility over in the western part of the state

where they are taking bison out of Yellowstone

National Park, putting them in the bison

quarantine facility, getting animals through

that program that come out, quote, "brucellosis

free", and then the state is looking for a place

to put those animals.

 I think in their charter, is they look

to go to federal, state or tribal lands. They

did send proposals around last year for the

first group of bison coming out of the

facilities. There where a couple of tribes that

expressed interest in taking those animals.

There where no federal or state agencies

interested in taking those animals, Fish &

Wildlife Service being one, so they ended up

going to Ted Turner, and that created quite a

stink.

 So, the State is trying to figure out

what they're going to do with these bison that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 59

1 are coming out of the quarantine facility. And

it was my understanding that was one of the

reasons why they started talking about

developing this bison restoration plan.

 Domestic bison convert to wild bison

that wander on the CMR?

 No, domestic bison that wander around

on the CMR are trespass livestock and are dealt

with as trespass livestock.

 Domestic bison grazing on CMR?

 Yes, we had one long-standing permittee

in Garfield County that's been grazing bison for

20 years.

 MR. BERG: 20-plus, yeah.

 MR. CRAWFORD: 20-plus years, and that

is it.

 I'm at the point where I need

bifocals. It is driving me crazy, because I

refuse to buy them. I'm not that old.

 Bison. Fence bison. How we keep from

cattle herds?

 Again, we're not proposing to do

anything with bison, so we are not going to

create a fenced bison herd. We have no interest

in maintaining a fenced bison herd. The two we

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 60

1 have in Lewistown is plenty.

 Taking fences out and reducing water.

How are we going to manage livestock? That's a

great question.

 And obviously this hasn't been thought

out all the way. You know, we're throwing stuff

down on paper as to what we would like to see

under this umbrella management plan.

 And one of the things, is we would like

to remove interior fences. We would like to see

animals move across the landscape. We would

like to see riparian areas restored by restoring

the natural water regimes as they flow down to

the river.

 Now, when we get to developing what's

called Habitat Management Plans, and those will

be done after this CCP is finalized, that's

where what I like to call the "boots meet the

dirt", okay. That's where the refuge staff sit

down with our partners, our neighbors, our

permittees, and they figure out how we're going

to implement, or how we're going to achieve our

wildlife and habitat management objectives.

 And if we're talking about using

livestock as prescriptive grazing, and we're

2

3

4

5

6

7

8

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12

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

15 (Pages 57 to 60)

Page 57

1 the constraints that we have to deal with.

 The State was comfortable with that.

So, I think they understood kind of the dilemma

that we're in, and they were respectful of that,

and they felt that we addressed it adequately

from their standpoint.

 Some of the bison issues.

 Talk about bison that migrate on the

refuge. Okay. Again, you know, we're talking

about if the State moved forward with their

proposal, okay, State Fish, Wildlife & Parks

moved forward with the proposal to reintroduce

bison somewhere in the state, somewhere in the

local area, and those bison moved onto the

refuge.

 So in the plan, we addressed how we

would work with the State for managing those

animals, okay.

 It is a valid concern. You know, how

do you deal with bison and livestock together?

It's been done down in the Henry Mountains area

of Utah. So, there is one example there.

 It's being done up in -- adjacent to

Grasslands National Park in Canada. So there

are examples out there of how bison herds and

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 58

1 cattle herds can get along in the same area.

 Let's see. State land species, where

they come from? A great question.

 Obviously everybody's heard, there's

quite a bit of talk about the bison quarantine

facility over in the western part of the state

where they are taking bison out of Yellowstone

National Park, putting them in the bison

quarantine facility, getting animals through

that program that come out, quote, "brucellosis

free", and then the state is looking for a place

to put those animals.

 I think in their charter, is they look

to go to federal, state or tribal lands. They

did send proposals around last year for the

first group of bison coming out of the

facilities. There where a couple of tribes that

expressed interest in taking those animals.

There where no federal or state agencies

interested in taking those animals, Fish &

Wildlife Service being one, so they ended up

going to Ted Turner, and that created quite a

stink.

 So, the State is trying to figure out

what they're going to do with these bison that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 59

1 are coming out of the quarantine facility. And

it was my understanding that was one of the

reasons why they started talking about

developing this bison restoration plan.

 Domestic bison convert to wild bison

that wander on the CMR?

 No, domestic bison that wander around

on the CMR are trespass livestock and are dealt

with as trespass livestock.

 Domestic bison grazing on CMR?

 Yes, we had one long-standing permittee

in Garfield County that's been grazing bison for

20 years.

 MR. BERG: 20-plus, yeah.

 MR. CRAWFORD: 20-plus years, and that

is it.

 I'm at the point where I need

bifocals. It is driving me crazy, because I

refuse to buy them. I'm not that old.

 Bison. Fence bison. How we keep from

cattle herds?

 Again, we're not proposing to do

anything with bison, so we are not going to

create a fenced bison herd. We have no interest

in maintaining a fenced bison herd. The two we

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 60

1 have in Lewistown is plenty.

 Taking fences out and reducing water.

How are we going to manage livestock? That's a

great question.

 And obviously this hasn't been thought

out all the way. You know, we're throwing stuff

down on paper as to what we would like to see

under this umbrella management plan.

 And one of the things, is we would like

to remove interior fences. We would like to see

animals move across the landscape. We would

like to see riparian areas restored by restoring

the natural water regimes as they flow down to

the river.

 Now, when we get to developing what's

called Habitat Management Plans, and those will

be done after this CCP is finalized, that's

where what I like to call the "boots meet the

dirt", okay. That's where the refuge staff sit

down with our partners, our neighbors, our

permittees, and they figure out how we're going

to implement, or how we're going to achieve our

wildlife and habitat management objectives.

 And if we're talking about using

livestock as prescriptive grazing, and we're

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

 It is a valid concern. You know, how

do you deal with bison and livestock together?

It's been done down in the Henry Mountains area

of Utah. So, there is one example there.

 It's being done up in -- adjacent to

Grasslands National Park in Canada. So there

are examples out there of how bison herds and

19

20

21

22

23

24

25

Page 58

1 cattle herds can get along in the same area.

 Let's see. State land species, where

they come from? A great question.

 Obviously everybody's heard, there's

quite a bit of talk about the bison quarantine

facility over in the western part of the state

where they are taking bison out of Yellowstone

National Park, putting them in the bison

quarantine facility, getting animals through

that program that come out, quote, "brucellosis

free", and then the state is looking for a place

to put those animals.

 I think in their charter, is they look

to go to federal, state or tribal lands. They

did send proposals around last year for the

first group of bison coming out of the

facilities. There where a couple of tribes that

expressed interest in taking those animals.

There where no federal or state agencies

interested in taking those animals, Fish &

Wildlife Service being one, so they ended up

going to Ted Turner, and that created quite a

stink.

 So, the State is trying to figure out

what they're going to do with these bison that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

refuse to 

 Bi

cattle he

 Ag

anything 

create a 

in maint

19

20

21

22

23

24

25

1 have in 

 Ta

How are 

great qu

 An

out all th

down on 

under th

 An

to remov

animals 

like to s

the natu

the river

 No

called H

be done 

where w

dirt", ok

down w

permitte

to imple

wildlife 

 An

livestock 

2

3

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8

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410 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 61

alking

e're

and our

wait a

use

re going to

e a

ross the

ybody else is

me type of

 together

nd of a

ded

and

eady have

r 15

umbrella

hat we're

Page 62

king

ing

nd John, and

o do",

 of crap.

is and

Page 63

1 published. We're looking -- we have done a lot

with fire history folks for several years now.

 And let's see. Is there more to that

question?

 MR. BERG: Peer-reviewed research.

 MR. SKINNER: Our plans of the, well,

principal direction we're heading is the patch

burn grazing. It's been published by Sam

Hildegard extensively.

 And we work closely with (inaudible) CS

people as appropriate, and their work is

published.

 And then if you look at our sentinel

plants, which are also called indicator plant,

or diagnostic plants, or focal species, or

decreasers of some plants, and you go to a place

like Hooper's Holler, there's thousands of

references related to those types of things.

 MR. CRAWFORD: Answer the question

about use of sentinel plants to develop where

it's been used, and the scientific basis or the

historic basis for those selected plants.

 MR. SKINNER: In our job, which is

wildlife management, our primary directive is to

manage for wildlife diversity. That's our

2

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11

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15

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21

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Page 64

1 marching orders.

 And plant diversity is the foundation

of the wildlife food web.

 And sentinel plants or diagnostic

plants or indicator plants, or focal plants or

decreasing strips, of course, are the first

2

3

4

5

6

(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

16 (Pages 61 to 64)

Page 61

1 talking about removing water, we're talking

about removing fences, that's where we're

expecting our partners, our neighbors and our

permittees to step up and say, "Well, wait a

minute. How are you expecting us to use

livestock as a management tool? We're going to

need this, this and this."

 And that's where we need to have a

meaningful dialogue back and forth across the

table so everybody knows where everybody else is

coming from, and we can all reach some type of

resolution of how we're going to work together

to accomplish this.

 MS. McKERLICK: Isn't that kind of a

lopsided partnership, though?

 MR. CRAWFORD: Is it a lopsided

partnership?

 If we're both sitting at the table and

talking --

 MS. McKERLICK: But you already have

this thing that you're going to go by for 15

years.

 MR. CRAWFORD: This is the umbrella

plan that throws out all the ideas of what we're

looking to do.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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Page 62

1 It didn't say what fences we're taking

out. It didn't say what water we're taking

out. So when we sit down with you and John, and

we say, "Okay, this is what we want to do",

that's when you can say, "You are full of crap.

This is not going to work. We need this and

this." And that's where we have that dialogue

back and forth.

 MS. McKERLICK: Why don't you do that

in the beginning?

 MR. CRAWFORD: Well, because we're not

at that stage yet. Then we would be talking 600

pages long.

 This is questions for Bob, talking

about the vision statement, adaptive management,

rooted in science, short grass permit research

that's been peer reviewed.

 Do you understand that question?

 BOB SKINNER: I think so.

 We work closely with several folks

looking at rangelands, wildlife habitat in

particular. We're looking very closely at the

patch burn grazing system with wildlife and

livestock participating.

 We have done -- and this is highly

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 63

1 published. We're looking -- we have done a lot

with fire history folks for several years now.

 And let's see. Is there more to that

question?

 MR. BERG: Peer-reviewed research.

 MR. SKINNER: Our plans of the, well,

principal direction we're heading is the patch

burn grazing. It's been published by Sam

Hildegard extensively.

 And we work closely with (inaudible) CS

people as appropriate, and their work is

published.

 And then if you look at our sentinel

plants, which are also called indicator plant,

or diagnostic plants, or focal species, or

decreasers of some plants, and you go to a place

like Hooper's Holler, there's thousands of

references related to those types of things.

 MR. CRAWFORD: Answer the question

about use of sentinel plants to develop where

it's been used, and the scientific basis or the

historic basis for those selected plants.

 MR. SKINNER: In our job, which is

wildlife management, our primary directive is to

manage for wildlife diversity. That's our

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 64

1 marching orders.

 And plant diversity is the foundation

of the wildlife food web.

 And sentinel plants or diagnostic

plants or indicator plants, or focal plants or

decreasing strips, of course, are the first

plants to vanish.

 So in order to maintain diversity, we

look to those in particular because they are the

ones that are sentinel.

 They are also highly palatable to all

herbivores. They're (inaudible) and buck

grasses. They're especially valuable for

wildlife for seeds, fruits, insects, and part of

the advantage and strategy to get those back is

to return to (inaudible) practices that occurred

that were apart of their past, which is this

patch burn grazing and total ungulate

management.

 Also, because it's a little narrower

than total plant community, monitoring is

accomplishable. It's very difficult to manage

all species. Is that an answer?

 MR. CRAWFORD: Sounds good. Thanks,

Bob.

2

3

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5

6

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8

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

16 (Pages 61 to 64)

Page 61

1 talking about removing water, we're talking

about removing fences, that's where we're

expecting our partners, our neighbors and our

permittees to step up and say, "Well, wait a

minute. How are you expecting us to use

livestock as a management tool? We're going to

need this, this and this."

 And that's where we need to have a

meaningful dialogue back and forth across the

table so everybody knows where everybody else is

coming from, and we can all reach some type of

resolution of how we're going to work together

to accomplish this.

 MS. McKERLICK: Isn't that kind of a

lopsided partnership, though?

 MR. CRAWFORD: Is it a lopsided

partnership?

 If we're both sitting at the table and

talking --

 MS. McKERLICK: But you already have

this thing that you're going to go by for 15

years.

 MR. CRAWFORD: This is the umbrella

plan that throws out all the ideas of what we're

looking to do.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 62

1 It didn't say what fences we're taking

out. It didn't say what water we're taking

out. So when we sit down with you and John, and

we say, "Okay, this is what we want to do",

that's when you can say, "You are full of crap.

This is not going to work. We need this and

this." And that's where we have that dialogue

back and forth.

 MS. McKERLICK: Why don't you do that

in the beginning?

 MR. CRAWFORD: Well, because we're not

at that stage yet. Then we would be talking 600

pages long.

 This is questions for Bob, talking

about the vision statement, adaptive management,

rooted in science, short grass permit research

that's been peer reviewed.

 Do you understand that question?

 BOB SKINNER: I think so.

 We work closely with several folks

looking at rangelands, wildlife habitat in

particular. We're looking very closely at the

patch burn grazing system with wildlife and

livestock participating.

 We have done -- and this is highly

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 63

1 published. We're looking -- we have done a lot

with fire history folks for several years now.

 And let's see. Is there more to that

question?

 MR. BERG: Peer-reviewed research.

 MR. SKINNER: Our plans of the, well,

principal direction we're heading is the patch

burn grazing. It's been published by Sam

Hildegard extensively.

 And we work closely with (inaudible) CS

people as appropriate, and their work is

published.

 And then if you look at our sentinel

plants, which are also called indicator plant,

or diagnostic plants, or focal species, or

decreasers of some plants, and you go to a place

like Hooper's Holler, there's thousands of

references related to those types of things.

 MR. CRAWFORD: Answer the question

about use of sentinel plants to develop where

it's been used, and the scientific basis or the

historic basis for those selected plants.

 MR. SKINNER: In our job, which is

wildlife management, our primary directive is to

manage for wildlife diversity. That's our

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Page 64

1 marching orders.

 And plant diversity is the foundation

of the wildlife food web.

 And sentinel plants or diagnostic

plants or indicator plants, or focal plants or

decreasing strips, of course, are the first

plants to vanish.

 So in order to maintain diversity, we

look to those in particular because they are the

ones that are sentinel.

 They are also highly palatable to all

herbivores. They're (inaudible) and buck

grasses. They're especially valuable for

wildlife for seeds, fruits, insects, and part of

the advantage and strategy to get those back is

to return to (inaudible) practices that occurred

that were apart of their past, which is this

patch burn grazing and total ungulate

management.

 Also, because it's a little narrower

than total plant community, monitoring is

accomplishable. It's very difficult to manage

all species. Is that an answer?

 MR. CRAWFORD: Sounds good. Thanks,

Bob.

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

talking --

 MS. McKERLICK: But you already have

this thing that you're going to go by for 15

years.

 MR. CRAWFORD: This is the umbrella

plan that throws out all the ideas of what we're

looking to do.

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Page 62

1 It didn't say what fences we're taking

out. It didn't say what water we're taking

out. So when we sit down with you and John, and

we say, "Okay, this is what we want to do",

that's when you can say, "You are full of crap.

This is not going to work. We need this and

this." And that's where we have that dialogue

back and forth.

 MS. McKERLICK: Why don't you do that

in the beginning?

 MR. CRAWFORD: Well, because we're not

at that stage yet. Then we would be talking 600

pages long.

 This is questions for Bob, talking

about the vision statement, adaptive management,

rooted in science, short grass permit research

that's been peer reviewed.

 Do you understand that question?

 BOB SKINNER: I think so.

 We work closely with several folks

looking at rangelands, wildlife habitat in

particular. We're looking very closely at the

patch burn grazing system with wildlife and

livestock participating.

 We have done -- and this is highly

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 MR. CR

about use of 

it's been used

historic basis 

 MR. SK

wildlife man

manage for w

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1 marching ord

 And pla

of the wildlif

 And se

plants or indi

decreasing st

plants to van

 So in o

look to those 

ones that are 

 They ar

herbivores. T

grasses. The

wildlife for s

the advantag

to return to (i

that were apa

patch burn gr

management

 Also, b

than total pla

accomplishab

all species. I

 MR. CR

Bob.

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VOLUME 2, Chapter 4—Public Hearing Testimony 411

Page 65

g Murray's

as a

ackson. He was

evelt to come

assessment and

t from a

ooked at it

 in '35. That

uld strive for.

ing

 lot that has

.

about was

and using

ant species.

 is, the

nd some of

e occurring,

m you want to

hy plants,

umber of those

back next year

.

Page 66

king to do,

as healthy as

apt or

o move from

r scientific

Page 67

1 gave them a different set of protection under

the Endangered Species Act.

 So that's how you have wolves up in the

Glacier area declared as fully endangered,

because they were a natural migration into the

area, versus wolves brought into the

Yellowstone, which were reintroduced and fall

under the experimental and nonessential

designation.

 But again, wolves are outside the

scope. We are not doing anything with wolves.

 I think that's all the questions I

had. Did I miss anything, Bill?

 MR. BERG: Mike McKeever asked about

payment in lieu of taxes.

 MR. CRAWFORD: Oh, that's a Bill

question.

 MR. BERG: You know, I wish we had

control over that, Mike.

 In Montana currently, the federal

agencies are paying about 30% of entitlement to

the counties.

 In eastern Montana, when we hit 50% of

entitlement, which is determined by Congress,

they're the ones that basically set aside that

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Page 68

1 moment for payment in lieu of taxes, where I

bought equity, as far as comparing it to private

lands and the taxes that are collected on those

properties.

 So, it's something we don't control.

Obviously some money that's generated on the

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

17 (Pages 65 to 68)

Page 65

1 I had a comment concerning Murray's

1935 assessment. Ellis Murray was a

world-renowned naturalist from Jackson. He was

commissioned by President Roosevelt to come

through here and do a biological assessment and

make a recommendation.

 We researched his work just from a

historical standpoint, okay. We looked at it

and said, this is what Murray saw in '35. That

should be something that we should strive for.

 It's a great question concerning

climate change. There has been a lot that has

changed, and continues to change.

 And what biologists talked about was

taking these ecological processes and using

those to build resilience within plant species.

The more resilient a plant species is, the

better that it can adapt or withstand some of

these drastic changes that could be occurring,

occurred, will occur, whatever term you want to

use, okay.

 So if you've got good, healthy plants,

you get a bad drought year, the number of those

plants that will survive and come back next year

increases as their health increases.

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Page 66

1 And so that's what we're looking to do,

is make these plant communities as healthy as

possible so that they can either adapt or

withstand change as it continues to move from

one end to the other.

 AUDIENCE: Where is your scientific

data on what you just said?

 MR. CRAWFORD: It's books.

 MS. MATHER: Folks, if you could hold

your questions, the staff will be around

afterwards. I just want Barron to get a chance

to answer all the questions.

 MR. CRAWFORD: There's talk about

wolves endanger rancher dues.

 I'm not sure about that. I think

wolves are -- wolves do have a dual status.

 This is outside the scope of the CCP,

but the question was asked so I will address it.

 Wolves up in the Glacier area naturally

migrated into the United States from Canada, so

they were protected under the full auspices of

the Endangered Species Act.

 Wolves brought into Yellowstone were

reintroduced. They were classified as an

experimental and nonessential population, which

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Page 67

1 gave them a different set of protection under

the Endangered Species Act.

 So that's how you have wolves up in the

Glacier area declared as fully endangered,

because they were a natural migration into the

area, versus wolves brought into the

Yellowstone, which were reintroduced and fall

under the experimental and nonessential

designation.

 But again, wolves are outside the

scope. We are not doing anything with wolves.

 I think that's all the questions I

had. Did I miss anything, Bill?

 MR. BERG: Mike McKeever asked about

payment in lieu of taxes.

 MR. CRAWFORD: Oh, that's a Bill

question.

 MR. BERG: You know, I wish we had

control over that, Mike.

 In Montana currently, the federal

agencies are paying about 30% of entitlement to

the counties.

 In eastern Montana, when we hit 50% of

entitlement, which is determined by Congress,

they're the ones that basically set aside that

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Page 68

1 moment for payment in lieu of taxes, where I

bought equity, as far as comparing it to private

lands and the taxes that are collected on those

properties.

 So, it's something we don't control.

Obviously some money that's generated on the

refuge does come back to the local communities

in the same format, but typically just the big

oil-producing refuges truly put back more than

what that land would bring if it was in some

other ownership. So, it's something we don't

control at this time.

 Another question Mike had, explanation

of water rights.

 We're currently going through a

Compact Commission. We've got a deadline of

October 15th to file with the Compact

Commission, which is the review board for water

rights in and around CMR.

 At that time, what they'll do is take

all the water rights that are filed on the

various tributaries. Obviously some will be

overappropriated, but that's kind of their job

to make that cut and determine, you know, who is

going to get what share of what water right that

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

17 (Pages 65 to 68)

Page 65

1 I had a comment concerning Murray's

1935 assessment. Ellis Murray was a

world-renowned naturalist from Jackson. He was

commissioned by President Roosevelt to come

through here and do a biological assessment and

make a recommendation.

 We researched his work just from a

historical standpoint, okay. We looked at it

and said, this is what Murray saw in '35. That

should be something that we should strive for.

 It's a great question concerning

climate change. There has been a lot that has

changed, and continues to change.

 And what biologists talked about was

taking these ecological processes and using

those to build resilience within plant species.

The more resilient a plant species is, the

better that it can adapt or withstand some of

these drastic changes that could be occurring,

occurred, will occur, whatever term you want to

use, okay.

 So if you've got good, healthy plants,

you get a bad drought year, the number of those

plants that will survive and come back next year

increases as their health increases.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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25

Page 66

1 And so that's what we're looking to do,

is make these plant communities as healthy as

possible so that they can either adapt or

withstand change as it continues to move from

one end to the other.

 AUDIENCE: Where is your scientific

data on what you just said?

 MR. CRAWFORD: It's books.

 MS. MATHER: Folks, if you could hold

your questions, the staff will be around

afterwards. I just want Barron to get a chance

to answer all the questions.

 MR. CRAWFORD: There's talk about

wolves endanger rancher dues.

 I'm not sure about that. I think

wolves are -- wolves do have a dual status.

 This is outside the scope of the CCP,

but the question was asked so I will address it.

 Wolves up in the Glacier area naturally

migrated into the United States from Canada, so

they were protected under the full auspices of

the Endangered Species Act.

 Wolves brought into Yellowstone were

reintroduced. They were classified as an

experimental and nonessential population, which

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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25

Page 67

1 gave them a different set of protection under

the Endangered Species Act.

 So that's how you have wolves up in the

Glacier area declared as fully endangered,

because they were a natural migration into the

area, versus wolves brought into the

Yellowstone, which were reintroduced and fall

under the experimental and nonessential

designation.

 But again, wolves are outside the

scope. We are not doing anything with wolves.

 I think that's all the questions I

had. Did I miss anything, Bill?

 MR. BERG: Mike McKeever asked about

payment in lieu of taxes.

 MR. CRAWFORD: Oh, that's a Bill

question.

 MR. BERG: You know, I wish we had

control over that, Mike.

 In Montana currently, the federal

agencies are paying about 30% of entitlement to

the counties.

 In eastern Montana, when we hit 50% of

entitlement, which is determined by Congress,

they're the ones that basically set aside that

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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19

20

21

22

23

24

25

Page 68

1 moment for payment in lieu of taxes, where I

bought equity, as far as comparing it to private

lands and the taxes that are collected on those

properties.

 So, it's something we don't control.

Obviously some money that's generated on the

refuge does come back to the local communities

in the same format, but typically just the big

oil-producing refuges truly put back more than

what that land would bring if it was in some

other ownership. So, it's something we don't

control at this time.

 Another question Mike had, explanation

of water rights.

 We're currently going through a

Compact Commission. We've got a deadline of

October 15th to file with the Compact

Commission, which is the review board for water

rights in and around CMR.

 At that time, what they'll do is take

all the water rights that are filed on the

various tributaries. Obviously some will be

overappropriated, but that's kind of their job

to make that cut and determine, you know, who is

going to get what share of what water right that

2

3

4

5

6

7

8

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(406)248-4064 Fax:(406)256-5525 E-Mail

BIG SKY REPORTING - FRANCE

these drastic changes that could be occurring,

occurred, will occur, whatever term you want to

use, okay.

 So if you've got good, healthy plants,

you get a bad drought year, the number of those

plants that will survive and come back next year

increases as their health increases.

19

20

21

22

23

24

25

Page 66

1 And so that's what we're looking to do,

is make these plant communities as healthy as

possible so that they can either adapt or

withstand change as it continues to move from

one end to the other.

 AUDIENCE: Where is your scientific

data on what you just said?

 MR. CRAWFORD: It's books.

 MS. MATHER: Folks, if you could hold

your questions, the staff will be around

afterwards. I just want Barron to get a chance

to answer all the questions.

 MR. CRAWFORD: There's talk about

wolves endanger rancher dues.

 I'm not sure about that. I think

wolves are -- wolves do have a dual status.

 This is outside the scope of the CCP,

but the question was asked so I will address it.

 Wolves up in the Glacier area naturally

migrated into the United States from Canada, so

they were protected under the full auspices of

the Endangered Species Act.

 Wolves brought into Yellowstone were

reintroduced. They were classified as an

experimental and nonessential population, which

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

control o

 In 

agencies 

the coun

 In 

entitlem

they're t

19

20

21

22

23

24

25

1 moment 

bought e

lands an

properti

 So

Obvious

refuge d

in the sa

oil-prod

what tha

other ow

control a

 An

of water 

 W

Compac

October 

Commis

rights in 

 At 

all the w

various 

overapp

to make 

going to 

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412 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 69

River

 it for

nd around

d your

overs it

rred

up examples

can

past,

eloped water

ended water

e it's

 than,

nds, federal

ld be one.

cently

n Prairie

s called the

Page 70

he one

on person

esults in

o the

Page 71

1 With the exception where that road runs

to private land or State land, those roads

remain open where historical roads access those

properties.

 So, what we're trying to avoid there is

creating an exclusive use of that public road on

CMR that's only accessible to a few people

because of what's going on off the refuge.

 We've attempted in several areas where

we have got access issues where the public can't

get to large blocks of CMR, we've actually

purchased rights of way from landowners either

as part of a land purchase or a sale to us, that

kind of thing, which has resolved some of that,

but that will be an option in the future for us

to try to do that where we can.

 MS. MATHER: Okay, folks, that's it.

 We have a number of CMR staff, most of

them are at the back, in addition to these two

up here, so you if you do have additional

questions, please grab one of them.

 We will be here for another half an

hour or so. Thank you very much for coming.

 (Whereupon, the hearing was concluded

at 3:45 p.m.)

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Page 72

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Wildlife Refuges

HEARING DATE: October 13, 2010

LOCATION: Jordan, Montana

 I hereby certify that the proceedings

d idhiid flld

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(406)248-4064 Fax:(406)256-5525 E-Mail:fran848@bresnan.net

BIG SKY REPORTING - FRANCES L. MOCK

18 (Pages 69 to 72)

Page 69

1 exists in each of its tributaries.

 They're doing that for the Milk River

right now, and they're also going to do it for

that portion of the Missouri River in and around

CMR.

 So, I don't know if that answered your

question, Mike, or not, but I think it covers it

a little bit.

 The other question that I had starred

here was Ralph Griink. You brought up examples

of other adjacent conservation lands.

 And a couple of examples that I can

think of just off the top here, is in the past,

what we've done where BLM has developed water

off the refuge, we have sometimes extended water

lines down ridges onto the refuge.

 And it's usually a situation where it's

easier to develop water in that manner than,

say, going and building some new ponds, federal

water quality in most cases. That would be one.

 Another example of that more recently

where a conservation buyer, American Prairie

Foundation, came in and bought what's called the

Wiedrich Ranch north of UL Bend.

 They initiated a pretty extensive

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Page 70

1 riparian restoration project similar to the one

that was brought up by the conservation person

here, and we've seen some excellent results in

that.

 We expanded that study to the

Department of (inaudible) Project onto the

refuge for Chef Bay and Valentine Creek to kind

of broaden the study area a little bit, and I

guess would be another example of other

conservation lands or practices where we've

partnered up with the adjacent landowner.

 What else?

 MS. SHANNON: Roads is the last thing.

 MR. BERG: Okay, a question came up

about roads.

 One of the things we've looked at

pretty closely here in the last few years is

there's situations where we don't control the

public access off the refuge. There's not a

legally identified access road coming off the

main county road.

 In situations where the public access

is cut off before it gets to CMR, what we've

done is also stopped the use of that road that's

not accessible to the public on the refuge.

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Page 71

1 With the exception where that road runs

to private land or State land, those roads

remain open where historical roads access those

properties.

 So, what we're trying to avoid there is

creating an exclusive use of that public road on

CMR that's only accessible to a few people

because of what's going on off the refuge.

 We've attempted in several areas where

we have got access issues where the public can't

get to large blocks of CMR, we've actually

purchased rights of way from landowners either

as part of a land purchase or a sale to us, that

kind of thing, which has resolved some of that,

but that will be an option in the future for us

to try to do that where we can.

 MS. MATHER: Okay, folks, that's it.

 We have a number of CMR staff, most of

them are at the back, in addition to these two

up here, so you if you do have additional

questions, please grab one of them.

 We will be here for another half an

hour or so. Thank you very much for coming.

 (Whereupon, the hearing was concluded

at 3:45 p.m.)

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Page 72

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Wildlife Refuges

HEARING DATE: October 13, 2010

LOCATION: Jordan, Montana

 I hereby certify that the proceedings

and evidence herein are contained fully and

accurately on the electronic notes reported by

Karlene Lehfeldt at the hearing in the above

case before the U.S. Fish & Wildlife Service,

and that this is a true and correct transcript

of the same.

 DATE: October 16, 2006

 Frances L. Mock

 Big Sky Reporting

 2308 Interlachen Circle

 Billings, Montana 59105

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BIG SKY REPORTING - FRANCES L. MOCK

18 (Pages 69 to 72)

Page 69

1 exists in each of its tributaries.

 They're doing that for the Milk River

right now, and they're also going to do it for

that portion of the Missouri River in and around

CMR.

 So, I don't know if that answered your

question, Mike, or not, but I think it covers it

a little bit.

 The other question that I had starred

here was Ralph Griink. You brought up examples

of other adjacent conservation lands.

 And a couple of examples that I can

think of just off the top here, is in the past,

what we've done where BLM has developed water

off the refuge, we have sometimes extended water

lines down ridges onto the refuge.

 And it's usually a situation where it's

easier to develop water in that manner than,

say, going and building some new ponds, federal

water quality in most cases. That would be one.

 Another example of that more recently

where a conservation buyer, American Prairie

Foundation, came in and bought what's called the

Wiedrich Ranch north of UL Bend.

 They initiated a pretty extensive

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 70

1 riparian restoration project similar to the one

that was brought up by the conservation person

here, and we've seen some excellent results in

that.

 We expanded that study to the

Department of (inaudible) Project onto the

refuge for Chef Bay and Valentine Creek to kind

of broaden the study area a little bit, and I

guess would be another example of other

conservation lands or practices where we've

partnered up with the adjacent landowner.

 What else?

 MS. SHANNON: Roads is the last thing.

 MR. BERG: Okay, a question came up

about roads.

 One of the things we've looked at

pretty closely here in the last few years is

there's situations where we don't control the

public access off the refuge. There's not a

legally identified access road coming off the

main county road.

 In situations where the public access

is cut off before it gets to CMR, what we've

done is also stopped the use of that road that's

not accessible to the public on the refuge.

2

3

4

5

6

7

8

9

10

11

12

13

14

15

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19

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21

22

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24

25

Page 71

1 With the exception where that road runs

to private land or State land, those roads

remain open where historical roads access those

properties.

 So, what we're trying to avoid there is

creating an exclusive use of that public road on

CMR that's only accessible to a few people

because of what's going on off the refuge.

 We've attempted in several areas where

we have got access issues where the public can't

get to large blocks of CMR, we've actually

purchased rights of way from landowners either

as part of a land purchase or a sale to us, that

kind of thing, which has resolved some of that,

but that will be an option in the future for us

to try to do that where we can.

 MS. MATHER: Okay, folks, that's it.

 We have a number of CMR staff, most of

them are at the back, in addition to these two

up here, so you if you do have additional

questions, please grab one of them.

 We will be here for another half an

hour or so. Thank you very much for coming.

 (Whereupon, the hearing was concluded

at 3:45 p.m.)

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Page 72

1 REPORTER'S CERTIFICATE

CASE TITLE: CMR & UL Bend Wildlife Refuges

HEARING DATE: October 13, 2010

LOCATION: Jordan, Montana

 I hereby certify that the proceedings

and evidence herein are contained fully and

accurately on the electronic notes reported by

Karlene Lehfeldt at the hearing in the above

case before the U.S. Fish & Wildlife Service,

and that this is a true and correct transcript

of the same.

 DATE: October 16, 2006

 Frances L. Mock

 Big Sky Reporting

 2308 Interlachen Circle

 Billings, Montana 59105

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(406)248-4064 Fax:(406)256-5525 E-Mail:fr

BIG SKY REPORTING - FRANCES L

say, going and building some new ponds, federal

water quality in most cases. That would be one.

 Another example of that more recently

where a conservation buyer, American Prairie

Foundation, came in and bought what's called the

Wiedrich Ranch north of UL Bend.

 They initiated a pretty extensive

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Page 70

1 riparian restoration project similar to the one

that was brought up by the conservation person

here, and we've seen some excellent results in

that.

 We expanded that study to the

Department of (inaudible) Project onto the

refuge for Chef Bay and Valentine Creek to kind

of broaden the study area a little bit, and I

guess would be another example of other

conservation lands or practices where we've

partnered up with the adjacent landowner.

 What else?

 MS. SHANNON: Roads is the last thing.

 MR. BERG: Okay, a question came up

about roads.

 One of the things we've looked at

pretty closely here in the last few years is

there's situations where we don't control the

public access off the refuge. There's not a

legally identified access road coming off the

main county road.

 In situations where the public access

is cut off before it gets to CMR, what we've

done is also stopped the use of that road that's

not accessible to the public on the refuge.

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them are at th

up here, so y

questions, pl

 We wil

hour or so. T

 (Where

at 3:45 p.m.)

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1 REPO

CASE TITLE

HEARING DA

LOCATION: 

 I hereby 

and evidence h

accurately on 

Karlene Lehfe

case before th

and that this is 

of the same.

 

 

 

 

 

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VOLUME 2, Chapter 4—Public Hearing Testimony 413

02/14/2011 11:36:41 AM Page 1 to 1 of 54 1 of 16 sheets

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1

PUBLIC MEETING

OCTOBER 14, 2010

GLASGOW, MONTANA

U.S. Fish & Wildlife Service.

Draft Comprehensive Conservation

Plan and Environmental Impact Statement

Charles M. Russell National Wildlife Refuge

and UL Bend National Wildlife Refuge

2 of 16 sheets Page 2 to 5 of 54 

2

MS. MATHER: Good afternoon everybody. 

Thank you for coming. Thanks for coming. My name is 

Mimi and I'll be facilitating the meeting today, and 

I'm up here with Barron Crawford, CMR's project leader, 

Bill Berg, the deputy project leader, and Laurie 

Shannon, the CCP planning leader. 

So the purpose of our meeting in the next two hours 

is really to collect -- the Fish and Wildlife Service 

to collect your comments on the Comprehensive 

Conservation Plan. We're going to start the meeting 

today with Barron giving a brief presentation about the 

CCP, and then we'll turn the floor to you and give 

folks that signed up on the list the opportunity to 

offer their comments. 

Just keep in mind, in order to let everybody give 

their comments, we're going to hold you to three 

minutes of comments, so if you have lots of ideas, 

start thinking about how you can streamline that down 

to a three-minute comment. So I'll turn it to Barron. 

MR. CRAWFORD: Alrighty. Thanks. 

Welcome everybody. I'm going to give you a brief 

overview of what we've been doing for the past three 

years, kind of tell you how we got to where we're at, 

and give you a brief overview of each of the 

alternatives. Take about 20 minutes or so. Just a 

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real brief run through here. 

So we started this process, basically, in January 

of 2007. We held a series of public scoping meetings; 

14 of those. Had several meetings with our 

cooperators. Those cooperators include the six 

counties, the Corp. Of Engineers, the Bureau of Land 

Management, the DNRC, Montana Fish, Wildlife & Parks, 

and the conservation districts. I knew I'd forget 

somebody. 

This is kind of the time line that we've been 

working under. We're right now at the release of the 

draft CCP. That's that 400 page document that 

everybody's been reading. We hope to be able to 

release the final CCP. This time line is a little out 

of whack, but we'd like to have the record of decision 

signed off on by the summer 2012. 

So basically why do we do CCPs? The first reason 

is the National Wildlife Refuge System Improvement Act 

of 1997 requires that all refuges have a CCP completed 

by 2012, and there's about 548 national refuges in the 

system, and about -- out of those about two-thirds of 

those are completed, all pushing towards the 2012 

deadline. 

The other reason is basically that this provides 

that critical management direction and guidance that's 

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based upon 

National Wi

statement, 

future mana

NEPA docume

impact stat

Due to 

went ahead 

The key is 

15-year pla

guide that 

This i

in putting 

number five

public hear

then move i

plan. Howe

possibility 

and maybe d

out and pre

done our jo

step. 

So now 

nutshell he

four of the

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Alternative

keep doing 

modificatio

Basically, 

65 habitat 

continue to 

the ranch s

be achieved 

identified 

approximate

continue pr

wilderness

Then w

"Alternativ

Wildlife Ha

managing th

the abundan

using both 

as fire and 

such as far

wildlife an

fishing, wi

use when th

In the 

various alt

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2 of 16 sheets Page 2 to 5 of 54 02/14/2011 11:36:41 AM

2

MS. MATHER: Good afternoon everybody. 

Thank you for coming. Thanks for coming. My name is 

Mimi and I'll be facilitating the meeting today, and 

I'm up here with Barron Crawford, CMR's project leader, 

Bill Berg, the deputy project leader, and Laurie 

Shannon, the CCP planning leader. 

So the purpose of our meeting in the next two hours 

is really to collect -- the Fish and Wildlife Service 

to collect your comments on the Comprehensive 

Conservation Plan. We're going to start the meeting 

today with Barron giving a brief presentation about the 

CCP, and then we'll turn the floor to you and give 

folks that signed up on the list the opportunity to 

offer their comments. 

Just keep in mind, in order to let everybody give 

their comments, we're going to hold you to three 

minutes of comments, so if you have lots of ideas, 

start thinking about how you can streamline that down 

to a three-minute comment. So I'll turn it to Barron. 

MR. CRAWFORD: Alrighty. Thanks. 

Welcome everybody. I'm going to give you a brief 

overview of what we've been doing for the past three 

years, kind of tell you how we got to where we're at, 

and give you a brief overview of each of the 

alternatives. Take about 20 minutes or so. Just a 

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real brief run through here. 

So we started this process, basically, in January 

of 2007. We held a series of public scoping meetings; 

14 of those. Had several meetings with our 

cooperators. Those cooperators include the six 

counties, the Corp. Of Engineers, the Bureau of Land 

Management, the DNRC, Montana Fish, Wildlife & Parks, 

and the conservation districts. I knew I'd forget 

somebody. 

This is kind of the time line that we've been 

working under. We're right now at the release of the 

draft CCP. That's that 400 page document that 

everybody's been reading. We hope to be able to 

release the final CCP. This time line is a little out 

of whack, but we'd like to have the record of decision 

signed off on by the summer 2012. 

So basically why do we do CCPs? The first reason 

is the National Wildlife Refuge System Improvement Act 

of 1997 requires that all refuges have a CCP completed 

by 2012, and there's about 548 national refuges in the 

system, and about -- out of those about two-thirds of 

those are completed, all pushing towards the 2012 

deadline. 

The other reason is basically that this provides 

that critical management direction and guidance that's 

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4

based upon the refuge purposes and the mission of the 

National Wildlife Refuge System. It outlines a vision 

statement, goals, objectives and strategies for that 

future management. It's accompanied by some type of 

NEPA document, either an environmental assessment or 

impact statement. 

Due to the complexity of issues here at the CMR, we

went ahead and did the Environmental Impact Statement. 

The key is that we provide the guidance for that 

15-year plan. It basically provides that road map to 

guide that future management. 

This is kind of the eight steps that are involved 

in putting together a CCP, and we're down here at 

number five. Hopefully, after we're done with the 

public hearings and we've gathered the comments, we 

then move into stage six, which is prepare the final 

plan. However, after the comments there is a 

possibility that we could go back to step four and look 

and maybe develop a new alternative, and then come back 

out and present that alternative. But hopefully we've 

done our jobs well and are able to move on to the next 

step. 

So now I'm just going to give you kind of a brief 

nutshell here of each of the alternatives. We have 

four of them. The first one was the No-Action 

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Alternative, and this is basically where we're going to 

keep doing what we've been doing, with just a few 

modifications, since the 1986 EIS was passed. 

Basically, we'll continue to manage the refuge in the 

65 habitat units that we have out there now, we'll 

continue to gradually move to prescriptive grazing as 

the ranch sells to a non-family member. Big game will 

be achieved to achieve the target levels that were 

identified in the 1986 EIS. We'll keep the 

approximately 670 miles of roads open, and we'll 

continue protection of the 155,288 acres of proposed 

wilderness.

Then we had three action alternatives. 

"Alternative B" was the one we kind of coined the 

Wildlife Habitat Emphasis. And, basically, this one is 

managing the landscape with our partners to emphasize 

the abundance and diversity of wildlife populations 

using both balanced natural ecological processes, such 

as fire and grazing, flooding and synthetic methods, 

such as farming or tree planting. We also encouraged 

wildlife and public uses, and those are hunting and 

fishing, wildlife photography, and we limit economic 

use when they compete for habitat resources. 

In the back we've got some maps that depict the 

various alternatives. Under this alternative pretty 

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MS. MATHER: Good afternoon everybody. 

Thank you for coming. Thanks for coming. My name is 

Mimi and I'll be facilitating the meeting today, and 

I'm up here with Barron Crawford, CMR's project leader, 

Bill Berg, the deputy project leader, and Laurie 

Shannon, the CCP planning leader. 

So the purpose of our meeting in the next two hours 

is really to collect -- the Fish and Wildlife Service 

to collect your comments on the Comprehensive 

Conservation Plan. We're going to start the meeting 

today with Barron giving a brief presentation about the 

CCP, and then we'll turn the floor to you and give 

folks that signed up on the list the opportunity to 

offer their comments. 

Just keep in mind, in order to let everybody give 

their comments, we're going to hold you to three 

minutes of comments, so if you have lots of ideas, 

start thinking about how you can streamline that down 

to a three-minute comment. So I'll turn it to Barron. 

MR. CRAWFORD: Alrighty. Thanks. 

Welcome everybody. I'm going to give you a brief 

overview of what we've been doing for the past three 

years, kind of tell you how we got to where we're at, 

and give you a brief overview of each of the 

alternatives. Take about 20 minutes or so. Just a 

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real brief run through here. 

So we started this process, basically, in January 

of 2007. We held a series of public scoping meetings; 

14 of those. Had several meetings with our 

1

2

3

4

5

4

based upon the refuge purposes and the mission of the 

National Wildlife Refuge System. It outlines a vision 

statement, goals, objectives and strategies for that 

future management. It's accompanied by some type of 

NEPA document, either an environmental assessment or 

impact statement. 

Due to the complexity of issues here at the CMR, we

went ahead and did the Environmental Impact Statement. 

The key is that we provide the guidance for that 

15-year plan. It basically provides that road map to 

guide that future management. 

This is kind of the eight steps that are involved 

in putting together a CCP, and we're down here at 

number five. Hopefully, after we're done with the 

public hearings and we've gathered the comments, we 

then move into stage six, which is prepare the final 

plan. However, after the comments there is a 

possibility that we could go back to step four and look 

and maybe develop a new alternative, and then come back 

out and present that alternative. But hopefully we've 

done our jobs well and are able to move on to the next 

step. 

So now I'm just going to give you kind of a brief 

nutshell here of each of the alternatives. We have 

four of them. The first one was the No-Action 

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5

Alternative, and this is basically where we're going to 

keep doing what we've been doing, with just a few 

modifications, since the 1986 EIS was passed. 

Basically, we'll continue to manage the refuge in the 

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3

4

5
414 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 2 to 5 of 54 02/14/2011 11:36:41 AM

a brief 

past three 

e we're at, 

he 

. Just a 

3

 in January 

ng meetings; 

r 

e six 

au of Land 

fe & Parks, 

d forget 

ve been 

ease of the 

that 

ble to 

a little out 

 of decision 

irst reason 

rovement Act 

CP completed 

fuges in the 

o-thirds of 

he 2012 

s provides 

dance that's 

ppy 

done our jobs well and are able to move on to the next 

step. 

So now I'm just going to give you kind of a brief 

nutshell here of each of the alternatives. We have 

four of them. The first one was the No-Action 

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22

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25

5

Alternative, and this is basically where we're going to 

keep doing what we've been doing, with just a few 

modifications, since the 1986 EIS was passed. 

Basically, we'll continue to manage the refuge in the 

65 habitat units that we have out there now, we'll 

continue to gradually move to prescriptive grazing as 

the ranch sells to a non-family member. Big game will 

be achieved to achieve the target levels that were 

identified in the 1986 EIS. We'll keep the 

approximately 670 miles of roads open, and we'll 

continue protection of the 155,288 acres of proposed 

wilderness.

Then we had three action alternatives. 

"Alternative B" was the one we kind of coined the 

Wildlife Habitat Emphasis. And, basically, this one is 

managing the landscape with our partners to emphasize 

the abundance and diversity of wildlife populations 

using both balanced natural ecological processes, such 

as fire and grazing, flooding and synthetic methods, 

such as farming or tree planting. We also encouraged 

wildlife and public uses, and those are hunting and 

fishing, wildlife photography, and we limit economic 

use when they compete for habitat resources. 

In the back we've got some maps that depict the 

various alternatives. Under this alternative pretty 

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02/14/2011 11:36:41 AM Page 6 to 9 of 54 3 of 16 sheets

6

substantial increase in proposed wilderness areas, 

substantial recommendations for some road closures. 

Same thing here on the east side of the refuge. 

Kind of some of the highlights of this one is we 

actively manage, manipulate habitats to create 

productive wildlife food and cover. We implement 

prescriptive grazing on about 50 to 75 percent of the 

refuge within a time period of four to seven years. We 

get aggressive in restoring the river bottoms. We work 

with Montana Fish Wildlife and Parks to provide quality 

hunting opportunities and sustain the populations of 

big game, and also the habitat for non-game species. 

Close approximately 106 miles of roads, and expand the 

acreage of proposed wilderness by 25,000. 

Then we move to "Alternative C," and this is kind 

of the Public Use and Economic Emphasis. And this 

someone again manages that landscape with your partners 

to emphasize and promote maximum compatible wildlife 

while protecting wildlife populations and habitats to 

the extent possible. We minimize damage to wildlife 

habitats while using a variety of management tools to 

enhance the diversity of public and economic 

opportunities. 

And again, the map. Very few road closures, no 

road closures, just a couple seasons proposed, no 

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expansion of wilderness. There is a couple of 

suggestions to eliminate some wilderness in proposed C, 

some proposed wilderness areas. 

So the main bullets for this one is manage habitats 

to provide more opportunities for recreation, maintain 

balance numbers of big game and livestock. Work with 

Fish Wildlife and Parks to expand and maximize hunting 

opportunities. Improve access to boat ramps and 

recommend eliminating four proposed wilderness areas 

for reduction of 35,880 acres. 

And then we move to "Alternative D," and this is 

our Proposed Action Alternative. We coin this one the 

Natural Processes or the Ecological Processes. And, 

again, working in cooperation with our partners, using 

those natural economic processes of fire, grazing, 

flooding, and active management, tree planting, farming 

in a balanced responsible manner to restore and/or 

maintain biological diversity, biological integrity and 

environmental health. 

Those three things right there come right from your 

Improvement Act as to what we're supposed to be doing 

here. Once we've restored those natural resources we 

take a more passive management approach. We still 

provide for those quality wildlife-dependent public 

uses and experiences, and we limit when they are either 

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injurious to the habitats or to the ecological process. 

Under this alternative we did propose expanding a 

couple of proposed wilderness areas. We did propose to 

eliminate a few as we got a few recommendations for 

some road closures. Same thing here on the east end. 

So under this alternative, the main points of it, 

economic uses would be limited when they are causing 

injury to ecological processes for the habitats out 

there. We'd apply management practices that mimic and 

restore natural processes, use fire and grazing whether 

its with wild or livestock, so prescriptively to mimic 

that historic interaction. Work with Fish Wildlife and 

Parks and maintain health and diversity of all species. 

Do about 25 miles of all road closures. We'd recommend 

expanding six of the proposed wilderness areas for 

about 18,000 acres, but also eliminating three for a 

loss of 26,000. 

So we've been doing several of these meetings now, 

and it's kind of the hot button topics that we've been 

hearing, prescriptive grazing, what is it? And 

basically it's using livestock to achieve a specific 

wildlife and/or habitat objective. One example is that 

let's say you have an area that is an important sage 

grouse breeding ground or important sage grouse 

wintering ground, and we've got a large grass buildup 

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in that area, and we can't use prescribed fire, or we 

don't want to use prescribed fire because of the 

potential impact on that sage grouse area. We could 

use livestock in a prescription to go in there and 

reduce that fuel load to protect that area from a 

wildfire event. 

Prescriptive fire, how will it be used? We've been 

working with five ecologists across the refuge now for 

the past five years, and along with some rain 

scientists to look at the historic fire frequency on 

the refuge, and we started at a very close level and 

have been working our way down to the very fine scale 

level. And what we found is we've got several areas on 

the refuge that historically burn within about a seven 

to 14-year time period. We have several areas on the 

refuge that maybe burn once every several hundred 

years, so we have quite a range.

And the idea is to go in and look at those areas, 

determine that historic fire frequency, and try to 

restore that back to that landscape. Some areas burn 

more frequently than others, some burn hardly at all. 

So it's using prescriptive fire to put it back into 

that historic fire condition. Several of those areas 

that historically burned in that 7 to 14-year period 

haven't seen fire in 60 or 70 years, and that's why 

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substantial increase in proposed wilderness areas, 

substantial recommendations for some road closures. 

Same thing here on the east side of the refuge. 

Kind of some of the highlights of this one is we 

actively manage, manipulate habitats to create 

productive wildlife food and cover. We implement 

prescriptive grazing on about 50 to 75 percent of the 

refuge within a time period of four to seven years. We 

get aggressive in restoring the river bottoms. We work 

with Montana Fish Wildlife and Parks to provide quality 

hunting opportunities and sustain the populations of 

big game, and also the habitat for non-game species. 

Close approximately 106 miles of roads, and expand the 

acreage of proposed wilderness by 25,000. 

Then we move to "Alternative C," and this is kind 

of the Public Use and Economic Emphasis. And this 

someone again manages that landscape with your partners 

to emphasize and promote maximum compatible wildlife 

while protecting wildlife populations and habitats to 

the extent possible. We minimize damage to wildlife 

habitats while using a variety of management tools to 

enhance the diversity of public and economic 

opportunities. 

And again, the map. Very few road closures, no 

road closures, just a couple seasons proposed, no 

1

2

3

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5

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expansion of wilderness. There is a couple of 

suggestions to eliminate some wilderness in proposed C, 

some proposed wilderness areas. 

So the main bullets for this one is manage habitats 

1

2

3

4

5

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injurious to the habitats or to the ecological process. 

Under this alternative we did propose expanding a 

couple of proposed wilderness areas. We did propose to 

eliminate a few as we got a few recommendations for 

some road closures. Same thing here on the east end. 

So under this alternative, the main points of it, 

economic uses would be limited when they are causing 

injury to ecological processes for the habitats out 

there. We'd apply management practices that mimic and 

restore natural processes, use fire and grazing whether 

its with wild or livestock, so prescriptively to mimic 

that historic interaction. Work with Fish Wildlife and 

Parks and maintain health and diversity of all species. 

Do about 25 miles of all road closures. We'd recommend 

expanding six of the proposed wilderness areas for 

about 18,000 acres, but also eliminating three for a 

loss of 26,000. 

So we've been doing several of these meetings now, 

and it's kind of the hot button topics that we've been 

hearing, prescriptive grazing, what is it? And 

basically it's using livestock to achieve a specific 

wildlife and/or habitat objective. One example is that 

let's say you have an area that is an important sage 

grouse breeding ground or important sage grouse 

wintering ground, and we've got a large grass buildup 

1

2

3

4

5

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in that area, and we can't use prescribed fire, or we 

don't want to use prescribed fire because of the 

potential impact on that sage grouse area. We could 

use livestock in a prescription to go in there and 

1

2

3

4

5

02/14/2011 11:36:41 AM Page 6 to 9 of 54 

6

substantial increase in proposed wilderness areas, 

substantial recommendations for some road closures. 

Same thing here on the east side of the refuge. 

Kind of some of the highlights of this one is we 

actively manage, manipulate habitats to create 

productive wildlife food and cover. We implement 

prescriptive grazing on about 50 to 75 percent of the 

refuge within a time period of four to seven years. We 

get aggressive in restoring the river bottoms. We work 

with Montana Fish Wildlife and Parks to provide quality 

hunting opportunities and sustain the populations of 

big game, and also the habitat for non-game species. 

Close approximately 106 miles of roads, and expand the 

acreage of proposed wilderness by 25,000. 

Then we move to "Alternative C," and this is kind 

of the Public Use and Economic Emphasis. And this 

someone again manages that landscape with your partners 

to emphasize and promote maximum compatible wildlife 

while protecting wildlife populations and habitats to 

the extent possible. We minimize damage to wildlife 

habitats while using a variety of management tools to 

enhance the diversity of public and economic 

opportunities. 

And again, the map. Very few road closures, no 

road closures, just a couple seasons proposed, no 

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expansion of wilderness. There is a couple of 

suggestions to eliminate some wilderness in proposed C, 

some proposed wilderness areas. 

So the main bullets for this one is manage habitats 

to provide more opportunities for recreation, maintain 

balance numbers of big game and livestock. Work with 

Fish Wildlife and Parks to expand and maximize hunting 

opportunities. Improve access to boat ramps and 

recommend eliminating four proposed wilderness areas 

for reduction of 35,880 acres. 

And then we move to "Alternative D," and this is 

our Proposed Action Alternative. We coin this one the 

Natural Processes or the Ecological Processes. And, 

again, working in cooperation with our partners, using 

those natural economic processes of fire, grazing, 

flooding, and active management, tree planting, farming 

in a balanced responsible manner to restore and/or 

maintain biological diversity, biological integrity and 

environmental health. 

Those three things right there come right from your 

Improvement Act as to what we're supposed to be doing 

here. Once we've restored those natural resources we 

take a more passive management approach. We still 

provide for those quality wildlife-dependent public 

uses and experiences, and we limit when they are either 

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injurious to th

Under this 

couple of prop

eliminate a few 

some road closu

So under this 

economic uses w

injury to ecol

there. We'd ap

restore natura

its with wild 

that historic 

Parks and main

Do about 25 mi

expanding six 

about 18,000 a

loss of 26,000

So we've b

and it's kind 

hearing, presc

basically it's 

wildlife and/o

let's say you h

grouse breeding 

wintering groun

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in that area, 

don't want to u

potential impa

use livestock 

reduce that fue

wildfire event

Prescripti

working with f

the past five 

scientists to 

the refuge, and 

have been work

level. And wh

the refuge tha

to 14-year time 

refuge that ma

years, so we h

And the id

determine that 

restore that b

more frequentl

So it's using p

that historic 

that historica

haven't seen f

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VOLUME 2, Chapter 4—Public Hearing Testimony 415

4 of 16 sheets Page 10 to 13 of 54 

10

you'd use prescriptive fire to reduce the fuel in that 

area and put it back into that condition. 

As part of the CCP process, we're mandated to look 

at our proposed wilderness areas and to evaluate those 

areas to see if they are still meeting those wilderness 

characteristics in which they were set aside for. So 

part of it is a subjective call on our part as to 

whether those areas still meet those wilderness 

characteristics in which they were established. And so 

in some of the alternatives, that's why we proposed 

expanding some areas and others we proposed eliminating 

some areas. A lot of it is based on the main topic of 

what that alternative was, and then the other is, 

again, a subjective examination of those -- those 

areas. 

The same thing with roads. We look at roads. Some 

of the roads that we proposed to close are roads that 

cross private property before entering the refuge, and 

there's either limited public access or no public 

access, and so, therefore, we can't create an exclusive 

use on the refuge, so those roads were proposed to be 

closed. Others, it's a fragmenting of the habitat, so 

it would allow animals to move more freely. Others 

it's a maintenance type issue. 

And then bison. Quite a few talks concerning 

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bison. I can just come out and say that we do not have 

a plan from the Fish and Wildlife Service to 

re-introduce bison. What's in the plan is based upon 

talks by Montana Fish Wildlife and Parks where they 

were considering, or they were looking to consider, 

evaluating the possibility of reintroducing bison 

somewhere in Montana. If such a proposal went forward, 

and if such a proposal identified areas around the 

refuge, we wanted to have something in our plan that 

addressed that. So everything in our plan is based 

upon Fish, Wildlife & Parks taking the lead and pulling 

together a bison proposal. So the service will not be 

reintroducing wild bison or creating a fence bison herd 

on the refuge. 

So as Mimi said, we're here to gather your 

comments. There are several ways to comment. One is 

through your public testimony today. The other is by 

one of the forms that was handed out to you as you came 

in the door. You can write your comment on that, drop 

it off as you leave today, or you can mail those back 

to us. You can send us a written letter. The 

addresses are on those forms; they are in the document. 

You can send Laurie an e-mail. She doesn't get nearly 

enough e-mails at work. And right now our comment 

period is scheduled to end November the 16th. We have 

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received nu

period. We 

decision wi

right now t

service is 

but a decis

weeks. 

So we'

and if you 

take all th

them as we 

rearranging 

next portio

of everybod

I'll call u

be ready. 

into the mi

it. We've 

proceedings

As Bar

that's fine

and Bill wi

15 minutes 

questions t

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rule. So y

to be stric

Husong is m

for two min

he'll waive 

20 seconds, 

which case 

person. Ot

keep things 

opinion, th

So with tha

got Nancy o

Medicine La

Refuge. Ca

question. 

cost (indic

shredding t

that master 

Medicine La

did the par

Was it $800 

dollars? H

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you'd use prescriptive fire to reduce the fuel in that 

area and put it back into that condition. 

As part of the CCP process, we're mandated to look 

at our proposed wilderness areas and to evaluate those 

areas to see if they are still meeting those wilderness 

characteristics in which they were set aside for. So 

part of it is a subjective call on our part as to 

whether those areas still meet those wilderness 

characteristics in which they were established. And so 

in some of the alternatives, that's why we proposed 

expanding some areas and others we proposed eliminating 

some areas. A lot of it is based on the main topic of 

what that alternative was, and then the other is, 

again, a subjective examination of those -- those 

areas. 

The same thing with roads. We look at roads. Some 

of the roads that we proposed to close are roads that 

cross private property before entering the refuge, and 

there's either limited public access or no public 

access, and so, therefore, we can't create an exclusive 

use on the refuge, so those roads were proposed to be 

closed. Others, it's a fragmenting of the habitat, so 

it would allow animals to move more freely. Others 

it's a maintenance type issue. 

And then bison. Quite a few talks concerning 

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bison. I can just come out and say that we do not have 

a plan from the Fish and Wildlife Service to 

re-introduce bison. What's in the plan is based upon 

talks by Montana Fish Wildlife and Parks where they 

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received numerous requests to extend that comment 

period. We are evaluating those requests, and a 

decision will be made in the next couple weeks, but 

right now there's still four weeks left, and so the 

service is not entertaining an extension at this time, 

but a decision will be made within the next couple of 

weeks. 

So we're going to open the floor up to you guys, 

and if you want to ask a question, go ahead. We'll 

take all those questions down and answer as many of 

them as we can at the end of the meeting. Thanks. 

MS. MATHER: While these guys are 

rearranging up here, I'll explain how we'll run the 

next portion of the comment period. So I've got a list 

of everybody that signed up. I'll call the folks off. 

I'll call up who's up next and who's on deck so you can 

be ready. What we'd ask is you come up here, speak 

into the microphone, please state your name and spell 

it. We've got a court reporter recording the 

proceedings. 

As Barron mentioned, if you just have a question, 

that's fine, come on up and ask your question. Barron 

and Bill will be taking notes, and we'll have about 

15 minutes at the end so we can respond to the 

questions they heard. Other than that, three-minute 

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rule. So you have three minutes up here. We're going 

to be strict to keeping you to three minutes. Brett 

Husong is my time keeper up here. When you've spoken 

for two minutes and you only have one minute left, 

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Page 6 to 9 of 54 3 of 16 sheets

age to wildlife 

agement tools to 

conomic 

ad closures, no 

proposed, no 

7

couple of 

ess in proposed C, 

 is manage habitats 

reation, maintain 

tock. Work with 

 maximize hunting 

t ramps and 

ilderness areas 

 D," and this is 

coin this one the 

rocesses. And, 

r partners, using 

ire, grazing, 

 planting, farming 

estore and/or 

ical integrity and 

ome right from your 

osed to be doing 

ral resources we 

ch. We still 

pendent public 

en they are either 

hearing, prescriptive grazing, what is it? And 

basically it's using livestock to achieve a specific 

wildlife and/or habitat objective. One example is that 

let's say you have an area that is an important sage 

grouse breeding ground or important sage grouse 

wintering ground, and we've got a large grass buildup 

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in that area, and we can't use prescribed fire, or we 

don't want to use prescribed fire because of the 

potential impact on that sage grouse area. We could 

use livestock in a prescription to go in there and 

reduce that fuel load to protect that area from a 

wildfire event. 

Prescriptive fire, how will it be used? We've been 

working with five ecologists across the refuge now for 

the past five years, and along with some rain 

scientists to look at the historic fire frequency on 

the refuge, and we started at a very close level and 

have been working our way down to the very fine scale 

level. And what we found is we've got several areas on 

the refuge that historically burn within about a seven 

to 14-year time period. We have several areas on the 

refuge that maybe burn once every several hundred 

years, so we have quite a range.

And the idea is to go in and look at those areas, 

determine that historic fire frequency, and try to 

restore that back to that landscape. Some areas burn 

more frequently than others, some burn hardly at all. 

So it's using prescriptive fire to put it back into 

that historic fire condition. Several of those areas 

that historically burned in that 7 to 14-year period 

haven't seen fire in 60 or 70 years, and that's why 

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4 of 16 sheets Page 10 to 13 of 54 02/14/2011 11:36:41 AM

10

you'd use prescriptive fire to reduce the fuel in that 

area and put it back into that condition. 

As part of the CCP process, we're mandated to look 

at our proposed wilderness areas and to evaluate those 

areas to see if they are still meeting those wilderness 

characteristics in which they were set aside for. So 

part of it is a subjective call on our part as to 

whether those areas still meet those wilderness 

characteristics in which they were established. And so 

in some of the alternatives, that's why we proposed 

expanding some areas and others we proposed eliminating 

some areas. A lot of it is based on the main topic of 

what that alternative was, and then the other is, 

again, a subjective examination of those -- those 

areas. 

The same thing with roads. We look at roads. Some 

of the roads that we proposed to close are roads that 

cross private property before entering the refuge, and 

there's either limited public access or no public 

access, and so, therefore, we can't create an exclusive 

use on the refuge, so those roads were proposed to be 

closed. Others, it's a fragmenting of the habitat, so 

it would allow animals to move more freely. Others 

it's a maintenance type issue. 

And then bison. Quite a few talks concerning 

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bison. I can just come out and say that we do not have 

a plan from the Fish and Wildlife Service to 

re-introduce bison. What's in the plan is based upon 

talks by Montana Fish Wildlife and Parks where they 

were considering, or they were looking to consider, 

evaluating the possibility of reintroducing bison 

somewhere in Montana. If such a proposal went forward, 

and if such a proposal identified areas around the 

refuge, we wanted to have something in our plan that 

addressed that. So everything in our plan is based 

upon Fish, Wildlife & Parks taking the lead and pulling 

together a bison proposal. So the service will not be 

reintroducing wild bison or creating a fence bison herd 

on the refuge. 

So as Mimi said, we're here to gather your 

comments. There are several ways to comment. One is 

through your public testimony today. The other is by 

one of the forms that was handed out to you as you came 

in the door. You can write your comment on that, drop 

it off as you leave today, or you can mail those back 

to us. You can send us a written letter. The 

addresses are on those forms; they are in the document. 

You can send Laurie an e-mail. She doesn't get nearly 

enough e-mails at work. And right now our comment 

period is scheduled to end November the 16th. We have 

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received numerous requests to extend that comment 

period. We are evaluating those requests, and a 

decision will be made in the next couple weeks, but 

right now there's still four weeks left, and so the 

service is not entertaining an extension at this time, 

but a decision will be made within the next couple of 

weeks. 

So we're going to open the floor up to you guys, 

and if you want to ask a question, go ahead. We'll 

take all those questions down and answer as many of 

them as we can at the end of the meeting. Thanks. 

MS. MATHER: While these guys are 

rearranging up here, I'll explain how we'll run the 

next portion of the comment period. So I've got a list 

of everybody that signed up. I'll call the folks off. 

I'll call up who's up next and who's on deck so you can 

be ready. What we'd ask is you come up here, speak 

into the microphone, please state your name and spell 

it. We've got a court reporter recording the 

proceedings. 

As Barron mentioned, if you just have a question, 

that's fine, come on up and ask your question. Barron 

and Bill will be taking notes, and we'll have about 

15 minutes at the end so we can respond to the 

questions they heard. Other than that, three-minute 

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rule. So you have three minutes up here. We're going 

to be strict to keeping you to three minutes. Brett 

Husong is my time keeper up here. When you've spoken 

for two minutes and you only have one minute left, 

he'll waive the one minute, and when you're down to 

20 seconds, that's when it's time to wrap it up, in 

which case we'll ask you to move the mic. to the next 

person. Other than that, we'd just ask, in order to 

keep things running smoothly and respect one another's 

opinion, that you hold back from cheering or applause. 

So with that, Kenneth is first on our list, and I've 

got Nancy on deck.

KENNETH LOCKE: MR. Kenneth A. Locke, 

Medicine Lake, next to the Medicine Lake Wildlife 

Refuge. Can I ask questions? 

MS. MATHER: Yes. You can ask your 

question. You won't get an answer until the end. 

KENNETH LOCKE: How much did this thing 

cost (indicating)? That's what they're using for 

shredding the trees at Medicine Lake. How much did 

that master plan cost? How much is the budget at 

Medicine Lake Wildlife Refuge for one year? How much 

did the parking lot at the Medicine Lake Refuge cost? 

Was it $800 and some thousand or was it a million 

dollars? How much was the parking lot at Fort Peck? 

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416 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 10 to 13 of 54 02/14/2011 11:36:41 AM

posed to be 

 habitat, so 

. Others 

ncerning 

11

e do not have 

to 

 based upon 

here they 

consider, 

g bison 

went forward, 

ound the 

 plan that 

 is based 

d and pulling 

 will not be 

ce bison herd 

 your 

nt. One is 

other is by 

u as you came 

n that, drop 

 those back 

The 

the document. 

t get nearly 

 comment 

th. We have 

As Barron mentioned, if you just have a question, 

that's fine, come on up and ask your question. Barron 

and Bill will be taking notes, and we'll have about 

15 minutes at the end so we can respond to the 

questions they heard. Other than that, three-minute 

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rule. So you have three minutes up here. We're going 

to be strict to keeping you to three minutes. Brett 

Husong is my time keeper up here. When you've spoken 

for two minutes and you only have one minute left, 

he'll waive the one minute, and when you're down to 

20 seconds, that's when it's time to wrap it up, in 

which case we'll ask you to move the mic. to the next 

person. Other than that, we'd just ask, in order to 

keep things running smoothly and respect one another's 

opinion, that you hold back from cheering or applause. 

So with that, Kenneth is first on our list, and I've 

got Nancy on deck.

KENNETH LOCKE: MR. Kenneth A. Locke, 

Medicine Lake, next to the Medicine Lake Wildlife 

Refuge. Can I ask questions? 

MS. MATHER: Yes. You can ask your 

question. You won't get an answer until the end. 

KENNETH LOCKE: How much did this thing 

cost (indicating)? That's what they're using for 

shredding the trees at Medicine Lake. How much did 

that master plan cost? How much is the budget at 

Medicine Lake Wildlife Refuge for one year? How much 

did the parking lot at the Medicine Lake Refuge cost? 

Was it $800 and some thousand or was it a million 

dollars? How much was the parking lot at Fort Peck? 

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02/14/2011 11:36:41 AM Page 14 to 17 of 54 

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Was it a hundred thousand for the employees to park on, 

or was it less? Why are you cutting trees down for 

pipets? How many pipets do we have at Medicine Lake? 

And I'll reserve the rest of my time. 

MS. MATHER: Thanks, Kenneth. Nancy with 

Ron on deck. 

NANCY HEINS: My name's Nancy Heins. I'm 

from Fort Peck, H-e-i-n-s. I had one basic question. 

Last fall we had a tremendous deer problem around the 

Fort Peck area, and I ask, who is responsible for the 

deer, CMR or the Corp? And I have not been able to get 

a straight answer, and I really would like to know 

that. 

MS. MATHER: Thanks, Nancy. Ron with 

Dave on deck. Dave Pippin. 

MR. GARWOOD: Yeah, my name is Ron 

Garwood. I'm a Valley County Conservation District 

supervisor, immediate past chairman. And I've -- the 

conservation district gave me permission to speak for 

them. And I have a -- have a written thing here from 

them that I wrote up. 

I've been hunting out on the CMR since '57, and it 

was a Fort Peck game range at that time, and -- and 

it's much the same now as it was then, except we don't 

have near the roads to drive on anymore. Ever since 

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the Fish and Wildlife Service took it over in '76 

they've been closing off roads, and the reason they're 

closing off roads is they're putting in these proposed 

wilderness areas out there, which we don't need out 

there. Anyone that has ever driven through that 

country can see that it's protected out there. No 

one's going to move out there. It's rugged country. 

And why do we have to have wilderness areas out 

there? When they do that, they have to close off all 

the roads within that area, and as hunters, it's hard 

for us to get around anymore. If we get something, 

it's hard to get them out to keep from spoiling, and so 

I'm not too happy with the Fish and Wildlife Service 

over that. 

The board -- the board of supervisors of the Valley 

County Conservation District are in favor of option "A" 

of the Comprehensive Conservation Plan and 

Environmental Impact Statement, which is no action. 

And most of the people that I've talked to about this 

say, well, why don't we just leave it the way it is? 

And most of Montanans, I believe -- I feel, believe 

that way, and especially native Montanans, and I 

consider myself a native Montanan because I was born 

and raised here, and I'm still here. I'm a native 

Montanan. And there's a lot of us here that are that 

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way, and I thin

We would li

of the comment 

two-and-a-half 

and Wildlife Se

still hasn't sh

to blame it on 

still like to g

But we are 

overseeing soil 

County, and I f

the true conser

isn't these env

problems for us

Tax free money 

Wildlife Servic

threaten to sue 

it's right or f

There's eno

now; we don't n

bison on the CM

and we feel tha

asinine. I can

this out there. 

fires, they got 

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they want to go 

fire? We can't 

MS

MR

County Conserva

Fish and Wildli

be a good neigh

keeping the man

last 25 years. 

chance to talk. 

pretty good guy

even though the 

company man and 

MR

MS

Janelle Holden 

CO

Dave Pippin. I 

generation Vall

through a new C

important to kn

comprises of.

Ballentine'

as "Such lands 

under general l

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Was it a hundred thousand for the employees to park on, 

or was it less? Why are you cutting trees down for 

pipets? How many pipets do we have at Medicine Lake? 

And I'll reserve the rest of my time. 

MS. MATHER: Thanks, Kenneth. Nancy with 

Ron on deck. 

NANCY HEINS: My name's Nancy Heins. I'm 

from Fort Peck, H-e-i-n-s. I had one basic question. 

Last fall we had a tremendous deer problem around the 

Fort Peck area, and I ask, who is responsible for the 

deer, CMR or the Corp? And I have not been able to get 

a straight answer, and I really would like to know 

that. 

MS. MATHER: Thanks, Nancy. Ron with 

Dave on deck. Dave Pippin. 

MR. GARWOOD: Yeah, my name is Ron 

Garwood. I'm a Valley County Conservation District 

supervisor, immediate past chairman. And I've -- the 

conservation district gave me permission to speak for 

them. And I have a -- have a written thing here from 

them that I wrote up. 

I've been hunting out on the CMR since '57, and it 

was a Fort Peck game range at that time, and -- and 

it's much the same now as it was then, except we don't 

have near the roads to drive on anymore. Ever since 

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the Fish and Wildlife Service took it over in '76 

they've been closing off roads, and the reason they're 

closing off roads is they're putting in these proposed 

wilderness areas out there, which we don't need out 

thAtht hdithh tht 

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way, and I think we feel the same way. 

We would like to ask for a 30 to 60 day extension 

of the comment period. Probably about two, 

two-and-a-half months ago I sent my card in to the Fish 

and Wildlife Service to get my big book. Well, it 

still hasn't showed up in the mail. I guess we'll have 

to blame it on the postal service, but, anyway, I would 

still like to get that. One minute left? 

But we are elected officials charged with 

overseeing soil and water conservation in Valley 

County, and I feel that the farmers and ranchers are 

the true conservationalists [sic] in this country. It 

isn't these environmental groups that are causing 

problems for us. They have money, big, free money. 

Tax free money is given to them to sue the Fish and 

Wildlife Service to do things. They either sue or they 

threaten to sue to get things done, and I don't think 

it's right or fair. 

There's enough wilderness area out in the CMR right 

now; we don't need anymore. We don't want free roaming 

bison on the CMR. We do not want wolves on the CMR, 

and we feel that prescribed burning on the CMR is just 

asinine. I can't believe that they're even considering 

this out there. When they go out there and fight 

fires, they got backpacks on. Good gosh, you know, and 

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they want to go out there and start up a prescribed 

fire? We can't trust them.

MS. MATHER: Ron, we need to interrupt.

MR. GARWOOD: Anyway, we, the Valley 

CtCtiDitit ik thUS

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Was it a hundred thousand for the employees to park on, 

or was it less? Why are you cutting trees down for 

pipets? How many pipets do we have at Medicine Lake? 

And I'll reserve the rest of my time. 

MS. MATHER: Thanks, Kenneth. Nancy with 

Ron on deck. 

NANCY HEINS: My name's Nancy Heins. I'm 

from Fort Peck, H-e-i-n-s. I had one basic question. 

Last fall we had a tremendous deer problem around the 

Fort Peck area, and I ask, who is responsible for the 

deer, CMR or the Corp? And I have not been able to get 

a straight answer, and I really would like to know 

that. 

MS. MATHER: Thanks, Nancy. Ron with 

Dave on deck. Dave Pippin. 

MR. GARWOOD: Yeah, my name is Ron 

Garwood. I'm a Valley County Conservation District 

supervisor, immediate past chairman. And I've -- the 

conservation district gave me permission to speak for 

them. And I have a -- have a written thing here from 

them that I wrote up. 

I've been hunting out on the CMR since '57, and it 

was a Fort Peck game range at that time, and -- and 

it's much the same now as it was then, except we don't 

have near the roads to drive on anymore. Ever since 

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the Fish and Wildlife Service took it over in '76 

they've been closing off roads, and the reason they're 

closing off roads is they're putting in these proposed 

wilderness areas out there, which we don't need out 

there. Anyone that has ever driven through that 

country can see that it's protected out there. No 

one's going to move out there. It's rugged country. 

And why do we have to have wilderness areas out 

there? When they do that, they have to close off all 

the roads within that area, and as hunters, it's hard 

for us to get around anymore. If we get something, 

it's hard to get them out to keep from spoiling, and so 

I'm not too happy with the Fish and Wildlife Service 

over that. 

The board -- the board of supervisors of the Valley 

County Conservation District are in favor of option "A" 

of the Comprehensive Conservation Plan and 

Environmental Impact Statement, which is no action. 

And most of the people that I've talked to about this 

say, well, why don't we just leave it the way it is? 

And most of Montanans, I believe -- I feel, believe 

that way, and especially native Montanans, and I 

consider myself a native Montanan because I was born 

and raised here, and I'm still here. I'm a native 

Montanan. And there's a lot of us here that are that 

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way, and I think we feel the same way. 

We would like to ask for a 30 to 60 day extension 

of the comment period. Probably about two, 

two-and-a-half months ago I sent my card in to the Fish 

and Wildlife Service to get my big book. Well, it 

still hasn't showed up in the mail. I guess we'll have 

to blame it on the postal service, but, anyway, I would 

still like to get that. One minute left? 

But we are elected officials charged with 

overseeing soil and water conservation in Valley 

County, and I feel that the farmers and ranchers are 

the true conservationalists [sic] in this country. It 

isn't these environmental groups that are causing 

problems for us. They have money, big, free money. 

Tax free money is given to them to sue the Fish and 

Wildlife Service to do things. They either sue or they 

threaten to sue to get things done, and I don't think 

it's right or fair. 

There's enough wilderness area out in the CMR right 

now; we don't need anymore. We don't want free roaming 

bison on the CMR. We do not want wolves on the CMR, 

and we feel that prescribed burning on the CMR is just 

asinine. I can't believe that they're even considering 

this out there. When they go out there and fight 

fires, they got backpacks on. Good gosh, you know, and 

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they want to go out there and start up a prescribed 

fire? We can't trust them.

MS. MATHER: Ron, we need to interrupt.

MR. GARWOOD: Anyway, we, the Valley 

County Conservation District supervisors, ask the U.S. 

Fish and Wildlife Service to respect Valley County and 

be a good neighbor by considering Alternate A and 

keeping the management the same as it has been for the 

last 25 years. And, once again, we thank you for the 

chance to talk. And I have got to know Bill Berg, 

pretty good guy, and I even kind of like Barron now, 

even though the first time I seen him I knew he was a 

company man and he wasn't going to listen to us. 

MR. CRAWFORD: I like Ron too. 

MS. MATHER: Thanks, Ron. Dave Pippin, 

Janelle Holden on deck.

COMMISSIONER PIPPIN: Hello. My name is 

Dave Pippin. I am a resident of Valley County, third 

generation Valley County resident. As we journey 

through a new CCP and EIS plan I think it's really 

important to know and understand what public land 

comprises of.

Ballentine's Law Dictionary describes public land 

as "Such lands as are open to sale or other disposition 

under general law." In the passing years some have 

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VOLUME 2, Chapter 4—Public Hearing Testimony 417

Page 14 to 17 of 54 5 of 16 sheets

 thing here from 

since '57, and it 

me, and -- and 

, except we don't 

re. Ever since 

15

 over in '76 

he reason they're 

in these proposed 

don't need out 

hrough that 

ut there. No 

rugged country. 

ness areas out 

to close off all 

nters, it's hard 

get something, 

m spoiling, and so 

ildlife Service 

sors of the Valley 

avor of option "A" 

n and 

 is no action. 

ed to about this 

 the way it is? 

 feel, believe 

nans, and I 

ause I was born 

I'm a native 

re that are that 

now; we dont need anymore. We dont want free roaming 

bison on the CMR. We do not want wolves on the CMR, 

and we feel that prescribed burning on the CMR is just 

asinine. I can't believe that they're even considering 

this out there. When they go out there and fight 

fires, they got backpacks on. Good gosh, you know, and 

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they want to go out there and start up a prescribed 

fire? We can't trust them.

MS. MATHER: Ron, we need to interrupt.

MR. GARWOOD: Anyway, we, the Valley 

County Conservation District supervisors, ask the U.S. 

Fish and Wildlife Service to respect Valley County and 

be a good neighbor by considering Alternate A and 

keeping the management the same as it has been for the 

last 25 years. And, once again, we thank you for the 

chance to talk. And I have got to know Bill Berg, 

pretty good guy, and I even kind of like Barron now, 

even though the first time I seen him I knew he was a 

company man and he wasn't going to listen to us. 

MR. CRAWFORD: I like Ron too. 

MS. MATHER: Thanks, Ron. Dave Pippin, 

Janelle Holden on deck.

COMMISSIONER PIPPIN: Hello. My name is 

Dave Pippin. I am a resident of Valley County, third 

generation Valley County resident. As we journey 

through a new CCP and EIS plan I think it's really 

important to know and understand what public land 

comprises of.

Ballentine's Law Dictionary describes public land 

as "Such lands as are open to sale or other disposition 

under general law." In the passing years some have 

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6 of 16 sheets Page 18 to 21 of 54 

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come to think that the changing of this definition may 

have eliminated many acquired rights and benefits that 

were acquired in an earlier time, long before the CMR. 

This is not the case. 

The CCP/EIS a document that has far reaching 

consequence and is of great importance to decide and 

evaluate all the existing rights on the CMR held by 

individuals and local governments before a new policy 

is set. It is also important to note that the FLMA, 

NEPA, Taylor Grazing Act and many other executive 

orders all address existing rights in various ways, and 

all have a savings clause that demand that existing 

rights will not be extinguished because of the 

enactment of new federal policy.

It should be further noted that the Data Quality 

Act directs the Office of Management and Budget to 

issue government-wide guidelines that provide policy 

and procedural guidance to federal agencies for 

ensuring and maximizing the quality, objectivity, 

utility and integrity of information, including 

statistical information disseminated by federal 

agencies. 

I believe that a comprehensive, independent study 

on prescriptive grazing and burning are required if you 

truly are to have an accurate, workable document. I 

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believe that the number of visitors visiting the CMR is 

a figure that is too high, as it includes many people 

that are not really visitors to the CMR, per se. I 

also question whether an accurate EIS statement has 

been done in a completed form. An environmental impact 

statement is a document required by the National 

Environmental Policy Act for federal government agency 

significantly affecting the quality of the human 

environment. 

A tool for decision making, an EIS describes the 

positive and negative environmental effects of proposed 

agency action and cites alternative actions. Several 

U.S. state governments have also adopted "little 

NEPA's". State laws imposing EIS requirements for 

particular statement actions. Montana has many of 

these and are -- and all are not listed in this 

coordination process. 

A full financial note of the cost to local 

economies is essential if we are to be treated fairly 

and be in compliance of the law. Surely a land mass 

that had 70,000 cattle on it in 1984 and only has 

18,000 grazing cattle on it in 2010 is a very 

considerable loss of value to the counties compromised 

by this reduction in livestock production. 

Partitioned roads and historical RS2477 right of 

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ways have 

document m

was not gr

offered to 

than the c

address ex

saving -- 

local gove

offered co

These 

observed a

Plan which 

this propo

time to Mr

plan "A". 

with a str

many of th

assumption 

documents 

away is to

far reachi

Most 

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presented 

time and e

them in a 

with fairn

public min

of all the 

with these 

us. 

deck. 

H-o-l-d-e-

Bozeman. 

recommende

wilderness 

"Alternati

recommenda

which woul

for road e

We va

the CMR Re

public lan

Wildlife S

for wildli

Service ha

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come to think that the changing of this definition may 

have eliminated many acquired rights and benefits that 

were acquired in an earlier time, long before the CMR. 

This is not the case. 

The CCP/EIS a document that has far reaching 

consequence and is of great importance to decide and 

evaluate all the existing rights on the CMR held by 

individuals and local governments before a new policy 

is set. It is also important to note that the FLMA, 

NEPA, Taylor Grazing Act and many other executive 

orders all address existing rights in various ways, and 

all have a savings clause that demand that existing 

rights will not be extinguished because of the 

enactment of new federal policy.

It should be further noted that the Data Quality 

Act directs the Office of Management and Budget to 

issue government-wide guidelines that provide policy 

and procedural guidance to federal agencies for 

ensuring and maximizing the quality, objectivity, 

utility and integrity of information, including 

statistical information disseminated by federal 

agencies. 

I believe that a comprehensive, independent study 

on prescriptive grazing and burning are required if you 

truly are to have an accurate, workable document. I 

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believe that the number of visitors visiting the CMR is 

a figure that is too high, as it includes many people 

that are not really visitors to the CMR, per se. I 

also question whether an accurate EIS statement has 

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20

ways have not been documented and identified on CCP 

document maps. The fact is that coordinating status 

was not granted to the counties around the CMR but was 

offered to other organizations that have less standing 

than the counties have. Almost all federal policies 

address existing rights in various ways, and have a 

saving -- I'm on the wrong page there -- require that 

local governments have coordination and not only be 

offered cooperative status. 

These federal policy requirements should be 

observed and honored. Valley County has a Recourse Use 

Plan which was not coordinated within the formation of 

this proposed CCP plan. Not once has the U.S. --

MR. PAGE: I'll give two minutes of my 

time to Mr. Pippin. 

MS. MATHER: I'm afraid we don't do that.

MR. PIPPIN: In conclusion, I support 

plan "A". No change should be your only consideration 

with a strong emphasis on addressing and correcting 

many of the items that were done in the past. The 

assumption that we will address these items with other 

documents or at a later date, or maybe it will just go 

away is totally unacceptable in a document that has the 

far reaching effect such as this. 

Most people know that the points that I have 

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presented here today have been on your table for a long 

time and exist because your agency has not addressed 

them in a timely manner. Tax payers should be treated 

with fairness and in a timely fashion. To let other 

1

2

3

4

6 of 16 sheets Page 18 to 21 of 54 02/14/2011 11:36:41 AM

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come to think that the changing of this definition may 

have eliminated many acquired rights and benefits that 

were acquired in an earlier time, long before the CMR. 

This is not the case. 

The CCP/EIS a document that has far reaching 

consequence and is of great importance to decide and 

evaluate all the existing rights on the CMR held by 

individuals and local governments before a new policy 

is set. It is also important to note that the FLMA, 

NEPA, Taylor Grazing Act and many other executive 

orders all address existing rights in various ways, and 

all have a savings clause that demand that existing 

rights will not be extinguished because of the 

enactment of new federal policy.

It should be further noted that the Data Quality 

Act directs the Office of Management and Budget to 

issue government-wide guidelines that provide policy 

and procedural guidance to federal agencies for 

ensuring and maximizing the quality, objectivity, 

utility and integrity of information, including 

statistical information disseminated by federal 

agencies. 

I believe that a comprehensive, independent study 

on prescriptive grazing and burning are required if you 

truly are to have an accurate, workable document. I 

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5

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believe that the number of visitors visiting the CMR is 

a figure that is too high, as it includes many people 

that are not really visitors to the CMR, per se. I 

also question whether an accurate EIS statement has 

been done in a completed form. An environmental impact 

statement is a document required by the National 

Environmental Policy Act for federal government agency 

significantly affecting the quality of the human 

environment. 

A tool for decision making, an EIS describes the 

positive and negative environmental effects of proposed 

agency action and cites alternative actions. Several 

U.S. state governments have also adopted "little 

NEPA's". State laws imposing EIS requirements for 

particular statement actions. Montana has many of 

these and are -- and all are not listed in this 

coordination process. 

A full financial note of the cost to local 

economies is essential if we are to be treated fairly 

and be in compliance of the law. Surely a land mass 

that had 70,000 cattle on it in 1984 and only has 

18,000 grazing cattle on it in 2010 is a very 

considerable loss of value to the counties compromised 

by this reduction in livestock production. 

Partitioned roads and historical RS2477 right of 

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ways have not been documented and identified on CCP 

document maps. The fact is that coordinating status 

was not granted to the counties around the CMR but was 

offered to other organizations that have less standing 

than the counties have. Almost all federal policies 

address existing rights in various ways, and have a 

saving -- I'm on the wrong page there -- require that 

local governments have coordination and not only be 

offered cooperative status. 

These federal policy requirements should be 

observed and honored. Valley County has a Recourse Use 

Plan which was not coordinated within the formation of 

this proposed CCP plan. Not once has the U.S. --

MR. PAGE: I'll give two minutes of my 

time to Mr. Pippin. 

MS. MATHER: I'm afraid we don't do that.

MR. PIPPIN: In conclusion, I support 

plan "A". No change should be your only consideration 

with a strong emphasis on addressing and correcting 

many of the items that were done in the past. The 

assumption that we will address these items with other 

documents or at a later date, or maybe it will just go 

away is totally unacceptable in a document that has the 

far reaching effect such as this. 

Most people know that the points that I have 

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presented here today have been on your table for a long 

time and exist because your agency has not addressed 

them in a timely manner. Tax payers should be treated 

with fairness and in a timely fashion. To let other 

public minded groups with other agendas not be informed 

of all the existing rights and privileges that exist 

with these lands is unfair to them, and it is unfair to 

us. 

MS. MATHER: Janelle with Leonard on 

deck. 

JANELLE HOLDEN: Janelle Holden, 

H-o-l-d-e-n, with the Wilderness Society out of 

Bozeman. We support "Alternative D," with some 

recommended changes to the wilderness -- proposed 

wilderness that is recommended to be eliminated in 

"Alternative D". We actually support the 

recommendations for wilderness in "Alternative B," 

which would expand wilderness, and the recommendations 

for road elimination in "Alternative B". 

We value very much the proposed wilderness areas on 

the CMR Refuge; they are very rare in our prairie 

public lands. We value the fact that the Fish and 

Wildlife Service has a mission to manage this refuge 

for wildlife, and we think the Fish and Wildlife 

Service has done a good job of creating a range of 

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418 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 18 to 21 of 54 02/14/2011 11:36:41 AM

g 

deral 

ndent study 

quired if you 

cument. I 

19

ng the CMR is 

many people 

er se. I 

ement has 

mental impact 

tional 

nment agency 

 human 

cribes the 

s of proposed 

s. Several 

little 

ents for 

 many of 

 this 

ocal 

ated fairly 

 land mass 

nly has 

ery 

 compromised 

 

7 right of 

y p

assumption that we will address these items with other 

documents or at a later date, or maybe it will just go 

away is totally unacceptable in a document that has the 

far reaching effect such as this. 

Most people know that the points that I have 

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25

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presented here today have been on your table for a long 

time and exist because your agency has not addressed 

them in a timely manner. Tax payers should be treated 

with fairness and in a timely fashion. To let other 

public minded groups with other agendas not be informed 

of all the existing rights and privileges that exist 

with these lands is unfair to them, and it is unfair to 

us. 

MS. MATHER: Janelle with Leonard on 

deck. 

JANELLE HOLDEN: Janelle Holden, 

H-o-l-d-e-n, with the Wilderness Society out of 

Bozeman. We support "Alternative D," with some 

recommended changes to the wilderness -- proposed 

wilderness that is recommended to be eliminated in 

"Alternative D". We actually support the 

recommendations for wilderness in "Alternative B," 

which would expand wilderness, and the recommendations 

for road elimination in "Alternative B". 

We value very much the proposed wilderness areas on 

the CMR Refuge; they are very rare in our prairie 

public lands. We value the fact that the Fish and 

Wildlife Service has a mission to manage this refuge 

for wildlife, and we think the Fish and Wildlife 

Service has done a good job of creating a range of 

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02/14/2011 11:36:41 AM Page 22 to 25 of 54 

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alternatives that support managing the refuge or 

wildlife. Thank you. 

MS. MATHER: Thanks, Janelle. Leonard 

with Jason on deck. 

LEONARD SWENSEN: Okay. First of all, 

I'm Leonard Swensen. My grandfather homesteaded here 

over a hundred years ago, been involved with the CMR 

for 30 years in sharing grazing, and there's been -- in 

fact, it's been 40 years, and there's been 30 years 

prior to that, that other ranchers have enjoyed 

grazing. 

I'm not so sure I share the excitement of nearly 

three years you work to get 450 pages drawn up. I 

haven't read through all of those, like our health bill 

people. I didn't read over the overview, and I guess I 

thought A was the best one. Usually you have four 

alternatives, have a preferred one, we have the public 

meetings, and then you choose the one you want anyway, 

but it's our chance to toot our horn a little bit here. 

And the most important thing to me is, is that 

renewable resource we have, and it's grass. When we 

hear you talk about burning it, it really bothers me. 

It's a renewable resource here on Earth and to use 

wisely. When you don't graze it properly, lightning 

hits or else you come along and have to burn it. It's 

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-- this is the best fire prevention you have. And it's 

-- grazing is the best for the habitat for the 

wildlife, as your own range specialists from North 

Dakota had in a magazine here. 

Talk about wilderness; to me it's the same as waste

land. It's already a wilderness, it's not going to 

change when its a study area out there. It's used only 

a couple months out of the year by the majority of 

people, and they don't even get to it. 

There's going to be more fires than what you know 

what to do with because of the grasses this last year. 

I think the Interpretive Center in Fort Peck is great. 

I think the James Kip Recreation is great where the BLM 

helped people to view it. The elk bugling view area is 

great, but I often wonder how many more people had 

enjoyed the beauty of the refuge if you had left the 

roads not closed. 

A little history about Lewis and Clark, keep 

hearing about them. They saw very little of the CMR, a 

little bit by where Ron Garwood lives, the rest is in 

the lake right now. When it was a game range. Charlie 

Russell would have been really proud to have it named 

after him. Now I think he's turning over in his grave. 

I'll skip ahead here a little bit. 

BLM built reservoirs, developed grazing systems, 

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totally rested 

interior fencin

their managemen

land. When it 

and then they t

seven acres to 

excess grass st

This prescr

either. It's n

antelope object

spring went by 

where there was 

going to happen 

I think thi

The alternative

better solution

MS

microphone down 

deck. 

JA

Holt, J-a-s-o-n

MS

great idea.

JA

I'm new to Vall

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years ago, and 

prospective. A

the CMR and the 

relationship. 

if you treat th

sense of owners

The ranch I 

years ago the B

kick the cows o

pasture. My fa

mother-in-law c

pasture gets gr

16 months to re

results of this 

creek works the 

That's wher

but not the ran

sites, so we ha

implementing a 

our own initiat

creek, we will 

that we were su

I know the 

think you would 

were treated mo

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alternatives that support managing the refuge or 

wildlife. Thank you. 

MS. MATHER: Thanks, Janelle. Leonard 

with Jason on deck. 

LEONARD SWENSEN: Okay. First of all, 

I'm Leonard Swensen. My grandfather homesteaded here 

over a hundred years ago, been involved with the CMR 

for 30 years in sharing grazing, and there's been -- in 

fact, it's been 40 years, and there's been 30 years 

prior to that, that other ranchers have enjoyed 

grazing. 

I'm not so sure I share the excitement of nearly 

three years you work to get 450 pages drawn up. I 

haven't read through all of those, like our health bill 

people. I didn't read over the overview, and I guess I 

thought A was the best one. Usually you have four 

alternatives, have a preferred one, we have the public 

meetings, and then you choose the one you want anyway, 

but it's our chance to toot our horn a little bit here. 

And the most important thing to me is, is that 

renewable resource we have, and it's grass. When we 

hear you talk about burning it, it really bothers me. 

It's a renewable resource here on Earth and to use 

wisely. When you don't graze it properly, lightning 

hits or else you come along and have to burn it. It's 

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-- this is the best fire prevention you have. And it's 

-- grazing is the best for the habitat for the 

wildlife, as your own range specialists from North 

Dakota had in a magazine here. 

Talk about wilderness; to me it's the same as waste

land. It's already a wilderness, it's not going to 

change when its a study area out there. It's used only 

a couple months out of the year by the majority of 

people, and they don't even get to it. 

There's going to be more fires than what you know 

what to do with because of the grasses this last year. 

I think the Interpretive Center in Fort Peck is great. 

I think the James Kip Recreation is great where the BLM 

helped people to view it. The elk bugling view area is 

great, but I often wonder how many more people had 

enjoyed the beauty of the refuge if you had left the 

roads not closed. 

A little history about Lewis and Clark, keep 

hearing about them. They saw very little of the CMR, a 

little bit by where Ron Garwood lives, the rest is in 

the lake right now. When it was a game range. Charlie 

Russell would have been really proud to have it named 

after him. Now I think he's turning over in his grave. 

I'll skip ahead here a little bit. 

BLM built reservoirs, developed grazing systems, 

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totally rested pastures when we used it, put in some 

interior fencing, and the BLM took a lot of pride in 

their management of the land for the wildlife and the 

land. When it became a refuge, grazing fees doubled 

and then they tripled. The best ratio was 21 -- was 

seven acres to a cow. You guys wanted 21; that's when 

excess grass started. 

This prescriptive grazing doesn't make any sense 

either. It's not realistic, like your grouse and 

antelope objectives. And on the way to Billings last 

spring went by that pristine looking bull mountain area 

where there was a fire, and makes me wonder what's 

going to happen with the rest of this. 

I think this alternative -- I guess my time's up. 

The alternatives have a lot of BS in them, and there's 

better solutions. Thanks. 

MS. MATHER: You want to tip that 

microphone down a little bit. Jason and Mark Good on 

deck. 

JASON HOLT: Hi. My name is Jason A. 

Holt, J-a-s-o-n, A, H-o-l-t. 

MS. MATHER: Maybe that wasn't such a 

great idea.

JASON HOLT: Hi. My name is Jason Holt. 

I'm new to Valley County. I moved here about five 

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years ago, and so I kind of have an outsider's 

prospective. And looking around it seems to me like 

the CMR and the ranchers don't have such a good 

relationship. I'd like to tell you what would happen 

if you treat the ranchers as partners and gave them a 

sense of ownership. 

The ranch I live on is on BLM right now. About 10 

years ago the BLM looked at Timber Creek but didn't 

kick the cows off. They said, let's make it their own 

pasture. My father-in-law built fences, my 

mother-in-law came up with a rotation system so if a 

pasture gets grazed in the spring of one year it has 

16 months to recover from a spring grazing. The 

results of this cooperative effort is that today that 

creek works the way the BLM wants it to. 

That's where BLM's involvement in the project ends, 

but not the ranchers. We're still monitoring those 

sites, so we have our fingers on the poles. We were 

implementing a program to control creeping foxtail on 

our own initiative because we know if that gets that 

creek, we will no longer be able to have the sections 

that we were supposed to be managing for. 

I know the CMR has a problem with noxious weeds. I 

think you would have fewer problems if the ranchers 

were treated more like partners, because on our place 

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alternatives that support managing the refuge or 

wildlife. Thank you. 

MS. MATHER: Thanks, Janelle. Leonard 

with Jason on deck. 

LEONARD SWENSEN: Okay. First of all, 

I'm Leonard Swensen. My grandfather homesteaded here 

over a hundred years ago, been involved with the CMR 

for 30 years in sharing grazing, and there's been -- in 

fact, it's been 40 years, and there's been 30 years 

prior to that, that other ranchers have enjoyed 

grazing. 

I'm not so sure I share the excitement of nearly 

three years you work to get 450 pages drawn up. I 

haven't read through all of those, like our health bill 

people. I didn't read over the overview, and I guess I 

thought A was the best one. Usually you have four 

alternatives, have a preferred one, we have the public 

meetings, and then you choose the one you want anyway, 

but it's our chance to toot our horn a little bit here. 

And the most important thing to me is, is that 

renewable resource we have, and it's grass. When we 

hear you talk about burning it, it really bothers me. 

It's a renewable resource here on Earth and to use 

wisely. When you don't graze it properly, lightning 

hits or else you come along and have to burn it. It's 

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-- this is the best fire prevention you have. And it's 

-- grazing is the best for the habitat for the 

wildlife, as your own range specialists from North 

Dakota had in a magazine here. 

1

2

3

4

24

totally rested pastures when we used it, put in some 

interior fencing, and the BLM took a lot of pride in 

their management of the land for the wildlife and the 

land. When it became a refuge, grazing fees doubled 

and then they tripled. The best ratio was 21 -- was 

seven acres to a cow. You guys wanted 21; that's when 

excess grass started. 

This prescriptive grazing doesn't make any sense 

either. It's not realistic, like your grouse and 

antelope objectives. And on the way to Billings last 

spring went by that pristine looking bull mountain area 

where there was a fire, and makes me wonder what's 

going to happen with the rest of this. 

I think this alternative -- I guess my time's up. 

The alternatives have a lot of BS in them, and there's 

better solutions. Thanks. 

MS. MATHER: You want to tip that 

microphone down a little bit. Jason and Mark Good on 

deck. 

JASON HOLT: Hi. My name is Jason A. 

Holt, J-a-s-o-n, A, H-o-l-t. 

MS. MATHER: Maybe that wasn't such a 

great idea.

JASON HOLT: Hi. My name is Jason Holt. 

I'm new to Valley County. I moved here about five 

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years ago, and so I kind of have an outsider's 

prospective. And looking around it seems to me like 

the CMR and the ranchers don't have such a good 

relationship. I'd like to tell you what would happen 

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4
VOLUME 2, Chapter 4—Public Hearing Testimony 419

Page 22 to 25 of 54 7 of 16 sheets

grass. When we 

ally bothers me. 

th and to use 

erly, lightning 

to burn it. It's 

23

ou have. And it's 

t for the 

ts from North 

 the same as waste

s not going to 

e. It's used only 

e majority of 

 

an what you know 

s this last year. 

rt Peck is great. 

reat where the BLM 

gling view area is 

re people had 

ou had left the 

Clark, keep 

ttle of the CMR, a 

 the rest is in 

me range. Charlie 

to have it named 

over in his grave. 

razing systems, 

Holt, J-a-s-o-n, A, H-o-l-t. 

MS. MATHER: Maybe that wasn't such a 

great idea.

JASON HOLT: Hi. My name is Jason Holt. 

I'm new to Valley County. I moved here about five 

21

22

23

24

25

25

years ago, and so I kind of have an outsider's 

prospective. And looking around it seems to me like 

the CMR and the ranchers don't have such a good 

relationship. I'd like to tell you what would happen 

if you treat the ranchers as partners and gave them a 

sense of ownership. 

The ranch I live on is on BLM right now. About 10 

years ago the BLM looked at Timber Creek but didn't 

kick the cows off. They said, let's make it their own 

pasture. My father-in-law built fences, my 

mother-in-law came up with a rotation system so if a 

pasture gets grazed in the spring of one year it has 

16 months to recover from a spring grazing. The 

results of this cooperative effort is that today that 

creek works the way the BLM wants it to. 

That's where BLM's involvement in the project ends, 

but not the ranchers. We're still monitoring those 

sites, so we have our fingers on the poles. We were 

implementing a program to control creeping foxtail on 

our own initiative because we know if that gets that 

creek, we will no longer be able to have the sections 

that we were supposed to be managing for. 

I know the CMR has a problem with noxious weeds. I 

think you would have fewer problems if the ranchers 

were treated more like partners, because on our place 

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8 of 16 sheets Page 26 to 29 of 54 

26

we found some Russian fireweed and we went after it; 

you know, we tried pulling it and mowing it, and that 

doesn't work. We had to spray it, and we didn't want 

to because there's frogs that live in that creek. But 

my mother-in-law, she was really careful and made sure 

she was spraying individual plants, and there was lots 

of patches, and it was not close to a road. She had a 

lot of work, but she -- she sprayed and sprayed the 

next year, and we made sure our success in that in two 

ways. 

Number one, the frogs are still singing, and when 

mom went all she needed was a little bitty spray can, 

and it only took her one day. You can't get those 

results with your weed strike team because you've got 

65 habitat units to manage, but the ranchers will do it 

for you if they have a stake in it. That wasn't on 

mom's land, but it was on her ranch. It was a state 

section of BLM grazing land, but it was on her ranch. 

Doesn't matter what you want to accomplish. If you 

want more salt bush or maximillian sunflowers, fewer 

noxious weeds, whatever you want to accomplish, the 

ranchers can do it for you, cheaper than anybody you 

can hire, and they will do it for free, in fact, 

they'll pay you. Thanks for listening. 

MS. MATHER: Thanks, Jason. Mark's up 

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with Scott on deck. And. Again, if I can ask you guys 

to hold your applause. Thank you. 

MARK GOOD: My name's Mark Good. I work 

for the Montana Wilderness Association. I'll bet I 

don't get an applause. I'm from Great Falls and I just 

want to -- I think it's worth talking about the mission 

for a bit about the refuge. 

As a national wildlife refuge it's supposed to be 

managed different from other BLM and forest service 

lands, and as a guiding principle, the refuge is to 

manage for the enhancement and protection of wildlife, 

and I think it's through this plan that these decisions 

have to be made. 

I know a lot of people don't like a refuge, maybe 

some would wish it just to go away. But it's not, I 

don't think it is anyway, and I think the reason is 

because wildlife refuges are popular with the American 

public, and I think popular with most Montanans. I do 

think it would be maybe more productive to make this 

refuge work for local communities that surround here. 

I think it's no secret that the population of the 

eastern half of the state has been decreasing. I don't 

think that's a trend that's likely to change, and maybe 

this refuge, as other protected landscapes, have taken 

advantage of these landscapes and then with their 

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communities

where they 

with some e

as protecte

I thin

the refuge 

communities

purchase of 

there's hun

there are a 

know the ex

activities 

than a lot 

Other 

some of the 

Out here th

guess maybe 

translates 

or thinking 

be done -- 

on the refu

think at so

now how to 

In the 

many people 

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them to oth

out and loo

around I fi

especially 

kind of bor

So maybe so

about the i

proposing t

It's Scott 

Valley Coun

is not a co

designed wi

vision base

as stated i

With a

CCP contain

or philosop

science and 

the CCP in 

underlying 

you have. 

"Senti

with accept

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8 of 16 sheets Page 26 to 29 of 54 02/14/2011 11:36:41 AM

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we found some Russian fireweed and we went after it; 

you know, we tried pulling it and mowing it, and that 

doesn't work. We had to spray it, and we didn't want 

to because there's frogs that live in that creek. But 

my mother-in-law, she was really careful and made sure 

she was spraying individual plants, and there was lots 

of patches, and it was not close to a road. She had a 

lot of work, but she -- she sprayed and sprayed the 

next year, and we made sure our success in that in two 

ways. 

Number one, the frogs are still singing, and when 

mom went all she needed was a little bitty spray can, 

and it only took her one day. You can't get those 

results with your weed strike team because you've got 

65 habitat units to manage, but the ranchers will do it 

for you if they have a stake in it. That wasn't on 

mom's land, but it was on her ranch. It was a state 

section of BLM grazing land, but it was on her ranch. 

Doesn't matter what you want to accomplish. If you 

want more salt bush or maximillian sunflowers, fewer 

noxious weeds, whatever you want to accomplish, the 

ranchers can do it for you, cheaper than anybody you 

can hire, and they will do it for free, in fact, 

they'll pay you. Thanks for listening. 

MS. MATHER: Thanks, Jason. Mark's up 

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with Scott on deck. And. Again, if I can ask you guys 

to hold your applause. Thank you. 

MARK GOOD: My name's Mark Good. I work 

for the Montana Wilderness Association. I'll bet I 

don't get an applause. I'm from Great Falls and I just 

want to -- I think it's worth talking about the mission 

for a bit about the refuge. 

As a national wildlife refuge it's supposed to be 

managed different from other BLM and forest service 

lands, and as a guiding principle, the refuge is to 

manage for the enhancement and protection of wildlife, 

and I think it's through this plan that these decisions 

have to be made. 

I know a lot of people don't like a refuge, maybe 

some would wish it just to go away. But it's not, I 

don't think it is anyway, and I think the reason is 

because wildlife refuges are popular with the American 

public, and I think popular with most Montanans. I do 

think it would be maybe more productive to make this 

refuge work for local communities that surround here. 

I think it's no secret that the population of the 

eastern half of the state has been decreasing. I don't 

think that's a trend that's likely to change, and maybe 

this refuge, as other protected landscapes, have taken 

advantage of these landscapes and then with their 

1

2

3

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5

6

7

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9

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communities. Economics are pretty simple; people care 

where they live and make a preference to live in places 

with some economic or some environmental values, such 

as protected landscape.

I think the refuge -- it should be noted, too, that 

the refuge does make a direct contribution to local 

communities; I think through employment, through the 

purchase of goods and services, and then, of course, 

there's hunting, which is a big activity. I think 

there are a hundred thousand hunting visits. I don't 

know the exact -- how much -- either of those 

activities contributes locally, but I bet it's more 

than a lot of people would think. 

Other than this part of the refuge mission is just 

some of the environmental education and interpretation. 

Out here there's the Interpretive Center, and so I 

guess maybe a question too is, I don't know what that 

translates into dollars, but I think it's worth asking 

or thinking about; what other kind of activities could 

be done -- interpretive activities that could be done 

on the refuge? Maybe bring people to the refuge. I 

think at some places access is an issue, people don't 

now how to get there or where. 

In the case of Slippery Ann you probably have too 

many people there, and maybe there's a way of directing 

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them to other places, and encouraging people to come 

out and look at other places in the state. When I look 

around I find people have a tendency to think, 

especially from the western side, that prairies are 

kind of boring and monotonous, but quite the reverse. 

So maybe someone could talk about some of your thoughts 

about the interpretation activities that you're 

proposing to do in the future. So, thanks. 

MS. MATHER: Scott with John on deck.

SCOTT CASSEL: My name's Scott Cassel. 

It's Scott with two Ts, C-a-s-s-e-l. I'm a resident of 

Valley County. It is plainly evident that the CMR CCP 

is not a conservation plan but is instead a document 

designed with a specific goal in mind. The goal is a 

vision based on what may have occurred 150 years ago, 

as stated in the CCP itself. 

With all due respect, it certainly appears that the 

CCP contains the tenants normally ascribed to religion 

or philosophy rather than the principles demanded by 

science and logic. Range science is nearly excluded in 

the CCP in favor of biological myopia. There's no 

underlying credible data to support this vision that 

you have. 

"Sentinel plant" is a term that is never associated 

with accepted range science. In this document it 

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we found some Russian fireweed and we went after it; 

you know, we tried pulling it and mowing it, and that 

doesn't work. We had to spray it, and we didn't want 

to because there's frogs that live in that creek. But 

my mother-in-law, she was really careful and made sure 

she was spraying individual plants, and there was lots 

of patches, and it was not close to a road. She had a 

lot of work, but she -- she sprayed and sprayed the 

next year, and we made sure our success in that in two 

ways. 

Number one, the frogs are still singing, and when 

mom went all she needed was a little bitty spray can, 

and it only took her one day. You can't get those 

results with your weed strike team because you've got 

65 habitat units to manage, but the ranchers will do it 

for you if they have a stake in it. That wasn't on 

mom's land, but it was on her ranch. It was a state 

section of BLM grazing land, but it was on her ranch. 

Doesn't matter what you want to accomplish. If you 

want more salt bush or maximillian sunflowers, fewer 

noxious weeds, whatever you want to accomplish, the 

ranchers can do it for you, cheaper than anybody you 

can hire, and they will do it for free, in fact, 

they'll pay you. Thanks for listening. 

MS. MATHER: Thanks, Jason. Mark's up 

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with Scott on deck. And. Again, if I can ask you guys 

to hold your applause. Thank you. 

MARK GOOD: My name's Mark Good. I work 

for the Montana Wilderness Association. I'll bet I 

1

2

3

4

5

28

communities. Economics are pretty simple; people care 

where they live and make a preference to live in places 

with some economic or some environmental values, such 

as protected landscape.

I think the refuge -- it should be noted, too, that 

the refuge does make a direct contribution to local 

communities; I think through employment, through the 

purchase of goods and services, and then, of course, 

there's hunting, which is a big activity. I think 

there are a hundred thousand hunting visits. I don't 

know the exact -- how much -- either of those 

activities contributes locally, but I bet it's more 

than a lot of people would think. 

Other than this part of the refuge mission is just 

some of the environmental education and interpretation. 

Out here there's the Interpretive Center, and so I 

guess maybe a question too is, I don't know what that 

translates into dollars, but I think it's worth asking 

or thinking about; what other kind of activities could 

be done -- interpretive activities that could be done 

on the refuge? Maybe bring people to the refuge. I 

think at some places access is an issue, people don't 

now how to get there or where. 

In the case of Slippery Ann you probably have too 

many people there, and maybe there's a way of directing 

1

2

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9

10

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them to other places, and encouraging people to come 

out and look at other places in the state. When I look 

around I find people have a tendency to think, 

especially from the western side, that prairies are 

1

2

3

4

5
420 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 26 to 29 of 54 02/14/2011 11:36:41 AM

, 

lish, the 

nybody you 

 fact, 

Mark's up 

27

 ask you guys 

od. I work 

'll bet I 

ls and I just 

t the mission 

posed to be 

t service 

uge is to 

of wildlife, 

ese decisions 

fuge, maybe 

t's not, I 

reason is 

the American 

anans. I do 

 make this 

round here. 

tion of the 

ing. I don't 

ge, and maybe 

, have taken 

h their 

p

on the refuge? Maybe bring people to the refuge. I 

think at some places access is an issue, people don't 

now how to get there or where. 

In the case of Slippery Ann you probably have too 

many people there, and maybe there's a way of directing 

21

22

23

24

25

29

them to other places, and encouraging people to come 

out and look at other places in the state. When I look 

around I find people have a tendency to think, 

especially from the western side, that prairies are 

kind of boring and monotonous, but quite the reverse. 

So maybe someone could talk about some of your thoughts 

about the interpretation activities that you're 

proposing to do in the future. So, thanks. 

MS. MATHER: Scott with John on deck.

SCOTT CASSEL: My name's Scott Cassel. 

It's Scott with two Ts, C-a-s-s-e-l. I'm a resident of 

Valley County. It is plainly evident that the CMR CCP 

is not a conservation plan but is instead a document 

designed with a specific goal in mind. The goal is a 

vision based on what may have occurred 150 years ago, 

as stated in the CCP itself. 

With all due respect, it certainly appears that the 

CCP contains the tenants normally ascribed to religion 

or philosophy rather than the principles demanded by 

science and logic. Range science is nearly excluded in 

the CCP in favor of biological myopia. There's no 

underlying credible data to support this vision that 

you have. 

"Sentinel plant" is a term that is never associated 

with accepted range science. In this document it 

1

2

3

4

5

6

7

8

9

10

11

12

13

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02/14/2011 11:36:41 AM Page 30 to 33 of 54 

30

appears to be a term that was created for the express 

support -- express purpose of supporting your vision. 

Flawed and failed management of the CMR is 

responsible for the present conditions out there on the 

ground. Mismanagement is producing a system prone to 

fire, which is being dominated by cheat grass and 

Japanese brome. The plant community is degrading into 

chaparral. All alternatives, with the exclusion of 

"Alternative A," would accelerate this trend to the 

detriment of the resource, the local economy and the 

tax base. 

Scientific data regarding range health is missing 

from the documents. Faulty methods were used for 

conclusions in the CCP. There are data deficiencies 

that are huge. The argument related to vegetation 

types is illogical, the interpretations are suspect. 

There's no sensitivity analysis in this document. 

All but Alternative A would take, or subvert, 

private property or private property rights, and would 

usurp county jurisdiction. No MEPA analysis has been 

conducted for the state lands that are inside the CMR. 

Barron Crawford has stated, and I quote, "You can not 

look at the refuge in a vacuum, you have to management 

at the landscape level." Knowing and admitting that 

fact, the CMR management should be operating in unison 

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31

with managers of the surrounding land managers, not in 

isolation under a vision. 

Local comments and concerns should be weighted more 

than comments that come from Tennessee. That's how 

FLPMA works. To choose any alternative but A is going 

to guarantee litigation, and the problem with that is 

the tax payers are going to be paying for both sides. 

It is plainly evident that the U.S. Fish and Wildlife 

Service should stick to fish and wildlife and not range 

management. When the overtly negative social, economic 

and cultural and resource -- and the resource impacts 

are logically evaluated, Alternative A is the only 

alternative that would be acceptable. To select any 

other alternative would be to make a choice not based 

on scientific method, credible research or relevant 

data, but based on pseudoscience and preliminary 

science of the worst kind. Thank you. 

MS. MATHER: Thanks, Scott. John with 

Maxine on deck. 

JOHN BRENDEN: I don't think I need that 

microphone. 

MS. MATHER: Can you state your name?

JOHN BRENDEN: My name is Senator John 

Brenden. I represent District 16, which is six 

counties up in. It's B-r-e-n-d-e-n. You know, I don't 

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even like "Alte

"Alternative B,

weeks ago, we d

Parks, we don't 

anymore wildern

roaming buffalo 

folks in this a

isn't somebody 

And I've fo

the point is, B

you going to be 

your job until 

"Alternative D,

the new guy com

like the good l

everything I ca

the farmers and 

here in Montana

What I don'

management, lik

government subj

180 degrees opp

MS

then I believe 

with the handwr

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MA

M-a-x-i-n-e, K-

in Valley Count

am going to sub

certified copy 

patents that ar

Recorder. That

the federal gov

those impertine

and the associa

the ownership o

use. 

All the ena

the wildlife re

has been previo

to valid preexi

Service has his

ignore the exis

include grazing 

appears in the 

That is defined 

take from the l

These right

wildlife refuge

the documents t

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02/14/2011 11:36:41 AM Page 30 to 33 of 54 9 of 16 sheets

30

appears to be a term that was created for the express 

support -- express purpose of supporting your vision. 

Flawed and failed management of the CMR is 

responsible for the present conditions out there on the 

ground. Mismanagement is producing a system prone to 

fire, which is being dominated by cheat grass and 

Japanese brome. The plant community is degrading into 

chaparral. All alternatives, with the exclusion of 

"Alternative A," would accelerate this trend to the 

detriment of the resource, the local economy and the 

tax base. 

Scientific data regarding range health is missing 

from the documents. Faulty methods were used for 

conclusions in the CCP. There are data deficiencies 

that are huge. The argument related to vegetation 

types is illogical, the interpretations are suspect. 

There's no sensitivity analysis in this document. 

All but Alternative A would take, or subvert, 

private property or private property rights, and would 

usurp county jurisdiction. No MEPA analysis has been 

conducted for the state lands that are inside the CMR. 

Barron Crawford has stated, and I quote, "You can not 

look at the refuge in a vacuum, you have to management 

at the landscape level." Knowing and admitting that 

fact, the CMR management should be operating in unison 

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with managers of the surrounding land managers, not in 

isolation under a vision. 

Local comments and concerns should be weighted more 

than comments that come from Tennessee. That's how 

FLPMA works. To choose any alternative but A is going 

to guarantee litigation, and the problem with that is 

the tax payers are going to be paying for both sides. 

It is plainly evident that the U.S. Fish and Wildlife 

Service should stick to fish and wildlife and not range 

management. When the overtly negative social, economic 

and cultural and resource -- and the resource impacts 

are logically evaluated, Alternative A is the only 

alternative that would be acceptable. To select any 

other alternative would be to make a choice not based 

on scientific method, credible research or relevant 

data, but based on pseudoscience and preliminary 

science of the worst kind. Thank you. 

MS. MATHER: Thanks, Scott. John with 

Maxine on deck. 

JOHN BRENDEN: I don't think I need that 

microphone. 

MS. MATHER: Can you state your name?

JOHN BRENDEN: My name is Senator John 

Brenden. I represent District 16, which is six 

counties up in. It's B-r-e-n-d-e-n. You know, I don't 

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even like "Alternative A". And why would I like 

"Alternative B," "C" or "D"? As I said in Malta a few 

weeks ago, we don't need anymore Montana National 

Parks, we don't need anymore wolves, we don't need 

anymore wilderness, and we don't need anymore free 

roaming buffalo because this is the livelihood of these 

folks in this area. It isn't somebody in Tennessee, it 

isn't somebody from New York City. 

And I've fought the bureaucrats all my life, and 

the point is, Barron, I guess I'd ask you, how long are 

you going to be in your job? Are you going to be in 

your job until the job is over and we've got 

"Alternative D," and then they move you around and then 

the new guy comes in? I'm just taking care of business 

like the good law directs me to. Well, I will do 

everything I can in the state legislature to protect 

the farmers and the ranchers and the business person 

here in Montana, and not only in my district. 

What I don't like to hear is subjectivity 

management, like you're talking about. Because 

government subjectivity management is totally 

180 degrees opposite of John Brenden's. Thank you. 

MS. MATHER: Thanks, John. Maxine? And 

then I believe it's Gene next. I have a little trouble 

with the handwriting. 

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MAXINE KORMAN: My name is Maxine Korman, 

M-a-x-i-n-e, K-o-r-m-a-n. My husband and I own a ranch 

in Valley County, in Hinsdale. I've got a document I 

am going to submit for the record. It contains the 

certified copy of our declaration of acceptance of land 

patents that are recorded with Valley County Clerk and 

Recorder. That's proof of our title as against even 

the federal government, including the pertinences. And 

those impertinences include Rs 223 stock water rights 

and the associated easements, which is recognized as 

the ownership of the fee or the inheritable right to 

use. 

All the enabling documents in the game range and 

the wildlife refuge contain the savings provision, as 

has been previously pointed out, which says, "Subject 

to valid preexisting rights, U.S. Fish and Wildlife 

Service has historically ignored and continues to 

ignore the existence of private rights." That would 

include grazing rights. The term grazing rights 

appears in the Stock Grazing Homestead Act statute. 

That is defined as an easement, the right to use and 

take from the land of another. 

These rights predate the game range and now the 

wildlife refuge. Nowhere in this document or in any of 

the documents that CMR has ever put out is there a 

1

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appears to be a term that was created for the express 

support -- express purpose of supporting your vision. 

Flawed and failed management of the CMR is 

responsible for the present conditions out there on the 

ground. Mismanagement is producing a system prone to 

fire, which is being dominated by cheat grass and 

Japanese brome. The plant community is degrading into 

chaparral. All alternatives, with the exclusion of 

"Alternative A," would accelerate this trend to the 

detriment of the resource, the local economy and the 

tax base. 

Scientific data regarding range health is missing 

from the documents. Faulty methods were used for 

conclusions in the CCP. There are data deficiencies 

that are huge. The argument related to vegetation 

types is illogical, the interpretations are suspect. 

There's no sensitivity analysis in this document. 

All but Alternative A would take, or subvert, 

private property or private property rights, and would 

usurp county jurisdiction. No MEPA analysis has been 

conducted for the state lands that are inside the CMR. 

Barron Crawford has stated, and I quote, "You can not 

look at the refuge in a vacuum, you have to management 

at the landscape level." Knowing and admitting that 

fact, the CMR management should be operating in unison 

1

2

3

4

5

6

7

8

9

10

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12

13

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31

with managers of the surrounding land managers, not in 

isolation under a vision. 

Local comments and concerns should be weighted more 

than comments that come from Tennessee. That's how 

khlibii

1

2

3

4

5

32

even like "Alternative A". And why would I like 

"Alternative B," "C" or "D"? As I said in Malta a few 

weeks ago, we don't need anymore Montana National 

Parks, we don't need anymore wolves, we don't need 

anymore wilderness, and we don't need anymore free 

roaming buffalo because this is the livelihood of these 

folks in this area. It isn't somebody in Tennessee, it 

isn't somebody from New York City. 

And I've fought the bureaucrats all my life, and 

the point is, Barron, I guess I'd ask you, how long are 

you going to be in your job? Are you going to be in 

your job until the job is over and we've got 

"Alternative D," and then they move you around and then 

the new guy comes in? I'm just taking care of business 

like the good law directs me to. Well, I will do 

everything I can in the state legislature to protect 

the farmers and the ranchers and the business person 

here in Montana, and not only in my district. 

What I don't like to hear is subjectivity 

management, like you're talking about. Because 

government subjectivity management is totally 

180 degrees opposite of John Brenden's. Thank you. 

MS. MATHER: Thanks, John. Maxine? And 

then I believe it's Gene next. I have a little trouble 

with the handwriting. 

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MAXINE KORMAN: My name is Maxine Korman, 

M-a-x-i-n-e, K-o-r-m-a-n. My husband and I own a ranch 

in Valley County, in Hinsdale. I've got a document I 

am going to submit for the record. It contains the 

ifid f dlif f ld 

1

2

3

4

5
VOLUME 2, Chapter 4—Public Hearing Testimony 421

Page 30 to 33 of 54 9 of 16 sheets

analysis has been 

re inside the CMR. 

te, "You can not 

have to management 

d admitting that 

perating in unison 

31

d managers, not in 

ld be weighted more 

e. That's how 

ve but A is going 

blem with that is 

g for both sides. 

Fish and Wildlife 

dlife and not range 

ve social, economic 

 resource impacts 

 A is the only 

 To select any 

 choice not based 

rch or relevant 

 preliminary 

u. 

ott. John with 

think I need that 

ate your name?

is Senator John 

hich is six 

 You know, I don't 

management, like youre talking about. Because 

government subjectivity management is totally 

180 degrees opposite of John Brenden's. Thank you. 

MS. MATHER: Thanks, John. Maxine? And 

then I believe it's Gene next. I have a little trouble 

with the handwriting. 

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21

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33

MAXINE KORMAN: My name is Maxine Korman, 

M-a-x-i-n-e, K-o-r-m-a-n. My husband and I own a ranch 

in Valley County, in Hinsdale. I've got a document I 

am going to submit for the record. It contains the 

certified copy of our declaration of acceptance of land 

patents that are recorded with Valley County Clerk and 

Recorder. That's proof of our title as against even 

the federal government, including the pertinences. And 

those impertinences include Rs 223 stock water rights 

and the associated easements, which is recognized as 

the ownership of the fee or the inheritable right to 

use. 

All the enabling documents in the game range and 

the wildlife refuge contain the savings provision, as 

has been previously pointed out, which says, "Subject 

to valid preexisting rights, U.S. Fish and Wildlife 

Service has historically ignored and continues to 

ignore the existence of private rights." That would 

include grazing rights. The term grazing rights 

appears in the Stock Grazing Homestead Act statute. 

That is defined as an easement, the right to use and 

take from the land of another. 

These rights predate the game range and now the 

wildlife refuge. Nowhere in this document or in any of 

the documents that CMR has ever put out is there a 

1

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5

6

7

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10 of 16 sheets Page 34 to 37 of 54 02/14/2011 11:36:41 AM

34

recognition of those rights, and there's never been any 

action to protect private rights, but rather to ignore 

them and extinguish them. This plan, I believe, is 

nothing more than a vehicle to advance treasured 

landscape and national monuments with the Antiquities 

Act, which ignores the United States Supreme Court law. 

All lands to which private rights and claims attach are 

not public lands. And the U.S. Court of Claims 

recognizes these lands as fee lands. 

I would ask you provide the Valley County 

Commissioners with the documentation that the United 

States Fish and Wildlife Service has authority to turn 

these lands over to intranational or international 

management authority and jurisdiction. Also, since 

wolves and grizzlies and bighorn sheep pop up in all 

but one proposed plan, I can only assume we intend to 

use endangered species as a method to regulate us out 

of business. 

In here I point to a particular part in Title I of 

the United States code. It has to do with laws enacted 

into positive law, and I'm also asking you provide the 

commissioners with when that title was enacted into 

positive law, so, in fact, the Endangered Species Act 

can be applied in Valley County or in the sovereign 

State of Montana. Thank you. Thank you. 

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MS. MATHER: Gene? Gene from Glasgow. I 

think it's Gene Etchart. And Steven Page on deck.

GENE ETCHART: Name is Gene, G-e-n-e, 

Etchart, E-t-c-h-a-r-t, address, Glasgow, Montana. My 

first suggestion to this group is that this thing 

should be moved so that the person that's trying to 

deliver a message can talk to the audience, as well as 

to you people. 

I'm wondering what I'm doing here. I'm 93 years of 

age. I was born and raised in this county. My first 

six years was living on a ranch, and now it's with the 

CMR. I spent about a page getting at my credentials. 

Before that I'd like to make one other observation. 

I think your time frame is too short. Everybody 

that's come up here is trying to rush through to have 

this fellow allow him to keep talking, and I think 

that's wrong. If you've got an important message, I 

think it should be important to you people to listen to 

it, and not only that, but for the neighbors to 

understand what he has to say. 

Now, I lived all -- all my life in this county. I 

operated several ranch units; some of you people are 

familiar with them. I'm going -- I'm going to try to 

speed this up a little bit, but I can remember the days 

before the Taylor Grazing Act and before the Fort Peck 

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Game Range. I can remember when the Air Force come in 

here with their bombers and wanted to move the ranchers 

out, all that sort of thing. 

I'll digress here a little bit, but I remember that 

someone talked about the content of your proposal. I 

think all four of those say nothing. I think they are 

written in such a way with elastic words that the Fish 

and Wildlife Service can do anything they want to in 

the future under any one of them, and that's -- that's 

my opinion. I read them, I try to say, what does this 

mean? Well, I think it means that you and I could have 

differing opinions, and either one could make the 

argument that it's in here. 

But at any rate, I have been on several grazing 

boards of the BLM. I was the chairman of the BLM's 

National Advisory Board Counsel for 10 years. I have 

the distinction, which I doubt if anybody else in the 

room has, is I have an citation from the Secretary of 

Interior as a conservation award for Man of the Year, 

something of that nature. 

I remember that when the first announcement on the 

Fort Peck Game Range was made, I can remember that, and 

I remember there was acceptance, generally. I think 

everybody thought it was a good idea. And I remember 

my father seemed to approve of it. FDR was a popular 

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person, but then -- and the other thing I want to say 

now, unless there's some confusion, I don't have any --

UNIDENTIFIED PERSON: You can have my 

three minutes, Gene.

GENE ETCHART: I have three more minutes. 

You want to start that over? 

MS. MATHER: Jim, we need you to just 

wrap it up.

GENE ETCHART: You do? 

UNIDENTIFIED PERSON: Keep going. 

MS. MATHER: Folks, we need to be fair. 

This is our 7th meeting. We'll give Gene one more 

minute, and that's it.

GENE ETCHART: Okay. The whole problem, 

the main problem we have here is because of the action 

that Senator Metcalf had taken when he passed the 

amendment to an obscure bill to hand the fish -- the 

CMR over to Fish and Wildlife, and it caused a lot of 

problems, just like there is in this room now. And 

some of the grazing districts sent people over to -- 

back to the -- Washington D.C. to talk to Senator 

Metcalf and said, what can we do about this problem? 

And there was just as much anxiety at that time as 

there is now over the buffalo. People were -- were 

very frightened over what it might mean, and Manson 

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34

recognition of those rights, and there's never been any 

action to protect private rights, but rather to ignore 

them and extinguish them. This plan, I believe, is 

nothing more than a vehicle to advance treasured 

landscape and national monuments with the Antiquities 

Act, which ignores the United States Supreme Court law. 

All lands to which private rights and claims attach are 

not public lands. And the U.S. Court of Claims 

recognizes these lands as fee lands. 

I would ask you provide the Valley County 

Commissioners with the documentation that the United 

States Fish and Wildlife Service has authority to turn 

these lands over to intranational or international 

management authority and jurisdiction. Also, since 

wolves and grizzlies and bighorn sheep pop up in all 

but one proposed plan, I can only assume we intend to 

use endangered species as a method to regulate us out 

of business. 

In here I point to a particular part in Title I of 

the United States code. It has to do with laws enacted 

into positive law, and I'm also asking you provide the 

commissioners with when that title was enacted into 

positive law, so, in fact, the Endangered Species Act 

can be applied in Valley County or in the sovereign 

State of Montana. Thank you. Thank you. 

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MS. MATHER: Gene? Gene from Glasgow. I 

think it's Gene Etchart. And Steven Page on deck.

GENE ETCHART: Name is Gene, G-e-n-e, 

Etchart, E-t-c-h-a-r-t, address, Glasgow, Montana. My 

first suggestion to this group is that this thing 

1

2

3

4

5

36

Game Range. I can remember when the Air Force come in 

here with their bombers and wanted to move the ranchers 

out, all that sort of thing. 

I'll digress here a little bit, but I remember that 

someone talked about the content of your proposal. I 

think all four of those say nothing. I think they are 

written in such a way with elastic words that the Fish 

and Wildlife Service can do anything they want to in 

the future under any one of them, and that's -- that's 

my opinion. I read them, I try to say, what does this 

mean? Well, I think it means that you and I could have 

differing opinions, and either one could make the 

argument that it's in here. 

But at any rate, I have been on several grazing 

boards of the BLM. I was the chairman of the BLM's 

National Advisory Board Counsel for 10 years. I have 

the distinction, which I doubt if anybody else in the 

room has, is I have an citation from the Secretary of 

Interior as a conservation award for Man of the Year, 

something of that nature. 

I remember that when the first announcement on the 

Fort Peck Game Range was made, I can remember that, and 

I remember there was acceptance, generally. I think 

everybody thought it was a good idea. And I remember 

my father seemed to approve of it. FDR was a popular 

1

2

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person, but then -- and the other thing I want to say 

now, unless there's some confusion, I don't have any --

UNIDENTIFIED PERSON: You can have my 

three minutes, Gene.

GENE ETCHART: I have three more minutes

1

2

3

4

5

10 of 16 sheets Page 34 to 37 of 54 

34

recognition of those rights, and there's never been any 

action to protect private rights, but rather to ignore 

them and extinguish them. This plan, I believe, is 

nothing more than a vehicle to advance treasured 

landscape and national monuments with the Antiquities 

Act, which ignores the United States Supreme Court law. 

All lands to which private rights and claims attach are 

not public lands. And the U.S. Court of Claims 

recognizes these lands as fee lands. 

I would ask you provide the Valley County 

Commissioners with the documentation that the United 

States Fish and Wildlife Service has authority to turn 

these lands over to intranational or international 

management authority and jurisdiction. Also, since 

wolves and grizzlies and bighorn sheep pop up in all 

but one proposed plan, I can only assume we intend to 

use endangered species as a method to regulate us out 

of business. 

In here I point to a particular part in Title I of 

the United States code. It has to do with laws enacted 

into positive law, and I'm also asking you provide the 

commissioners with when that title was enacted into 

positive law, so, in fact, the Endangered Species Act 

can be applied in Valley County or in the sovereign 

State of Montana. Thank you. Thank you. 

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MS. MATHER: Gene? Gene from Glasgow. I 

think it's Gene Etchart. And Steven Page on deck.

GENE ETCHART: Name is Gene, G-e-n-e, 

Etchart, E-t-c-h-a-r-t, address, Glasgow, Montana. My 

first suggestion to this group is that this thing 

should be moved so that the person that's trying to 

deliver a message can talk to the audience, as well as 

to you people. 

I'm wondering what I'm doing here. I'm 93 years of 

age. I was born and raised in this county. My first 

six years was living on a ranch, and now it's with the 

CMR. I spent about a page getting at my credentials. 

Before that I'd like to make one other observation. 

I think your time frame is too short. Everybody 

that's come up here is trying to rush through to have 

this fellow allow him to keep talking, and I think 

that's wrong. If you've got an important message, I 

think it should be important to you people to listen to 

it, and not only that, but for the neighbors to 

understand what he has to say. 

Now, I lived all -- all my life in this county. I 

operated several ranch units; some of you people are 

familiar with them. I'm going -- I'm going to try to 

speed this up a little bit, but I can remember the days 

before the Taylor Grazing Act and before the Fort Peck 

1

2

3

4

5

6

7

8

9

10

11

12

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Game Range

here with 

out, all t

I'll d

someone ta

think all 

written in 

and Wildli

the future 

my opinion

mean? Wel

differing 

argument t

But at 

boards of 

National A

the distin

room has, 

Interior a

something 

I reme

Fort Peck 

I remember 

everybody 

my father 

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person, bu

now, unles

three minu

You want t

wrap it up

This is ou

minute, an

the main p

that Senat

amendment 

CMR over t

problems, 

some of th

back to th

Metcalf an

And th

there is n

very frigh

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422 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 34 to 37 of 54 02/14/2011 11:36:41 AM

 provide the 

cted into 

Species Act 

sovereign 

35

 Glasgow. I 

on deck.

G-e-n-e, 

Montana. My 

s thing 

trying to 

, as well as 

m 93 years of 

. My first 

t's with the 

redentials. 

ervation. 

 Everybody 

ugh to have 

 I think 

message, I 

 to listen to 

rs to 

is county. I 

people are 

g to try to 

mber the days 

he Fort Peck 

g 

I remember that when the first announcement on the 

Fort Peck Game Range was made, I can remember that, and 

I remember there was acceptance, generally. I think 

everybody thought it was a good idea. And I remember 

my father seemed to approve of it. FDR was a popular 

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person, but then -- and the other thing I want to say 

now, unless there's some confusion, I don't have any --

UNIDENTIFIED PERSON: You can have my 

three minutes, Gene.

GENE ETCHART: I have three more minutes. 

You want to start that over? 

MS. MATHER: Jim, we need you to just 

wrap it up.

GENE ETCHART: You do? 

UNIDENTIFIED PERSON: Keep going. 

MS. MATHER: Folks, we need to be fair. 

This is our 7th meeting. We'll give Gene one more 

minute, and that's it.

GENE ETCHART: Okay. The whole problem, 

the main problem we have here is because of the action 

that Senator Metcalf had taken when he passed the 

amendment to an obscure bill to hand the fish -- the 

CMR over to Fish and Wildlife, and it caused a lot of 

problems, just like there is in this room now. And 

some of the grazing districts sent people over to -- 

back to the -- Washington D.C. to talk to Senator 

Metcalf and said, what can we do about this problem? 

And there was just as much anxiety at that time as 

there is now over the buffalo. People were -- were 

very frightened over what it might mean, and Manson 

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38

Bailey, Jr., who was a fish and game commissioner here 

in Montana, plus a legislator, he and I on a different 

schedule were commissioned to go talk to Senator 

Metcalf. And Senator Metcalf looked me in the eye and 

he said -- 15 seconds. 

MS. MATHER: 15 seconds. Count down.

GENE ETCHART: He said the game range 

would be administered under the Taylor Grazing Act, and 

he said, you go back and tell your friends and your 

neighbors and your people that that's the way it's 

going to be. And fish and game -- Fish and Wildlife 

never adhered to that at all, and it comes back to the 

points somebody else made. I don't think there's 

anybody alive that remembers that, except that he gave 

me the commitment to bring it back to you people that 

it would be administered under the Fish and Game Act, 

or rather, the Taylor Grazing Act, and he said, tell 

your friends they've got no problems. 

MS. MATHER: Thank you, Jim. Steve? 

STEVEN PAGE: My name is Steven Page. 

I'm a local rancher. For the record, I would like to 

state that I fully support, since we have no other 

options than to support one of the options, I would be 

in favor of option "A". 

I have a number of things that I would like to say, 

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but I think I would just be repeating a number of 

points that have already been made. But one of the 

things that I was noticing as I was reviewing your 

handout, and no one has mentioned it at this point, is 

it would appear to me as though we are saying that if a 

pack of wolves show up on the CMR, they'll remain on 

the CMR, and you have no intention of controlling wolf 

populations because you stated that you are going to 

eliminate your relationship with the USDA predator 

service. And so I guess I have the question to ask 

you. Do you intend to allow wolves to survive on the 

game range? Thank you. 

MS. MATHER: Thanks, Steve. Did anyone 

else have a comment or a question before Barron answers 

questions?

SCOTT CASSEL: Yes.

MS. MATHER: Can you please come on up?

SCOTT CASSEL: I have to come up to ask a 

question? 

MS. MATHER: Yep. 

SCOTT CASSEL: What congressional 

authority exists where you guys assert the right or 

convince me that you have the right to expand or change 

wilderness areas without the authority of Congress? 

Thank you. 

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MS. MATHER: Anybody else? Come on up. 

Thank you. 

RON GARWOOD: Beings I didn't get to get 

everything out, I'm for continued cattle grazing out on 

the CMR, and I think the "Alternative A" is the best 

option, but what -- the other day, about two weeks ago, 

I was coming out of Harper's Ridge and we met a bunch 

of people walking down the road. Anyway, kind of 

curious what was going on, so we stopped, they wanted 

me to stop, so I stopped. Here I found out because 

they asked, how far is the next fence? Of course I got 

to thinking, whoa, and I asked them, are you taking out 

fence? And they said yes. 

So then I told them what was going on here, and I 

wanted to keep cattle grazing here, and all of a sudden 

they backed away from the outfit. They didn't want to 

talk to me or divulge anymore information. Anyway, as 

I got back down to where they had left their outfit, it 

was the Montana Conservation Corp. And it almost seems 

to me like you're working on that D Alternative 

already, taking out cross fences, and I was wondering, 

who gave them permission to do that, or did they do it 

on their own, or what? 

MS. MATHER: Okay. I'm going to let 

Barron and Bill -- do you have a question?

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GENE ETCHART: Can I have two minutes? 

MS. MATHER: No. Do you have a question? 

I can't give you any more time. They'll be plenty of 

time afterwards. 

GENE ETCHART: I think I have a picture 

that you'll all enjoy. 

MS. MATHER: Would you like no hold it up 

and share?

UNIDENTIFIED PERSON: Ask a question with 

it, Gene, and it will be fine. 

MS. MATHER: Go ahead.

GENE ETCHART: The thing I wanted to say 

is that -- 

MS. MATHER: Gene, our recorder can't 

hear you from there. Gene, I'm giving you 30 seconds 

this time. Believe me, I love a story teller as much 

as anyone else, but this is not the venue. 30 seconds.

GENE ETCHART: The thing I wanted to say 

is the Fish and Wildlife Service has been too modest on 

the size of this CMR, and I have a picture that I think 

will illustrate that and I need both hands here to get 

at it. But this is a picture. Can you folks see it? 

There's six beautiful elk if that picture, and they are 

grazing in a horse pasture at the stone house. And 

that's 15 miles north of the nearest CMR boundary. The 

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38

Bailey, Jr., who was a fish and game commissioner here 

in Montana, plus a legislator, he and I on a different 

schedule were commissioned to go talk to Senator 

Metcalf. And Senator Metcalf looked me in the eye and 

he said -- 15 seconds. 

MS. MATHER: 15 seconds. Count down.

GENE ETCHART: He said the game range 

would be administered under the Taylor Grazing Act, and 

he said, you go back and tell your friends and your 

neighbors and your people that that's the way it's 

going to be. And fish and game -- Fish and Wildlife 

never adhered to that at all, and it comes back to the 

points somebody else made. I don't think there's 

anybody alive that remembers that, except that he gave 

me the commitment to bring it back to you people that 

it would be administered under the Fish and Game Act, 

or rather, the Taylor Grazing Act, and he said, tell 

your friends they've got no problems. 

MS. MATHER: Thank you, Jim. Steve? 

STEVEN PAGE: My name is Steven Page. 

I'm a local rancher. For the record, I would like to 

state that I fully support, since we have no other 

options than to support one of the options, I would be 

in favor of option "A". 

I have a number of things that I would like to say, 

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but I think I would just be repeating a number of 

points that have already been made. But one of the 

things that I was noticing as I was reviewing your 

handout, and no one has mentioned it at this point, is 

it would appear to me as though we are saying that if a 

pack of wolves show up on the CMR, they'll remain on 

the CMR, and you have no intention of controlling wolf 

populations because you stated that you are going to 

eliminate your relationship with the USDA predator 

service. And so I guess I have the question to ask 

you. Do you intend to allow wolves to survive on the 

game range? Thank you. 

MS. MATHER: Thanks, Steve. Did anyone 

else have a comment or a question before Barron answers 

questions?

SCOTT CASSEL: Yes.

MS. MATHER: Can you please come on up?

SCOTT CASSEL: I have to come up to ask a 

question? 

MS. MATHER: Yep. 

SCOTT CASSEL: What congressional 

authority exists where you guys assert the right or 

convince me that you have the right to expand or change 

wilderness areas without the authority of Congress? 

Thank you. 

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MS

Thank you. 

RO

everything out, 

the CMR, and I 

option, but wha

I was coming ou

of people walki

curious what wa

me to stop, so 

they asked, how 

to thinking, wh

fence? And the

So then I t

wanted to keep 

they backed awa

talk to me or d

I got back down 

was the Montana 

to me like you'

already, taking 

who gave them p

on their own, o

MS

Barron and Bill 

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GE

MS

I can't give yo

time afterwards

GE

that you'll all 

MS

and share?

UN

it, Gene, and i

MS

GE

is that -- 

MS

hear you from t

this time. Bel

as anyone else, 

GE

is the Fish and 

the size of thi

will illustrate 

at it. But thi

There's six bea

grazing in a ho

that's 15 miles 

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38

Bailey, Jr., who was a fish and game commissioner here 

in Montana, plus a legislator, he and I on a different 

schedule were commissioned to go talk to Senator 

Metcalf. And Senator Metcalf looked me in the eye and 

he said -- 15 seconds. 

MS. MATHER: 15 seconds. Count down.

GENE ETCHART: He said the game range 

would be administered under the Taylor Grazing Act, and 

he said, you go back and tell your friends and your 

neighbors and your people that that's the way it's 

going to be. And fish and game -- Fish and Wildlife 

never adhered to that at all, and it comes back to the 

points somebody else made. I don't think there's 

anybody alive that remembers that, except that he gave 

me the commitment to bring it back to you people that 

it would be administered under the Fish and Game Act, 

or rather, the Taylor Grazing Act, and he said, tell 

your friends they've got no problems. 

MS. MATHER: Thank you, Jim. Steve? 

STEVEN PAGE: My name is Steven Page. 

I'm a local rancher. For the record, I would like to 

state that I fully support, since we have no other 

options than to support one of the options, I would be 

in favor of option "A". 

I have a number of things that I would like to say, 

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but I think I would just be repeating a number of 

points that have already been made. But one of the 

things that I was noticing as I was reviewing your 

handout, and no one has mentioned it at this point, is 

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MS. MATHER: Anybody else? Come on up. 

Thank you. 

RON GARWOOD: Beings I didn't get to get 

everything out, I'm for continued cattle grazing out on 

the CMR, and I think the "Alternative A" is the best 

option, but what -- the other day, about two weeks ago, 

I was coming out of Harper's Ridge and we met a bunch 

of people walking down the road. Anyway, kind of 

curious what was going on, so we stopped, they wanted 

me to stop, so I stopped. Here I found out because 

they asked, how far is the next fence? Of course I got 

to thinking, whoa, and I asked them, are you taking out 

fence? And they said yes. 

So then I told them what was going on here, and I 

wanted to keep cattle grazing here, and all of a sudden 

they backed away from the outfit. They didn't want to 

talk to me or divulge anymore information. Anyway, as 

I got back down to where they had left their outfit, it 

was the Montana Conservation Corp. And it almost seems 

to me like you're working on that D Alternative 

already, taking out cross fences, and I was wondering, 

who gave them permission to do that, or did they do it 

on their own, or what? 

MS. MATHER: Okay. I'm going to let 

Barron and Bill -- do you have a question?

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GENE ETCHART: Can I have two minutes? 

MS. MATHER: No. Do you have a question? 

I can't give you any more time. They'll be plenty of 

time afterwards. 

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VOLUME 2, Chapter 4—Public Hearing Testimony 423

Page 38 to 41 of 54 11 of 16 sheets

s Steven Page. 

 I would like to 

 have no other 

tions, I would be 

 would like to say, 

39

 a number of 

But one of the 

eviewing your 

at this point, is 

e saying that if a 

ey'll remain on 

 controlling wolf 

ou are going to 

USDA predator 

uestion to ask 

o survive on the 

eve. Did anyone 

ore Barron answers 

ease come on up?

o come up to ask a 

gressional 

t the right or 

o expand or change 

y of Congress? 

to me like youre working on that D Alternative 

already, taking out cross fences, and I was wondering, 

who gave them permission to do that, or did they do it 

on their own, or what? 

MS. MATHER: Okay. I'm going to let 

Barron and Bill -- do you have a question?

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GENE ETCHART: Can I have two minutes? 

MS. MATHER: No. Do you have a question? 

I can't give you any more time. They'll be plenty of 

time afterwards. 

GENE ETCHART: I think I have a picture 

that you'll all enjoy. 

MS. MATHER: Would you like no hold it up 

and share?

UNIDENTIFIED PERSON: Ask a question with 

it, Gene, and it will be fine. 

MS. MATHER: Go ahead.

GENE ETCHART: The thing I wanted to say 

is that -- 

MS. MATHER: Gene, our recorder can't 

hear you from there. Gene, I'm giving you 30 seconds 

this time. Believe me, I love a story teller as much 

as anyone else, but this is not the venue. 30 seconds.

GENE ETCHART: The thing I wanted to say 

is the Fish and Wildlife Service has been too modest on 

the size of this CMR, and I have a picture that I think 

will illustrate that and I need both hands here to get 

at it. But this is a picture. Can you folks see it? 

There's six beautiful elk if that picture, and they are 

grazing in a horse pasture at the stone house. And 

that's 15 miles north of the nearest CMR boundary. The 

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12 of 16 sheets Page 42 to 45 of 54 

42

sportsmen tell me that deer like the private land 

section better. 

Now, if these deer are 15 miles off of that, just 

think if you take 200 miles -- 

MS. MATHER: Did you have a question, 

Gene?

GENE ETCHART: Well... 

MS. MATHER: Okay. Thank you for the 

picture. 

SENATOR BRENDEN: I have one question. 

Why do you treat us so rudely when you're working for 

we the tax payers? 

MS. MATHER: Okay. I'm going -- I have 

no intention of treating you rudely. I'm actually 

trying to treat everybody fairly. This is about our 

sixth or seventh meeting, and we've handled them all 

exactly the same. I'm now turning the mic. over to 

Barron to answer questions.

GENE ETCHART: I still didn't make my 

point. 

MS. MATHER: You'll have time afterwards, 

Gene. 

GENE ETCHART: My point is that those 

seven or eight elk were off the refuge.

MS. MATHER: Gene, with all due respect, 

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Barron's got a number of questions to answer.

GENE ETCHART: If they were cattle on the 

refuge -- 

MS. MATHER: Thank you. 

MR. CRAWFORD: I'll have to admit, this 

has been the most lively meeting we've had out of the 

six, so I appreciate you guys making it interesting. 

To address John's comment about how many years am I 

going to be around? I'm around one day. Today is my 

last day, officially, as an employee of CMR, and I am 

proud to say I'm going back to Tennessee, my home 

roots, glad to go back to family. 

I've enjoyed my time immensely here in Montana, but 

as you all spoke, the pull of home is very strong, and 

the pull to my home is extremely strong. So I took the 

opportunity to go back and to be two hours from the 

farm that I grew up on and have the opportunity for my 

children to have the same experiences that I had on 

that farm. 

So, Kenneth, this is a CMR meeting. We don't 

manage Medicine Lake, so I'm sorry, I can't answer any 

of your questions about Medicine Lake. That's Jerry 

Rodriguez up there, and so I don't have any idea what 

the budget is. I don't have any idea what their master 

plan is. I don't know about their parking lot and I 

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don't know 

is CMR.

that cost? 

this cost. 

But I don'

Nancy 

Peck. Who

Wildlife & 

Let's see, 

Okay. 

the differ

Service an

Forest Ser

the only a

fish, wild

multiple-u

Management 

We hav

National W

and then t

Refuge Sys

were congr

it states 

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Refuge Sys

Okay. Our 

States all 

the way to 

There 

Land Prote

Those two 

Land Manag

not apply 

system. 

Let's 

renewable 

and there 

there, it'

animals, i

whole vari

striving f

there. Yo

have forbs 

providing 

species fr

tailed gro

of habitat

successful

What e

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sportsmen tell me that deer like the private land 

section better. 

Now, if these deer are 15 miles off of that, just 

think if you take 200 miles -- 

MS. MATHER: Did you have a question, 

Gene?

GENE ETCHART: Well... 

MS. MATHER: Okay. Thank you for the 

picture. 

SENATOR BRENDEN: I have one question. 

Why do you treat us so rudely when you're working for 

we the tax payers? 

MS. MATHER: Okay. I'm going -- I have 

no intention of treating you rudely. I'm actually 

trying to treat everybody fairly. This is about our 

sixth or seventh meeting, and we've handled them all 

exactly the same. I'm now turning the mic. over to 

Barron to answer questions.

GENE ETCHART: I still didn't make my 

point. 

MS. MATHER: You'll have time afterwards, 

Gene. 

GENE ETCHART: My point is that those 

seven or eight elk were off the refuge.

MS. MATHER: Gene, with all due respect, 

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Barron's got a number of questions to answer.

GENE ETCHART: If they were cattle on the 

refuge -- 

MS. MATHER: Thank you. 

CO'll hdihi

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don't know about them cutting trees down. Sorry. This 

is CMR.

KENNETH LOCKE: Can I ask you how much 

that cost? 

MR. CRAWFORD: Oh, I don't know how much 

this cost. A lot of staff time, I can tell you that. 

But I don't have a dollar figure. 

Nancy asked about the deer problem around Fort 

Peck. Who's responsible? That's the Montana Fish, 

Wildlife & Parks. They manage resident wildlife. 

Let's see, what else did I have here? 

Okay. One of the things I want to talk about is 

the difference between the U.S. Fish and Wildlife 

Service and the Bureau of Land Management and the 

Forest Service. The U.S. Fish and Wildlife Service is 

the only agency that has the sole mission of managing 

fish, wildlife and habitats. Okay. We are not a 

multiple-use agency such as the Bureau of Land 

Management or the forest service. 

We have a very clearcut mission that comes from the 

National Wildlife Refuge Administration Act of 1966, 

and then that was updated with the National Wildlife 

Refuge System Improvement Act of 1997. Both of those 

were congressional laws passed by Congress. In there 

it states what we are to do as a National Wildlife 

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Refuge System, and the key word there is "national". 

Okay. Our policies stretch from the Eastern United 

States all the way to the Hawaiian Islands, Alaska, all 

the way to Puerto Rico. 

hlf lk bhdl 

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12 of 16 sheets Page 42 to 45 of 54 02/14/2011 11:36:41 AM

42

sportsmen tell me that deer like the private land 

section better. 

Now, if these deer are 15 miles off of that, just 

think if you take 200 miles -- 

MS. MATHER: Did you have a question, 

Gene?

GENE ETCHART: Well... 

MS. MATHER: Okay. Thank you for the 

picture. 

SENATOR BRENDEN: I have one question. 

Why do you treat us so rudely when you're working for 

we the tax payers? 

MS. MATHER: Okay. I'm going -- I have 

no intention of treating you rudely. I'm actually 

trying to treat everybody fairly. This is about our 

sixth or seventh meeting, and we've handled them all 

exactly the same. I'm now turning the mic. over to 

Barron to answer questions.

GENE ETCHART: I still didn't make my 

point. 

MS. MATHER: You'll have time afterwards, 

Gene. 

GENE ETCHART: My point is that those 

seven or eight elk were off the refuge.

MS. MATHER: Gene, with all due respect, 

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Barron's got a number of questions to answer.

GENE ETCHART: If they were cattle on the 

refuge -- 

MS. MATHER: Thank you. 

MR. CRAWFORD: I'll have to admit, this 

has been the most lively meeting we've had out of the 

six, so I appreciate you guys making it interesting. 

To address John's comment about how many years am I 

going to be around? I'm around one day. Today is my 

last day, officially, as an employee of CMR, and I am 

proud to say I'm going back to Tennessee, my home 

roots, glad to go back to family. 

I've enjoyed my time immensely here in Montana, but 

as you all spoke, the pull of home is very strong, and 

the pull to my home is extremely strong. So I took the 

opportunity to go back and to be two hours from the 

farm that I grew up on and have the opportunity for my 

children to have the same experiences that I had on 

that farm. 

So, Kenneth, this is a CMR meeting. We don't 

manage Medicine Lake, so I'm sorry, I can't answer any 

of your questions about Medicine Lake. That's Jerry 

Rodriguez up there, and so I don't have any idea what 

the budget is. I don't have any idea what their master 

plan is. I don't know about their parking lot and I 

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don't know about them cutting trees down. Sorry. This 

is CMR.

KENNETH LOCKE: Can I ask you how much 

that cost? 

MR. CRAWFORD: Oh, I don't know how much 

this cost. A lot of staff time, I can tell you that. 

But I don't have a dollar figure. 

Nancy asked about the deer problem around Fort 

Peck. Who's responsible? That's the Montana Fish, 

Wildlife & Parks. They manage resident wildlife. 

Let's see, what else did I have here? 

Okay. One of the things I want to talk about is 

the difference between the U.S. Fish and Wildlife 

Service and the Bureau of Land Management and the 

Forest Service. The U.S. Fish and Wildlife Service is 

the only agency that has the sole mission of managing 

fish, wildlife and habitats. Okay. We are not a 

multiple-use agency such as the Bureau of Land 

Management or the forest service. 

We have a very clearcut mission that comes from the 

National Wildlife Refuge Administration Act of 1966, 

and then that was updated with the National Wildlife 

Refuge System Improvement Act of 1997. Both of those 

were congressional laws passed by Congress. In there 

it states what we are to do as a National Wildlife 

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Refuge System, and the key word there is "national". 

Okay. Our policies stretch from the Eastern United 

States all the way to the Hawaiian Islands, Alaska, all 

the way to Puerto Rico. 

There was lots of talk about FLPMA, the Federal 

Land Protection Management Act and Taylor Grazing. 

Those two laws apply to multiple lands; the Bureau of 

Land Management and the U.S. Forest Service. They do 

not apply in managing a national wildlife refuge 

system. 

Let's see, what else do we have here? Grass is a 

renewable resource. That was an interesting concept, 

and there is -- there is lots of uses for grass out 

there, it's just not used to be eaten by various 

animals, it's used as nesting cover. It's used for a 

whole variety of insects, and the idea that we're 

striving for in this plan is to create to diversity out 

there. You have short grass, you have tall grass, you 

have forbs and you have shrubs, and, therefore, you're 

providing these microhabitats for a whole wide range of 

species from mountain plovers all the way up to sharp 

tailed grouse. Both of those require different types 

of habitats in order for them to raise chicks and be 

successful. 

What else do we have here? What other kind of 

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424 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 42 to 45 of 54 02/14/2011 11:36:41 AM

 afterwards, 

at those 

ue respect, 

43

er.

attle on the 

dmit, this 

 out of the 

teresting. 

ears am I 

Today is my 

R, and I am 

my home 

n Montana, but 

 strong, and 

So I took the 

 from the 

unity for my 

 I had on 

We don't 

t answer any 

at's Jerry 

y idea what 

 their master 

 lot and I 

National Wildlife Refuge Administration Act of 1966, 

and then that was updated with the National Wildlife 

Refuge System Improvement Act of 1997. Both of those 

were congressional laws passed by Congress. In there 

it states what we are to do as a National Wildlife 

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45

Refuge System, and the key word there is "national". 

Okay. Our policies stretch from the Eastern United 

States all the way to the Hawaiian Islands, Alaska, all 

the way to Puerto Rico. 

There was lots of talk about FLPMA, the Federal 

Land Protection Management Act and Taylor Grazing. 

Those two laws apply to multiple lands; the Bureau of 

Land Management and the U.S. Forest Service. They do 

not apply in managing a national wildlife refuge 

system. 

Let's see, what else do we have here? Grass is a 

renewable resource. That was an interesting concept, 

and there is -- there is lots of uses for grass out 

there, it's just not used to be eaten by various 

animals, it's used as nesting cover. It's used for a 

whole variety of insects, and the idea that we're 

striving for in this plan is to create to diversity out 

there. You have short grass, you have tall grass, you 

have forbs and you have shrubs, and, therefore, you're 

providing these microhabitats for a whole wide range of 

species from mountain plovers all the way up to sharp 

tailed grouse. Both of those require different types 

of habitats in order for them to raise chicks and be 

successful. 

What else do we have here? What other kind of 

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interpretive activities have we done? We do have -- we 

had -- we had a person that was stationed at Fort Peck 

that was an outdoor rec. planner that worked with the 

Corp staff on taking programs to schools, and 

unfortunately we lost that position about three years 

ago and have not filled it back. What we have done is 

converted a person in our Lewistown office from admin. 

position to a manager/trainee position with part of her 

duties being environmental education outreach, and been 

working in mostly the Lewistown district right now 

because that's where she's based out of. Hopefully in 

the plan we've identified the need for additional 

outdoor rec. planner, environmental education type 

planners that could assist with taking environmental 

education programs to the schools. 

Other things we identified in the plan was the 

building of various interpretive trails, a couple of 

them here on the east end of the refuge to interpret 

the natural and historical resources of the area. 

No, we're not going to introduce wolves. What we 

state in the plan is it involves naturally colonizing 

the area. We would work with Fish, Wildlife & Parks to 

identify a management plan for them. We are not going 

to consider hunting those species if they do migrate on 

to the refuge. We do have in there that we will 

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authorize the taking of wolves that are causing 

livestock deprivation. The canceling of the service 

with Avis, USDA is mostly for coyote control, that's 

being done on the southeast portion of the refuge at 

this time. 

I had a question as to what authority do we have to 

expand wilderness. What we're doing is we're talking 

about proposed wilderness. We're not talking about 

designated wilderness. Only Congress has the authority 

to designate wilderness. Within the refuge we have CMR 

and we have UL Bend. UL Bend has designated wilderness 

on it. All the other areas are proposed. Proposed 

means they've been evaluated by the service, they've 

been approved by the service, they've been approved by 

the Secretary of Interior, and are waiting action by 

Congress. 

Since they have not been designated, the service 

can go back during this planning process and reevaluate 

those lands and determine whether they still meet that 

wilderness characteristic, and make a recommendation 

back to our director's office and then up to the 

secretaries office. According to our policy, we do 

manage proposed wilderness as if it was designated, so 

we maintain those characteristics until Congress goes 

ahead and acts on that. 

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I think we 

cross fences dow

exclosure. It w

divided pasture

burned up in a 

wilderness area

rebuild that exc

fence out. 

RO

isn't in a propo

north side of Ha

MR

but it was a fen

it was non-funct

Ron.

RO

one question. A

fighting fires o

it got away from 

that's when it b

out cross fence

MR

anymore for live

we're taking it 

I just want

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question about U

we've got a coup

in and remove p

livestock, most

Point, Garfield 

operate in that 

tip of Haxby Po

What we're 

table. When dep

address those in

the record, the 

a few years bac

authorizing the 

it occurred the

refuge. It ende

Timber Creek, bu

proposing to han

If wolves d

along for a peri

problems, you kn

and kill them ju

We'll be ar

people here. Bo

about the sentin

different names 

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02/14/2011 11:36:41 AM Page 46 to 49 of 54 13 of 16 sheets

46

interpretive activities have we done? We do have -- we 

had -- we had a person that was stationed at Fort Peck 

that was an outdoor rec. planner that worked with the 

Corp staff on taking programs to schools, and 

unfortunately we lost that position about three years 

ago and have not filled it back. What we have done is 

converted a person in our Lewistown office from admin. 

position to a manager/trainee position with part of her 

duties being environmental education outreach, and been 

working in mostly the Lewistown district right now 

because that's where she's based out of. Hopefully in 

the plan we've identified the need for additional 

outdoor rec. planner, environmental education type 

planners that could assist with taking environmental 

education programs to the schools. 

Other things we identified in the plan was the 

building of various interpretive trails, a couple of 

them here on the east end of the refuge to interpret 

the natural and historical resources of the area. 

No, we're not going to introduce wolves. What we 

state in the plan is it involves naturally colonizing 

the area. We would work with Fish, Wildlife & Parks to 

identify a management plan for them. We are not going 

to consider hunting those species if they do migrate on 

to the refuge. We do have in there that we will 

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authorize the taking of wolves that are causing 

livestock deprivation. The canceling of the service 

with Avis, USDA is mostly for coyote control, that's 

being done on the southeast portion of the refuge at 

this time. 

I had a question as to what authority do we have to 

expand wilderness. What we're doing is we're talking 

about proposed wilderness. We're not talking about 

designated wilderness. Only Congress has the authority 

to designate wilderness. Within the refuge we have CMR 

and we have UL Bend. UL Bend has designated wilderness 

on it. All the other areas are proposed. Proposed 

means they've been evaluated by the service, they've 

been approved by the service, they've been approved by 

the Secretary of Interior, and are waiting action by 

Congress. 

Since they have not been designated, the service 

can go back during this planning process and reevaluate 

those lands and determine whether they still meet that 

wilderness characteristic, and make a recommendation 

back to our director's office and then up to the 

secretaries office. According to our policy, we do 

manage proposed wilderness as if it was designated, so 

we maintain those characteristics until Congress goes 

ahead and acts on that. 

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I think we had one other one that was about the 

cross fences down in Harper's Ridge. And that was on 

exclosure. It wasn't an interior type fence that 

divided pastures, it was a habitat exclosure that 

burned up in a fire, and since it is in a proposed 

wilderness area, we weren't going to go back in and 

rebuild that exclosure, so we went ahead and took that 

fence out. 

RON GARWOOD: Excuse me, Barron. That 

isn't in a proposed wilderness area over there on the 

north side of Harper's Ridge. 

MR. CRAWFORD: It's just outside of it, 

but it was a fence no longer needed for management, and 

it was non-functional. It was laying on the ground, 

Ron.

RON GARWOOD: I know that, and excuse me, 

one question. And in the fires of 2006 when you were 

fighting fires on the south side of Harper's Ridge and 

it got away from you and burned on the north side, 

that's when it burned those up, and now you're taking 

out cross fences.

MR. BERG: But that fence is not needed 

anymore for livestock management. That's the reason 

we're taking it out. 

I just wanted to expand a little bit on Steve's 

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question about USDA permits. Under current management 

we've got a couple blanket agreements with USDA to go 

in and remove predators when they cause trouble for 

livestock, mostly sheep, in the area around Haxby 

Point, Garfield County. Some of those sheep no longer 

operate in that area. There are no sheep out on the 

tip of Haxby Point like there used to be. 

What we're proposing to do is take those off the 

table. When depredation problems do arise, we'll 

address those individually as they come up. And, for 

the record, the wolf that was shot down in Timber Creek 

a few years back, we actually issued a permit 

authorizing the taking of that animal on the refuge if 

it occurred there, so -- and it wasn't taken on the 

refuge. It ended up being taken several miles up 

Timber Creek, but just so you understand how we're 

proposing to handle that in the future. 

If wolves did move onto an area and they could get 

along for a period of time without causing depredation 

problems, you know, our policy would be not to go in 

and kill them just for the sake of killing them.

We'll be around afterwards here. Several staff 

people here. Bob Skinner, somebody had a question 

about the sentinel plant concept. There's a lot of 

different names for sentinel plants, and maybe Bob can 

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interpretive activities have we done? We do have -- we 

had -- we had a person that was stationed at Fort Peck 

that was an outdoor rec. planner that worked with the 

Corp staff on taking programs to schools, and 

unfortunately we lost that position about three years 

ago and have not filled it back. What we have done is 

converted a person in our Lewistown office from admin. 

position to a manager/trainee position with part of her 

duties being environmental education outreach, and been 

working in mostly the Lewistown district right now 

because that's where she's based out of. Hopefully in 

the plan we've identified the need for additional 

outdoor rec. planner, environmental education type 

planners that could assist with taking environmental 

education programs to the schools. 

Other things we identified in the plan was the 

building of various interpretive trails, a couple of 

them here on the east end of the refuge to interpret 

the natural and historical resources of the area. 

No, we're not going to introduce wolves. What we 

state in the plan is it involves naturally colonizing 

the area. We would work with Fish, Wildlife & Parks to 

identify a management plan for them. We are not going 

to consider hunting those species if they do migrate on 

to the refuge. We do have in there that we will 

1

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47

authorize the taking of wolves that are causing 

livestock deprivation. The canceling of the service 

with Avis, USDA is mostly for coyote control, that's 

being done on the southeast portion of the refuge at 

1

2

3

4

5

48

I think we had one other one that was about the 

cross fences down in Harper's Ridge. And that was on 

exclosure. It wasn't an interior type fence that 

divided pastures, it was a habitat exclosure that 

burned up in a fire, and since it is in a proposed 

wilderness area, we weren't going to go back in and 

rebuild that exclosure, so we went ahead and took that 

fence out. 

RON GARWOOD: Excuse me, Barron. That 

isn't in a proposed wilderness area over there on the 

north side of Harper's Ridge. 

MR. CRAWFORD: It's just outside of it, 

but it was a fence no longer needed for management, and 

it was non-functional. It was laying on the ground, 

Ron.

RON GARWOOD: I know that, and excuse me, 

one question. And in the fires of 2006 when you were 

fighting fires on the south side of Harper's Ridge and 

it got away from you and burned on the north side, 

that's when it burned those up, and now you're taking 

out cross fences.

MR. BERG: But that fence is not needed 

anymore for livestock management. That's the reason 

we're taking it out. 

I just wanted to expand a little bit on Steve's 

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question about USDA permits. Under current management 

we've got a couple blanket agreements with USDA to go 

in and remove predators when they cause trouble for 

livestock, mostly sheep, in the area around Haxby 

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VOLUME 2, Chapter 4—Public Hearing Testimony 425

Page 46 to 49 of 54 13 of 16 sheets

rally colonizing 

ildlife & Parks to 

We are not going 

they do migrate on 

hat we will 

47

re causing 

 of the service 

control, that's 

f the refuge at 

rity do we have to 

is we're talking 

 talking about 

 has the authority 

refuge we have CMR 

ignated wilderness 

sed. Proposed 

ervice, they've 

 been approved by 

iting action by 

ed, the service 

ess and reevaluate 

y still meet that 

 recommendation 

n up to the 

 policy, we do 

as designated, so 

il Congress goes 

p, yg 

out cross fences.

MR. BERG: But that fence is not needed 

anymore for livestock management. That's the reason 

we're taking it out. 

I just wanted to expand a little bit on Steve's 

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49

question about USDA permits. Under current management 

we've got a couple blanket agreements with USDA to go 

in and remove predators when they cause trouble for 

livestock, mostly sheep, in the area around Haxby 

Point, Garfield County. Some of those sheep no longer 

operate in that area. There are no sheep out on the 

tip of Haxby Point like there used to be. 

What we're proposing to do is take those off the 

table. When depredation problems do arise, we'll 

address those individually as they come up. And, for 

the record, the wolf that was shot down in Timber Creek 

a few years back, we actually issued a permit 

authorizing the taking of that animal on the refuge if 

it occurred there, so -- and it wasn't taken on the 

refuge. It ended up being taken several miles up 

Timber Creek, but just so you understand how we're 

proposing to handle that in the future. 

If wolves did move onto an area and they could get 

along for a period of time without causing depredation 

problems, you know, our policy would be not to go in 

and kill them just for the sake of killing them.

We'll be around afterwards here. Several staff 

people here. Bob Skinner, somebody had a question 

about the sentinel plant concept. There's a lot of 

different names for sentinel plants, and maybe Bob can 

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14 of 16 sheets Page 50 to 53 of 54 

50

give you a better idea what those plants are. Matt 

DeRosier is in the back there, west end Sand Creek 

manager. Aaron Johnson up here in the front is at Fort 

Peck, closer to home. Paula Gouse is in the back, 

Jared Eatmon in the back.

UNIDENTIFIED PERSON: I've got a quick 

question. I'm sorry. Is this a cooperation or a 

coordination with Valley County? 

MR. CRAWFORD: Valley County was one of 

the cooperating agencies on this planning effort. They 

were included in the county group. They weren't always 

represented in the meetings because they had other 

county commissioners from some of the adjacent counties 

that were represented.

UNIDENTIFIED PERSON: But cooperate or 

coordinate? 

MR. CRAWFORD: Cooperating?

UNIDENTIFIED PERSON: Do they have 

coordinating status and will they?

MR. BERG: You know, I guess in my mind 

there's not much difference. For example, on -- 

something came up on roads here earlier where we're not 

proposing to address some of the -- like the 2477 

issue, petition roads, some of those things. That's 

going to be part of the road management plan that we 

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do, which is a subset of this. In an instance like 

that, the counties would be a cooperating agency. We 

work directly with them, probably more with the 

counties than anybody else, and some of the adjacent 

land owners that those roads effect, so in that case 

they would be a coordinating agency. Coordinating 

where they have a say, and you have to listen, instead 

of cooperating where they say but you do what you want.

And the reason for that, as you define it -- I've 

never heard it defined that way -- the fact is some of 

those roads that proverse [sic] the refuge have 

petition, so we legally would have to address those on 

the refuge because there's another entity that has a 

legal identifier to that road.

COMMISSIONER PIPPIN: Valley County has a 

further question that never was addressed in the 

responses to questions. We've repeatedly brought up 

the issue of valid, preexisting rights. 

Now, when you read the cases in the United States 

Court of Claims where people have been forced to file a 

claim against the federal government for the taking of 

their property under the Tucker Act. The court 

recognized that under the prior appropriation doctrine 

ranchers, for example, owned vested water rights, and 

the court said the rancher owns the fee. That's 

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because the 

for vested 

local law, 

please, sir

were grazin

on in inher

you know wh

pass the pe

the permit 

court recog

that proper

the court h

extinguish 

Valley 

letters in 

pretty much 

rights, wha

has to do, 

General ove

in this cas

answer. Co

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or the plan 

regard to w

Etchart. I

address, I

Thanks. 

left? I'm 

to last unt

you have an

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give you a better idea what those plants are. Matt 

DeRosier is in the back there, west end Sand Creek 

manager. Aaron Johnson up here in the front is at Fort 

Peck, closer to home. Paula Gouse is in the back, 

Jared Eatmon in the back.

UNIDENTIFIED PERSON: I've got a quick 

question. I'm sorry. Is this a cooperation or a 

coordination with Valley County? 

MR. CRAWFORD: Valley County was one of 

the cooperating agencies on this planning effort. They 

were included in the county group. They weren't always 

represented in the meetings because they had other 

county commissioners from some of the adjacent counties 

that were represented.

UNIDENTIFIED PERSON: But cooperate or 

coordinate? 

MR. CRAWFORD: Cooperating?

UNIDENTIFIED PERSON: Do they have 

coordinating status and will they?

MR. BERG: You know, I guess in my mind 

there's not much difference. For example, on -- 

something came up on roads here earlier where we're not 

proposing to address some of the -- like the 2477 

issue, petition roads, some of those things. That's 

going to be part of the road management plan that we 

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do, which is a subset of this. In an instance like 

that, the counties would be a cooperating agency. We 

work directly with them, probably more with the 

counties than anybody else, and some of the adjacent 

land owners that those roads effectso in that case 

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52

because the federal government in 1866 passed a statute 

for vested water rights and rights of way according to 

local law, custom and decisions of courts.

MR. BERG: Well --

COMMISSIONER PIPPIN: Let me finish, 

please, sir. Now, well before a BLM was created there 

were grazing rights recognized, bought and sold, passed 

on in inheritance. Traditionally this agency has said, 

you know what, if you go to a family, we'll let you 

pass the permit down, but if you sell the place, nope, 

the permit doesn't go. You haven't addressed that the 

court recognizes that the permit is not property, and 

that property exists independent of the permit. And 

the court has said, cancellation of a permit does not 

extinguish the property. 

Valley county's question is because we've got 

letters in our file, we've got responses back that 

pretty much say, nope, we say there are no private 

rights, what -- my question is: What is it the county 

has to do, short of calling for an Office of Inspector 

General oversight, to get Fish and Wildlife Service -- 

MR. BERG: That might be the best avenue 

in this case.

COMMISSIONER PIPPIN: Okay. Got our 

answer. Commissioner Pippin. 

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MR. BERG: Because this isn't the venue 

or the plan that's going to address that issue. In 

regard to water rights, we have an expert, Gene 

Etchart. If you have a water rights issue we can't 

addressI'm sure Gene could help us with that

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14 of 16 sheets Page 50 to 53 of 54 02/14/2011 11:36:41 AM

50

give you a better idea what those plants are. Matt 

DeRosier is in the back there, west end Sand Creek 

manager. Aaron Johnson up here in the front is at Fort 

Peck, closer to home. Paula Gouse is in the back, 

Jared Eatmon in the back.

UNIDENTIFIED PERSON: I've got a quick 

question. I'm sorry. Is this a cooperation or a 

coordination with Valley County? 

MR. CRAWFORD: Valley County was one of 

the cooperating agencies on this planning effort. They 

were included in the county group. They weren't always 

represented in the meetings because they had other 

county commissioners from some of the adjacent counties 

that were represented.

UNIDENTIFIED PERSON: But cooperate or 

coordinate? 

MR. CRAWFORD: Cooperating?

UNIDENTIFIED PERSON: Do they have 

coordinating status and will they?

MR. BERG: You know, I guess in my mind 

there's not much difference. For example, on -- 

something came up on roads here earlier where we're not 

proposing to address some of the -- like the 2477 

issue, petition roads, some of those things. That's 

going to be part of the road management plan that we 

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2

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5

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9

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do, which is a subset of this. In an instance like 

that, the counties would be a cooperating agency. We 

work directly with them, probably more with the 

counties than anybody else, and some of the adjacent 

land owners that those roads effect, so in that case 

they would be a coordinating agency. Coordinating 

where they have a say, and you have to listen, instead 

of cooperating where they say but you do what you want.

And the reason for that, as you define it -- I've 

never heard it defined that way -- the fact is some of 

those roads that proverse [sic] the refuge have 

petition, so we legally would have to address those on 

the refuge because there's another entity that has a 

legal identifier to that road.

COMMISSIONER PIPPIN: Valley County has a 

further question that never was addressed in the 

responses to questions. We've repeatedly brought up 

the issue of valid, preexisting rights. 

Now, when you read the cases in the United States 

Court of Claims where people have been forced to file a 

claim against the federal government for the taking of 

their property under the Tucker Act. The court 

recognized that under the prior appropriation doctrine 

ranchers, for example, owned vested water rights, and 

the court said the rancher owns the fee. That's 

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because the federal government in 1866 passed a statute 

for vested water rights and rights of way according to 

local law, custom and decisions of courts.

MR. BERG: Well --

COMMISSIONER PIPPIN: Let me finish, 

please, sir. Now, well before a BLM was created there 

were grazing rights recognized, bought and sold, passed 

on in inheritance. Traditionally this agency has said, 

you know what, if you go to a family, we'll let you 

pass the permit down, but if you sell the place, nope, 

the permit doesn't go. You haven't addressed that the 

court recognizes that the permit is not property, and 

that property exists independent of the permit. And 

the court has said, cancellation of a permit does not 

extinguish the property. 

Valley county's question is because we've got 

letters in our file, we've got responses back that 

pretty much say, nope, we say there are no private 

rights, what -- my question is: What is it the county 

has to do, short of calling for an Office of Inspector 

General oversight, to get Fish and Wildlife Service -- 

MR. BERG: That might be the best avenue 

in this case.

COMMISSIONER PIPPIN: Okay. Got our 

answer. Commissioner Pippin. 

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MR. BERG: Because this isn't the venue 

or the plan that's going to address that issue. In 

regard to water rights, we have an expert, Gene 

Etchart. If you have a water rights issue we can't 

address, I'm sure Gene could help us with that. 

Thanks. 

MS. MATHER: That's it --

UNIDENTIFIED PERSON: Have I got any time 

left? I'm all washed up. 

MS. MATHER: You can talk to staff.

UNIDENTIFIED PERSON: This was supposed 

to last until 3:00. 

MS. MATHER: We'll be here until 3:00, if 

you have any questions of the staff. 

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426 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 50 to 53 of 54 02/14/2011 11:36:41 AM

 on -- 

ere we're not 

he 2477 

s. That's 

an that we 

51

ance like 

agency. We 

h the 

e adjacent 

 that case 

dinating 

ten, instead 

hat you want.

e it -- I've 

t is some of 

 have 

ess those on 

 that has a 

 County has a 

in the 

 brought up 

nited States 

ced to file a 

he taking of 

 court 

ion doctrine 

rights, and 

That's 

General oversight, to get Fish and Wildlife Service -- 

MR. BERG: That might be the best avenue 

in this case.

COMMISSIONER PIPPIN: Okay. Got our 

answer. Commissioner Pippin. 

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MR. BERG: Because this isn't the venue 

or the plan that's going to address that issue. In 

regard to water rights, we have an expert, Gene 

Etchart. If you have a water rights issue we can't 

address, I'm sure Gene could help us with that. 

Thanks. 

MS. MATHER: That's it --

UNIDENTIFIED PERSON: Have I got any time 

left? I'm all washed up. 

MS. MATHER: You can talk to staff.

UNIDENTIFIED PERSON: This was supposed 

to last until 3:00. 

MS. MATHER: We'll be here until 3:00, if 

you have any questions of the staff. 

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54

CERTIFICATE

STATE OF MONTANA )

)ss

COUNTY OF VALLEY )

 I, Kelley A. Barstad, Official Court Reporter of

the Montana Seventeenth Judicial District Court, and

Notary Public for the County of Valley, State of

Montana, residing at Glasgow, Montana DO HEREBY

CERTIFY:

That I was duly authorized to and did report the

foregoing proceeding. Said testimony and

proceedings were reported and transcribed by me with

 a computerized transcription system.

That the foregoing transcript of this matter

constitutes a true and accurate transcription of the

proceedings which were heard.

IN WITNESS WHEREOF, I have hereunto set my hand and

affixed my notarial seal this 30th day of January,

2011.

____________________________

Kelley A. Barstad

Certified Shorthand Reporter

My commission expires 2-2-14
VOLUME 2, Chapter 4—Public Hearing Testimony 427

02/14/2011 11:37:33 AM Page 1 to 1 of 44 1 of 14 sheets

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1

PUBLIC HEARING

OCTOBER 14, 2010

MALTA, MONTANA

U.S. Fish & Wildlife Service.

Draft Comprehensive Conservation

Plan and Environmental Impact Statement

Charles M. Russell National Wildlife Refuge

and UL Bend National Wildlife Refuge

2 of 14 sheets Page 2 to 5 of 44 

2

MS. MATHER: Good evening, everybody. 

Thank you for coming. If you take a seat, we can get 

started here. Somebody's lights are on across the 

street, a white Taurus. Anybody's? Okay. Thank you 

all for coming this evening. My name's Mimi. I'll be 

facilitating the meeting this evening. I'm up here 

with Barron Crawford, CMRs project leader, Bill Berg, 

the deputy project leader, and Laurie Shannon, the 

planning team leader for the CCP. 

The purpose of today's meeting is for the Fish and 

Wildlife Service to collect your comments on the 

conservation plan, the Draft CCP, as we've been calling 

it. We'll start the evening with Barron giving a 

presentation on the CCP, and then we'll turn it over to 

you. 

Most people have signed up who want to give a 

comment. If you want to sign up later, that's fine 

too. Keep in mind, though, we're going to be limiting 

it to three minutes, so if you've got a lot to say, 

start thinking about how you can streamline your 

thoughts and get it down to three minutes. With that 

I'll turn it over to Barron. 

MR. CRAWFORD: Thanks everyone for taking 

time out of your evening to come here tonight. I've 

been asked to speak a little bit slower as I go through 

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this, which shouldn't be a problem for me. I'll just 

pull out the southern twang out here a little built, 

draw stuff out. So we're going to talk about the CCP 

for the Charles M. Russell and the UL Bend National 

Wildlife Refuges. 

We started this process back in 2007. We held 14 

public meetings, collected about 24,000 comments. 

We've had numerous meetings with your cooperators, and 

now we're at the point where we've developed this draft 

document where everybody has had a chance, or is having 

a chance to review. 

This is kind of the timeline of what we've been 

doing and when we've been doing it. So right now we're 

in the fall of 2010 with the draft out. Hope to have 

the final CCP out by the winter of 2012 with a record 

of decision by that summer. So basically we do a CCP 

for several reasons. The first is it's mandated by 

Congress. 

The National Wildlife Refuge System Improvement Act 

of 1997 said all national wildlife refuges will have a 

CCP completed by 2011, so there's about 548 refuges. 

Right now about two-thirds of those have completed 

plans. The rest of us, like CMR, are working 

feverishly trying to make that 2012 deadline. We've 

received some comments from folks about why are you 

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rushing th

deadline. 

So the

first one 

gives guid

and the mi

Refuge man

others. A

management 

there's no

thoughts o

outlines a 

strategies 

It's a

either an 

And due to 

here at CM

Impact Sta

document i

it provide

period. T

time perio

So thi

steps. We

comments, 

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move up he

plan, you 

haven't me

the servic

management

So one 

there's a 

accused of 

have done 

this strat

gather inf

evaluate t

those goal

component 

So we 

the no act

been opera

would be a 

the 65 hab

gradually 

doing now. 

levels tha

per square 

keep the 6

provide pr

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MS. MATHER: Good evening, everybody. 

Thank you for coming. If you take a seat, we can get 

started here. Somebody's lights are on across the 

street, a white Taurus. Anybody's? Okay. Thank you 

all for coming this evening. My name's Mimi. I'll be 

facilitating the meeting this evening. I'm up here 

with Barron Crawford, CMRs project leader, Bill Berg, 

the deputy project leader, and Laurie Shannon, the 

planning team leader for the CCP. 

The purpose of today's meeting is for the Fish and 

Wildlife Service to collect your comments on the 

conservation plan, the Draft CCP, as we've been calling 

it. We'll start the evening with Barron giving a 

presentation on the CCP, and then we'll turn it over to 

you. 

Most people have signed up who want to give a 

comment. If you want to sign up later, that's fine 

too. Keep in mind, though, we're going to be limiting 

it to three minutes, so if you've got a lot to say, 

start thinking about how you can streamline your 

thoughts and get it down to three minutes. With that 

I'll turn it over to Barron. 

MR. CRAWFORD: Thanks everyone for taking 

time out of your evening to come here tonight. I've 

been asked to speak a little bit slower as I go through 

1

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this, which shouldn't be a problem for me. I'll just 

pull out the southern twang out here a little built, 

draw stuff out. So we're going to talk about the CCP 

for the Charles M. Russell and the UL Bend National 

WildlifRf

1

2

3

4

5

4

rushing through this. It's basically to meet this 

deadline. 

So there's several key elements to a CCP. The 

first one is it provides that management direction, 

gives guidance. It's based upon the refuge purposes 

and the mission of the National Wildlife Refuge System. 

Refuge managers come and go, some stay longer than 

others. As new managers come in, they basically have a 

management plan to guide that management, and so 

there's not an abrupt change, you know, based upon the 

thoughts or ideas of a new manager coming on board. It 

outlines a vision statement with goals, objectives and 

strategies for that future management. 

It's accompanied by some type of a NEPA document, 

either an environmental assessment or impact statement. 

And due to the complexity of issues we're dealing with 

here at CMR, we went ahead and did an Environmental 

Impact Statement, and that's one of the reasons this 

document is 400 some pages long. And the last thing is 

it provides that long term guidance for that 15-year 

period. There are 15-year plans. At the end of that 

time period the process starts over again. 

So this is where we're at. There's kind of eight 

steps. We're down here at number five. After public 

comments, after we've evaluated those public comments, 

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move up here to number six, and then you implement the 

plan, you monitor and evaluate. That's one thing I 

haven't mentioned at some of the previous meetings is 

the services adopted in this policy called adaptive 

t

1

2

3

4

5

2 of 14 sheets Page 2 to 5 of 44 02/14/2011 11:37:33 AM

2

MS. MATHER: Good evening, everybody. 

Thank you for coming. If you take a seat, we can get 

started here. Somebody's lights are on across the 

street, a white Taurus. Anybody's? Okay. Thank you 

all for coming this evening. My name's Mimi. I'll be 

facilitating the meeting this evening. I'm up here 

with Barron Crawford, CMRs project leader, Bill Berg, 

the deputy project leader, and Laurie Shannon, the 

planning team leader for the CCP. 

The purpose of today's meeting is for the Fish and 

Wildlife Service to collect your comments on the 

conservation plan, the Draft CCP, as we've been calling 

it. We'll start the evening with Barron giving a 

presentation on the CCP, and then we'll turn it over to 

you. 

Most people have signed up who want to give a 

comment. If you want to sign up later, that's fine 

too. Keep in mind, though, we're going to be limiting 

it to three minutes, so if you've got a lot to say, 

start thinking about how you can streamline your 

thoughts and get it down to three minutes. With that 

I'll turn it over to Barron. 

MR. CRAWFORD: Thanks everyone for taking 

time out of your evening to come here tonight. I've 

been asked to speak a little bit slower as I go through 

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this, which shouldn't be a problem for me. I'll just 

pull out the southern twang out here a little built, 

draw stuff out. So we're going to talk about the CCP 

for the Charles M. Russell and the UL Bend National 

Wildlife Refuges. 

We started this process back in 2007. We held 14 

public meetings, collected about 24,000 comments. 

We've had numerous meetings with your cooperators, and 

now we're at the point where we've developed this draft 

document where everybody has had a chance, or is having 

a chance to review. 

This is kind of the timeline of what we've been 

doing and when we've been doing it. So right now we're 

in the fall of 2010 with the draft out. Hope to have 

the final CCP out by the winter of 2012 with a record 

of decision by that summer. So basically we do a CCP 

for several reasons. The first is it's mandated by 

Congress. 

The National Wildlife Refuge System Improvement Act 

of 1997 said all national wildlife refuges will have a 

CCP completed by 2011, so there's about 548 refuges. 

Right now about two-thirds of those have completed 

plans. The rest of us, like CMR, are working 

feverishly trying to make that 2012 deadline. We've 

received some comments from folks about why are you 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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19

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21

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25

4

rushing through this. It's basically to meet this 

deadline. 

So there's several key elements to a CCP. The 

first one is it provides that management direction, 

gives guidance. It's based upon the refuge purposes 

and the mission of the National Wildlife Refuge System. 

Refuge managers come and go, some stay longer than 

others. As new managers come in, they basically have a 

management plan to guide that management, and so 

there's not an abrupt change, you know, based upon the 

thoughts or ideas of a new manager coming on board. It 

outlines a vision statement with goals, objectives and 

strategies for that future management. 

It's accompanied by some type of a NEPA document, 

either an environmental assessment or impact statement. 

And due to the complexity of issues we're dealing with 

here at CMR, we went ahead and did an Environmental 

Impact Statement, and that's one of the reasons this 

document is 400 some pages long. And the last thing is 

it provides that long term guidance for that 15-year 

period. There are 15-year plans. At the end of that 

time period the process starts over again. 

So this is where we're at. There's kind of eight 

steps. We're down here at number five. After public 

comments, after we've evaluated those public comments, 

1

2

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5

move up here to number six, and then you implement the 

plan, you monitor and evaluate. That's one thing I 

haven't mentioned at some of the previous meetings is 

the services adopted in this policy called adaptive 

management. 

So one of the comments we received is it seems like 

there's a lot of vagueness in this plan, and being 

accused of doing that on purpose. Well, like, yeah, we 

have done that on purpose because we'll be employing 

this strategy called adaptive management. As you 

gather information, as you do make changes, you 

evaluate those changes to make sure you're meeting 

those goals, and then you adapt. So that is a 

component that is built in to this planning process. 

So we have four alternatives. "Alternative A" is 

the no action. It's basically keep operating as we've 

been operating since the 1986 EIS was completed. There 

would be a few minor changes. We continue to manage on 

the 65 habitat units like we're doing now. We'd 

gradually implement prescriptive grazing like we're 

doing now. We'd manage big game to achieve the target 

levels that were identified in that '86 EIS, 2.5 elk 

per square mile, 10 mule deer per square mile. We'd 

keep the 670 Miles Of Road open, and we'd continue to 

provide protection to the 155,000 acres of proposed 

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428 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 2 to 5 of 44 02/14/2011 11:37:33 AM

ne your 

 With that 

ne for taking 

ight. I've 

s I go through 

3

 I'll just 

ttle built, 

bout the CCP 

d National 

 We held 14 

omments. 

perators, and 

ped this draft 

 or is having 

we've been 

ight now we're 

Hope to have 

ith a record 

 we do a CCP 

andated by 

mprovement Act 

s will have a 

8 refuges. 

completed 

king 

ine. We've 

hy are you 

it provides that long term guidance for that 15year 

period. There are 15-year plans. At the end of that 

time period the process starts over again. 

So this is where we're at. There's kind of eight 

steps. We're down here at number five. After public 

comments, after we've evaluated those public comments, 

20

21

22

23

24

25

5

move up here to number six, and then you implement the 

plan, you monitor and evaluate. That's one thing I 

haven't mentioned at some of the previous meetings is 

the services adopted in this policy called adaptive 

management. 

So one of the comments we received is it seems like 

there's a lot of vagueness in this plan, and being 

accused of doing that on purpose. Well, like, yeah, we 

have done that on purpose because we'll be employing 

this strategy called adaptive management. As you 

gather information, as you do make changes, you 

evaluate those changes to make sure you're meeting 

those goals, and then you adapt. So that is a 

component that is built in to this planning process. 

So we have four alternatives. "Alternative A" is 

the no action. It's basically keep operating as we've 

been operating since the 1986 EIS was completed. There 

would be a few minor changes. We continue to manage on 

the 65 habitat units like we're doing now. We'd 

gradually implement prescriptive grazing like we're 

doing now. We'd manage big game to achieve the target 

levels that were identified in that '86 EIS, 2.5 elk 

per square mile, 10 mule deer per square mile. We'd 

keep the 670 Miles Of Road open, and we'd continue to 

provide protection to the 155,000 acres of proposed 

1

2

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5

6

7

8

9

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02/14/2011 11:37:33 AM Page 6 to 9 of 44 3 of 14 sheets

6

wilderness. 

So then we've got three action alternatives. The 

first one we've coined the Wildlife and Habitat 

emphasis. And basically this one is we're managing the 

landscape in cooperation with our partners to emphasize 

an abundance and diversity of wildlife that uses both 

natural ecological processes, such as fire and grazing, 

and synthetic processes such as farming or tree 

planting. 

We encourage wildlife and public uses such as 

hunting, fishing, photography and wildlife 

interpretation, and we'd limit economic uses when they 

compete for habitat resources. 

So outside the door as you were coming in we had 

several maps set up, and these maps depict what the 

various alternatives might look like, so under 

"Alternative B" we've got expansion of some proposed 

wilderness areas, and we've got some suggestions for 

some road closures. 

And this is the east half of the refuge. So some 

of the main points of "Alternative B" is we'd actively 

manage, manipulate habitats for productive wildlife 

food and cover. We'd get aggressive in moving towards 

prescriptive grazing. We'd want to be prescriptively 

grazing 50 to 75 percent of the refuge within four to 

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seven years. Right now we're grazing about 35 percent. 

We'd get aggressive in restoration on the river 

bottoms. We'd work with Fish Wildlife and Parks to 

provide quality hunting opportunities, sustain 

populations of big game, and habitats for non-game. 

We'd close about 106 miles of roads, and we'd expand 

acreage in the proposed wilderness areas by 

25,000 acres. 

So the next alternative, "C," was what we coined 

the Public Use and Economic Emphasis. And this one 

again we're working in cooperation to manage the 

landscape to emphasize and promote maximum compatible 

wildlife dependent uses and economic uses, while 

protecting wildlife and habitats to the extent 

possible, and we'd minimize impacts to wildlife 

habitats while using a variety of tools that enhance 

the diversity of public and economic opportunities. 

So under this alternative you don't see any road 

closures, no proposed expansion of any wilderness 

areas, and recommendations of eliminating a couple of 

wilderness areas. There's one. 

So kind of the main points of this one is manage 

habitats to provide more opportunities for recreation. 

Work with Fish Wildlife and Parks to maintain balanced 

numbers of big game and livestock. Expand and maximize 

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some hunting opportunities. Improve access to boat 

ramps and then recommend eliminating four proposed 

wilderness units for a loss of 35,880 acres. 

And then the last alternative, "Alternative D," is 

the one that's called our proposed action. We've 

coined this the Natural Processes or the Ecological 

Processes, and, again, working with our partners, 

intensively use those natural ecological processes of 

fire and grazing in a balanced, responsible manner to 

restore and maintain the biological integrity of 

environmental health. 

And that phrase comes straight from our organic 

legislation as to what we're supposed to do on a 

national wildlife refuge. So once those processes are 

restored, we'd take a more passive approach. We'd 

still work to provide those quality public uses, and 

we'd limit those uses when they are causing injury to 

either the plants or habitats out there. 

So on this map we've got expansion of a couple of 

wilderness areas. We've got proposed to close a couple 

of roads, and we've proposed to eliminate a couple of 

wilderness areas, proposed wilderness areas, here and 

here. 

So main points here, economic use would be limited 

when they are injurious to the natural processes. 

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Apply management practices that mimic and restore 

natural processes, and those natural processes again, 

fire and grazing. Use fire and grazing whether its 

with wild or livestock, so prescriptively to mimic that 

historic interaction. 

Again, work with Fish Wildlife and Parks to 

maintain diversity of species. Close about 25 miles of 

roads, so quite a difference, and then recommend 

expanding six of the proposed wilderness areas for 

18,000 acres, but eliminate three for a loss of 26,000. 

So kind of strike a little bit of balance there between 

B, C and D. 

So this is our seventh meeting for this round. 

We've had a lot of good comments. Some of the hot 

button topics or questions that we've received during 

this is what is prescriptive grazing. Kind of a lot of 

questions surrounding that, and the basic way to answer 

that is prescriptive grazing is using livestock to meet 

a very specific wildlife and/or habitat objective. 

So one example of that is say we have an area 

that's important for wintering sage grouse, or it's an 

important sage grouse lek, and we've got heavy grass 

coming into that area and there's a threat of wild fire 

that could come through there and eliminate that sage 

grouse habitat. We would use livestock to go in there 

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02/14/2011 11:37:33 AM Page 6 to 9 of 44 

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wilderness. 

So then we've got three action alternatives. The 

first one we've coined the Wildlife and Habitat 

emphasis. And basically this one is we're managing the 

landscape in cooperation with our partners to emphasize 

an abundance and diversity of wildlife that uses both 

natural ecological processes, such as fire and grazing, 

and synthetic processes such as farming or tree 

planting. 

We encourage wildlife and public uses such as 

hunting, fishing, photography and wildlife 

interpretation, and we'd limit economic uses when they 

compete for habitat resources. 

So outside the door as you were coming in we had 

several maps set up, and these maps depict what the 

various alternatives might look like, so under 

"Alternative B" we've got expansion of some proposed 

wilderness areas, and we've got some suggestions for 

some road closures. 

And this is the east half of the refuge. So some 

of the main points of "Alternative B" is we'd actively 

manage, manipulate habitats for productive wildlife 

food and cover. We'd get aggressive in moving towards 

prescriptive grazing. We'd want to be prescriptively 

grazing 50 to 75 percent of the refuge within four to 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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seven years. Right now we're grazing about 35 percent. 

We'd get aggressive in restoration on the river 

bottoms. We'd work with Fish Wildlife and Parks to 

provide quality hunting opportunities, sustain 

populations of big game, and habitats for non-game. 

We'd close about 106 miles of roads, and we'd expand 

acreage in the proposed wilderness areas by 

25,000 acres. 

So the next alternative, "C," was what we coined 

the Public Use and Economic Emphasis. And this one 

again we're working in cooperation to manage the 

landscape to emphasize and promote maximum compatible 

wildlife dependent uses and economic uses, while 

protecting wildlife and habitats to the extent 

possible, and we'd minimize impacts to wildlife 

habitats while using a variety of tools that enhance 

the diversity of public and economic opportunities. 

So under this alternative you don't see any road 

closures, no proposed expansion of any wilderness 

areas, and recommendations of eliminating a couple of 

wilderness areas. There's one. 

So kind of the main points of this one is manage 

habitats to provide more opportunities for recreation. 

Work with Fish Wildlife and Parks to maintain balanced 

numbers of big game and livestock. Expand and maximize 

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some hunting op

ramps and then 

wilderness unit

And then th

the one that's 

coined this the 

Processes, and, 

intensively use 

fire and grazin

restore and mai

environmental h

And that ph

legislation as 

national wildli

restored, we'd 

still work to p

we'd limit thos

either the plan

So on this 

wilderness area

of roads, and w

wilderness area

here. 

So main po

when they are i

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Apply managemen

natural process

fire and grazin

with wild or li

historic intera

Again, wor

maintain divers

roads, so quite 

expanding six o

18,000 acres, b

So kind of stri

B, C and D. 

So this is 

We've had a lot 

button topics o

this is what is 

questions surro

that is prescri

a very specific 

So one exam

that's importan

important sage 

coming into tha

that could come 

grouse habitat. 

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wilderness. 

So then we've got three action alternatives. The 

first one we've coined the Wildlife and Habitat 

emphasis. And basically this one is we're managing the 

landscape in cooperation with our partners to emphasize 

an abundance and diversity of wildlife that uses both 

natural ecological processes, such as fire and grazing, 

and synthetic processes such as farming or tree 

planting. 

We encourage wildlife and public uses such as 

hunting, fishing, photography and wildlife 

interpretation, and we'd limit economic uses when they 

compete for habitat resources. 

So outside the door as you were coming in we had 

several maps set up, and these maps depict what the 

various alternatives might look like, so under 

"Alternative B" we've got expansion of some proposed 

wilderness areas, and we've got some suggestions for 

some road closures. 

And this is the east half of the refuge. So some 

of the main points of "Alternative B" is we'd actively 

manage, manipulate habitats for productive wildlife 

food and cover. We'd get aggressive in moving towards 

prescriptive grazing. We'd want to be prescriptively 

grazing 50 to 75 percent of the refuge within four to 

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seven years. Right now we're grazing about 35 percent. 

We'd get aggressive in restoration on the river 

bottoms. We'd work with Fish Wildlife and Parks to 

provide quality hunting opportunities, sustain 

ltif bid hbittf

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some hunting opportunities. Improve access to boat 

ramps and then recommend eliminating four proposed 

wilderness units for a loss of 35,880 acres. 

And then the last alternative, "Alternative D," is 

the one that's called our proposed action. We've 

coined this the Natural Processes or the Ecological 

Processes, and, again, working with our partners, 

intensively use those natural ecological processes of 

fire and grazing in a balanced, responsible manner to 

restore and maintain the biological integrity of 

environmental health. 

And that phrase comes straight from our organic 

legislation as to what we're supposed to do on a 

national wildlife refuge. So once those processes are 

restored, we'd take a more passive approach. We'd 

still work to provide those quality public uses, and 

we'd limit those uses when they are causing injury to 

either the plants or habitats out there. 

So on this map we've got expansion of a couple of 

wilderness areas. We've got proposed to close a couple 

of roads, and we've proposed to eliminate a couple of 

wilderness areas, proposed wilderness areas, here and 

here. 

So main points here, economic use would be limited 

when they are injurious to the natural processes. 

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Apply management practices that mimic and restore 

natural processes, and those natural processes again, 

fire and grazing. Use fire and grazing whether its 

with wild or livestock, so prescriptively to mimic that 

hitiitti

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VOLUME 2, Chapter 4—Public Hearing Testimony 429

Page 6 to 9 of 44 3 of 14 sheets

 refuge. So some 

" is we'd actively 

uctive wildlife 

 in moving towards 

be prescriptively 

ge within four to 

7

g about 35 percent. 

n the river 

fe and Parks to 

s, sustain 

s for non-game. 

 and we'd expand 

reas by 

s what we coined 

. And this one 

o manage the 

aximum compatible 

 uses, while 

the extent 

to wildlife 

ols that enhance 

 opportunities. 

n't see any road 

ny wilderness 

ating a couple of 

is one is manage 

es for recreation. 

 maintain balanced 

Expand and maximize 

wilderness areas. Weve got proposed to close a couple 

of roads, and we've proposed to eliminate a couple of 

wilderness areas, proposed wilderness areas, here and 

here. 

So main points here, economic use would be limited 

when they are injurious to the natural processes. 

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Apply management practices that mimic and restore 

natural processes, and those natural processes again, 

fire and grazing. Use fire and grazing whether its 

with wild or livestock, so prescriptively to mimic that 

historic interaction. 

Again, work with Fish Wildlife and Parks to 

maintain diversity of species. Close about 25 miles of 

roads, so quite a difference, and then recommend 

expanding six of the proposed wilderness areas for 

18,000 acres, but eliminate three for a loss of 26,000. 

So kind of strike a little bit of balance there between 

B, C and D. 

So this is our seventh meeting for this round. 

We've had a lot of good comments. Some of the hot 

button topics or questions that we've received during 

this is what is prescriptive grazing. Kind of a lot of 

questions surrounding that, and the basic way to answer 

that is prescriptive grazing is using livestock to meet 

a very specific wildlife and/or habitat objective. 

So one example of that is say we have an area 

that's important for wintering sage grouse, or it's an 

important sage grouse lek, and we've got heavy grass 

coming into that area and there's a threat of wild fire 

that could come through there and eliminate that sage 

grouse habitat. We would use livestock to go in there 

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4 of 14 sheets Page 10 to 13 of 44 

10

and graze that area to reduce that risk of wild fire 

instead of using prescribed fire. 

So that brings us to prescribed fire. How will it 

be used? We've been working with fire ecologists and 

range ecologists from across the country mapping the 

historic fire frequency of the refuge, and what we have 

found is that it's highly variable across the refuge. 

You've got some areas that historically burn on an 

average of every 17 to 14 years. You've got other 

areas that saw fire maybe once every 500 years. And so 

the idea is to go into those areas that burn frequently 

that haven't seen fire in several decades, write a 

prescription. 

The prescription would let you know as to what 

conditions you would use fire, temperature, humidity, 

fuel moisture, wind speed, wind direction, and you 

would go ahead and use that fire to restore that area 

to its historic fire frequency. 

Wilderness. As part of the CCP process we're 

mandated to evaluate our proposed wilderness areas. 

Part of that evaluation is to make sure that they are 

meeting their wilderness characteristics in which they 

were established. Some of it is subjective. You look 

at it and you make the best guess based upon what the 

alternative is trying to achieve. That's why you see a 

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diverse recommendation as far as areas to keep and 

areas to recommend for elimination or for expansion. 

The same thing with roads. We looked at roads, 

looked at the alternative, the major focus of the 

alternative, and determined which roads are impacting 

our ability to manage that area, which one does the 

public not have access due to private land ownership 

off the refuge, which ones are cherry-stem roads that 

just lead out of ridges that fragment habitat. 

And then the last subject is bison, and I've been 

consistent in my message. The Fish and Wildlife 

Service is not proposing to re-introduce bison on the 

refuge. The sections in the document that talk about 

bison are in there in case Montana Fish Wildlife and 

Park develop a proposal that looked at restoring bison 

somewhere around a refuge. We would work cooperatively 

with them to see what role the refuge may play, but the 

Fish and Wildlife Service is not going to take the lead 

in reintroducing bison on the CMR. We are not going to 

create a fenced herd. Okay. 

So now we're at the point where you guys get to 

tell us what you think. What I would ask is that we're 

here to address the items that are in this plan. I 

know a month ago everybody was here to talk about the 

monument and treasured landscapes. That is not what 

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this plan 

the CMR, s

focused on 

Numero

give it to 

them as yo

e-mail, yo

voting con

weigh more 

relative c

turn it ba

just let m

evening wi

signed up 

as well as 

could come 

your name. 

proceeding

Again

That's wha

That's wha

sell or gi

somebody e

Brett's my 

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for two mi

one minute 

time is up 

I know 

question. 

your quest

When we're 

you and yo

ask once I

has a comm

will respo

comments. 

The on

applause a

comments s

Holden, an

Holden, J-

of the sev

Service ha

want to st

appreciate 

put these 

to do the 

It's e

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and graze that area to reduce that risk of wild fire 

instead of using prescribed fire. 

So that brings us to prescribed fire. How will it 

be used? We've been working with fire ecologists and 

range ecologists from across the country mapping the 

historic fire frequency of the refuge, and what we have 

found is that it's highly variable across the refuge. 

You've got some areas that historically burn on an 

average of every 17 to 14 years. You've got other 

areas that saw fire maybe once every 500 years. And so 

the idea is to go into those areas that burn frequently 

that haven't seen fire in several decades, write a 

prescription. 

The prescription would let you know as to what 

conditions you would use fire, temperature, humidity, 

fuel moisture, wind speed, wind direction, and you 

would go ahead and use that fire to restore that area 

to its historic fire frequency. 

Wilderness. As part of the CCP process we're 

mandated to evaluate our proposed wilderness areas. 

Part of that evaluation is to make sure that they are 

meeting their wilderness characteristics in which they 

were established. Some of it is subjective. You look 

at it and you make the best guess based upon what the 

alternative is trying to achieve. That's why you see a 

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diverse recommendation as far as areas to keep and 

areas to recommend for elimination or for expansion. 

The same thing with roads. We looked at roads, 

looked at the alternative, the major focus of the 

lid did hih dii

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this plan is about. This plan is about management of 

the CMR, so I would ask that you keep your comments 

focused on that. 

Numerous ways to provide comments. You can get up, 

give it to us orally, you can write them down, drop 

them as you walk out the door. You can send Laurie an 

e-mail, you can drop them in the mail box. It's not a 

voting contest. There's not one form of comments that 

weigh more than the other, and we'll consider all the 

relative comments that we receive. So with that, I'll 

turn it back over to Mimi and you guys. Thanks. 

MS. MATHER: Thanks. Just real quickly 

just let me explain how the comment portion of the 

evening will run. I've got a list of everybody that is 

signed up to comment. I ask -- I'll read who's up next 

as well as who's on deck so you can be ready. If you 

could come up here, speak into the microphone and spell 

your name. We've got a court recorder recording the 

proceedings for the meeting. 

Again, we're going to keep it to three minutes. 

That's what we've been doing for the last six meetings. 

That's what we're going to do tonight. You can not 

sell or give away or barter your three minutes to 

somebody else, so please keep it to three minutes. 

Brett's my time keeper back here. Once you've spoken 

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for two minutes and only have a minute left, he has a 

one minute sign. He's also got a 20 second sign and a 

time is up sign. 

I know some of you mentioned you just have a 

ih'kld jk 

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4 of 14 sheets Page 10 to 13 of 44 02/14/2011 11:37:33 AM

10

and graze that area to reduce that risk of wild fire 

instead of using prescribed fire. 

So that brings us to prescribed fire. How will it 

be used? We've been working with fire ecologists and 

range ecologists from across the country mapping the 

historic fire frequency of the refuge, and what we have 

found is that it's highly variable across the refuge. 

You've got some areas that historically burn on an 

average of every 17 to 14 years. You've got other 

areas that saw fire maybe once every 500 years. And so 

the idea is to go into those areas that burn frequently 

that haven't seen fire in several decades, write a 

prescription. 

The prescription would let you know as to what 

conditions you would use fire, temperature, humidity, 

fuel moisture, wind speed, wind direction, and you 

would go ahead and use that fire to restore that area 

to its historic fire frequency. 

Wilderness. As part of the CCP process we're 

mandated to evaluate our proposed wilderness areas. 

Part of that evaluation is to make sure that they are 

meeting their wilderness characteristics in which they 

were established. Some of it is subjective. You look 

at it and you make the best guess based upon what the 

alternative is trying to achieve. That's why you see a 

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diverse recommendation as far as areas to keep and 

areas to recommend for elimination or for expansion. 

The same thing with roads. We looked at roads, 

looked at the alternative, the major focus of the 

alternative, and determined which roads are impacting 

our ability to manage that area, which one does the 

public not have access due to private land ownership 

off the refuge, which ones are cherry-stem roads that 

just lead out of ridges that fragment habitat. 

And then the last subject is bison, and I've been 

consistent in my message. The Fish and Wildlife 

Service is not proposing to re-introduce bison on the 

refuge. The sections in the document that talk about 

bison are in there in case Montana Fish Wildlife and 

Park develop a proposal that looked at restoring bison 

somewhere around a refuge. We would work cooperatively 

with them to see what role the refuge may play, but the 

Fish and Wildlife Service is not going to take the lead 

in reintroducing bison on the CMR. We are not going to 

create a fenced herd. Okay. 

So now we're at the point where you guys get to 

tell us what you think. What I would ask is that we're 

here to address the items that are in this plan. I 

know a month ago everybody was here to talk about the 

monument and treasured landscapes. That is not what 

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this plan is about. This plan is about management of 

the CMR, so I would ask that you keep your comments 

focused on that. 

Numerous ways to provide comments. You can get up, 

give it to us orally, you can write them down, drop 

them as you walk out the door. You can send Laurie an 

e-mail, you can drop them in the mail box. It's not a 

voting contest. There's not one form of comments that 

weigh more than the other, and we'll consider all the 

relative comments that we receive. So with that, I'll 

turn it back over to Mimi and you guys. Thanks. 

MS. MATHER: Thanks. Just real quickly 

just let me explain how the comment portion of the 

evening will run. I've got a list of everybody that is 

signed up to comment. I ask -- I'll read who's up next 

as well as who's on deck so you can be ready. If you 

could come up here, speak into the microphone and spell 

your name. We've got a court recorder recording the 

proceedings for the meeting. 

Again, we're going to keep it to three minutes. 

That's what we've been doing for the last six meetings. 

That's what we're going to do tonight. You can not 

sell or give away or barter your three minutes to 

somebody else, so please keep it to three minutes. 

Brett's my time keeper back here. Once you've spoken 

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for two minutes and only have a minute left, he has a 

one minute sign. He's also got a 20 second sign and a 

time is up sign. 

I know some of you mentioned you just have a 

question. That's okay. Please come up and just ask 

your question, if that's all it is, and not a comment. 

When we're done -- if somebody else's comment inspires 

you and your name's not on the list, don't worry, I'll 

ask once I've gone through this list if anybody else 

has a comment or question, and then Barron and Bill 

will respond to the questions they heard and the 

comments. 

The only other thing is we ask you refrain from 

applause and cheering so we can move through these 

comments smoothly. With that, our first is Janelle 

Holden, and I've got Mark on deck. 

JANELLE HOLDEN: My name is Janelle 

Holden, J-a-n-e-l-l-e, H-o-l-d-e-n. This is my seventh 

of the seven meetings that the Fish and Wildlife 

Service has held, so I've sort of been on tour, and I 

want to start my comments by saying that I really 

appreciate the way the Fish and Wildlife Service has 

put these meetings together, and I hope they continue 

to do the same for the final comments. 

It's easy for agencies -- I've been to a lot of 

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430 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 10 to 13 of 44 02/14/2011 11:37:33 AM

at they are 

n which they 

e. You look 

on what the 

why you see a 

11

keep and 

expansion. 

 at roads, 

 of the 

e impacting 

 does the 

 ownership 

 roads that 

tat. 

nd I've been 

ldlife 

ison on the 

 talk about 

ldlife and 

toring bison 

cooperatively 

play, but the 

take the lead 

 not going to 

uys get to 

is that we're 

 plan. I 

k about the 

s not what 

That's what we've been doing for the last six meetings. 

That's what we're going to do tonight. You can not 

sell or give away or barter your three minutes to 

somebody else, so please keep it to three minutes. 

Brett's my time keeper back here. Once you've spoken 

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for two minutes and only have a minute left, he has a 

one minute sign. He's also got a 20 second sign and a 

time is up sign. 

I know some of you mentioned you just have a 

question. That's okay. Please come up and just ask 

your question, if that's all it is, and not a comment. 

When we're done -- if somebody else's comment inspires 

you and your name's not on the list, don't worry, I'll 

ask once I've gone through this list if anybody else 

has a comment or question, and then Barron and Bill 

will respond to the questions they heard and the 

comments. 

The only other thing is we ask you refrain from 

applause and cheering so we can move through these 

comments smoothly. With that, our first is Janelle 

Holden, and I've got Mark on deck. 

JANELLE HOLDEN: My name is Janelle 

Holden, J-a-n-e-l-l-e, H-o-l-d-e-n. This is my seventh 

of the seven meetings that the Fish and Wildlife 

Service has held, so I've sort of been on tour, and I 

want to start my comments by saying that I really 

appreciate the way the Fish and Wildlife Service has 

put these meetings together, and I hope they continue 

to do the same for the final comments. 

It's easy for agencies -- I've been to a lot of 

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02/14/2011 11:37:33 AM Page 14 to 17 of 44 

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agency meetings, and it's very easy for agencies to 

chicken out, so to speak. Agencies often can host an 

open house type format where they put staff around the 

room, and you can go and ask them questions, but I find 

that those are a lot less productive, and get a lot 

fewer comments than the meetings that have been set up 

by the Fish and Wildlife Service this way around, which 

provide a presentation and then a format for 

commenting. And then what's really important is that 

they are answering the public's questions at the end. 

You don't often get that in public meetings, so I 

really appreciate that. 

The staff has been professional, sometimes in 

difficult circumstances, and I thank you for that. So 

one of the things that we've heard from a lot of people 

during these meetings is concern about changes in the 

proposed wilderness areas and the refuge. There are a 

lot of people who really treasure these places, they 

find a lot of value in them, they find all of the 

things that make wilderness wilderness; solitude, 

quiet, recreation, opportunities, just an awesome view 

of a landscape that is under represented in our 

national wilderness system. 

So I think the comments demonstrated how much 

people love and care about the CMR, and they recognize 

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it is a gem for Montana and it's a gem for the United 

States, and actually a gem world wide. 

So with that, I just want to conclude by saying 

thank you to Barron. This is his last day on the job, 

and I think he's done an excellent job as manager, and 

I wish him well on his way to Tennessee, and I hope 

that his final meeting will go smoothly. Thanks. 

MS. MATHER: Thanks, Janelle. Mark with 

Mike on deck. 

MARK MANOUKIAN: Three minutes. The lead 

document was only 22 pages and we got three minutes. 

Okay. For the record, my name is Mark 

M-a-n-o-u-k-i-a-n. 

The CM Russell Wildlife Refuge is a part of the 

Fort Peck watershed. The watershed comprises over 

3.3 million acres. Private lands account for 

36 percent of that watershed. The BLM compromises 

29 percent of that watershed, and CMR is 21 percent of 

that watershed. I think that's an important figure for 

your document as it reflects the breath of the resource 

we're talking about. 

You say there's over 250,000 visitors that visit 

your refuge each year. I'd like to know the methods 

and materials in which you determine that number. You 

talk about excessive livestock grazing. The record 

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decision alloca

refuge, 60,000 

currently based 

used by elk, mu

time you've red

1980. I questi

read Where the 

Richard H. Hart

grazing prehist

You're work

sentinel plant 

Science from th

ARS, BLM and US

health, technic

you to look at 

a way to monito

range science a

For years t

endangered spec

responsibilitie

salt seed locat

pool level on t

was fishing thi

uplands are now 

found it severa

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ways from the s

being transloca

time. 

The service

grass and Japan

all lands in Mo

desire to use f

Both cheat gras

Without compreh

appears the leg

this species. 

In addition

in several loca

of the Missouri 

grazing plans a

grazing for the 

wildlife habita

regard to anima

think you are g

prescriptive ve

grazing can be 

cites. Thank y

MS

with Troy on de

MI

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02/14/2011 11:37:33 AM Page 14 to 17 of 44 5 of 14 sheets

14

agency meetings, and it's very easy for agencies to 

chicken out, so to speak. Agencies often can host an 

open house type format where they put staff around the 

room, and you can go and ask them questions, but I find 

that those are a lot less productive, and get a lot 

fewer comments than the meetings that have been set up 

by the Fish and Wildlife Service this way around, which 

provide a presentation and then a format for 

commenting. And then what's really important is that 

they are answering the public's questions at the end. 

You don't often get that in public meetings, so I 

really appreciate that. 

The staff has been professional, sometimes in 

difficult circumstances, and I thank you for that. So 

one of the things that we've heard from a lot of people 

during these meetings is concern about changes in the 

proposed wilderness areas and the refuge. There are a 

lot of people who really treasure these places, they 

find a lot of value in them, they find all of the 

things that make wilderness wilderness; solitude, 

quiet, recreation, opportunities, just an awesome view 

of a landscape that is under represented in our 

national wilderness system. 

So I think the comments demonstrated how much 

people love and care about the CMR, and they recognize 

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it is a gem for Montana and it's a gem for the United 

States, and actually a gem world wide. 

So with that, I just want to conclude by saying 

thank you to Barron. This is his last day on the job, 

and I think he's done an excellent job as manager, and 

I wish him well on his way to Tennessee, and I hope 

that his final meeting will go smoothly. Thanks. 

MS. MATHER: Thanks, Janelle. Mark with 

Mike on deck. 

MARK MANOUKIAN: Three minutes. The lead 

document was only 22 pages and we got three minutes. 

Okay. For the record, my name is Mark 

M-a-n-o-u-k-i-a-n. 

The CM Russell Wildlife Refuge is a part of the 

Fort Peck watershed. The watershed comprises over 

3.3 million acres. Private lands account for 

36 percent of that watershed. The BLM compromises 

29 percent of that watershed, and CMR is 21 percent of 

that watershed. I think that's an important figure for 

your document as it reflects the breath of the resource 

we're talking about. 

You say there's over 250,000 visitors that visit 

your refuge each year. I'd like to know the methods 

and materials in which you determine that number. You 

talk about excessive livestock grazing. The record 

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decision allocated a hundred thousand AUMs on the 

refuge, 60,000 for wildlife, 40,000 for livestock, 

currently based on pages 203 through 206. 73,000 AUMs 

used by elk, mule deer and wild tail deer. At the same 

time you've reduced grazing by 90 percent since the 

1980. I question the decision. I encourage you to 

read Where the Buffalo Roamed - Or Did They? by 

Richard H. Hart. He has some interesting aspects on 

grazing prehistory. 

You're working with Samuel Fuhlendorf on the 

sentinel plant monitoring. I have a degree in Range 

Science from the people's University of Bozeman. The 

ARS, BLM and USGS have a way to interpret range land 

health, technical reference 1734-6. I would encourage 

you to look at that, and to hire somebody to figure out 

a way to monitor range lands, or you make a fallacy of 

range science and the art of range science. 

For years the service has -- this is under 

endangered species -- has argued about the management 

responsibilities with the Army Corps of Engineers on 

salt seed located on Cedar. Now that it has jumped the 

pool level on the southern part of the refuge, when I 

was fishing this summer, the drainage systems and the 

uplands are now well inundated with salt seed. We also 

found it several miles within Phillips County, a long 

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ways from the service or the river system, so that is 

being translocated great distance at this point and 

time. 

The services indicated additionally there is cheat 

grass and Japanese brome within the refuge just like 

all lands in Montana. The services indicated the 

desire to use fire vegetation management on the refuge. 

Both cheat grass and salt cedar are fire responders. 

Without comprehensive methods to control salt cedar it 

appears the legacy will result in continued invasion of 

this species. 

In addition, Eurasian watermilfoil has been found 

in several locations in the reservoir and the main stem 

of the Missouri River. Prescriptive grazing -- all 

grazing plans are prescriptive in nature. Using 

grazing for the purpose of manipulating vegetation or 

wildlife habitat with regard to animal -- without 

regard to animal performance is targeted grazing. I 

think you are grossly confused as in the use of 

prescriptive versus targeted grazing, and that targeted 

grazing can be found on the fish and wildlife web 

cites. Thank you for coming today. 

MS. MATHER: Thanks, Mark. Mike's up 

with Troy on deck.

MIKE SJOSTROM: My name's Mike Sjostrom. 

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agency meetings, and it's very easy for agencies to 

chicken out, so to speak. Agencies often can host an 

open house type format where they put staff around the 

room, and you can go and ask them questions, but I find 

that those are a lot less productive, and get a lot 

fewer comments than the meetings that have been set up 

by the Fish and Wildlife Service this way around, which 

provide a presentation and then a format for 

commenting. And then what's really important is that 

they are answering the public's questions at the end. 

You don't often get that in public meetings, so I 

really appreciate that. 

The staff has been professional, sometimes in 

difficult circumstances, and I thank you for that. So 

one of the things that we've heard from a lot of people 

during these meetings is concern about changes in the 

proposed wilderness areas and the refuge. There are a 

lot of people who really treasure these places, they 

find a lot of value in them, they find all of the 

things that make wilderness wilderness; solitude, 

quiet, recreation, opportunities, just an awesome view 

of a landscape that is under represented in our 

national wilderness system. 

So I think the comments demonstrated how much 

people love and care about the CMR, and they recognize 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

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15

it is a gem for Montana and it's a gem for the United 

States, and actually a gem world wide. 

So with that, I just want to conclude by saying 

thank you to Barron. This is his last day on the job, 

1

2

3

4

5

16

decision allocated a hundred thousand AUMs on the 

refuge, 60,000 for wildlife, 40,000 for livestock, 

currently based on pages 203 through 206. 73,000 AUMs 

used by elk, mule deer and wild tail deer. At the same 

time you've reduced grazing by 90 percent since the 

1980. I question the decision. I encourage you to 

read Where the Buffalo Roamed - Or Did They? by 

Richard H. Hart. He has some interesting aspects on 

grazing prehistory. 

You're working with Samuel Fuhlendorf on the 

sentinel plant monitoring. I have a degree in Range 

Science from the people's University of Bozeman. The 

ARS, BLM and USGS have a way to interpret range land 

health, technical reference 1734-6. I would encourage 

you to look at that, and to hire somebody to figure out 

a way to monitor range lands, or you make a fallacy of 

range science and the art of range science. 

For years the service has -- this is under 

endangered species -- has argued about the management 

responsibilities with the Army Corps of Engineers on 

salt seed located on Cedar. Now that it has jumped the 

pool level on the southern part of the refuge, when I 

was fishing this summer, the drainage systems and the 

uplands are now well inundated with salt seed. We also 

found it several miles within Phillips County, a long 

1

2

3

4

5

6

7

8

9

10

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ways from the service or the river system, so that is 

being translocated great distance at this point and 

time. 

The services indicated additionally there is cheat 

1

2

3

4

5
VOLUME 2, Chapter 4—Public Hearing Testimony 431

Page 14 to 17 of 44 5 of 14 sheets

t an awesome view 

ted in our 

ted how much 

nd they recognize 

15

m for the United 

. 

lude by saying 

t day on the job, 

b as manager, and 

ee, and I hope 

ly. Thanks. 

elle. Mark with 

inutes. The lead 

 three minutes. 

k 

 a part of the 

omprises over 

ount for 

M compromises 

 is 21 percent of 

portant figure for 

th of the resource 

tors that visit 

now the methods 

that number. You 

g. The record 

salt seed located on Cedar. Now that it has jumped the 

pool level on the southern part of the refuge, when I 

was fishing this summer, the drainage systems and the 

uplands are now well inundated with salt seed. We also 

found it several miles within Phillips County, a long 

21

22

23

24

25

17

ways from the service or the river system, so that is 

being translocated great distance at this point and 

time. 

The services indicated additionally there is cheat 

grass and Japanese brome within the refuge just like 

all lands in Montana. The services indicated the 

desire to use fire vegetation management on the refuge. 

Both cheat grass and salt cedar are fire responders. 

Without comprehensive methods to control salt cedar it 

appears the legacy will result in continued invasion of 

this species. 

In addition, Eurasian watermilfoil has been found 

in several locations in the reservoir and the main stem 

of the Missouri River. Prescriptive grazing -- all 

grazing plans are prescriptive in nature. Using 

grazing for the purpose of manipulating vegetation or 

wildlife habitat with regard to animal -- without 

regard to animal performance is targeted grazing. I 

think you are grossly confused as in the use of 

prescriptive versus targeted grazing, and that targeted 

grazing can be found on the fish and wildlife web 

cites. Thank you for coming today. 

MS. MATHER: Thanks, Mark. Mike's up 

with Troy on deck.

MIKE SJOSTROM: My name's Mike Sjostrom. 

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6 of 14 sheets Page 18 to 21 of 44 02/14/2011 11:37:33 AM

18

It's spelled S-j-o-s-t-r-o-m. And I just state in 

support of no loss of cattle numbers on the CMR. I 

think we've seen enough of that already. I don't own a 

cow, probably never will own a cow in the future, but I 

do understand a little bit about economics and what 

it's doing to our local communities, our tax base, and 

like I say, just wanted to go on record that I don't 

feel we should see any loss of livestock production 

there. Thanks. 

MS. MATHER: Troy, Don on deck.

TROY BLUNT: Thank you. My name is Troy 

Blunt, B-l-u-n-t. I'm a rancher in South Phillips 

County, and a Phillips County Commissioner, and 

chairman of the Six County Fort Peck Lake Group, which 

are the six counties that surround the Fort Peck Lake. 

My comment is on bison on page 93, and I quote from 

this document, it says, "The service has taken the 

position that it will not consider reintroducing bison 

on the refuge unless MFWP initiates an effort to 

restore bison, as a wildlife species on a large 

landscape." Skipping one sentence down then it says, 

"MFWP does not have any plans at this time to consider 

reintroducing a free-ranging herd of bison in the 

area," therefore, I conclude that the rest of the 

information in relation to bison in this document is 

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irrelevant and should be stricken. 

Also, the Six County Fort Peck Lake Group requested 

an extension on the comment period, and we would like 

that to be on record again and request that you take 

that into consideration. Thank you. 

MS. MATHER: John with Craig on deck. 

RONNIE KORMAN: My name's Ronnie Korman. 

Every one of these ranchers in here have a land patent, 

and if they bring that land patent up into their name, 

that's proof of our title against the federal 

government, including all apprentices. All enabling 

documents contain the savings rezinum, subject to 

valid, preexisting rights. 

All ranchers has water rights and grazing rights on 

the CMR. Lands which has private rights and claims 

attached is not public lands. Nowhere in this document 

of this plan that you have do you recognize to protect 

them private rights. I'm going to ask you also, are 

you going to coordinate with the county commissioners 

in this county, or are you just going to go along with, 

as you are doing at this time cooperating with them? 

Thank you. 

MS. MATHER: Craig. Mark on deck.

CRAIG FRENCH: My name is Craig French, 

F-r-e-n-c-h. Nothing special there. My main concern, 

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as touched on by Mark, is the salt cedar and your plan 

on trying to curb that spread. I see that as the most 

invasive species that we are faced with in south 

Phillips County. It has made it up to our place, and 

we are actively curtailing that. I blame it on two 

theories, heavy equipment and elk and/or birds, but 

can't really prove either one. 

And then I never had this plan, but they also said 

I might as well speak, but I wish that the main 

emphasis would be on land. I attend several meetings 

where it's either the buffalo, the ferret, prairie dog,

the sage hen, doesn't seem to matter, we just go from 

one animal to the next. But if focusing on land and 

water management was the focus, those animals are 

geared up to take care of themselves, and if they 

can't, extinction is a natural process. That's about 

it. Thanks. 

MS. MATHER: Okay. Mark. Richard on 

deck. 

MARK GOOD: My name is Mark good. 

Nothing special about that either, G-o-o-d. I'm from 

Great Falls. I work with the Montana Wilderness 

Association. I just attended some of these meetings 

too, and I think it's helpful to explain a little bit 

more about the purpose of the wildlife refuge and how 

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it's managed differently from other forest service and 

BLM lands. 

Certainly my understanding of a national wildlife 

refuge, the guiding principle for management is the 

enhancement and protection of wildlife, and other uses 

are secondary; compatible but the primary mission of 

the refuge. Now, I know some people don't like that, 

wish it were different, but I don't think that's going 

to change. Because wildlife refuges generally aren't 

popular with the American public, and I think popular 

with most Montanans. 

That said, I think it would seem that it might be 

possible to figure out how to make the refuge maybe 

work better for some of the surrounding communities. I 

think although I think it's also overlooked that the 

refuge makes significant contributions to local 

economies; I think first through employment, purchases, 

goods and services, and of course interpretive centers 

and activities such as Fort Peck, but probably in a 

more indirect way through hunting, wildlife viewing, 

people coming through. 

And while these are significant, I think more could 

be done in terms of creating an economic contributor, 

and that might be the landscape itself, which I think 

helps make a community an attractive place to live, 

1

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18

It's spelled S-j-o-s-t-r-o-m. And I just state in 

support of no loss of cattle numbers on the CMR. I 

think we've seen enough of that already. I don't own a 

cow, probably never will own a cow in the future, but I 

do understand a little bit about economics and what 

it's doing to our local communities, our tax base, and 

like I say, just wanted to go on record that I don't 

feel we should see any loss of livestock production 

there. Thanks. 

MS. MATHER: Troy, Don on deck.

TROY BLUNT: Thank you. My name is Troy 

Blunt, B-l-u-n-t. I'm a rancher in South Phillips 

County, and a Phillips County Commissioner, and 

chairman of the Six County Fort Peck Lake Group, which 

are the six counties that surround the Fort Peck Lake. 

My comment is on bison on page 93, and I quote from 

this document, it says, "The service has taken the 

position that it will not consider reintroducing bison 

on the refuge unless MFWP initiates an effort to 

restore bison, as a wildlife species on a large 

landscape." Skipping one sentence down then it says, 

"MFWP does not have any plans at this time to consider 

reintroducing a free-ranging herd of bison in the 

area," therefore, I conclude that the rest of the 

information in relation to bison in this document is 

1

2

3

4

5

6

7

8

9

10

11

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13

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irrelevant and should be stricken. 

Also, the Six County Fort Peck Lake Group requested 

an extension on the comment period, and we would like 

that to be on record again and request that you take 

tht itidtiThk 

1

2

3

4

5

20

as touched on by Mark, is the salt cedar and your plan 

on trying to curb that spread. I see that as the most 

invasive species that we are faced with in south 

Phillips County. It has made it up to our place, and 

we are actively curtailing that. I blame it on two 

theories, heavy equipment and elk and/or birds, but 

can't really prove either one. 

And then I never had this plan, but they also said 

I might as well speak, but I wish that the main 

emphasis would be on land. I attend several meetings 

where it's either the buffalo, the ferret, prairie dog,

the sage hen, doesn't seem to matter, we just go from 

one animal to the next. But if focusing on land and 

water management was the focus, those animals are 

geared up to take care of themselves, and if they 

can't, extinction is a natural process. That's about 

it. Thanks. 

MS. MATHER: Okay. Mark. Richard on 

deck. 

MARK GOOD: My name is Mark good. 

Nothing special about that either, G-o-o-d. I'm from 

Great Falls. I work with the Montana Wilderness 

Association. I just attended some of these meetings 

too, and I think it's helpful to explain a little bit 

more about the purpose of the wildlife refuge and how 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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it's managed differently from other forest service and 

BLM lands. 

Certainly my understanding of a national wildlife 

refuge, the guiding principle for management is the 

ht d ttif ildlifd th

1

2

3

4

5

6 of 14 sheets Page 18 to 21 of 44 

18

It's spelled S-j-o-s-t-r-o-m. And I just state in 

support of no loss of cattle numbers on the CMR. I 

think we've seen enough of that already. I don't own a 

cow, probably never will own a cow in the future, but I 

do understand a little bit about economics and what 

it's doing to our local communities, our tax base, and 

like I say, just wanted to go on record that I don't 

feel we should see any loss of livestock production 

there. Thanks. 

MS. MATHER: Troy, Don on deck.

TROY BLUNT: Thank you. My name is Troy 

Blunt, B-l-u-n-t. I'm a rancher in South Phillips 

County, and a Phillips County Commissioner, and 

chairman of the Six County Fort Peck Lake Group, which 

are the six counties that surround the Fort Peck Lake. 

My comment is on bison on page 93, and I quote from 

this document, it says, "The service has taken the 

position that it will not consider reintroducing bison 

on the refuge unless MFWP initiates an effort to 

restore bison, as a wildlife species on a large 

landscape." Skipping one sentence down then it says, 

"MFWP does not have any plans at this time to consider 

reintroducing a free-ranging herd of bison in the 

area," therefore, I conclude that the rest of the 

information in relation to bison in this document is 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

19

irrelevant and should be stricken. 

Also, the Six County Fort Peck Lake Group requested 

an extension on the comment period, and we would like 

that to be on record again and request that you take 

that into consideration. Thank you. 

MS. MATHER: John with Craig on deck. 

RONNIE KORMAN: My name's Ronnie Korman. 

Every one of these ranchers in here have a land patent, 

and if they bring that land patent up into their name, 

that's proof of our title against the federal 

government, including all apprentices. All enabling 

documents contain the savings rezinum, subject to 

valid, preexisting rights. 

All ranchers has water rights and grazing rights on 

the CMR. Lands which has private rights and claims 

attached is not public lands. Nowhere in this document 

of this plan that you have do you recognize to protect 

them private rights. I'm going to ask you also, are 

you going to coordinate with the county commissioners 

in this county, or are you just going to go along with, 

as you are doing at this time cooperating with them? 

Thank you. 

MS. MATHER: Craig. Mark on deck.

CRAIG FRENCH: My name is Craig French, 

F-r-e-n-c-h. Nothing special there. My main concern, 

1

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5

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7

8

9

10

11

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as touched 

on trying 

invasive s

Phillips C

we are act

theories, 

can't real

And th

I might as 

emphasis w

where it's 

the sage h

one animal 

water mana

geared up 

can't, ext

it. Thank

deck. 

Nothing sp

Great Fall

Associatio

too, and I 

more about 

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it's manag

BLM lands. 

Certa

refuge, th

enhancemen

are second

the refuge

wish it we

to change. 

popular wi

with most 

That 

possible t

work bette

think alth

refuge mak

economies; 

goods and 

and activi

more indir

people com

And wh

be done in 

and that m

helps make 

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432 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 18 to 21 of 44 02/14/2011 11:37:33 AM

en it says, 

 to consider 

 in the 

 of the 

ocument is 

19

roup requested 

 would like 

t you take 

 on deck. 

nie Korman. 

 land patent, 

 their name, 

ral 

l enabling 

ject to 

zing rights on 

nd claims 

this document 

e to protect 

 also, are 

mmissioners 

o along with, 

with them? 

 deck.

ig French, 

ain concern, 

Nothing special about that either, G-o-o-d. I'm from 

Great Falls. I work with the Montana Wilderness 

Association. I just attended some of these meetings 

too, and I think it's helpful to explain a little bit 

more about the purpose of the wildlife refuge and how 

21

22

23

24

25

21

it's managed differently from other forest service and 

BLM lands. 

Certainly my understanding of a national wildlife 

refuge, the guiding principle for management is the 

enhancement and protection of wildlife, and other uses 

are secondary; compatible but the primary mission of 

the refuge. Now, I know some people don't like that, 

wish it were different, but I don't think that's going 

to change. Because wildlife refuges generally aren't 

popular with the American public, and I think popular 

with most Montanans. 

That said, I think it would seem that it might be 

possible to figure out how to make the refuge maybe 

work better for some of the surrounding communities. I 

think although I think it's also overlooked that the 

refuge makes significant contributions to local 

economies; I think first through employment, purchases, 

goods and services, and of course interpretive centers 

and activities such as Fort Peck, but probably in a 

more indirect way through hunting, wildlife viewing, 

people coming through. 

And while these are significant, I think more could 

be done in terms of creating an economic contributor, 

and that might be the landscape itself, which I think 

helps make a community an attractive place to live, 

1

2

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5

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02/14/2011 11:37:33 AM Page 22 to 25 of 44 

22

thereby holding and attracting residents. I think 

economics are simple, people care where they live and 

act on that preference. 

During the past few decades the western part of the 

state has been the job growth, while the eastern 

Montana has been in the bottom of the ten states 

actually losing population, and I think that's the 

surrounding landscape. I think it's also important to 

remember it hasn't always been that way, but the 

attraction of mountains, mountainous areas is a 

relatively new phenomenon. 

The problem is that I think prairies are too often 

viewed as monotonous, boring, but I think those that 

know the refuge and surrounding lands know it's quite 

diverse, and in my mind a whole lot more interesting 

than mountains to the west. My position is that 

people's appreciation for lands develop, and I don't 

think it would take a major reversal of American 

attitudes towards prairie to help to maybe attract 

people here. 

In a country with over $3 million people it would 

only take a tiny fraction that would need to develop 

this appreciation for places like the refuge, so I just 

want to say I think more should be done to promote the 

refuge, and I don't think there's a whole lot of down 

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side to doing that. Again, we appreciate you guys for 

holding the meetings, and thanks. 

MS. MATHER: Richard, Leslie on deck.

RICHARD DUNBAR: Richard Dunbar, Phillips 

County Commissioner and rancher. I'd just like to hit 

a few topics. Roads. You say in the scope -- outside 

the scope of your document, in your documents you say 

outside the scope of your documents we're going to talk 

about roads, but in the document you're proposing 

closing up to a hundred miles of road in one 

alternative. As you know, Phillips County has 

petitioned county roads down in the CMR, and we 

recognize all roads that we have petitions on. 

Livestock grazing. There's grazing permits on the 

CMR. These grazing permits must be kept as they 

currently are so the ranchers using these allotments 

year after year know their livestock, get acquainted to 

them so they know where they are located at. 

Prescribed burns. When we were in Bozeman, I don't 

know if it was Bill or Barron made the comment that 

prescribed burns put carbon back into the ground. I 

found no one to tell me any information that that is 

anywhere -- that that happens. All the information I 

find is that it puts carbon in the air and they're not 

very cost-effective. You got to spend a lot of money 

1

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to set up a pre

thing for a who

Wilderness. 

wilderness area

commissioners m

read them -- po

burnt lodge wil

Russell Nationa

impending actio

out of the conf

to the county c

that the follow

percent of the 

approximately 3

economic value 

a reasonable re

game, for the h

therefore, feed 

with no noticea

nature. 

The scenic 

that soon calls 

for the hardies

with nature. T

creation, and i

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little change, 

the main point 

appears the des

very character 

present status 

It seems po

some use and ch

be no use. The

or restriction 

in the best int

state or nation

Wilke, Duane Co

35 years ago an

MS

LE

Robinson, R-o-b

south, and a Ph

hit a little bi

document. Your 

"D," and in tha

current staff p

positions. 

It says, "A

million dollars 

jobs, $569,600 

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02/14/2011 11:37:33 AM Page 22 to 25 of 44 7 of 14 sheets

22

thereby holding and attracting residents. I think 

economics are simple, people care where they live and 

act on that preference. 

During the past few decades the western part of the 

state has been the job growth, while the eastern 

Montana has been in the bottom of the ten states 

actually losing population, and I think that's the 

surrounding landscape. I think it's also important to 

remember it hasn't always been that way, but the 

attraction of mountains, mountainous areas is a 

relatively new phenomenon. 

The problem is that I think prairies are too often 

viewed as monotonous, boring, but I think those that 

know the refuge and surrounding lands know it's quite 

diverse, and in my mind a whole lot more interesting 

than mountains to the west. My position is that 

people's appreciation for lands develop, and I don't 

think it would take a major reversal of American 

attitudes towards prairie to help to maybe attract 

people here. 

In a country with over $3 million people it would 

only take a tiny fraction that would need to develop 

this appreciation for places like the refuge, so I just 

want to say I think more should be done to promote the 

refuge, and I don't think there's a whole lot of down 

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side to doing that. Again, we appreciate you guys for 

holding the meetings, and thanks. 

MS. MATHER: Richard, Leslie on deck.

RICHARD DUNBAR: Richard Dunbar, Phillips 

County Commissioner and rancher. I'd just like to hit 

a few topics. Roads. You say in the scope -- outside 

the scope of your document, in your documents you say 

outside the scope of your documents we're going to talk 

about roads, but in the document you're proposing 

closing up to a hundred miles of road in one 

alternative. As you know, Phillips County has 

petitioned county roads down in the CMR, and we 

recognize all roads that we have petitions on. 

Livestock grazing. There's grazing permits on the 

CMR. These grazing permits must be kept as they 

currently are so the ranchers using these allotments 

year after year know their livestock, get acquainted to 

them so they know where they are located at. 

Prescribed burns. When we were in Bozeman, I don't 

know if it was Bill or Barron made the comment that 

prescribed burns put carbon back into the ground. I 

found no one to tell me any information that that is 

anywhere -- that that happens. All the information I 

find is that it puts carbon in the air and they're not 

very cost-effective. You got to spend a lot of money 

1

2

3

4

5

6

7

8

9

10

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to set up a prescribed burn. Grazing will do the same 

thing for a whole lot less dollars. 

Wilderness. Phillips County opposes anymore 

wilderness areas, and I have some minutes from the 

commissioners minutes, May 8th of 1974, and I'd like to 

read them -- portions of them. "Protest against the 

burnt lodge wilderness proposal for the Charles M. 

Russell National Wildlife Range. In view of the 

impending action of creating a wilderness area in and 

out of the confines of Phillips County, we feel as due 

to the county commissioners in our neighboring county 

that the following point should be considered: 33 

percent of the area lies in Phillips County and grazes 

approximately 300 head of cattle for six months. The 

economic value of this area lies in its grass, which is 

a reasonable resource. It provides a substance for 

game, for the hunter, livestock for the rancher, 

therefore, feed for the nation. The area provides this 

with no noticeable distraction from its essential 

nature. 

The scenic value of this area is a vast emptiness 

that soon calls for lack of variety and comfort, except 

for the hardiest of those in pursuit of communication 

with nature. This area shows little change since its 

creation, and if left as it is at its present, shows 

1

2

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5

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little change, if any change, in the future, as this is 

the main point in creating a wilderness area. It 

appears the desired result is already assured by the 

very character of the area itself, without changing its 

present status in any way. 

It seems pointless to take land from which there is 

some use and change it to an area for which there will 

be no use. Therefore, we protest any new designation 

or restriction as being not only not necessary, but not 

in the best interest of the citizens of this county, 

state or nation. Board of county commissioners, Lester 

Wilke, Duane Compton, Dan Garrison. That was said 

35 years ago and it's the same today. Thank you. 

MS. MATHER: Leslie, Jim on deck.

LESLIE ROBINSON: My name is Leslie 

Robinson, R-o-b-i-n-s-o-n. I'm a rancher from out 

south, and a Phillips County Commissioner. I want to 

hit a little bit on the economics that are in the 

document. Your proposed or preferred alternative is 

"D," and in that alternative it calls for all of the 

current staff positions plus seven additional 

positions. 

It says, "Alternative D" would generate $2.1 

million dollars more in local output, 25 additional 

jobs, $569,600 more in labor income compared to 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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22

thereby holding and attracting residents. I think 

economics are simple, people care where they live and 

act on that preference. 

During the past few decades the western part of the 

state has been the job growth, while the eastern 

Montana has been in the bottom of the ten states 

actually losing population, and I think that's the 

surrounding landscape. I think it's also important to 

remember it hasn't always been that way, but the 

attraction of mountains, mountainous areas is a 

relatively new phenomenon. 

The problem is that I think prairies are too often 

viewed as monotonous, boring, but I think those that 

know the refuge and surrounding lands know it's quite 

diverse, and in my mind a whole lot more interesting 

than mountains to the west. My position is that 

people's appreciation for lands develop, and I don't 

think it would take a major reversal of American 

attitudes towards prairie to help to maybe attract 

people here. 

In a country with over $3 million people it would 

only take a tiny fraction that would need to develop 

this appreciation for places like the refuge, so I just 

want to say I think more should be done to promote the 

refuge, and I don't think there's a whole lot of down 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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19

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23

side to doing that. Again, we appreciate you guys for 

holding the meetings, and thanks. 

MS. MATHER: Richard, Leslie on deck.

RICHARD DUNBAR: Richard Dunbar, Phillips 

1

2

3

4

24

to set up a prescribed burn. Grazing will do the same 

thing for a whole lot less dollars. 

Wilderness. Phillips County opposes anymore 

wilderness areas, and I have some minutes from the 

commissioners minutes, May 8th of 1974, and I'd like to 

read them -- portions of them. "Protest against the 

burnt lodge wilderness proposal for the Charles M. 

Russell National Wildlife Range. In view of the 

impending action of creating a wilderness area in and 

out of the confines of Phillips County, we feel as due 

to the county commissioners in our neighboring county 

that the following point should be considered: 33 

percent of the area lies in Phillips County and grazes 

approximately 300 head of cattle for six months. The 

economic value of this area lies in its grass, which is 

a reasonable resource. It provides a substance for 

game, for the hunter, livestock for the rancher, 

therefore, feed for the nation. The area provides this 

with no noticeable distraction from its essential 

nature. 

The scenic value of this area is a vast emptiness 

that soon calls for lack of variety and comfort, except 

for the hardiest of those in pursuit of communication 

with nature. This area shows little change since its 

creation, and if left as it is at its present, shows 

1

2

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5

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little change, if any change, in the future, as this is 

the main point in creating a wilderness area. It 

appears the desired result is already assured by the 

very character of the area itself, without changing its 

1

2

3

4
VOLUME 2, Chapter 4—Public Hearing Testimony 433

Page 22 to 25 of 44 7 of 14 sheets

 people it would 

need to develop 

 refuge, so I just 

ne to promote the 

hole lot of down 

23

iate you guys for 

slie on deck.

 Dunbar, Phillips 

 just like to hit 

 scope -- outside 

ocuments you say 

e're going to talk 

re proposing 

 in one 

ounty has 

MR, and we 

tions on. 

ng permits on the 

ept as they 

hese allotments 

 get acquainted to 

ted at. 

n Bozeman, I don't 

e comment that 

 the ground. I 

on that that is 

he information I 

r and they're not 

d a lot of money 

The scenic value of this area is a vast emptiness 

that soon calls for lack of variety and comfort, except 

for the hardiest of those in pursuit of communication 

with nature. This area shows little change since its 

creation, and if left as it is at its present, shows 

21

22

23

24

25

25

little change, if any change, in the future, as this is 

the main point in creating a wilderness area. It 

appears the desired result is already assured by the 

very character of the area itself, without changing its 

present status in any way. 

It seems pointless to take land from which there is 

some use and change it to an area for which there will 

be no use. Therefore, we protest any new designation 

or restriction as being not only not necessary, but not 

in the best interest of the citizens of this county, 

state or nation. Board of county commissioners, Lester 

Wilke, Duane Compton, Dan Garrison. That was said 

35 years ago and it's the same today. Thank you. 

MS. MATHER: Leslie, Jim on deck.

LESLIE ROBINSON: My name is Leslie 

Robinson, R-o-b-i-n-s-o-n. I'm a rancher from out 

south, and a Phillips County Commissioner. I want to 

hit a little bit on the economics that are in the 

document. Your proposed or preferred alternative is 

"D," and in that alternative it calls for all of the 

current staff positions plus seven additional 

positions. 

It says, "Alternative D" would generate $2.1 

million dollars more in local output, 25 additional 

jobs, $569,600 more in labor income compared to 

1

2

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5

6

7

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8 of 14 sheets Page 26 to 29 of 44 

26

"Alternative A", which is the current alternative, but 

that's excluding livestock. So I want to hit a little 

bit about the economics you have in your document about 

livestock. 

One job for every 1350 AUMs of livestock grazing, 

and in Phillips County that's 4,849 AUMs, which is 

25.7 percent of the AUMs on the CMR. That creates 3.6 

jobs, $199,303 of production and $385,500 in total 

economic output. 

I don't think that you should be excluding the 

grazing when you look at your complete picture, and all 

of the increase in staff positions would have little or 

no impact on Phillips County where decreasing grazing 

would have a large impact on Phillips County. The 

document says, however, considering that the refuge 

currently supplies less than one percent of all AUMs in 

the region, the regional cumulative effect of the 

refuge management actions, which combined with economic 

effects of other land management, changes would be 

next, I believe. I question if 3.6 jobs and $385,500 

in economic output is negligible for Phillips County. 

Therein, also you say in the document there will be 

some increases in the level of visitation, so to me 

that means that the only real increase in the economic 

output is only from the seven additional jobs on the 

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CMR. 

I would like to see a copy of the study that says 

that carbon is sequestered with a prescriptive fire. 

Also in your document it says, "While there are no 

requirements to base management decisions on public 

opinion, the Service values and considers input from 

the public." I know there is technically no 

requirements, but I would suggest that you take the 

input from the public as a -- seriously when you do 

your plan. Thank you. 

MS. MATHER: Jim?

JIM ROBINSON: Jim Robinson, 

R-o-b-i-n-s-o-n. If I speak for three minutes, that's 

three minutes more than I've probably spoke all my 

life. I want to start off with the wilderness. Most 

of this country is pristine the way it is. Why protect 

it? For some reason, it seems like when things start 

getting protected, they don't stay that way. It 

happened with the prairie dog. It's been protected and 

now there's no prairie dogs anywhere. 

The grazing. Prescriptive grazing. If I get it 

right, if you have an area that wants grazed, you could 

call us up and say we need 700 head of yearlings for 

three-and-a-half weeks to graze it, and it might be in 

south Phillips or it could be at Jordan. It's not 

1

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going to h

feasible f

As far 

inception 

Service ha

been cut, 

haven't. 

to do with

bears once 

deer, you 

turkeys th

And as 

salt cedar

We've seen 

recipients 

before I l

in here th

there were 

livestock 

there in s

meeting th

down next 

question w

eventually 

introduced 

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eradicated

my list. 

else that 

chance to 

your comme

said, this 

have accep

report as 

Refuge bac

project le

officially 

you, Bill. 

do is go t

answer som

if there a

picked up 

we'll pick 

The fi

question e

be conside

was a litt

process, w

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26

"Alternative A", which is the current alternative, but 

that's excluding livestock. So I want to hit a little 

bit about the economics you have in your document about 

livestock. 

One job for every 1350 AUMs of livestock grazing, 

and in Phillips County that's 4,849 AUMs, which is 

25.7 percent of the AUMs on the CMR. That creates 3.6 

jobs, $199,303 of production and $385,500 in total 

economic output. 

I don't think that you should be excluding the 

grazing when you look at your complete picture, and all 

of the increase in staff positions would have little or 

no impact on Phillips County where decreasing grazing 

would have a large impact on Phillips County. The 

document says, however, considering that the refuge 

currently supplies less than one percent of all AUMs in 

the region, the regional cumulative effect of the 

refuge management actions, which combined with economic 

effects of other land management, changes would be 

next, I believe. I question if 3.6 jobs and $385,500 

in economic output is negligible for Phillips County. 

Therein, also you say in the document there will be 

some increases in the level of visitation, so to me 

that means that the only real increase in the economic 

output is only from the seven additional jobs on the 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

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27

CMR. 

I would like to see a copy of the study that says 

that carbon is sequestered with a prescriptive fire. 

Also in your document it says, "While there are no 

requirements to base management decisions on public 

1

2

3

4

5

28

going to happen. It's not economical and it's not 

feasible for us to do. 

As far as grazing and wildlife, ever since the 

inception of the CMR, or since the Fish and Wildlife 

Service has taken it over, the grazing permits have 

been cut, and as far as wildlife populations, they 

haven't. I mean, we've got more elk than we know what 

to do with. There's mountain lions down there, a few 

bears once in a while. I mean, we got white tail mule 

deer, you name it, it's there. There's even wild 

turkeys that have shown up. 

And as far as the weeds, we do have a problem with 

salt cedar. It's starting to creep up the drainages. 

We've seen it outside the CMR, and we were the 

recipients of that from the CMR. And one more thing 

before I leave. Three years ago at the scoping meeting 

in here the questions were asked on the buffalo, if 

there were plans. The answer was no. I asked about 

livestock grazing and the reply was, it would always be 

there in some form or another, and then after the 

meeting the biologist by the name of Bob Skinner sat 

down next to me and said your answer, or your grazing 

question was not answered correctly. He said, 

eventually as new species such as buffalo are 

introduced onto the CMR, livestock grazing will be 

1

2

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5

6

7

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9

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eradicated. Thank you. 

MS. MATHER: Jim was the last person on 

my list. Before we answer questions, is there anybody 

else that has a question or comment that didn't get a 

chance to come up? OkayPlease do send in or email 

1

2

3

4

5

8 of 14 sheets Page 26 to 29 of 44 02/14/2011 11:37:33 AM

26

"Alternative A", which is the current alternative, but 

that's excluding livestock. So I want to hit a little 

bit about the economics you have in your document about 

livestock. 

One job for every 1350 AUMs of livestock grazing, 

and in Phillips County that's 4,849 AUMs, which is 

25.7 percent of the AUMs on the CMR. That creates 3.6 

jobs, $199,303 of production and $385,500 in total 

economic output. 

I don't think that you should be excluding the 

grazing when you look at your complete picture, and all 

of the increase in staff positions would have little or 

no impact on Phillips County where decreasing grazing 

would have a large impact on Phillips County. The 

document says, however, considering that the refuge 

currently supplies less than one percent of all AUMs in 

the region, the regional cumulative effect of the 

refuge management actions, which combined with economic 

effects of other land management, changes would be 

next, I believe. I question if 3.6 jobs and $385,500 

in economic output is negligible for Phillips County. 

Therein, also you say in the document there will be 

some increases in the level of visitation, so to me 

that means that the only real increase in the economic 

output is only from the seven additional jobs on the 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

27

CMR. 

I would like to see a copy of the study that says 

that carbon is sequestered with a prescriptive fire. 

Also in your document it says, "While there are no 

requirements to base management decisions on public 

opinion, the Service values and considers input from 

the public." I know there is technically no 

requirements, but I would suggest that you take the 

input from the public as a -- seriously when you do 

your plan. Thank you. 

MS. MATHER: Jim?

JIM ROBINSON: Jim Robinson, 

R-o-b-i-n-s-o-n. If I speak for three minutes, that's 

three minutes more than I've probably spoke all my 

life. I want to start off with the wilderness. Most 

of this country is pristine the way it is. Why protect 

it? For some reason, it seems like when things start 

getting protected, they don't stay that way. It 

happened with the prairie dog. It's been protected and 

now there's no prairie dogs anywhere. 

The grazing. Prescriptive grazing. If I get it 

right, if you have an area that wants grazed, you could 

call us up and say we need 700 head of yearlings for 

three-and-a-half weeks to graze it, and it might be in 

south Phillips or it could be at Jordan. It's not 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

28

going to happen. It's not economical and it's not 

feasible for us to do. 

As far as grazing and wildlife, ever since the 

inception of the CMR, or since the Fish and Wildlife 

Service has taken it over, the grazing permits have 

been cut, and as far as wildlife populations, they 

haven't. I mean, we've got more elk than we know what 

to do with. There's mountain lions down there, a few 

bears once in a while. I mean, we got white tail mule 

deer, you name it, it's there. There's even wild 

turkeys that have shown up. 

And as far as the weeds, we do have a problem with 

salt cedar. It's starting to creep up the drainages. 

We've seen it outside the CMR, and we were the 

recipients of that from the CMR. And one more thing 

before I leave. Three years ago at the scoping meeting 

in here the questions were asked on the buffalo, if 

there were plans. The answer was no. I asked about 

livestock grazing and the reply was, it would always be 

there in some form or another, and then after the 

meeting the biologist by the name of Bob Skinner sat 

down next to me and said your answer, or your grazing 

question was not answered correctly. He said, 

eventually as new species such as buffalo are 

introduced onto the CMR, livestock grazing will be 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

29

eradicated. Thank you. 

MS. MATHER: Jim was the last person on 

my list. Before we answer questions, is there anybody 

else that has a question or comment that didn't get a 

chance to come up? Okay. Please do send in or e-mail 

your comments. 

MR. CRAWFORD: All right. As Janelle 

said, this is my last day as manager of the CMR. I 

have accepted a job going back home. I leave Monday to 

report as refuge manager of Tennessee National Wildlife 

Refuge back where I grew up. Bill Berg will be acting 

project leader for an extended period of time, so I'm 

officially passing management of the refuge over to 

you, Bill. 

MR. BERG: Gee, thanks. What I'll try to 

do is go through the notes I have here and try to 

answer some of the questions that I made note of, and 

if there are any other ones that Laurie or Barron 

picked up on that I didn't put an asteric by here, 

we'll pick up those shortly after that. 

The first one was asked by Ron Korman. We had this 

question earlier today, whether or not counties would 

be considered coordinators or cooperators, and there 

was a little bit of confusion there. As part of this 

process, we formed a cooperators group. Barron 

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434 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 26 to 29 of 44 02/14/2011 11:37:33 AM

ips County. 

 there will be 

 so to me 

the economic 

obs on the 

27

dy that says 

tive fire. 

e are no 

on public 

input from 

no 

 take the 

en you do 

utes, that's 

e all my 

ness. Most 

 Why protect 

hings start 

y. It 

protected and 

f I get it 

ed, you could 

rlings for 

 might be in 

It's not 

meeting the biologist by the name of Bob Skinner sat 

down next to me and said your answer, or your grazing 

question was not answered correctly. He said, 

eventually as new species such as buffalo are 

introduced onto the CMR, livestock grazing will be 

21

22

23

24

25

29

eradicated. Thank you. 

MS. MATHER: Jim was the last person on 

my list. Before we answer questions, is there anybody 

else that has a question or comment that didn't get a 

chance to come up? Okay. Please do send in or e-mail 

your comments. 

MR. CRAWFORD: All right. As Janelle 

said, this is my last day as manager of the CMR. I 

have accepted a job going back home. I leave Monday to 

report as refuge manager of Tennessee National Wildlife 

Refuge back where I grew up. Bill Berg will be acting 

project leader for an extended period of time, so I'm 

officially passing management of the refuge over to 

you, Bill. 

MR. BERG: Gee, thanks. What I'll try to 

do is go through the notes I have here and try to 

answer some of the questions that I made note of, and 

if there are any other ones that Laurie or Barron 

picked up on that I didn't put an asteric by here, 

we'll pick up those shortly after that. 

The first one was asked by Ron Korman. We had this 

question earlier today, whether or not counties would 

be considered coordinators or cooperators, and there 

was a little bit of confusion there. As part of this 

process, we formed a cooperators group. Barron 

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mentioned those participants earlier in the 

presentation. The intent of that group was to sit down 

with us and help us draft this plan. I'm not sure what 

the distinction is, Ron, between cooperators and 

coordinators, but the example I gave earlier was that 

when we get further along with some of the stepdown 

plans, for example, the road management plan that we'll 

develop, we will truly be a coordinator with the 

counties, and the main reason for that is, based on 

what some of the commissioners brought up, is the fact 

that some of the roads on the refuge are petitioned 

county roads, and it would be good for both our agency 

and the counties to clear up, you know, which roads are 

truly county roads, which roads are refuge roads, and 

so forth, and in some cases it's going to be one in the 

same. I don't know if that answers your question, Ron.

MR. KORMAN: Well, coordinator is equal 

status, right?

MR. BERG: I think what we should do is 

let me go through the ones that are marked, and we can 

talk about that more at the end, and maybe you can give 

a better explanation of what you mean by that, if 

that's all right?

MR. KORMAN: Yeah. 

MR. BERG: Okay. Another topic that's 

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come up time and time again, and we've been asked to 

kind of give an explanation of refuges versus other 

federal public lands, and again it was noted during the 

earlier presentation, but refuges have a specific 

mission, that being wildlife and wildlife habitat. 

Most of the other federal agencies, BLM, Forest 

Service, to some extent, Bureau of Reclamation have 

more of a multiple mandate, so, for example, on BLM 

lands, whether it's grazing, timber harvest, mining, 

all those uses on those types of lands have equal 

weight with wildlife or recreation, and so forth. 

On refuge lands it's real specific. It's more 

similar to how the national parks were set up for 

public recreation. Refuges were set up for wildlife 

and wildlife habitat, so quite a difference. 

The other thing that comes up, too, is also the 

grazing programs that we have on refuges versus grazing 

programs and other public lands. On BLM lands, those 

grazing rules and regulations fall under what's called 

the Taylor Grazing Act. Quite a bit, I would say more 

liberal, or maybe that's not the right choice of words, 

but quite a bit of different types of use are allowed 

under Taylor Grazing versus grazing on a national 

wildlife refuge. All the grazing we do is for the 

purpose of improving habitat, in the long run. So 

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quite a differe

We don't do 

except on some 

it for habitat 

is not allowed 

totally differe

Okay. Jim 

grazing not bei

permittee. And 

grazing is goin

permittees. 

Currently, 

on the refuge. 

probably have f

units in the fu

with our existi

this prescripti

to sit down wit

existing permit

tool to use on 

combination of 

What we'll 

in and say, oka

of yearlings to 

know that's not 

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industry that b

refuge. So tha

not only make i

want to use cat

improve it, we'

manner where it 

But I'll be 

permittees we h

cow/calf pair o

keep their catt

them out onto t

back in or shif

going to be tha

It might be the 

bit further awa

depending on ho

big challenges 

and try to coor

You know, w

tools to manage 

we talked about 

which will infl

When it starts 

of the young le

burned, which t

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02/14/2011 11:37:33 AM Page 30 to 33 of 44 9 of 14 sheets

30

mentioned those participants earlier in the 

presentation. The intent of that group was to sit down 

with us and help us draft this plan. I'm not sure what 

the distinction is, Ron, between cooperators and 

coordinators, but the example I gave earlier was that 

when we get further along with some of the stepdown 

plans, for example, the road management plan that we'll 

develop, we will truly be a coordinator with the 

counties, and the main reason for that is, based on 

what some of the commissioners brought up, is the fact 

that some of the roads on the refuge are petitioned 

county roads, and it would be good for both our agency 

and the counties to clear up, you know, which roads are 

truly county roads, which roads are refuge roads, and 

so forth, and in some cases it's going to be one in the 

same. I don't know if that answers your question, Ron.

MR. KORMAN: Well, coordinator is equal 

status, right?

MR. BERG: I think what we should do is 

let me go through the ones that are marked, and we can 

talk about that more at the end, and maybe you can give 

a better explanation of what you mean by that, if 

that's all right?

MR. KORMAN: Yeah. 

MR. BERG: Okay. Another topic that's 

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come up time and time again, and we've been asked to 

kind of give an explanation of refuges versus other 

federal public lands, and again it was noted during the 

earlier presentation, but refuges have a specific 

mission, that being wildlife and wildlife habitat. 

Most of the other federal agencies, BLM, Forest 

Service, to some extent, Bureau of Reclamation have 

more of a multiple mandate, so, for example, on BLM 

lands, whether it's grazing, timber harvest, mining, 

all those uses on those types of lands have equal 

weight with wildlife or recreation, and so forth. 

On refuge lands it's real specific. It's more 

similar to how the national parks were set up for 

public recreation. Refuges were set up for wildlife 

and wildlife habitat, so quite a difference. 

The other thing that comes up, too, is also the 

grazing programs that we have on refuges versus grazing 

programs and other public lands. On BLM lands, those 

grazing rules and regulations fall under what's called 

the Taylor Grazing Act. Quite a bit, I would say more 

liberal, or maybe that's not the right choice of words, 

but quite a bit of different types of use are allowed 

under Taylor Grazing versus grazing on a national 

wildlife refuge. All the grazing we do is for the 

purpose of improving habitat, in the long run. So 

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quite a difference there between the agencies. 

We don't do any timber harvest, for the most part, 

except on some of the eastern refuges where we're doing 

it for habitat reasons. Most of the mineral extraction 

is not allowed on refuges, but it's just kind of a 

totally different target that we're looking at. 

Okay. Jim Robinson brought up the prescriptive 

grazing not being economical or feasible for a 

permittee. And we recognize the fact that prescriptive 

grazing is going to be a major change for some of our 

permittees. 

Currently, we have several units or habitat units 

on the refuge. Barron mentioned we had 65. We'll 

probably have fewer than that, but probably larger 

units in the future. The challenge we're going to face 

with our existing permittees when we transition into 

this prescriptive program is that we're going to have 

to sit down with individuals that have current, 

existing permits where we don't have another management 

tool to use on that landscape, or we might even use a 

combination of the two. 

What we'll do is, you know, we realize we can't go 

in and say, okay, five years from now we want 500 head 

of yearlings to run for two months on the refuge. We 

know that's not the possibility with the livestock 

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industry that boarders or currently has permits on the 

refuge. So that will be our challenge to sit down and 

not only make it workable for you guys so that when we 

want to use cattle as a tool to manage habitat or to 

improve it, we're going to have to set it up in such a 

manner where it still fits your operation. 

But I'll be honest with you, there are quite a few 

permittees we have right now that are strictly a small, 

cow/calf pair operation. They might calf back home, 

keep their cattle in for about a month, and then turn 

them out onto the refuge for three months, bring them 

back in or shift them to another pasture. It's not 

going to be that consistent, same pasture every year. 

It might be the one next to it, or slightly or a little 

bit further away, or it might be a bigger pasture, 

depending on how it's set up. I think that will be the 

big challenges for our managers to actually sit down 

and try to coordinate that. 

You know, we're going to try to plug in some other 

tools to manage habitat out there. One of the things 

we talked about was doing some prescriptive grazing, 

which will influence the use of that area, you know. 

When it starts to green up, we will actually move some 

of the young lets into those areas that have been 

burned, which theoretically will take the pressure off 

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mentioned those participants earlier in the 

presentation. The intent of that group was to sit down 

with us and help us draft this plan. I'm not sure what 

the distinction is, Ron, between cooperators and 

coordinators, but the example I gave earlier was that 

when we get further along with some of the stepdown 

plans, for example, the road management plan that we'll 

develop, we will truly be a coordinator with the 

counties, and the main reason for that is, based on 

what some of the commissioners brought up, is the fact 

that some of the roads on the refuge are petitioned 

county roads, and it would be good for both our agency 

and the counties to clear up, you know, which roads are 

truly county roads, which roads are refuge roads, and 

so forth, and in some cases it's going to be one in the 

same. I don't know if that answers your question, Ron.

MR. KORMAN: Well, coordinator is equal 

status, right?

MR. BERG: I think what we should do is 

let me go through the ones that are marked, and we can 

talk about that more at the end, and maybe you can give 

a better explanation of what you mean by that, if 

that's all right?

MR. KORMAN: Yeah. 

MR. BERG: Okay. Another topic that's 

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come up time and time again, and we've been asked to 

kind of give an explanation of refuges versus other 

federal public lands, and again it was noted during the 

earlier presentation, but refuges have a specific 

missionthat being wildlife and wildlife habitat

1

2

3

4

5

32

quite a difference there between the agencies. 

We don't do any timber harvest, for the most part, 

except on some of the eastern refuges where we're doing 

it for habitat reasons. Most of the mineral extraction 

is not allowed on refuges, but it's just kind of a 

totally different target that we're looking at. 

Okay. Jim Robinson brought up the prescriptive 

grazing not being economical or feasible for a 

permittee. And we recognize the fact that prescriptive 

grazing is going to be a major change for some of our 

permittees. 

Currently, we have several units or habitat units 

on the refuge. Barron mentioned we had 65. We'll 

probably have fewer than that, but probably larger 

units in the future. The challenge we're going to face 

with our existing permittees when we transition into 

this prescriptive program is that we're going to have 

to sit down with individuals that have current, 

existing permits where we don't have another management 

tool to use on that landscape, or we might even use a 

combination of the two. 

What we'll do is, you know, we realize we can't go 

in and say, okay, five years from now we want 500 head 

of yearlings to run for two months on the refuge. We 

know that's not the possibility with the livestock 

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industry that boarders or currently has permits on the 

refuge. So that will be our challenge to sit down and 

not only make it workable for you guys so that when we 

want to use cattle as a tool to manage habitat or to 

improve itwe're going to have to set it up in such a 

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2

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VOLUME 2, Chapter 4—Public Hearing Testimony 435

Page 30 to 33 of 44 9 of 14 sheets

maybe you can give 

 by that, if 

r topic that's 

31

e been asked to 

s versus other 

s noted during the 

e a specific 

life habitat. 

es, BLM, Forest 

clamation have 

xample, on BLM 

arvest, mining, 

s have equal 

nd so forth. 

ic. It's more 

e set up for 

up for wildlife 

erence. 

oo, is also the 

ges versus grazing 

BLM lands, those 

der what's called 

 I would say more 

t choice of words, 

 use are allowed 

n a national 

do is for the 

long run. So 

combination of the two. 

What we'll do is, you know, we realize we can't go 

in and say, okay, five years from now we want 500 head 

of yearlings to run for two months on the refuge. We 

know that's not the possibility with the livestock 

21

22

23

24

25

33

industry that boarders or currently has permits on the 

refuge. So that will be our challenge to sit down and 

not only make it workable for you guys so that when we 

want to use cattle as a tool to manage habitat or to 

improve it, we're going to have to set it up in such a 

manner where it still fits your operation. 

But I'll be honest with you, there are quite a few 

permittees we have right now that are strictly a small, 

cow/calf pair operation. They might calf back home, 

keep their cattle in for about a month, and then turn 

them out onto the refuge for three months, bring them 

back in or shift them to another pasture. It's not 

going to be that consistent, same pasture every year. 

It might be the one next to it, or slightly or a little 

bit further away, or it might be a bigger pasture, 

depending on how it's set up. I think that will be the 

big challenges for our managers to actually sit down 

and try to coordinate that. 

You know, we're going to try to plug in some other 

tools to manage habitat out there. One of the things 

we talked about was doing some prescriptive grazing, 

which will influence the use of that area, you know. 

When it starts to green up, we will actually move some 

of the young lets into those areas that have been 

burned, which theoretically will take the pressure off 

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10 of 14 sheets Page 34 to 37 of 44 

34

some of the other habitats. 

So, again, this plan the way it is right now, isn't 

specific enough to, I know, ease your concerns about 

how prescriptive grazing will work, but of all the 

other refuges in the system, CMR is one of the few 

refuges that still does an annual grazing program like 

we have right now. 

What else? I'm going to have to defer on that one, 

the carbon sequestration. Okay. Anything else? Okay. 

Salt cedar. We're aware of that. I don't personally 

take the blame for all the salt cedar problems in 

Montana. Some of the oldest documented plants in 

Montana exist in the town of Jordan and the town of 

Roundup. Matter of fact, Malta at the USDA office here 

had a salt cedar plant growing off the southwest corner 

of their building up until three years ago here. That 

plant was there for 10 years plus. So to blame all the 

salt cedar problems on the refuge I don't think is fair 

either. 

We do a lot of work with the Corps of Engineers, we 

put a lot of money into the salt cedar control the last 

few years. It's one of those plants that I don't think 

you could put enough money towards right now to 

control. One encouraging thing we've heard, though, is 

there's a pretty good biological control, an insect 

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that defoliates the plant, actually knocks it back. It 

doesn't totally kill it out, but it thins it out, and 

we're hopeful that that will become adaptive to the 

plants we have here in Montana. It's actually working 

in the southwest fairly well, so we'll continue to 

treat noxious weeds. With the lake the way it is and 

the fluctuations in water levels, and, you know, stuff 

coming down the Musselshell and Missouri River, it's a 

tough one to deal with. 

Just matter of fact, or the way it grows and where 

it grows, it's a tough one to deal with. We've got a 

real aggressive noxious weed program going on with some 

of our spotted knapweeds, and some of those things that 

are fairly common in some of the upper river bottoms. 

Spurge is a little bit less of a problem, but we do 

have some spurge too, which in my eyes is even more of 

a concern than some of the knapweed. 

But just as an example of what can be done, I 

think, with some of the noxious weeds, you know, the 

agency has spent millions of dollars on salt cedar over 

the years, our agency and others also. And now there's 

a real effective biological control agent, if you've 

ever been through any of the parks in North Dakota, 

Medora and the one to the north, those hill sides used 

to be yellow with spurge, and now there's an insect 

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that actua

hopeful so

cedar and 

Excell

what we co

health ver

our mind, 

also got g

reverse of 

pasture ou

the vegeta

it can sti

got all th

The ch

can't just 

species th

that are r

spring nes

growth, an

looked at 

ones that 

Bob's 

calling se

about that

or indicat

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like salt 

shrubs tha

as or more 

than the c

We all 

more adapt

there more 

know, we'r

lot more d

you know, 

sure that 

needs for 

I'll d

I'm the on

an active 

service, b

develop cl

was the fi

developing 

service wa

effects wo

change. 

So wor

of researc

of Tom DeL

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34

some of the other habitats. 

So, again, this plan the way it is right now, isn't 

specific enough to, I know, ease your concerns about 

how prescriptive grazing will work, but of all the 

other refuges in the system, CMR is one of the few 

refuges that still does an annual grazing program like 

we have right now. 

What else? I'm going to have to defer on that one, 

the carbon sequestration. Okay. Anything else? Okay. 

Salt cedar. We're aware of that. I don't personally 

take the blame for all the salt cedar problems in 

Montana. Some of the oldest documented plants in 

Montana exist in the town of Jordan and the town of 

Roundup. Matter of fact, Malta at the USDA office here 

had a salt cedar plant growing off the southwest corner 

of their building up until three years ago here. That 

plant was there for 10 years plus. So to blame all the 

salt cedar problems on the refuge I don't think is fair 

either. 

We do a lot of work with the Corps of Engineers, we 

put a lot of money into the salt cedar control the last 

few years. It's one of those plants that I don't think 

you could put enough money towards right now to 

control. One encouraging thing we've heard, though, is 

there's a pretty good biological control, an insect 

1

2

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that defoliates the plant, actually knocks it back. It 

doesn't totally kill it out, but it thins it out, and 

we're hopeful that that will become adaptive to the 

plants we have here in Montana. It's actually working 

1

2

3

4

5

36

that actually keeps it in check pretty good. So we're 

hopeful something like that gets going with the salt 

cedar and it's not as big of an issue down the road. 

Excellent question. A lot of disagreement with 

what we consider wildlife health or wildlife habitat 

health versus good range condition. In my mind, or in 

our mind, if you've got good wildlife habitat you've 

also got good or excellent range condition, but the 

reverse of that isn't always true. You can have a 

pasture out there that's totally, a hundred percent of 

the vegetation is removed at the end of the year, and 

it can still be an excellent range condition, if you've 

got all the components there. 

The challenge we face as wildlife managers is we 

can't just manage for, you know, a slate or a list of 

species that are there but are not providing the cover 

that are required for winter habitat, the following 

spring nesting, which is usually the previous year's 

growth, and also some of the species that are often 

looked at from a range condition standpoint aren't the 

ones that are most important for wildlife. 

Bob's done some real good work on what we're 

calling sentinel plants. A little bit of confusion 

about that. Sometimes they call them diagnostic plants 

or indicator plants, but those are some of the species 

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like salt brush, salt bush, winter fat, some of your 

shrubs that are important to mule deer that truly are 

as or more important to some of the wildlife species 

than the common forage plants or the grasses out there. 

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2

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4

5

10 of 14 sheets Page 34 to 37 of 44 02/14/2011 11:37:33 AM

34

some of the other habitats. 

So, again, this plan the way it is right now, isn't 

specific enough to, I know, ease your concerns about 

how prescriptive grazing will work, but of all the 

other refuges in the system, CMR is one of the few 

refuges that still does an annual grazing program like 

we have right now. 

What else? I'm going to have to defer on that one, 

the carbon sequestration. Okay. Anything else? Okay. 

Salt cedar. We're aware of that. I don't personally 

take the blame for all the salt cedar problems in 

Montana. Some of the oldest documented plants in 

Montana exist in the town of Jordan and the town of 

Roundup. Matter of fact, Malta at the USDA office here 

had a salt cedar plant growing off the southwest corner 

of their building up until three years ago here. That 

plant was there for 10 years plus. So to blame all the 

salt cedar problems on the refuge I don't think is fair 

either. 

We do a lot of work with the Corps of Engineers, we 

put a lot of money into the salt cedar control the last 

few years. It's one of those plants that I don't think 

you could put enough money towards right now to 

control. One encouraging thing we've heard, though, is 

there's a pretty good biological control, an insect 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

35

that defoliates the plant, actually knocks it back. It 

doesn't totally kill it out, but it thins it out, and 

we're hopeful that that will become adaptive to the 

plants we have here in Montana. It's actually working 

in the southwest fairly well, so we'll continue to 

treat noxious weeds. With the lake the way it is and 

the fluctuations in water levels, and, you know, stuff 

coming down the Musselshell and Missouri River, it's a 

tough one to deal with. 

Just matter of fact, or the way it grows and where 

it grows, it's a tough one to deal with. We've got a 

real aggressive noxious weed program going on with some 

of our spotted knapweeds, and some of those things that 

are fairly common in some of the upper river bottoms. 

Spurge is a little bit less of a problem, but we do 

have some spurge too, which in my eyes is even more of 

a concern than some of the knapweed. 

But just as an example of what can be done, I 

think, with some of the noxious weeds, you know, the 

agency has spent millions of dollars on salt cedar over 

the years, our agency and others also. And now there's 

a real effective biological control agent, if you've 

ever been through any of the parks in North Dakota, 

Medora and the one to the north, those hill sides used 

to be yellow with spurge, and now there's an insect 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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25

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that actually keeps it in check pretty good. So we're 

hopeful something like that gets going with the salt 

cedar and it's not as big of an issue down the road. 

Excellent question. A lot of disagreement with 

what we consider wildlife health or wildlife habitat 

health versus good range condition. In my mind, or in 

our mind, if you've got good wildlife habitat you've 

also got good or excellent range condition, but the 

reverse of that isn't always true. You can have a 

pasture out there that's totally, a hundred percent of 

the vegetation is removed at the end of the year, and 

it can still be an excellent range condition, if you've 

got all the components there. 

The challenge we face as wildlife managers is we 

can't just manage for, you know, a slate or a list of 

species that are there but are not providing the cover 

that are required for winter habitat, the following 

spring nesting, which is usually the previous year's 

growth, and also some of the species that are often 

looked at from a range condition standpoint aren't the 

ones that are most important for wildlife. 

Bob's done some real good work on what we're 

calling sentinel plants. A little bit of confusion 

about that. Sometimes they call them diagnostic plants 

or indicator plants, but those are some of the species 

1

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like salt brush, salt bush, winter fat, some of your 

shrubs that are important to mule deer that truly are 

as or more important to some of the wildlife species 

than the common forage plants or the grasses out there. 

We all realize that elk, you know, are a little 

more adaptive and probably utilize that forage out 

there more similar to cattle than, say, deer, but, you 

know, we're charged with managing that habitat for a 

lot more diversity of species than just those two, so, 

you know, we have to look at those other plants to make 

sure that they are in enough abundance to provide the 

needs for some of those other species. 

I'll do the carbon sequestration question, since 

I'm the one that made the comment. I've taken kind of 

an active role in the climate change issue for the 

service, been on a couple of national teams helping to 

develop climate change policy. One of the things that 

was the first topic that came up when we were 

developing our current climate change policy for the 

service was the use of prescribed fire, and what 

effects would prescribed fire have on potential climate 

change. 

So working with Bob we started doing a little bit 

of research, and we came across a professor by the name 

of Tom DeLuca, and Tom was in Bozeman, and Tom was 

1

2

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436 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana

Page 34 to 37 of 44 02/14/2011 11:37:33 AM

g, 

trol the last 

I don't think 

ow to 

d, though, is 

an insect 

35

 it back. It 

it out, and 

ve to the 

ally working 

tinue to 

y it is and 

 know, stuff 

iver, it's a 

ows and where 

We've got a 

 on with some 

e things that 

er bottoms. 

but we do 

even more of 

 done, I 

 know, the 

lt cedar over 

d now there's 

 if you've 

h Dakota, 

l sides used 

an insect 

gp

ones that are most important for wildlife. 

Bob's done some real good work on what we're 

calling sentinel plants. A little bit of confusion 

about that. Sometimes they call them diagnostic plants 

or indicator plants, but those are some of the species 

21

22

23

24

25

37

like salt brush, salt bush, winter fat, some of your 

shrubs that are important to mule deer that truly are 

as or more important to some of the wildlife species 

than the common forage plants or the grasses out there. 

We all realize that elk, you know, are a little 

more adaptive and probably utilize that forage out 

there more similar to cattle than, say, deer, but, you 

know, we're charged with managing that habitat for a 

lot more diversity of species than just those two, so, 

you know, we have to look at those other plants to make 

sure that they are in enough abundance to provide the 

needs for some of those other species. 

I'll do the carbon sequestration question, since 

I'm the one that made the comment. I've taken kind of 

an active role in the climate change issue for the 

service, been on a couple of national teams helping to 

develop climate change policy. One of the things that 

was the first topic that came up when we were 

developing our current climate change policy for the 

service was the use of prescribed fire, and what 

effects would prescribed fire have on potential climate 

change. 

So working with Bob we started doing a little bit 

of research, and we came across a professor by the name 

of Tom DeLuca, and Tom was in Bozeman, and Tom was 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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02/14/2011 11:37:33 AM Page 38 to 41 of 44 

38

doing climate research work for the Wilderness Society. 

And we got to speaking with Dr. DeLuca and started 

talking about carbon sequestration and prairies, and he 

became real excited and we started developing a couple 

of research proposals wanting to look at how much 

carbon could be sequestered in prairie. 

Quite a bit of biomass sitting down below those 

roots. And how much carbon is released when that is 

burned and how much goes back into the soil? It is new 

science. There's not been a lot of work on it. 

There's been a lot of work in the Ponderosa Pine forest 

west of here. Not a lot in the prairie. And that is 

something that we're interested in, the CMR is 

interested in, and so we're trying to get a couple of 

research proposals put together to look at that and to 

determine. So on page 419 of the CCP there's four 

articles referenced by T.H. DeLuca, and that's where 

those comments come from. 

Tom, unfortunately, took a job as the head of the 

climate program at the University of Wales. He's a 

little hard to get a hold of now, but we've been 

successful in keeping in touch with him in the past, 

and hopefully one of these days one of those research 

proposals will get funded and we'll be able to bring 

Tom back to the states and have him work out here in 

1

2

3

4

5

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8

9

10

11

12

13

14

15

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39

the prairie landscape again. 

Looking through my notes here I came across a 

couple other, or one other item. A question came up 

from Mark Manoukian, I think, about our 250,000 visitor 

use days we reference in the document. That comes out 

of a refuge reporting system that we have annually put 

together, but the basis for that is several places the 

Corps of Engineers document use on many of their 

recreation areas. 

We have upwards of 50 traffic counters on roads 

leading into the refuge. Those are some of the smaller 

bladed or two track roads. It's not an impact science, 

but, you know, it's a pretty calculated estimate of 

what we think's going on out there. The majority of 

those uses are associated with hunting and fishing, to 

be honest with you. We are seeing an increase in some 

of that just recreational camping, elk viewing, 

wildlife viewing type activity, and that's a trend we 

see nationwide, so that's increasing, but I would be 

safe to say, I think, that that number is probably as 

accurate as we can get, without more traffic counters 

or survey type stuff. 

We are doing a visitor use survey right now that 

will get us a little more data in that area, mainly 

like length of stay, amount of money spent, you know, 

1

2

3

4

5

6

7

8

9

10

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12

13

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how far those pe

So we're expandi

with that, we'll 

comment period. 

Laurie, since th

MS

is November 16th 

received several 

however, right n

to go, so it's a 

when there's sti

are going to do 

a decision about 

the comment peri

register. I wil

notify all of th

to get the word 

extension, okay? 

MR

around here and 

up. Bob Skinner

Paula Gouse from 

visitor question

Matchett is our 

with our ferret 

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Sand Creek, and 

area touch base 

information. Wh

lion biologist. 

and is probably 

we've initiated 

coming winter. 

there. 

UN

talk about your 

partner? You ke

you talk about t

talking do you d

MR

definition of pa

specifically ide

coordinate our w

a rough descript

below the high w

high water mark

it, where we're 

contractors. Th

involved coopera

With the co

the counties to 

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02/14/2011 11:37:33 AM Page 38 to 41 of 44 11 of 14 sheets

38

doing climate research work for the Wilderness Society. 

And we got to speaking with Dr. DeLuca and started 

talking about carbon sequestration and prairies, and he 

became real excited and we started developing a couple 

of research proposals wanting to look at how much 

carbon could be sequestered in prairie. 

Quite a bit of biomass sitting down below those 

roots. And how much carbon is released when that is 

burned and how much goes back into the soil? It is new 

science. There's not been a lot of work on it. 

There's been a lot of work in the Ponderosa Pine forest 

west of here. Not a lot in the prairie. And that is 

something that we're interested in, the CMR is 

interested in, and so we're trying to get a couple of 

research proposals put together to look at that and to 

determine. So on page 419 of the CCP there's four 

articles referenced by T.H. DeLuca, and that's where 

those comments come from. 

Tom, unfortunately, took a job as the head of the 

climate program at the University of Wales. He's a 

little hard to get a hold of now, but we've been 

successful in keeping in touch with him in the past, 

and hopefully one of these days one of those research 

proposals will get funded and we'll be able to bring 

Tom back to the states and have him work out here in 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

39

the prairie landscape again. 

Looking through my notes here I came across a 

couple other, or one other item. A question came up 

from Mark Manoukian, I think, about our 250,000 visitor 

use days we reference in the document. That comes out 

of a refuge reporting system that we have annually put 

together, but the basis for that is several places the 

Corps of Engineers document use on many of their 

recreation areas. 

We have upwards of 50 traffic counters on roads 

leading into the refuge. Those are some of the smaller 

bladed or two track roads. It's not an impact science, 

but, you know, it's a pretty calculated estimate of 

what we think's going on out there. The majority of 

those uses are associated with hunting and fishing, to 

be honest with you. We are seeing an increase in some 

of that just recreational camping, elk viewing, 

wildlife viewing type activity, and that's a trend we 

see nationwide, so that's increasing, but I would be 

safe to say, I think, that that number is probably as 

accurate as we can get, without more traffic counters 

or survey type stuff. 

We are doing a visitor use survey right now that 

will get us a little more data in that area, mainly 

like length of stay, amount of money spent, you know, 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

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19

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25

40

how far those people have come from, things like that. 

So we're expanding on that effort a little bit. Well, 

with that, we'll shut it down, and we've got the 

comment period. Yeah, I'll let you talk about that, 

Laurie, since that date's a little bit questionable. 

MS. SHANNON: Okay. The comment period 

is November 16th to get your comments in. We have 

received several requests to extend our comment period; 

however, right now there are still more than four weeks 

to go, so it's a little hard to say you need more time 

when there's still lots of time to comment. So what we 

are going to do is in the next week or so we will make 

a decision about if or when, how long we will extend 

the comment period. That notice will go in the federal 

register. I will put out a press release. I will 

notify all of the agencies. I will do everything I can 

to get the word out as to how long, if there will be an 

extension, okay? So I hope that answers that. 

MR. BERG: Yeah, and we're going to stick 

around here and answer some questions if anything comes 

up. Bob Skinner's the person to talk to about plants. 

Paula Gouse from our Fort Peck office if you have 

visitor questions or biological problems. Randy 

Matchett is our senior wildlife biologist and works 

with our ferret programs. Matt Derosier is from our 

1

2

3

4

5

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7

8

9

10

11

12

13

14

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41

Sand Creek, and I see a bunch of people that hunt that 

area touch base with him if you want some more 

information. Who else did I miss? Doug, our mountain 

lion biologist. Actually, Doug is our pilot right now 

and is probably going to head up a mountain lion study 

we've initiated with Fish Wildlife and Parks this 

coming winter. With that we have a lot of cookies back 

there. 

UNIDENTIFIED PERSON: Before you go, you 

talk about your partner. Can you identify your 

partner? You keep talking about your partners and also 

you talk about the Corps of Engineers. How much 

talking do you do with the local people?

MR. BERG: Well, you know, I guess the 

definition of partners is pretty broad. You 

specifically identify Corps of Engineers. We routinely 

coordinate our weed control efforts with them. Kind of 

a rough description of what we do, they treat stuff 

below the high water mark, we treat stuff above the 

high water mark. We share data, we map it, we document 

it, where we're working, we share crews, we share 

contractors. That would be one of our, I guess, more 

involved cooperators. 

With the counties, years past, we cooperated with 

the counties to get funds for graveling roads to access 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

38

doing climate research work for the Wilderness Society. 

And we got to speaking with Dr. DeLuca and started 

talking about carbon sequestration and prairies, and he 

became real excited and we started developing a couple 

of research proposals wanting to look at how much 

carbon could be sequestered in prairie. 

Quite a bit of biomass sitting down below those 

roots. And how much carbon is released when that is 

burned and how much goes back into the soil? It is new 

science. There's not been a lot of work on it. 

There's been a lot of work in the Ponderosa Pine forest 

west of here. Not a lot in the prairie. And that is 

something that we're interested in, the CMR is 

interested in, and so we're trying to get a couple of 

research proposals put together to look at that and to 

determine. So on page 419 of the CCP there's four 

articles referenced by T.H. DeLuca, and that's where 

those comments come from. 

Tom, unfortunately, took a job as the head of the 

climate program at the University of Wales. He's a 

little hard to get a hold of now, but we've been 

successful in keeping in touch with him in the past, 

and hopefully one of these days one of those research 

proposals will get funded and we'll be able to bring 

Tom back to the states and have him work out here in 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

39

the prairie landscape again. 

Looking through my notes here I came across a 

couple other, or one other item. A question came up 

from Mark Manoukian, I think, about our 250,000 visitor 

1

2

3

4

40

how far those people have come from, things like that. 

So we're expanding on that effort a little bit. Well, 

with that, we'll shut it down, and we've got the 

comment period. Yeah, I'll let you talk about that, 

Laurie, since that date's a little bit questionable. 

MS. SHANNON: Okay. The comment period 

is November 16th to get your comments in. We have 

received several requests to extend our comment period; 

however, right now there are still more than four weeks 

to go, so it's a little hard to say you need more time 

when there's still lots of time to comment. So what we 

are going to do is in the next week or so we will make 

a decision about if or when, how long we will extend 

the comment period. That notice will go in the federal 

register. I will put out a press release. I will 

notify all of the agencies. I will do everything I can 

to get the word out as to how long, if there will be an 

extension, okay? So I hope that answers that. 

MR. BERG: Yeah, and we're going to stick 

around here and answer some questions if anything comes 

up. Bob Skinner's the person to talk to about plants. 

Paula Gouse from our Fort Peck office if you have 

visitor questions or biological problems. Randy 

Matchett is our senior wildlife biologist and works 

with our ferret programs. Matt Derosier is from our 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

41

Sand Creek, and I see a bunch of people that hunt that 

area touch base with him if you want some more 

information. Who else did I miss? Doug, our mountain 

lion biologist. Actually, Doug is our pilot right now 

1

2

3

4
VOLUME 2, Chapter 4—Public Hearing Testimony 437

Page 38 to 41 of 44 11 of 14 sheets

im in the past, 

f those research 

e able to bring 

ork out here in 

39

came across a 

uestion came up 

ur 250,000 visitor 

. That comes out 

have annually put 

everal places the 

ny of their 

unters on roads 

ome of the smaller 

an impact science, 

ed estimate of 

The majority of 

g and fishing, to 

 increase in some 

k viewing, 

hat's a trend we 

 but I would be 

r is probably as 

traffic counters 

y right now that 

t area, mainly 

spent, you know, 

Paula Gouse from our Fort Peck office if you have 

visitor questions or biological problems. Randy 

Matchett is our senior wildlife biologist and works 

with our ferret programs. Matt Derosier is from our 

22

23

24

25

41

Sand Creek, and I see a bunch of people that hunt that 

area touch base with him if you want some more 

information. Who else did I miss? Doug, our mountain 

lion biologist. Actually, Doug is our pilot right now 

and is probably going to head up a mountain lion study 

we've initiated with Fish Wildlife and Parks this 

coming winter. With that we have a lot of cookies back 

there. 

UNIDENTIFIED PERSON: Before you go, you 

talk about your partner. Can you identify your 

partner? You keep talking about your partners and also 

you talk about the Corps of Engineers. How much 

talking do you do with the local people?

MR. BERG: Well, you know, I guess the 

definition of partners is pretty broad. You 

specifically identify Corps of Engineers. We routinely 

coordinate our weed control efforts with them. Kind of 

a rough description of what we do, they treat stuff 

below the high water mark, we treat stuff above the 

high water mark. We share data, we map it, we document 

it, where we're working, we share crews, we share 

contractors. That would be one of our, I guess, more 

involved cooperators. 

With the counties, years past, we cooperated with 

the counties to get funds for graveling roads to access 

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

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25

12 of 14 sheets Page 42 to 43 of 44 

42

the refuge and the rec. areas. I don't think we would 

have gotten anywhere by ourselves without cooperating 

with the counties on that effort. 

Fire, both prescriptive and wild fire work that we 

do, state agencies, BLM, forest service, counties. 

Counties are becoming a huge player in our fire program 

because of the engines and stuff they have around the 

counties. We've got a couple of individuals that we 

cooperate with, like APF, for example, on repairian 

work on Telegraph and Valentine Creek. We have done 

some cooperative studies there where they had a grad. 

student who was trying to restore some repairing areas. 

Fish, Wildlife & Parks, we deal with them weekly 

almost on different issues. Don't always see 

eye-to-eye but we work together as much as we can. Law 

enforcement, working with the counties, BLM, ride in 

the same trucks with Fish, Wildlife & Parks dealing 

with law enforcement issues. Help with almost any law 

enforcement effort that goes on in the six county area. 

Why don't we break now and we'll get together with 

individuals. Probably would be a little easier 

handling it that way, especially some of the questions 

that need a little more clarification.

UNIDENTIFIED PERSON: I would just like 

to ask one thing before you quit. How come you guys 

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will not recognize private property rights along the 

CMR?

MR. BERG: Come on up, Ron, and I'll talk 

to you. 

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12 of 14 sheets Page 42 to 43 of 44 02/14/2011 11:37:33 AM

42

the refuge and the rec. areas. I don't think we would 

have gotten anywhere by ourselves without cooperating 

with the counties on that effort. 

Fire, both prescriptive and wild fire work that we 

do, state agencies, BLM, forest service, counties. 

Counties are becoming a huge player in our fire program 

because of the engines and stuff they have around the 

counties. We've got a couple of individuals that we 

cooperate with, like APF, for example, on repairian 

work on Telegraph and Valentine Creek. We have done 

some cooperative studies there where they had a grad. 

student who was trying to restore some repairing areas. 

Fish, Wildlife & Parks, we deal with them weekly 

almost on different issues. Don't always see 

eye-to-eye but we work together as much as we can. Law 

enforcement, working with the counties, BLM, ride in 

the same trucks with Fish, Wildlife & Parks dealing 

with law enforcement issues. Help with almost any law 

enforcement effort that goes on in the six county area. 

Why don't we break now and we'll get together with 

individuals. Probably would be a little easier 

handling it that way, especially some of the questions 

that need a little more clarification.

UNIDENTIFIED PERSON: I would just like 

to ask one thing before you quit. How come you guys 

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43

will not recognize private property rights along the 

CMR?

MR. BERG: Come on up, Ron, and I'll talk 

to you. 

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02/14/2011 11:37:33 AM Page 44 to 44 of 44 13 of 14 sheets

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44

CERTIFICATE

STATE OF MONTANA )

)ss

COUNTY OF VALLEY )

 I, Kelley A. Barstad, Official Court Reporter of

the Montana Seventeenth Judicial District Court, and

Notary Public for the County of Valley, State of

Montana, residing at Glasgow, Montana DO HEREBY

CERTIFY:

That I was duly authorized to and did report the

foregoing proceeding. Said testimony and

proceedings were reported and transcribed by me with

 a computerized transcription system.

That the foregoing transcript of this matter

constitutes a true and accurate transcription of the

proceedings which were heard.

IN WITNESS WHEREOF, I have hereunto set my hand and

affixed my notarial seal this 30th day of January,

2011.

____________________________

Kelley A. Barstad

Certified Shorthand Reporter

My commission expires 2-2-14

Bibliography

Adams, S.M.; Dood, A.R. 2011. Background information on issues of concern for Montana: plains bison 

ecology, management, and conservation. Bozeman, MT: Montana Department of Fish, Wildlife 

and Parks. 16 p.

Alfonso, James M. 1991. South fork of Rock Creek 

riparian habitat. Rehabilitation project summary. U.S. Fish and Wildlife Service internal 

memo. Unpublished. On file at Charles M. Russell 

National Wildlife Refuge, Lewistown, MT. 7 p.

American Bird Conservancy. 2009. Threats to birds—

introduced species. <www.abcbirds.org/conservation

issues/threats/invasives.html> accessed February 

2010.

American Ornithologists’ Union. 2000. American 

Ornithologists’ Union checklist of Northern 

American birds. 7th edition (1998), 42nd supplement (2000). [Pages unknown].

American Prairie Foundation. 2011. American Prairie Foundation annual report. <www.american

prairie.org/projectprogress/land/land-acquisition> 

accessed December 30, 2011.

Ames, Charles R. 1977. Wildlife conflicts in riparian 

management—grazing. In: Proceedings; Importance, preservation and management of riparian habitat—a symposium; [Date of symposium 

unknown]; Tucson, Arizona. General Technical 

Report RM–43. Fort Collins, Colorado: USDA 

Forest Service Rocky Mountain Forest and 

Range Experiment Station. 49–51.

Anderson, R.C. 1990. The historic role of fire in 

the North American grassland. In: Collins, S.L.; 

Wallace, L.L.; editors. Fire in North American 

tallgrass prairies. Norman, OK: University of 

Oklahoma Press. 8–18.

Anderson, Stanley H. 1985. Managing our wildlife resources. Columbus, OH: Charles E. Merrill 

Publishing Company. 156 p.

Atkinson, Shirley J.; Dood, Arnold R. 2006a. Montana interior least tern management plan. Bozeman, MT: Montana Department of Fish, Wildlife 

and Parks. 47 p.

———. 2006b. Montana piping plover management 

plan. Bozeman, MT: Montana Department of Fish, 

Wildlife and Parks. 78 p.

Auble, G.T.; Scott, M.L. 1998. Fluvial disturbance 

patches and cottonwood recruitment along the 

upper Missouri River, Montana. Wetlands 18:546–

56. 

Auble, G.T.; Scott, M.L.; Frazier, J.; Krause, C.; 

Merigliano, M. 2005. Cottonwood in the Missouri 

Breaks National Monument. U.S. Geological Survey, Biological Resources Discipline, Fact Sheet 

2005–3132. 4 p.

Bailey, Joseph K.; Schweitzer, Jennifer A.; Whitham, 

Thomas G. 2001. Salt cedar negatively affects biodiversity of aquatic macroinvertebrates. Wetlands 21(3):442–47. 

Ball, I.J.; Eng, Robert L.; Ball, Susan Kraft. 1995. 

Population density and productivity of ducks on 

large grassland tracts in northcentral Montana. 

Wildlife Society Bulletin 23(4):767–73. 

Battazzo, A.M. 2007. Winter survival and habitat 

use by female greater sage-grouse in South Phillips County, Montana 2004–2006 [master’s thesis]. 

Missoula, MT: The University of Montana. 71 p.

Belsky, A.J.; Matzke, A.; Uselman, S. 1999. Survey 

of livestock influences on stream and riparian ecosystems in the western United States. Journal of 

Soil and Water Conservation 54:419–31. 

Bender-Keigley, Janet. 2008. Landowners’ guide 

to eastern Montana wetlands and grasslands. 

Montana Watercourse. <www.mtwatercourse.

org/publications/Publications.htm> [access date 

unknown].

Bengston, David N. 1994. Changing forest values 

and ecosystem management. Society and Natural 

Resources 7:515–33. 

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