Comprehensive Conservation Plan

Sullys Hill National Game Preserve

Comprehensive Conservation Plan Approval 

Sullys Hill National Game Preserve

Contents 

Summary ..................................................................................................................... ix

Abbreviations ............................................................................................................... xii

1 Introduction ............................................................................................................ 1

1.1 Purpose and Need for the Plan .................................................................................

1.2 The U.S. Fish and Wildlife Service and the Refuge System .............................................

1.3 National and Regional Mandates ..............................................................................

1.4 Refuge Contributions to National and Regional Plans ...................................................

1.5 Ecosystem Description and Threats ...........................................................................

1.6 Planning Process ...................................................................................................

 1

 3

 4

 4

 7

 7

2 The Refuge ............................................................................................................... 13

2.1 Establishment, Acquisition, and Management History ...................................................

2.2 Special Values of the Refuge ....................................................................................

2.3 Purpose ...............................................................................................................

2.4 Vision ..................................................................................................................

 13

 14

 14

 15

2.5 Goals .................................................................................................................. 15

2.6 Planning Issues ...................................................................................................... 16

 3 Refuge Resources and Description ........................................................................... 19

3.1 Physical Environment .............................................................................................

3.2 Biological Resources .............................................................................................

3.3 Cultural Resources ................................................................................................

 22

 24

 30

3.4 Special Management Areas ....................................................................................

3.5 Visitor Services ...................................................................................................

31

31

3.6 Socioeconomic Environment .................................................................................... 32

3.7 Operations ............................................................................................................ 33

4 Management Direction ............................................................................................. 35

4.1 Management Focus ................................................................................................

4.2 Goals, Objectives, Strategies, and Rationale ...............................................................

Prairie Habitat Goal .............................................................................................

 35

 36

36

Woodland Habitat Goal .......................................................................................... 41

Wildlife Population Management Goal .....................................................................

Environmental Education, Interpretation, and Outreach Goal .......................................

Visitor Services Goal .............................................................................................

44

49

51

Protection and Maintenance Goal ........................................................................... 54

4.3 Staffing and Funding .............................................................................................

4.4 Partnerships .........................................................................................................

4.5 Step-down Management Plans .................................................................................

4.6 Monitoring and Evaluation .......................................................................................

 55

55

55

56

Glossary ........................................................................................................................ 59

Appendices

A. Key Legislation and Policies ....................................................................................

B. Preparers ...............................................................................................................

C. Public Involvement ................................................................................................

65

69

71

D. Section 7 Biological Evaluation ................................................................................. 75
vi CCP, Sullys Hill National Game Preserve, ND

E. Environmental Compliance ....................................................................................... 79

F. Species List ............................................................................................................ 81 

G. Fire Management Program ....................................................................................... 93

H. Compatibility Determinations .................................................................................... 97

Bibliography ..................................................................................................................101
List of Figures and Tables

FIGURES

 1 Vicinity map for Sullys Hill National Game Preserve, North Dakota ........................... 2

 2 Physiographic areas of the United States ............................................................... 6

 3 Mississippi Headwaters/Tall-grass Prairie ecosystem map ....................................... 8

 4 Steps in the planning process .............................................................................. 9

 5 Sullys Hill National Game Preserve boundary map ................................................... 20

 6 Sullys Hill National Game Preserve management units ............................................. 21

 7 Vegetative communities within Sullys Hill National Game Preserve ........................... 25

 8 Sullys Hill National Game Preserve visitor services map .......................................... 53 

TABLES

 1 Planning process summary and timeline for Sullys Hill National Game Preserve ............ 10

 2 Current and proposed staff for Sullys Hill National Game Preserve ........................... 56

 3 Step-down management plans for Sullys Hill National Game Preserve ........................ 57

 

Summary

This is a summary of the comprehensive conservation 

plan developed by the U.S. Fish and Wildlife Service 

for the Sullys Hill National Game Preserve in Benson 

County, North Dakota. This plan, approved in 2008, 

will guide management of the refuge for the next 

15 years. The National Wildlife Refuge System 

Improvement Act of 1997 requires the U.S. Fish 

and Wildlife Service to develop a comprehensive 

conservation plan by 2012 for each national wildlife 

refuge in the National Wildlife Refuge System. This 

brief summary describes the refuge and its purposes, 

the planning process, and the comprehensive 

conservation plan.

THE REFUGE AND ITS PURPOSE

Sullys Hill National Game Preserve is a 1,675-acre 

national wildlife refuge sitting on the south shores 

of Devils Lake, about 10 miles south of the city of 

Devils Lake, North Dakota. The refuge was first 

established on April 27, 1904, as a national park, 

but was later transferred to the Service in 1921 as 

a national wildlife refuge. This refuge supports a 

unique community of habitats such as an oak, ash, 

basswood, and aspen woodland; and mixed-grass 

prairie, interspersed with some natural and created 

wetlands. These diverse habitats create a large 

ecotone that provides “edge” habitat for over 250 

species of migratory birds, plains bison, Rocky 

Mountain elk, white-tailed deer, turkeys, and prairie 

dogs. 

The refuge is 1 of only 19 designated natural areas in 

North Dakota, of which only 4 are national wildlife 

refuges. It is also one of only four refuges established 

for national bison conservation.

Sullys Hill National Game Preserve has a long 

history of visitation with over 60,000 annual visitors, 

making it the most visited refuge in North Dakota. 

The refuge is becoming a progressive regional 

conservation learning center, promoting the 

conservation role of the National Wildlife Refuge 

System while educating visitors about the functions 

and benefits of the refuge and the surrounding 

prairie wetlands and grasslands. The refuge uses 

both indoor and outdoor education with a focus on the 

sciences, biodiversity, and human dimensions in the 

environment, providing area educators a unique tool 

to make learning exciting, interesting, and effective. 

According to the refuge’s legislative purposes, there 

is no hunting permitted.

Every refuge has a purpose for which it was 

established. These purposes, found in legislative acts 

or administrative orders, are the foundation upon 

which to build all refuge programs, from biology and 

public use, to maintenance and facilities. No action 

that the Service or public takes may conflict with 

these purposes. 

The purposes for Sullys Hill National Game Preserve 

are described in the following legislation and public 

land orders:

Q “All the lands that are now reserved or may 

hereafter be included within the boundaries of 

the ... Sullys Hill National Park Game Preserve 

... are hereby further reserved and set apart 

for the use ... as refuges and breeding grounds 

for birds.” (Executive Order 3596, December 21, 

1921)

Q “As a big game preserve, refuge, and breeding 

grounds for wild animals and birds ... provided, 

that the said game preserve is to be made 

available to the public for recreational purposes 

in so far as consistent with the use of this area 

as a game preserve ... provided further, that 

hunting shall not be permitted on said game 

preserve.” (46 Stat. 1509, Act of March 3, 1931)

VISION STATEMENT

The vision for Sullys Hill National Game Preserve 

is based on the establishing purposes of the refuge, 

resource conditions and potential, and the issues. 

Entrance sign for Sullys Hill National Game Preserve.

USFWS
x CCP, Sullys Hill National Game Preserve, ND

Overlooking North Dakota’s largest natural 

lake and riding the tops of a glacial thrust 

block formation, Sullys Hill National Game 

Preserve is dressed in undulating native 

woodlands and prairie. Teddy Roosevelt’s 

vision and broad community support 

are largely responsible for the successful 

conservation of these habitats ensuring the 

preservation of the refuge’s plains bison 

and Rocky Mountain elk while supporting 

migrating waves of warblers and other 

native bird species. 

Sullys Hill National Game Preserve is 

renowned as a regional conservation 

learning center—greeting families, 

students, and outdoor enthusiasts of all 

abilities. Children are able to learn about 

their natural world using all their senses, 

which fosters their own environmental 

ethics. Each visitor’s experience not only 

enriches their personal lives, but instills 

a unique understanding and appreciation 

for preserving native prairie and wetland 

habitats, the natural resources of the 

Devils Lake Basin, and the mission of the 

National Wildlife Refuge System to preserve 

America’s wildlife heritage.

GOALS

The goals described below reflect the vision for 

Sullys Hill National Game Preserve.

Prairie Habitat Goal

Maintain prairie plant communities representative of 

the historical mixed-grass prairies to support healthy 

populations of grassland-dependent migratory birds 

in balance with bison, elk, and other indigenous 

wildlife.

Woodland Habitat Goal

Manage for healthy native woodlands of various 

age classes and structure to provide habitat for 

migratory birds in balance with bison, elk, and other 

indigenous wildlife.

Wildlife PoPulation ManaGeMent Goal

Carry out management practices that ensure healthy 

populations of Rocky Mountain elk, plains bison, and 

other indigenous wildlife species that exemplify the 

genetic integrity of historical prairie wildlife.

E

Deliver quality, interactive environmental education 

programming to regional schools, communities, 

organizations, Spirit Lake Nation, and local 

governments to garner support and appreciation 

for Sullys Hill National Game Preserve, North 

Dakota’s wetland and grassland resources, and 

the conservation role of the U.S. Fish and Wildlife 

Service.

V

Provide captivating visitor services facilities and 

activities for visitors of all abilities, community 

groups, youth groups, and the members of Spirit 

Lake Nation to provide enjoyment that results 

in a greater understanding and support of the 

preservation of native habitats and landscapes of 

North Dakota’s Prairie Pothole Region and the 

mission of the Refuge System.

Protection and Maintenance Goal

Refuge visitors, staff, and volunteers will have a 

safe, protected, and well-maintained environment 

in which to learn about, work with, understand, and 

appreciate the importance of protecting the unique 

natural and cultural resources of Sullys Hill National 

Game Preserve.

PLANNING PROCESS

In 2006, a planning team of refuge and other 

Service staff gathered to begin planning the future 

direction of Sullys Hill National Game Preserve. 

The planning process included designing a vision 

for the refuge, along with goals to reach that vision. 

The team invited the public to participate in the 
Summary xi

planning process. A mailing list of about 320 names 

was created which included private citizens; local, 

regional, and state government representatives 

and legislators; other federal agencies; tribal 

governments; and nonprofit organizations. Key issues 

(habitat, wildlife, public outreach, public use, and 

refuge operations) were identified during analysis 

of the concerns raised by refuge staff, partners, and 

the public. The unique qualities and values of the 

refuge were also determined. The team identified 

which of these qualities and issues were crucial to 

achieving the vision and goals. These were addressed 

throughout the planning process and in the 

comprehensive conservation plan. Three alternatives 

were developed for addressing substantive issues 

and managing refuge programs. Through the 

environmental analysis process, the Service has 

selected alternative C from the draft conservation 

plan and environmental assessment, published 

in June 2008. This alternative is now the final 

comprehensive conservation plan. Implementation 

of this plan will be monitored throughout its 15-year 

effective period.

ISSUES

Because of its location, serving as a conservation 

learning center is an important designation and 

direction for this refuge. Yet, even though the refuge 

hosts 60,000 visitors annually, there is minimal 

law enforcement presence. There has been some 

vandalism, including fires set on refuge lands. Given 

the small staff size and budget, numerous habitat 

needs have not been addressed, including promoting 

forest regeneration, plant inventories, habitat health, 

invasive species, and disease management. Invasive 

species such as brome and bluegrass need to be 

reduced and native species restored. Also, there 

needs to be a better understanding of the carrying 

capacity of the area to support the populations of 

bison, elk, and white-tailed deer to ensure that forest 

and prairie management can improve migratory bird 

production.

EXPECTED OUTCOMES OF THE PLAN

This comprehensive conservation plan is designed 

to optimize the biological potential for big game and 

migratory birds while creating an inviting place 

for visitors to enjoy and learn about the refuge’s 

resources, the National Wildlife Refuge System, and 

the importance of conserving prairie wetlands and 

grasslands. This refuge will serve as an outreach tool 

for the Devils Lake Wetland Management District 

and its habitat protection programs, while serving as 

a conservation learning center in this region. 

Habitat and Wildlife ManaGeMent

Habitat management will address enhancing and 

restoring native prairie habitat, and promoting 

forest regeneration. Ungulate populations will be 

maintained at lower levels (≤20 bison, ≤18 elk, and 

≤18 white-tailed deer) to control the overgrazing 

and overbrowsing that has impacted refuge habitats 

in the past. Management tools, including exclusion 

fences and other appropriate methods such as 

chemical, biological, and mechanical techniques 

(including prescribed fire), will be used to restore 

and enhance habitat for the benefit of forest interior 

breeding and grassland nesting birds. Selected 

hayland acres will be restored to native vegetation. 

Fuels treatment (including prescribed fire or other 

mechanical means) will also be used to reduce 

hazardous fuels, minimizing the threat to life and 

property. Invasive species will be treated and 

areas restored. The ungulate herd health program 

will take a more active disease surveillance and 

treatment approach, including timely introduction 

of ungulates to maintain genetic health, particularly 

for the refuge’s plains bison. A biologist trainee 

will be recruited to conduct the refuge’s biological, 

management, and restoration programs. 

V

There will be an increase in delivery of both on- and 

off-site programming of youth environmental 

education programs. In cooperation with local 

teachers, a formal wetland and grassland 

conservation curriculum will be designed for targeted 

grade levels and will meet local and state standards. 

Emphasis will be placed on developing education 

partnerships with Spirit Lake Nation schools and 

agencies and recruiting students for careers in refuge 

management. The refuge’s limited fishery will be 

used for environmental education programs only. A 

comprehensive cultural resource survey of the refuge 

will be completed in partnership with other agencies 

and organizations, and the area’s cultural history 

will be interpreted in a visitor center display. One 

additional staff person, an environmental education 

specialist, will be recruited to assist with the design 

and implementation of these expanded programs. 

Protection and Maintenance

Visitor, staff, facility, and wildlife safety will be 

improved through year-round patrols by a full-time 

law enforcement officer. Facilities will be maintained 

and the refuge roads will remain open all year 

through the addition of a full-time maintenance 

worker.
Abbreviations

Administration Act National Wildlife Refuge System Administration Act

amsl above mean sea level

CCP comprehensive conservation plan

CO2 carbon dioxide

CFR Code of Federal Regulations

CWCS comprehensive wildlife conservation strategy

CWD chronic wasting disease

DNC dense nesting cover

EA environmental assessment

EPA Environmental Protection Agency

F Fahrenheit

FMP fire management plan

GIS Geographic Information System

Improvement Act National Wildlife Refuge System Improvement Act of 1997

IPM integrated pest management

NAWMP North American Waterfowl Management Plan

ND North Dakota

NDGF North Dakota Game and Fish Department

NDSU North Dakota State University

NEPA National Environmental Policy Act

NHPA National Historic Preservation Act

NOA notice of availability

NOI notice of intent

NRCS Natural Resources Conservation Service (USDA)

PL public law

refuge Sullys Hill National Game Preserve

Refuge System National Wildlife Refuge System

Service U.S. Fish and Wildlife Service

spp. species (plural)

SWG state wildlife grant

UND University of North Dakota

USC United States Code

USDA U.S. Department of Agriculture

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey 

VOR visual obstruction reading

WG wage grade pay schedule (civil service employees) 

WPA wetlands production area

WUI wildland-urban interface

YCC Youth Conservation Corps

Definitions of these and other terms are in the glossary, located after Chapter 4.
1 Introduction

Birders

Scott Ralston/USFWS

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

developed this comprehensive conservation plan 

(CCP) to provide a foundation for the management 

and use of Sullys Hill National Game Preserve, 

which is located in Benson County near the town 

of Fort Totten, North Dakota (see figure 1, vicinity 

map). This CCP will serve as a working guide for 

management programs and actions over the next 15 

years. This chapter provides an introduction to the 

CCP process and describes the involvement of the 

Service, the state of North Dakota, the public, and 

others, as well as conservation issues and plans that 

affect Sullys Hill National Game Preserve.

This CCP was developed in compliance with the 

National Wildlife Refuge System Improvement Act 

of 1997 (Improvement Act) and Part 602 (National 

Wildlife Refuge System Planning) of “The Fish and 

Wildlife Service Manual.” The actions described in 

this CCP meet the requirements of the Council on 

Environmental Quality regulations that implement 

the National Environmental Policy Act of 1969 

(NEPA). Compliance with NEPA is also being 

achieved through involvement of the public.

The CCP specifies the necessary actions to achieve 

the vision and purposes of the refuge. Wildlife is 

the first priority in refuge management, and visitor 

services (wildlife-dependent recreation) are allowed 

and encouraged as long as they are compatible with 

the refuge’s purposes. 

This CCP has been prepared by a planning team 

comprised of representatives from various Service 

programs. In addition, the planning team used public 

input, public involvement, and the planning process 

as described in section 1.6, “Planning Process.”

After reviewing a wide range of public comments 

and management needs, the planning team 

developed alternatives for managing the refuge. 

This was documented in the “Draft Comprehensive 

Conservation Plan and Environmental Assessment—

Sullys Hill National Game Preserve.” The regional 

director of region 6 selected alternative C as the 

Service’s preferred alternative for management of 

the refuge. This action addressed all substantive 

issues, while determining how best to achieve the 

purposes of the refuge. 

1.1 PURPOSE AND NEED FOR THE PLAN

The purpose of this CCP is to identify the role 

that Sullys Hill National Game Preserve will play 

in support of the mission of the National Wildlife 

Refuge System (Refuge System) and to provide 

long-term guidance for management of refuge 

programs and activities. The CCP is needed

Q to communicate with the public and other 

partners in order to carry out the mission of the 

Refuge System;

Q to provide a clear statement of direction for 

management of the refuge;
2 CCP, Sullys Hill National Game Preserve, ND

Figure 1. Vicinity map for Sullys Hill National Game Preserve, North Dakota.
Chapter 1 — Introduction 3

Q to provide neighbors, visitors, and government 

officials with an understanding of the Service’s 

management actions on and around the refuge;

Q to ensure that the Service’s management 

actions are consistent with the mandates of the 

Improvement Act;

Q to ensure that management of the refuge is 

consistent with federal, state, and county plans; 

Q to provide a basis for development of 

budget requests for the refuge’s operation, 

maintenance, and capital improvement needs.

Sustaining the nation’s fish and wildlife resources 

is a task that can be accomplished only through the 

combined efforts of governments, businesses, and 

private citizens. 

1.2 U.S. FISH AND WILDLIFE SERVICE 

AND THE REFUGE SYSTEM

The Service is the principal federal agency 

responsible for fish, wildlife, and plant conservation. 

The Refuge System is one of the Service’s major 

programs. 

U

The mission of the U.S. Fish and Wildlife Service, 

working with others, is to conserve, protect, and 

enhance fish and wildlife and their habitats for 

the continuing benefit of the American people.

Over a century ago, America’s fish and wildlife 

resources were declining at an alarming rate. 

Concerned citizens, scientists, and hunting and 

angling groups joined together to restore and sustain 

America’s national wildlife heritage. This was the 

genesis of the U.S. Fish and Wildlife Service. 

Today, the Service enforces federal wildlife laws, 

manages migratory bird populations, restores 

nationally significant fisheries, conserves and 

restores vital wildlife habitat, protects and recovers 

endangered species, and helps other governments 

with conservation efforts. In addition, the Service 

administers a federal aid program that distributes 

hundreds of millions of dollars to states for fish and 

wildlife restoration, boating access, hunter education, 

and related programs across America. 

S

Service activities in North Dakota contribute to 

the state’s economy, ecosystems, and education 

programs. The following list describes the Service’s 

presence and activities:

Q employed 201 people in North Dakota

Q assisted by 623 volunteers who donated more 

than 14,245 hours in support of Service projects

Q managed two national fish hatcheries and one 

fish and wildlife management assistance office

Q managed 65 national wildlife refuges 

encompassing 342,799 acres (0.8% of the state)

Q managed 12 wetland management districts 

including

— 284,317 acres of fee waterfowl production 

areas (0.6% of the state)

— 1,046,358 wetland acres under various leases 

or easements (2.4% of the state)

Q hosted more than 394,063 annual visitors to 

Service-managed lands including

— 152,160 hunting visits

— 2,360 trapping visits 

— 83,650 fishing visits

— 142,281 wildlife observation visits

— environmental education programs for over 

51,000 students

Q provided $3.3 million to North Dakota Game 

and Fish Department (NDGF) for sport 

fish restoration and $3.4 million for wildlife 

restoration and hunter education

Q helped private landowners restore more than 

191,225 acres on 4,464 sites and restore 47.8 

miles of river since 1987, through the Partners 

for Wildlife Program

Q employed 11 Partners for Wildlife Program 

managers

Q paid North Dakota counties $352,271 under the 

Refuge Revenue Sharing Act (money used for 

schools and roads)

N

In 1903, President Theodore Roosevelt designated 

the 5.5-acre Pelican Island in Florida as the nation’s 

first wildlife refuge for the protection of brown 

pelicans and other native, nesting birds. This was the 

first time the federal government set aside land for 

wildlife. This small but significant designation was 

the beginning of the Refuge System. 

One hundred years later, the Refuge System has 

become the largest collection of lands in the world 

specifically managed for wildlife. It encompasses over 

96 million acres within 547 refuges and more than 

3,000 small areas for waterfowl breeding and nesting. 

Today, there is at least one refuge in every state, 

including the territories of Puerto Rico and the U.S. 

Virgin Islands. 

In 1997, the Improvement Act established a clear 

mission for the Refuge System. 
4 CCP, Sullys Hill National Game Preserve, ND

The mission of the National Wildlife Refuge 

System is to administer a national network 

of lands and waters for the conservation, 

management, and where appropriate, restoration 

of the fish, wildlife and plant resources and their 

habitats within the United States for the benefit of 

present and future generations of Americans.

The Improvement Act states that each national 

wildlife refuge (that is, each unit of the Refuge 

System, which includes wetland management 

districts) shall be managed

Q to fulfill the mission of the Refuge System;

Q to fulfill the individual purposes of each refuge;

Q to consider the needs of fish and wildlife first;

Q to fulfill the requirement of developing a CCP 

for each unit of the Refuge System and fully 

involve the public in the preparation of these 

plans;

Q to maintain the biological integrity, diversity, 

and environmental health of the Refuge 

System;

Q to recognize that wildlife-dependent recreation 

activities including hunting, fishing, wildlife 

observation, wildlife photography, and 

environmental education and interpretation, are 

legitimate and priority public uses;

Q to retain the authority of refuge managers to 

determine compatible visitor services.

In addition to the mission for the Refuge System, the 

wildlife and habitat vision for each unit of the Refuge 

System stresses the following principles:

Q Wildlife comes first.

Q Ecosystems, biodiversity, and wilderness are 

vital concepts in refuge management.

Q Habitats must be healthy.

Q Growth of refuges must be strategic.

Q The Refuge System serves as a model for 

habitat management with broad participation 

from others.

Following passage of the Improvement Act, the 

Service immediately began to carry out the direction 

of the new legislation, including preparation of 

CCPs for all national wildlife refuges and wetland 

management districts. Consistent with the 

Improvement Act, the Service prepares all CCPs in 

conjunction with public involvement. Each refuge is 

required to complete its CCP within a 15-year time 

frame (by 2012).

PeoPle and tHe refuGe systeM

The nation’s fish and wildlife heritage contributes to 

the quality of American lives and is an integral part 

of the country’s greatness. Wildlife and wild places 

have always given people special opportunities to 

have fun, relax, and appreciate the natural world. 

Whether through bird watching, fishing, hunting, 

photography, or other wildlife pursuits, wildlife 

recreation contributes millions of dollars to local 

economies. In 2002, approximately 35.5 million 

people visited the Refuge System, mostly to observe 

wildlife in their natural habitats. Visitors are most 

often accommodated through nature trails, auto 

tours, interpretive programs, and hunting and 

fishing opportunities. Significant economic benefits 

are generated for the local communities that 

surround refuges and wetland management districts. 

Economists report that Refuge System visitors 

contribute more than $792 million annually to local 

economies. 

1.3 NATIONAL AND REGIONAL 

MANDATES 

Refuge System units are managed to achieve the 

mission and goals of the Refuge System, along with 

the designated purpose of the refuges (as described 

in establishing legislation, executive orders, or 

other establishing documents). Key concepts and 

guidance for the Refuge System are in the National 

Wildlife Refuge System Administration Act of 1966 

(Administration Act), Title 50 of the Code of Federal 

Regulations (CFR), “The Fish and Wildlife Service 

Manual,” and the Improvement Act. 

The Improvement Act amends the Administration 

Act by providing a unifying mission for the Refuge 

System, a new process for determining compatible 

visitor services on refuges, and a requirement 

that each refuge be managed under a CCP. The 

Improvement Act states that wildlife conservation 

is the priority of Refuge System lands and that 

the Secretary of the Interior will ensure that the 

biological integrity, diversity, and environmental 

health of refuge lands are maintained. Each refuge 

must be managed to fulfill the Refuge System’s 

mission and the specific purposes for which it was 

established. The Improvement Act requires the 

Service to monitor the status and trends of fish, 

wildlife, and plants in each refuge. 

A detailed description of these and other laws and 

executive orders that may affect the CCP or the 

Service’s implementation of the CCP is in appendix 

A. Service policies on planning and day-to-day 

management of refuges are in the “Refuge Manual” 

and “The Fish and Wildlife Service Manual.”

1.4 REFUGE CONTRIBUTIONS TO 

NATIONAL AND REGIONAL PLANS

Sullys Hill National Game Preserve contributes to 

the conservation efforts described here.
Chapter 1 — Introduction 5

F

A 1999 report, “Fulfilling the Promise, The 

National Wildlife Refuge System” (USFWS 1999), 

is the culmination of a yearlong process by teams 

of Service employees to evaluate the Refuge 

System nationwide. This report was the focus of 

the first national Refuge System conference in 

1998—attended by refuge managers, other Service 

employees, and representatives from leading 

conservation organizations. 

The report contains 42 recommendations packaged 

with three vision statements dealing with wildlife 

and habitat; people; and leadership—this CCP deals 

with these three major topics. The planning team 

reviewed the recommendations in the report for 

guidance during CCP planning. 

Partners in fliGHt

The “Partners in Flight” program began in 1990 with 

the recognition of declining population levels of many 

migratory bird species. The challenge is, according 

to the program, maintaining functional natural 

ecosystems in the face of human population growth. 

To meet this challenge, Partners in Flight worked to 

identify priority land bird species and habitat types. 

Partners in Flight activities have resulted in the 

development of 52 bird conservation plans covering 

the continental United States.

The primary goal of Partners in Flight is to provide 

for the long-term health of the bird life of this 

continent. The first priority is to prevent the rarest 

species from becoming extinct. The second priority 

is to prevent uncommon species from descending 

into threatened status. The third priority is to “keep 

common birds common.” 

There are 58 physiographic areas, defined by similar 

physical geographic features, wholly or partially 

contained within the contiguous United States, 

and several others wholly or partially contained in 

Alaska. The Sullys Hill National Game Preserve 

lies within the physiographic area known as the 

northern mixed-grass prairie, area 37 (see figure 2, 

physiographic areas). 

The northern mixed-grass prairie physiographic 

area includes almost the entire eastern half of South 

Dakota and central North Dakota, from the Red 

River Valley on the east, to the Missouri River and 

Montana border on the south and west. In Canada, 

it includes a small portion of southern Manitoba and 

a swath that crosses Saskatchewan and extends into 

Alberta. The southern edge of this physiographic 

area is the terminus of a glacial moraine parallel 

to the course of the nearby Missouri River. To the 

north, prairie gives way to aspen parkland. 

Precipitation declines and evaporation rates 

increase from east to west across the northern 

mixed-grass prairie, resulting in differences in the 

height of dominant grasses. To the east, the mixed 

grass begins as topography rises out of the tallgrass prairie of the Red River Valley. Grass height 

gradually decreases toward the western boundary of 

this physiographic area. 

Because of the glacial history of the northern 

mixed-grass prairie and the relationship between 

precipitation and evapotranspiration, the area is 

dotted with thousands of depressions that range from 

permanently to periodically wet. This area is known 

as the Prairie Pothole Region. 

Priority bird species and habitats of the northern 

mixed-grass prairie include the following:

Grassland

Baird’s sparrow

greater prairie-chicken

McCown’s longspur

Sprague’s pipit

Le Conte’s sparrow

Wetland

yellow rail

Nelson’s sharp-tailed sparrow

marbled godwit

Riparian Woodland

Bell’s vireo

River Sandbars

piping plover

waterfowl

shorebirds

Maintenance of large, unfragmented grassland 

ecosystems is the conservation objective for areas 

where agriculture is not dominant. On the drift 

prairie and other agricultural areas, conservation of 

discrete blocks of grassland-wetland complexes is 

recommended. 

N

Written in 1986, the “North American Waterfowl 

Management Plan” (NAWMP) (USFWS et al. 1998) 

envisioned a 15-year effort to achieve landscape 

conditions that could sustain waterfowl populations. 

Specific NAWMP objectives are to increase and 

restore duck populations to the average levels of the 

1970s—62 million breeding ducks and a fall flight of 

100 million birds. 

By 1985 waterfowl populations had plummeted 

to record lows. Habitat that waterfowl depend on 

was disappearing at a rate of 60 acres per hour. 

Recognizing the importance of waterfowl and 

wetlands to North Americans and the need for 

international cooperation to help in the recovery of a 
6 CCP, Sullys Hill National Game Preserve, ND

shared resource, the United States and Canadian 

governments developed a strategy to restore 

waterfowl populations through habitat protection, 

restoration, and enhancement. Mexico became a 

signatory to the plan in 1994. 

The plan is innovative because of its international 

scope, plus its implementation at the regional 

level. Its success depends on the strength 

of partnerships called “joint ventures,” 

involving federal, state, provincial, tribal, and 

local governments; businesses; conservation 

organizations; and individual citizens. Joint 

ventures are regional, self-directed partnerships 

that carry out science-based conservation projects 

through a wide array of community participation 

efforts. Joint ventures develop implementation 

plans focusing on areas of concern. Sullys Hill 

National Game Preserve is part of the “Prairie 

Pothole Joint Venture.”

Figure 2. Physiographic areas of the United States. (Source: Partners in Flight)

R

Where federally listed threatened or endangered 

species occur at the Sullys Hill National Game 

Preserve, management goals and strategies in 

their respective recovery plans will be followed. 

The list of threatened or endangered species 

that occur at the refuge will change as species 

are listed or delisted, or as listed species are 

discovered on refuge lands. Currently, 8 species 

of fish, 15 species of birds, 6 species of mammals, 

4 species of reptiles, 6 species of insects, 4 species 

of mollusks, and 7 species of plants native to 

the ecosystem are listed as either threatened 

or endangered, or are under status review for 

possible listing. If these species are ever found 

residing on the refuge, the staff will follow recovery 

plan guidelines.

S

Over the past several decades, declines of wildlife 

populations have been documented nationwide. 

Congress created the State Wildlife Grant (SWG) 

program in 2001. This program provides states 

and territories with federal dollars to support 

conservation aimed at protecting wildlife and 

preventing species from becoming endangered under 

the Endangered Species Act. The SWG program 

represents an ambitious endeavor to take an active 

hand in keeping species from becoming threatened or 

endangered in the future. 

According to the SWG program, each state, territory, 

and the District of Columbia were required to 

complete a comprehensive wildlife conservation 

strategy (CWCS) by October 1, 2005, in order to 

receive future funding. 

These strategies help define an integrated approach 

to the stewardship of all wildlife species, with 

additional emphasis on species of concern and 

habitats at risk. The goal is to shift focus from singlespecies management and highly specialized individual 

efforts to a geographically based, ecosystem and 

landscape-oriented fish and wildlife conservation 

effort. The Service approves CWCSs and administers 

SWG program funding. 

The CWCS for the state of North Dakota was 

reviewed and this information was used during 
Chapter 1 — Introduction 7

development of this CCP. Implementation of CCP 

habitat goals and objectives will support the goals 

and objectives of the CWCS.

1.5 ECOSYSTEM DESCRIPTION AND 

THREATS

MississiPPi HeadWaters/tall-Grass Prairie

ecosysteM

Sullys Hill National Game Preserve is located within 

the “Mississippi Headwaters/Tall-grass Prairie 

Ecosystem” (figure 3). This ecosystem—primarily 

located in Minnesota, South Dakota, and North 

Dakota, with small sections extending into Wisconsin 

and Iowa—encompasses a major portion of the 

Prairie Pothole Region of North America. The 

Prairie Pothole Region annually produces 20% of the 

continental waterfowl populations.

Historically, this portion of North America was 

subject to periodic glaciation. Glacial meltwaters 

were instrumental in forming the five major river 

systems located or partly located within this 

ecosystem: Minnesota, Mississippi, Missouri, Red, 

and St. Croix river systems. Glacial moraines 

and other deposits resulted in a myriad of lakes 

and wetlands common throughout this area. This 

significant variation in topography and soils attest 

to the ecosystem’s dynamic glacial history.

The three major ecological communities within 

this ecosystem are tall-grass prairie, northern 

boreal forest, and eastern deciduous forest. Grasses 

common to tall-grass prairie include big bluestem, 

little bluestem, Indiangrass, sideoats grama, and 

switchgrass. In addition, native tall-grass prairie 

supports ecologically important forbs such as prairie 

coneflower, purple prairie clover, and blazing star. 

The northern boreal forest comprises a variety 

of coniferous species such as jack pine, balsam fir, 

and spruce. Common tree species in the eastern 

deciduous forest include maple, basswood, red 

oak, white oak, and ash. Due to its ecological and 

vegetative diversity, the “Mississippi HeadwatersTall-grass Prairie Ecosystem” supports at least 121 

species of Neotropical migrants and other migratory 

birds. It provides breeding and migration habitat for 

significant populations of waterfowl, plus a variety 

of other waterbirds. The ecosystem supports several 

species of candidate and federally listed threatened 

and endangered species including bald eagle, piping 

plover, Higgins eye pearly mussel, Karner blue 

butterfly, prairie bushclover, Leedy’s roseroot, 

dwarf troutlily, and western prairie fringed orchid. 

Additionally, the increasingly rare paddlefish and 

lake sturgeon are found in portions of this ecosystem.

Current land uses range from tourism and timber 

industries in the northern forests to intensive 

agriculture in the historical tall-grass prairie. Of the 

three major ecological communities, tall-grass prairie 

is the most threatened, with more than 99% having 

been converted for agricultural purposes. Other major 

industrial developments include logging, mining, and 

hydroelectric development. Management of old growth 

and late-succession forests to make up for reduced 

timber harvests, and a focus on smarter energy 

solutions, head the priorities for this ecosystem.

1.6 PLANNING PROCESS

This CCP for Sullys Hill National Game Preserve 

was developed in compliance with the Improvement 

Act, NEPA, and the implementing regulations of 

both acts. The Service issued its Refuge System 

planning policy in 2000, which established requirements 

and guidance for refuge plans—including CCPs and 

step-down management plans—to ensure that planning 

efforts comply with the Improvement Act. The 

planning policy identified several steps of the CCP 

and environmental analysis process (see figure 4, 

steps in the planning process).

Table 1 lists the specific steps in the planning process 

for the preparation of this CCP. The Service began 

the pre-planning process in January 2006 with the 

establishment of a planning team (see appendix B). 

The planning team is comprised primarily of Service 

personnel from the Devils Lake Wetland Management 

District (the managing station). Other partners 

include other Service divisions, the Spirit Lake 

Nation Tribe, NDGF, North Dakota Forest Service, 

Natural Resource Conservation Service (NRCS), 

North Dakota Bureau of Animal Health, local 

teachers, and researchers at the University of North 

Dakota. 

During pre-planning, the team developed a mailing 

list, a list of internal issues, and a special qualities 

list. The team also identified and reviewed current 

refuge programs; compiled and analyzed relevant 

data; and determined the purpose of the refuge. In 

May of 2006 a notice of intent (NOI) was published 

in the Federal Register to notify the public of this 

planning process and to invite them to comment. 

The planning team met with many experts from 

the Service and other state, tribal, and federal 

agencies to evaluate existing refuge programs. This 

information was used to develop three separate 

alternatives designed to address issues and guide 

future refuge management. The environmental 

consequences of these three alternatives were 

evaluated and a draft CCP and final EA were 

prepared. This document was then reviewed 

internally by a group of Service, state, and tribal 

employees. The document was revised based on some 

of their comments. 

In June 2008, the Service published a notice of 

availability (NOA) announcing that the Draft CCP 

and EA was available for a 30-day public review. 

Hard copies of the document and/or a planning 

update, summarizing the plan, were mailed to 238 
8 CCP, Sullys Hill National Game Preserve, ND

Figure 3. Mississippi Headwaters/Tall-grass Prairie ecosystem map.
Chapter 1 — Introduction 9

federal, state, and local agencies; organizations; 

and citizens. The document was also posted on the 

region 6 website. A summary of the comments and 

responses can be found in appendix C. An intraService Section 7 evaluation was completed on the 

document by the Service’s ecological services office to 

evaluate any impacts to threatened and endangered 

species (appendix D). The regional director reviewed 

the document, the analysis of alternatives, and all 

public comments. He selected alternative C as the 

preferred alternative for the final CCP. Subsequently, 

the draft CCP was modified in accordance with 

substantive public comments to produce this final 

CCP, which the regional director approved in 

August 2008 after documentation of a “finding of no 

significant impact” (see appendix E).

1. PREPLANNING:

 Plan the Plan 2. INITIATE PUBLIC INVOLVEMENT 

 AND SCOPING

 —Involve the public

8. REVIEW AND REVISE PLAN

 —Public involvement 

 when applicable

6. PREPARE AND ADOPT

 FINAL PLAN

 —Respond to public comment

 —Select preferred alternative 5. PREPARE DRAFT 

 PLAN AND NEPA 

 DOCUMENT

 —Public comment 

 and review

3. DRAFT VISION

 STATEMENT AND GOALS

 AND DETERMINE 

 SUBSTANTIVE ISSUES

4. DEVELOP AND ANALYZE

 ALTERNATIVES

 —Create a reasonable range

 of alternatives including a

 no-action alternative

The

Comprehensive

Conservation

Planning Process and

NEPA Compliance

7. IMPLEMENT PLAN, 

 MONITOR, AND EVALUATE

 —Public involvement

 when applicable

Figure 4. Steps in the planning process.
10 CCP, Sullys Hill National Game Preserve, ND

Table 1. Planning process summary and timeline for Sullys Hill National Game Preserve.

Date Event Outcome

June 23, 2005 Forest management review. Forest management program review with the 

ND Forest Service, NRCS, and Service staff.

January 26, 2006 Kickoff meeting.

CCP overview; planning team list finalized; 

purposes identified; initial issues and qualities 

list developed; development of mailing list 

started. Biological and mapping needs identified; 

public scoping planned.

May 1, 2006 Vision statement.

Worked with team members, including NDGF, 

to develop first draft of vision statement for 

CCP.

May 23, 2006 NOI. NOI published in Federal Register initiating 

public scoping.

June 8, 2006 Planning update.

First planning update sent to mailing list 

describing planning process and announcing 

upcoming public scoping meeting.

June 15, 2006 Focus group meeting (woodland birds).

Discussed woodland bird habitat needs and 

impacts of grazing by bison (Service nongame 

biologists).

June 17, 2006 Sullys Hill National Game Preserve 

Annual Birding Festival. 

Presentations and displays reach over 1,200 

attendees at the annual birding festival.

June 29, 2006 Public meeting, Sullys Hill National 

Game Preserve visitor center.

Public opportunity offered to learn about the 

CCP and provide comments.

August 1, 2006 Public scoping.

All public scoping comments were due. 

Comments were compiled for consideration by 

planning team.

August 1, 2006 Focus group meeting (disease control/

grazing).

Discussed ungulate grazing and disease control 

(Service, NRCS, and UND researchers).

August 23, 2006 Focus group meeting

(disease control).

Discussed fenced animal disease issues with 

North Dakota Board of Animal Health.

August 29, 2006 Meeting with Spirit Lake Nation tribal 

council.

Presented CCP process and potential 

partnership proposals to Spirit Lake Nation 

tribal council members and chairwoman. 

August 30–31, 

2006 Vision and goals workshop. Fine-tuned initial vision statement and developed goals to support it.

September 20, 

2006

Focus group meeting

(visitor services).

Visitor services program experts from the 

Service and tribal members reviewed the 

current refuge program.

September 21–22, 

2006 Alternatives workshop. Alternatives table developed.
Chapter 1 — Introduction 11

Table 1. Planning process summary and timeline for Sullys Hill National Game Preserve.

Date Event Outcome 

January 17–18, 

2007 Objectives and strategies workshop. Finalized alternatives table and began writing objectives/strategies for the proposed action.

February 2007–

June 2007 Draft plan. Planning team prepared draft CCP and EA.

March 18–April 2, 

2008 Internal review.

Draft CCP and EA reviewed by other Service 

divisions along with interested state and tribal 

agencies. 

June 26, 2008 NOA. The public was notified that the draft plan was 

available for review and comment.

July 22, 2008 Public meeting. Public opportunity offered to learn about the 

draft plan and offer comments.

July 25, 2008 End of public comment period. All public comments were received or 

postmarked by this date.

August 29, 2008 FONSI. The regional director selected the preferred 

alternative and signed the FONSI.

C

A mailing list was prepared during the preplanning 

phase. The list includes more than 320 names 

of private citizens; local, regional, and state 

government representatives and legislators; other 

federal agencies; and interested organizations. A 

summary of the nongovernmental, state, and federal 

organizations who participated in public involvement 

is in appendix B. 

The first planning update issue was sent to everyone 

on the mailing list in June 2006. Information was 

provided on the history of the refuge and the CCP 

process, along with an invitation to the public scoping 

meeting. Each planning update included a comment 

form and postage-paid envelope to give the public an 

opportunity to provide written comments. Comments 

via email were also accepted at the refuge’s email 

address.

Presentations about the CCP process were made 

during all public activities including the refuge 

annual birding festival, attended by more than 

1,200 individuals. The public scoping meeting was 

held on June 29, 2006, at the refuge visitor center. 

There were 10 attendees including local citizens, 

local teachers, and members of the Spirit Lake 

Nation. After a presentation about the refuge 

and an overview of the CCP and NEPA process, 

attendees met with presenters to ask questions and 

offer comments. Each attendee was given a written 

comment form to submit additional thoughts or 

questions. All written comments were due August 1, 

2006. A total of 183 written comments were received 

throughout the scoping process. All comments were 

reviewed by the planning team and considered 

throughout the planning process. 

S

The Service’s region 6 director sent an invitation 

letter in April 2006 to the director of NDGF 

requesting the department’s participation in the 

CCP process. Several representatives from the 

NDGF have participated in the planning process. 

Local NDGF wildlife managers and the refuge staff 

maintain excellent, ongoing working relations that 

preceded the start of the CCP process.

The NDGF’s mission is to “protect, conserve, and 

enhance fish and wildlife populations and their 

habitats for sustained public consumptive and 

nonconsumptive uses.” In addition to enforcing 

the state’s protection laws for migratory birds and 

endangered species, the NDGF is also responsible for 

managing natural resource lands owned by the state. 

The state manages over 78,000 acres in support of 

wildlife, recreation, and fisheries. 

T

The Spirit Lake Tribal Council was sent a written 

invitation in April 2006 to participate in the 

CCP planning process. The Spirit Lake Nation 

Reservation surrounds the refuge boundary on three 

sides. Although no initial response was received, 

tribal members did attend the public scoping 
12 CCP, Sullys Hill National Game Preserve, ND

meeting. At that time another meeting was proposed 

for the tribal council meeting in August. 

On August 28, 2006, the tribal chairwoman and 

11 other members of the tribe, including 3 council 

members and tribal planning staff, met with refuge 

staff and the planning team leader at the Sullys 

Hill National Game Preserve education and visitor 

center. A presentation on the CCP process and a 

separate presentation outlining common goals and 

interests between the refuge and the tribe were 

presented. Tribal representatives also attended the 

visitor services workshop held the following month. 

Their insights were valuable and all comments were 

considered during development of alternatives. 

In particular, the refuge staff recognized several 

opportunities to further incorporate the tribe’s 

history and culture into future visitor services 

programs. 

R

Table 1 and appendix C summarize all scoping 

activities. Comments collected from scoping 

meetings and correspondence, including comment 

forms, were used in the development of a final list 

of issues to be addressed in this CCP. The Service 

determined which alternatives could best address 

the issues. The planning process ensures that issues 

with the greatest potential effect on the refuge will 

be resolved or given priority over the life of the 

CCP. These issues are summarized in chapter 2. In 

addition, the Service considered suggested changes 

to current refuge management presented by the 

public and other groups.

Plan aMendMent 

and revision

This CCP will be reviewed 

annually to determine 

the need for revision. 

A revision will occur 

if and when significant 

information becomes 

available, such as a change 

in ecological conditions. 

The CCP will be 

augmented by detailed 

step-down management 

plans to address the 

completion of specific 

strategies in support of the 

CCP goals and objectives. 

Revisions to the CCP and 

the step-down management 

plans will be subject to 

public review and NEPA 

compliance. At a minimum, 

this plan will be evaluated 

every 5 years and revised 

after 15 years. Song Sparrow
2 The Refuge

View of lower forest surrounding Sweetwater Lake.

Scott Ralston/USFWS

This chapter discusses the history, purpose, and 

special values of Sullys Hill National Game Preserve, 

the proposed vision and goals, and planning issues.

2.1 ESTABLISHMENT, ACQUISITION, 

AND MANAGEMENT HISTORY

The establishment of Sullys Hill National Game 

Preserve was first addressed in April 27, 1904, by 

the Fifty-Eighth Congress of the United States. 

The Senate and House of Representatives enacted 

bill H.R.11128, known as Public Law No. 179, which 

authorized President Theodore Roosevelt to reserve 

a tract of land embracing Sullys Hill as a public park. 

It stated that a portion of unallotted lands within 

the Devils Lake Indian Reservation, including the 

unallotted tract of land known as the Fort Totten 

Military Reservation, would be set aside for this 

purpose. Much of the remaining unallotted lands 

would be disposed under the general provisions of 

the homestead and town site laws of the United 

States and opened to settlement by proclamation 

of the President. The final Proclamation, No. 32, 

was signed on June 2, 1904, by President Roosevelt, 

officially establishing Sullys Hill Park as part of the 

National Park Service system. Ten years later, on 

June 30, 1914, appropriations were made for the 

creation of a big-game preserve within the park.

On December 22, 1921, President Warren Harding, 

by Executive Order 3596, ordered that all lands 

within the boundaries of Sullys Hill National Park 

Game Preserve be reserved and set apart as a refuge 

and breeding grounds for birds. 

In the Act of March 3, 1931, President Herbert 

Hoover transferred the preserve from the National 

Park Service to the U.S. Fish and Wildlife Service 

and renamed it Sullys Hill National Game Preserve. 

This transfer became law by the Seventy-First 

Congress where it was stated that the refuge should 

be administered “as a big game preserve, refuge and 

breeding grounds for wild animals and birds.” Sullys 

Hill National Game Preserve is administered as part 

of the National Wildlife Refuge System.

Sullys Hill National Game Preserve has a rich 

history of management, primarily centered on the 

purposes of migratory birds, big game, and visitor 

service. Refuge management history indicates that 

regular timber management occurred throughout 

the woodlands by cutting and coppice regeneration 

(growth of new shoots from stumps). Defoliation of 

grasslands primarily occurred because of grazing and 

haying activities associated with the management of 

the herds of bison, elk, and deer. Extensive visitor 

use continues to be a major component of the refuge.

Historical records show that through 1943, the refuge 

used the services of Works Project Administration 

personnel, a depression-era program that was used 

for many public projects. A shortage of material 

and human resources caused by World War II 

(1939–1945) made refuge management very difficult. 
14 CCP, Sullys Hill National Game Preserve, ND

Historical data from the manager’s log indicates 

that staff did not have time to serve the public so 

they did their “work” during the daytime shift and 

then worked off-the-clock in the evenings to service 

visitors and maintain the facilities. Much of the 

historical visitation to the refuge was for wildlife 

viewing and social gatherings. Visitation during this 

broader public or “park” use was up to 90,000 visitors 

annually. 

Current management of the refuge reflects its 

original purposes, and specifically supports the 

National Refuge System’s vision of putting wildlife 

first. As an example, managing habitat for migratory 

birds is a major focus in managing the forest and 

prairie areas. Bison management has recently 

evolved to center upon Service-wide metapopulation 

management, focusing on the genetic conservation 

of this species. Visitor service is based on wildlifedependent interpretative activities and education 

programs. The goal has been to use the refuge as a 

regional conservation learning center, keeping the 

refuge habitats and associated wildlife at the core. 

Approximately 5,000 students are taught each year 

in the indoor and outdoor classrooms, and there are 

60,000 visitors annually.

2.2 SPECIAL VALUES OF THE REFUGE

Qualities are defined as the characteristics and 

features that make the areas special and worthy 

of refuge status. The planning team and the public 

identified the following outstanding qualities of 

Sullys Hill National Game Preserve:

Q The refuge contains shallow wetland, deep lake, 

woodland, and grassland habitats. Together 

they provide for a wide variety of migratory 

birds; unique small mammals and furbearers; 

and large ungulates, such as bison and elk.

Q The refuge protects an important piece of 

native woodland, a habitat type found only 

in 2% of North Dakota. This woodland likely 

includes the most western range of American 

basswood. 

Q The refuge attracts a diversity of woodland bird 

species, such as warblers, that are absent from 

the surrounding grassland ecosystem. 

Q Several unique plant species thrive on the 

undisturbed hills across the refuge, including 

ball cactus, downy paintbrush, Indian pipe, and 

marsh marigold.

Q The woodlands of Sullys Hill National Game 

Preserve provide a significant acreage to 

support over 250 species of nesting and staging 

migratory birds unique to North Dakota.

Q Sullys Hill National Game Preserve is 1 of only 

19 designated natural areas in North Dakota of 

which only 4 are national wildlife refuges.

Q Interactions with both flora and fauna are 

available to refuge visitors.

Q At the station’s education and visitor center, 

the Service has a tremendous opportunity to 

educate the visiting public about the value of 

wetlands and grasslands, and about the refuges 

and wetland management districts in North 

Dakota and throughout the nation. There is 

no other place in this region of the country 

where the Service has this type of facility 

to accomplish its mission of outreach and 

environmental education.

Q The education and visitor center has numerous 

outreach displays, tools, and techniques available 

to Service personnel, teachers, and other 

educators to conduct both student and adult 

environmental education and interpretation. 

Q The refuge is a great education and learning 

destination for both indoor and outdoor 

environmental education with a focus on the 

sciences, biodiversity, and human dimensions in 

the natural environment.

Q Special events educate visitors from the 

surrounding areas and the nation on the values 

of the Refuge System for the purpose of 

garnering support for the Service’s mission.

Q The refuge is the Service’s link to the local 

community. The outreach conducted through 

the refuge is instrumental in educating the 

public and garnering support for the work 

carried out by the Devils Lake Wetland 

Management District Complex, especially for 

the protection of wetlands and grasslands. 

Q The “friends group” at Sullys Hill National 

Game Preserve was the first formed in North 

Dakota and has been an active supporter of 

both the refuge and the conservation activities 

conducted by the staff at Devils Lake Wetland 

Management District Complex.

Q The refuge has several archaeological sites that 

reflect thousands of years of human occupation 

and use.

2.3 PURPOSE

Every refuge has a purpose for which it was 

established. This purpose is the foundation upon 

which to build all refuge programs, from biology and 

visitor services, to maintenance and facilities. No 

action that the Service or public takes may conflict 

with this purpose. The refuge purposes are found 

in legislative acts or administrative orders, which 

provide the authorities to transfer or acquire a piece 

of land for a refuge. Over time, an individual refuge 

may contain lands that have been acquired under 

a variety of transfer and acquisition authorities, 

giving a refuge more than one purpose. The goals, 

objectives, and strategies identified in the CCP are 

intended to support the individual purposes for which 

the refuge was established.
Chapter 2 — The Refuge 15

The purposes for Sullys Hill National Game Preserve 

are described in the following legislation and public 

land orders:

Q “All the lands that are now reserved or may 

hereafter be included within the boundaries of 

the ... Sullys Hill National Park Game Preserve 

... are hereby further reserved and set apart 

for the use ... as refuges and breeding grounds 

for birds.” (Executive Order 3596, December 

21, 1921)

Q “As a big game preserve, refuge, and breeding 

grounds for wild animals and birds ... provided, 

that the said game preserve is to be made 

available to the public for recreational purposes 

in so far as consistent with the use of this area 

as a game preserve ... provided further, that 

hunting shall not be permitted on said game 

preserve.” (46 Stat. 1509, Act of March 3, 1931)

2.4 VISION

A vision is a concept and includes the desired 

conditions for the future that the Service is trying to 

accomplish at the refuge. The vision for a refuge is a 

future-oriented statement designed to be achieved 

through refuge management throughout the life 

of a CCP and beyond. This is the vision statement 

developed by the planning team for the Sullys Hill 

National Game Preserve.

Overlooking North Dakota’s largest natural 

lake and riding the tops of a glacial thrust 

block formation, Sullys Hill National Game 

Preserve is dressed in undulating native 

woodlands and prairie. Teddy Roosevelt’s 

vision and broad community support 

are largely responsible for the successful 

conservation of these habitats ensuring the 

preservation of the refuge’s plains bison 

and Rocky Mountain elk while supporting 

migrating waves of warblers and other 

native bird species. 

Sullys Hill National Game Preserve is 

renowned as a regional conservation 

learning center––greeting families, 

students, and outdoor enthusiasts of all 

abilities. Children are able to learn about 

their natural world using all their senses 

which fosters their own environmental 

ethics. Each visitor’s experience not only 

enriches their personal lives, but instills 

a unique understanding and appreciation 

for preserving native prairie and wetland 

habitats, the natural resources of the 

Devils Lake Basin, and the mission of the 

National Wildlife Refuge System to preserve 

America’s wildlife heritage.

2.5 GOALS

The Service developed a set of goals for Sullys Hill 

National Game Preserve based on the Improvement 

Act, the refuge’s purposes, and information 

developed during CCP planning. The goals achieve 

the vision and purposes of the refuge and outline 

approaches for managing refuge resources. The 

Service established six goals for the refuge.

Prairie Habitat Goal

Maintain prairie plant communities representative of 

the historical mixed-grass prairies to support healthy 

populations of grassland-dependent migratory birds 

in balance with bison, elk, and other indigenous 

wildlife.

Woodland Habitat Goal

Manage for healthy native woodlands of various 

age classes and structure to provide habitat for 

migratory birds, in balance with bison, elk, and other 

indigenous wildlife.

Wildlife PoPulation ManaGeMent Goal

Carry out management practices that ensure healthy 

populations of Rocky Mountain elk, plains bison, and 

other indigenous wildlife species that exemplify the 

genetic integrity of historical prairie wildlife. 

E

Deliver quality, interactive environmental education 

programming to regional schools, communities, 

organizations, Spirit Lake Nation, and local 

governments to garner support and appreciation 

for Sullys Hill National Game Preserve, North 

Dakota’s wetland and grassland resources, and 

the conservation role of the U.S. Fish and Wildlife 

Service. 

V

Provide captivating visitor services facilities and 

activities for visitors of all abilities, community 

groups, youth groups, and the members of Spirit 

Lake Nation to provide enjoyment that results 

in a greater understanding and support of the 

preservation of native habitats and landscapes of 

North Dakota’s Prairie Pothole Region and the 

mission of the Refuge System.

Protection and Maintenance Goal

Refuge visitors, staff, and volunteers will have a 

safe, protected, and well-maintained environment 

in which to learn about, work with, understand, and 
16 CCP, Sullys Hill National Game Preserve, ND

appreciate the importance of protecting the unique 

natural and cultural resources of Sullys Hill National 

Game Preserve.

2.6 PLANNING ISSUES

Although Sullys Hill National Game Preserve is well 

established, celebrating its 100th birthday on June 

4, 2004, it is not without challenges or management 

issues that need to be addressed. These challenges 

include areas such as staffing, funding, visitor use and 

opportunities, accessibility, flooding, refuge support, 

biology, disease, and overall habitat and wildlife 

management. The following summarizes these issues 

and some of their effects:

staffinG issues

Q Serving as a conservation learning center is 

an important designation and direction for 

this refuge. Inadequate staff for conservation 

education has created a roadblock to the 

refuge reaching its full potential. Numerous 

opportunities have been lost to instill a 

greater understanding and appreciation for 

the important conservation role of the Refuge 

System here in the Devils Lake Basin and 

abroad. 

Q The refuge struggles to remain open in the 

winter season due to lack of staff to keep roads 

clear.

Q This refuge has historically had only one 

full-time person dedicated to its management. 

The refuge hosts more than 60,000 students 

and guests annually. Providing a safe and 

educational experience for these visitors is very 

important but leaves little time for wildlife and 

habitat management. The minimal staffing also 

prevents the expansion of programs into the 

surrounding schools and communities.

Q Wildlife management needs at the refuge 

include herd management, disease prevention, 

genetics, population dynamics, and trust species 

needs. 

Q Given the small staff-size and budget, numerous 

habitat needs have not been addressed, 

including promoting forest regeneration, 

determining native prairie carrying capacities, 

plant inventories, habitat health, invasive 

species, and disease management. 

Q There is no administrative staff located at the 

refuge.

Q Even though the refuge hosts 60,000 visitors 

annually, there is minimal law enforcement 

presence. There has been some vandalism, 

including fires set on refuge lands. 

V

Q The refuge is part of the Devils Lake Wetland 

Management District Complex, responsible 

for protecting and restoring grassland and 

wetland habitats in the Devils Lake Basin. 

There has been some confusion and mistrust 

as to the role of the Service in protecting these 

dwindling habitats. The refuge could serve as a 

resource to the community to provide a clearer 

understanding of the importance of protecting 

these resources, as well as acquiring rights 

from willing landowners. 

Q Improved communication is needed with 

the members of Spirit Lake Nation, along 

with assistance in development of education 

curriculum, technical help, fire training 

opportunities, cultural and religious needs, and 

overall marketing and outreach of our joint 

landscapes and resources. 

Q There is potential to significantly increase the 

number of students educated, but the current 

staff of one person limits the ability to reach 

these additional students. 

Q Approximately 20 different schools visit the 

refuge annually to participate in environmental 

education programs. The success of this 

program has relied on initiative from the 

schools due to lack of Service staff to facilitate 

visits, conduct programs, and conduct outreach 

to surrounding schools. This has resulted in a 

less structured program which does not provide 

a consistent message of wetland and grassland 

protection, and there have been missed 

opportunities to ensure students are aware 

of the Refuge System. There is much more 

potential to actively pursue partnerships with 

other schools within North Dakota if there were 

resources and a dedicated staff member. 

Q Because of the flooding that has occurred 

throughout the last 10–15 years, there have 

been many impacts to the accessible trails, 

hiking trails, amphitheater, outdoor classroom 

clearings, and remote classrooms.

Q There is also a need for additional accessible 

trails.

Q The Sullys Hill education and visitor center 

building has been completed, but the 

interpretive displays have not been addressed. 

Q Curriculum needs to complement the state and 

local schools’ standards and education goals. 

Nature education could be used to improve 

math and science scores, while generating 

an overall understanding and support for the 

conservation role of the Refuge System.

Q Part of the refuge’s auto tour route needs to be 

resurfaced.
Chapter 2 — The Refuge 17

Q The possibility of using funds from the sale of 

refuge elk for developing education and visitor 

services programs should be explored.

Q The refuge staff and Spirit Lake Nation 

members should discuss how to complement 

and support each other’s roles and activities and 

develop partnerships when possible.

Q The auto tour route goes through the big game 

unit where bison and elk roam freely. Although 

there are signs warning visitors not to approach 

wildlife, there is always concern for the safety 

of both visitors and wildlife. 

Wildlife and Habitat issues

Q There needs to be a better understanding of 

the carrying capacity of the area to support the 

populations of bison, elk, and white-tailed deer 

to ensure that forest and prairie management 

can improve migratory bird production.

Q There is no complete plant inventory at the 

refuge. 

Q Invasive species such as brome and bluegrass 

need to be reduced and native species restored. 

Q There needs to be a feral dog and prairie dog 

management plan.

Q Habitat management plans need to be 

developed and implemented.

Q There is a lack of forest regeneration as a result 

of grazing ungulates. 

Q Chronic wasting disease (CWD) continues to be 

a disease issue among cervids. This and other 

disease issues such as brainworm, lungworm, 

and parasites all need to be part of an overall 

management plan.

Q There is a need for cross fencing, enclosures, 

and water development for better herd 

distribution and forest regeneration. Currently, 

the refuge land receives year-round grazing. 

Q The refuge should be part of the Service’s 

program to maintain genetically pure bison 

in the nation. The Service needs to define 

the refuge’s role and then a plan needs to 

be developed to ensure the success of this 

program. 

Q A review needs to be completed on winter 

feeding operations and its efficacy to determine 

if it can be eliminated, reduced, or better 

managed. 

Protection and facilities

Maintenance issues

Q There are known occurrences of drug and 

alcohol use and vandalism on the refuge. The 

potential poses a danger to the visiting public 

and facilities. Without consistent patrols, the 

refuge will continue to serve as a place for 

unlawful activities, putting wildlife, staff, and 

visitors at risk. 

Q Recreation fee compliance is based on a 

voluntary honor system with an estimated 

compliance rate of 40%, resulting in a loss of 

revenue for refuge programs. 

Q There is no on-site maintenance staff. Refuge 

facilities are maintained on an “as needed” basis 

if staff is available. 

Q There is no comprehensive survey of historical 

and cultural resources on the refuge, only 

sporadic documentation as sites are discovered.

Q Due to minimal law enforcement resources, big 

game animals are vulnerable to illegal activities 

such as poaching and harassment.

Challenges abound in the refuge, and these issues 

will be dynamic over the years and will have to be 

reviewed, changed, and added to as management 

actions are put into place, and as environmental and 

social issues interact with refuge purposes and plans. 

Dragonfly on lead plant.

Scott Ralston/USFWS

3 Refuge Resources and Description

Flowing Stream

Scott Ralston/USFWS

This chapter describes the current characteristics 

and resources of Sullys Hill National Game Preserve. 

It specifically addresses physical, biological, cultural, 

and socioeconomic resources, as well as recreational 

opportunities. 

Sullys Hill National Game Preserve is a 1,675-acre 

national wildlife refuge sitting on the south shores 

of Devils Lake, about 10 miles south of the city of 

Devils Lake, North Dakota. The refuge supports a 

unique community of habitats such as an oak, ash, 

basswood and aspen woodland; mixed-grass prairie; 

and natural wetlands; along with beaver ponds and 

created wetlands (see figure 5, boundary map). It is 

also 1 of only 19 identified sites to be listed in North 

Dakota’s list of natural areas, of which only 4 are 

national wildlife refuges. In addition, the refuge is 

one of four refuges nationally established for the 

purpose of bison conservation.

Administratively, the refuge consists of two 

noncontiguous blocks of land (see figure 5, boundary 

map). The main unit of the refuge supports the big 

game forest, lower forest, big game prairie, several 

wetlands, and the visitor services and education 

infrastructure. The second block of land is comprised 

of windbreaks, south forest, south prairie, haylands, 

and wetlands (see figure 6, management units map). 

The refuge blends a unique plant community with 

a diverse mixture of wildlife in an area of historical, 

geological, and archaeological significance. The 

woods and prairies of the refuge sit atop the glacial 

moraine hills and rise to an elevation well above 

the level of Devils Lake. The area is a thrust block 

formation resulting from glaciers mining a large 

area, now called Devils Lake, and depositing all 

this material in the range of hills which includes 

the refuge. Thus, the refuge is a unique landform or 

anomaly within this flat prairie region. As such, this 

area is a large ecotone that provides “edge” habitat 

for many species of birds as well as plains bison, elk, 

white-tailed deer, turkeys, and prairie dogs. More 

specifically, this edge is the joining of palustrine 

(vegetated wetlands) and lacustrine (lake) wetlands 

with woodlands and grasslands. This ecotone is very 

attractive to many forms of wildlife, including more 

than 250 species of migratory birds; unique small 

mammals, such as woodchucks, fishers, and the large 

ungulates (hoofed mammals) that have made the 

refuge a destination for many visitors. A primary 

purpose of the refuge is to provide habitat and 

breeding grounds for birds. 

The unique topography of the refuge also provides 

for some unique plant species that are not common 

to the area. These plants include ferns, ball cactus, 

sarsaparilla, downy paintbrush, Indian pipe, showy 

lady’s slipper, and marsh marigolds. 

This exceptional mix of topography, vegetation, 

and wildlife attracts many visitors to the area 

because of the variety of interaction with easily 

accessible flora and fauna. Visitation has long been 

a tradition at the refuge. In the early years, the 
20 CCP, Sullys Hill National Game Preserve, ND

Figure 5. Sullys Hill National Game Preserve boundary map.
Chapter 3 — Refuge Resources and Description 21

Figure 6. Sullys Hill National Game Preserve management units.
22 CCP, Sullys Hill National Game Preserve, ND

area was frequented by visitors for picnics, enjoying 

the playgrounds, reunions, and other “park-type” 

activities. As the area transformed from a park into 

a game preserve and refuge, so did visitor activities. 

Gradually, the refuge is becoming a progressive 

regional conservation learning center, promoting the 

conservation role of the Refuge System, as well as 

educating the public about the functions and benefits 

of prairie wetlands and grasslands. Additional 

learning opportunities are available through hiking 

trails, scenic wildlife overlooks, a self-guided auto 

route, and the refuge education and visitor center. 

All activities support efforts to educate and provide 

interpretation to visitors through premier education 

facilities. Ultimately, the refuge uses the dual concept 

of indoor and outdoor environmental education with 

a focus on the sciences, biodiversity, and human 

dimensions in the environment and provides area 

educators an environment that makes learning more 

exciting and interesting. 

Sullys Hill National Game Preserve has gained much 

community support and boasts North Dakota’s first 

refuge “friends group.” This group has supported 

special events such as the “Birding and Nature 

Festival” and “Sullys Hill Winterfest.” 

The refuge has become the Service’s link to the 

community and the traveling visitor. While visiting, 

they receive information on the values of wetland and 

grassland conservation and the roles of the Refuge 

System. 

3.1 PHYSICAL ENVIRONMENT

The following sections describe physical 

environmental resources that may be affected by the 

implementation of the CCP. Physical characteristics 

include physiography, geography, soils, water 

resources, climate, and the effects of global warming. 

Sullys Hill National Game Preserve’s hilly terrain is a 

prominent fixture on the south shore of Devils Lake. 

Bluemle (1991) indicates that Devils Lake occupies 

the former valley of the ancestral Cannonball River, 

and that the large-scale glacial activity that occurred 

in North Dakota formed the lake and adjacent hills, 

including Sullys Hill. This part of North Dakota is 

situated in the drift prairie physiographic region, and 

Sullys Hill National Game Preserve is specifically 

included in the end-moraine complex ecoregion. The 

refuge is considered part of the Devils Lake Wetland 

Management District Complex, headquartered at 

Devils Lake, where greater than 250,000 acres of 

Refuge System lands in northeastern North Dakota 

are protected and managed. 

Global WarMinG

The U.S. Department of the Interior issued an order 

in January 2001 requiring federal agencies under its 

direction that have land management responsibilities 

to consider potential climate change effects as part 

of long-range planning endeavors. The Department 

of Energy’s report, “Carbon Sequestration Research 

and Development,” concluded that ecosystem 

protection is important to carbon sequestration 

and may reduce or prevent loss of carbon currently 

stored in the terrestrial biosphere. The report defines 

carbon sequestration as “the capture and secure 

storage of carbon that would otherwise be emitted to 

or remain in the atmosphere.”

The increase of carbon dioxide (CO2) within the 

earth’s atmosphere has been linked to the gradual 

rise in surface temperature commonly referred to 

as “global warming.” In relation to comprehensive 

conservation planning for Refuge System units, 

carbon sequestration constitutes to be the primary 

climate-related effect considered in planning. 

Vegetated land is a tremendous factor in carbon 

sequestration. Large, naturally occurring 

communities of plants and animals that occupy major 

habitats—grasslands, forests, wetlands, tundra, 

and desert—are effective both in preventing carbon 

emission and in acting as biological “scrubbers” 

of atmospheric CO2. One Service activity in 

particular—prescribed fire—releases CO2, directly 

to the atmosphere from the biomass consumed 

during combustion. However, there is no net loss of 

carbon because new vegetation quickly germinates 

and sprouts to replace the burned-up biomass. 

This vegetation sequesters approximately an equal 

amount of carbon as is lost to the air (Dai et al. 2006).

Several other effects of climate change may need to 

be considered in the future:

Q Habitat available in lakes and streams for 

cold-water fish such as trout and salmon could 

be reduced.

Q Forests may change, with some plant species 

shifting their range northward or dying out and 

other trees moving in to take their place.

Q Ducks and other waterfowl could lose breeding 

habitat because of stronger and more frequent 

droughts.

Q Changes in the timing of migration and nesting 

could put some birds out of synchronization 

with the life cycles of their prey.

C

Sullys Hill National Game Preserve has a continental 

climate characterized by relatively warm short 

summers, long cold winters, and rapidly changing 

weather patterns. January is the coldest month, 

with an average mean temperature of -6°Fahrenheit 

(F), while July is the warmest, averaging 81°F. The 

average growing season varies from 98 to 106 days.

The average high temperature for the year is 49°F 

with the average low being 28°F. The average daily 

summer temperature ranges from 5°F to a high of 
Chapter 3 — Refuge Resources and Description 23

81°F with 10.8 days above 90°F. The average winter 

temperatures range from -6°F to a high of 34°F, with 

189 days below freezing (32°F or below). High winds 

are prevalent all year and can create extreme wind 

chills. 

Average annual precipitation is 17.5 inches. Average 

snowfall is 35.7 inches per year, with the greatest 

amount normally received during December. In the 

winter, snow and high winds can bring frequent 

blizzard conditions to the area. The frost-free season 

generally runs from May 20 to September 15.

PHysioGraPHy, GeoGraPHy, and soils

The Devils Lake basin is a distinguishing feature of 

the drift prairie physiographic region, and according 

to Bluemle (1991) is one of the largest and bestdefined glacially excavated depressions in central 

North America. By most accounts, it is considered an 

internally drained basin that spans an area of around 

3,810 square miles. When water levels rise to 1,446.5 

feet above mean sea level (amsl), they overflow 

southeastward into the Stump Lake system. In the 

event that the combined waters of Devils Lake and 

Stump Lake rise to approximately 1,459 feet amsl, 

the southern moraines are breached and waters 

overflow into the Sheyenne River. Since 1993, Devils 

Lake has risen 25.5 feet in elevation, and the volume 

of water has quadrupled to a current acreage of 

134,000 acres (U.S. Geological Service 2007). 

In geological terms, Sullys Hill is considered an 

ice-thrust landform, consisting of a discrete hill of 

glacial deposits and Cretaceous shale down glacier 

from the Devils Lake basin. This landform was likely 

created as a result of the last known glacier, which 

occurred 12,000 years ago, and is known as the Late 

Wisconsinan Glacier. This moved over the Spiritwood 

aquifer, underlying the current day Sullys Hill/Devils 

Lake thrust complex, and pressurized the water with 

its tremendous weight. As a result, a large block 

containing brecciated shale and deformed glacial 

sediment was shoved up (creating Sullys Hill), and a 

lake-filled depression (now Devils Lake basin) formed 

in the area where the block was removed (Bluemle 

1991). Bluemle (1991) indicates that the total relief 

between the bottom of Devils Lake to the adjacent 

ice-thrust Cretaceous blocks exceeds 650 feet. 

The soils identified in Benson County are believed 

to be formed from glacial material derived from 

pre-glacial granite, gneiss, sandstone, shale, 

limestone, and basalt (Strum et al. 1977). Soils that 

underlie the refuge are those typical of deep, rolling, 

well-drained soils on glacial till plains and moraines. 

The ridge tops and surrounding slopes of the refuge 

support hardwood trees and typically have a thin 

topsoil layer. Available water capacity in these areas 

may be high and rapid runoff and water erosion 

regularly occurs. Other hardwood vegetated areas of 

the refuge are associated with alluvial soils present 

at the base of slopes and are often present in coulees 

(a valley or drainage landform such as a pond or 

creek) that were formed by glaciation and erosion. 

Also prominent across these soils are thick layers 

of organic material. The latter is a direct result of 

plant material breakdown that occurs with high soil 

moisture content and humidity. This decomposition 

is supplemented by the continual erosion of uphill 

slopes which produces a layering affect of soil and 

organic matter. 

The prairie areas of the refuge typically contain deep 

undulating to hilly, well-drained, medium-textured 

soils formed in loam glacial till. Map units included 

for these soils possess slow permeability, with high 

available water capacity and rapid runoff potential 

(Strum et al. 1977). These prairie areas are located 

in the noncontiguous portions of the refuge and in 

scattered areas throughout the woodland portions of 

the refuge.

Water resources

Portions of the Devils Lake basin also are included 

within the boundary of the Sullys Hill National Game 

Preserve. Devils Lake is primarily an internally 

drained basin that has been rising rapidly since a 

historical low around 1940. Lake levels in 1992 were 

approximately 1,423 feet, while current levels hover 

around 1,446 feet, and even reached 1,449 in 2006. 

Recent records and even prehistoric estimations 

indicate that the water levels in Devils Lake have 

fluctuated significantly, usually owing to the dynamic 

climate of the region. A primary factor in the most 

recent rise that started in 1993 was the above-normal 

precipitation that has continued for more than a 

decade. Unfortunately, because of the significant 

loss of wetlands in the upper basin, the capacity 

to store water has been reduced. This flooding has 

impacted tens of thousands of acres of the Devils 

Lake Basin, including towns, communities, roads, 

and agricultural land. The high water levels in recent 

years preempted the relocation of multiple refuge 

buildings. 

In addition, the refuge is located within the Prairie 

Pothole Region of the United States. The scouring 

and shearing action of glaciers or the collapse of ice 

blocks left to melt after the glaciers retreated formed 

shallow basins across the landscape, known today as 

prairie potholes (Kantrud et al. 1989). These potholes 

encompass myriad small wetlands ranging from wet 

meadows and shallow ponds to saline lakes, marshes, 

and fens. It is estimated that, in the late 1700s, 

between 7 and 8 million acres of wetlands existed 

in North Dakota and South Dakota combined (Dahl 

1990). There are approximately 30 prairie pothole 

wetlands across Sullys Hill National Game Preserve. 

Water quality, air quality, and water rights are not 

major issues at the refuge.
24 CCP, Sullys Hill National Game Preserve, ND

3.2 BIOLOGICAL RESOURCES

The following sections describe the biological 

resources that may be impacted by the 

implementation of the CCP. Biological characteristics 

include vegetation communities, birds, mammals, 

insects, reptiles, and amphibians.

The Sullys Hill National Game Preserve landscape 

is distinguished by the prominence of native 

hardwood forest habitat interspersed with pockets 

of mixed-grass prairie and associated wetlands 

(see figure 6, management units map). The refuge 

supports a diversity of wildlife, including naturally 

occurring species such as migratory birds, as well 

as reintroduced species including bison, Rocky 

Mountain elk, and white-tailed deer. The climax 

forest on Sullys Hill National Game Preserve is 

dominated by American elm and basswood, while 

cooler, dry areas and north-facing slopes are covered 

with bur oak and green ash. The mixed-grass prairie 

areas support species typical of this prairie type, 

including porcupine grass species and even big 

bluestem species. 

V

This section describes the three vegetation 

communities present at Sullys Hill National Game 

Preserve, namely woodlands, grasslands, and 

wetlands. Spatial distributions of these habitats 

are shown on a map (see figure 7, vegetative 

communities map). 

Woodlands

Although the mixed-grass prairie is typically 

considered the climax vegetation of the northern 

Great Plains (Clements and Shelford 1939), native 

woodlands occur where moisture and soil regimes 

provide necessary support (Hopkins 1984), and 

where protection (such as lakes and rivers) from fires 

would have existed. Stewart (1975) indicated that 

only about 2% of North Dakota is forest habitat. The 

majority of this was in the Turtle Mountains, Killdeer 

Mountains, Pembina Hills, and the Devils Lake 

area, as well as along major rivers and associated 

tributaries (Haugen et al. 2004). The Pembina Hills in 

northeastern North Dakota and the Turtle Mountains 

in north-central North Dakota are considered the 

two major deciduous forest ecosystems in the state 

(Faanes and Andrew 1983). Sullys Hill National 

Game Preserve is also part of this unique habitat 

across the state with its nearly 700 acres of native 

deciduous forest. The refuge was likely protected by 

the nearby river valleys and Devils Lake basin and 

therefore did not endure frequent fires as did the 

surrounding grasslands. In addition, Heidt (1977) 

indicates that differences in soil parent material 

at the refuge also played a role in supporting the 

occurrence of woody vegetation. Severson and 

Sieg (2006) indicate that possible tree species in 

the Devils Lake area from 1797–1871 were quaking 

aspen, white oak, black oak, bur oak, ash, elm, linden, 

and boxelder. The big game forest, lower forest, 

and south forest are native woodlands with mixed 

deciduous hardwood trees. Predominant woodland 

species across the refuge include:

Q bur oak

Q American elm

Q boxelder

Q American basswood

Q green ash

Q cottonwood aspen

Q chokecherry

Q paper birch

Q hawthorn

Q wild plum

Q western snowberry 

There are stands of hardwood trees within the big 

game forest that are located on the ridge tops and 

surrounding slopes. Throughout this CCP, these 

areas are referred to as oak-dominated areas. 

Overstory species in these areas are bur oak and 

green ash, and possibly an occasional American elm 

or American basswood. The predominant understory 

species is chokecherry, while western snowberry 

is the primary shrub species. The predominant 

herbaceous species covering the forest floor are 

sedge species, Virginia wildrye, and smooth brome. 

Throughout the big game forest are hardwood trees 

found on the bottom and side slopes of ravines and 

adjacent overflow sites. Throughout this CCP, these 

areas are referred to as basswood-dominated areas. 

Overstory species in these areas are American 

basswood, bur oak, green ash, boxelder, and an 

occasional American elm. The most prevalent 

understory species are overwhelmingly chokecherry, 

intermixed with American basswood, American 

elm, and boxelder. Western snowberry is the major 

shrub species, and forest floor cover mainly consists 

of sedge species. The primary management activity 

implemented throughout this forest is ungulate 

grazing, with infrequent fire and occasional selective 

harvesting activities. 

Similar species exist in the lower and south forests, 

which are not accessible to the ungulates in the big 

game forest. For oak-dominated areas, the bur oak 

and green ash are the most prevalent overstory 

species, mixed with a few American basswood and 

boxelder trees. Dominant understory species are 

bur oak, green ash, basswood, and chokecherry. 

Shrub species also occur in these areas, including 

western snowberry and Juneberry. In the 

basswood-dominated hardwood forest areas, the 

dominant overstory species are green ash, American 

elm, and basswood, intermixed with other species 

such as white birch, bur oak, and aspen. The two 

dominant species in the understory are green ash 
Chapter 3 — Refuge Resources and Description 25

Figure 7. Vegetative communities within Sullys Hill National Game Preserve.
26 CCP, Sullys Hill National Game Preserve, ND

and chokecherry. Other species that occur in the 

understory are bur oak, American elm, and aspen. 

Western snowberry is the primary shrub species; 

however, a few Juneberry shrubs also occur. Forbs 

also flourish in the understory, including species such 

as wild sarsaparilla, poison ivy, meadow rue, cow 

parsnip, golden alexander, and even a few unique 

orchids. Past management in these forests was 

primarily idleness, with an occasional fire and minor 

selective harvesting activities. 

Grasslands

Grassland acreage lost in North Dakota since 

settlement is estimated at upwards of 70% (Conner 

et al. 2001). More vividly stated, <1% of the original 

eastern tall-grass prairie and about 32% of the 

mixed-grass prairie remain in North Dakota (Samson 

and Knopf 1994, Samson et al. 1998). Grasslands 

throughout Sullys Hill National Game Preserve are 

situated in the mixed-grass prairie of the drift prairie 

physiographic region; however, the tall-grass prairie 

can be found just east of the refuge boundary. Plants 

of the refuge’s prairie are characterized by the warmseason grasses of the short-grass prairie to the west 

and the tall-, cool- and warm-season grasses to the 

east. This ecotonal mixing from the west and east 

causes the mixed-grass prairie to possess more plant 

species than other types of prairies, including short-, 

intermediate-, and tall-grass species (Samson et al. 

1998). 

Vegetation composition at the regional and local 

levels was determined by several interrelated 

factors, including elevation, topography, climate, soil 

characteristics, herbivory, and fire (Coupland 1950, 

Hanson and Whitman 1938). Based on the locality of 

the refuge, local vegetative associations would have 

been more mesic (adapted to an environment having 

a balanced supply of moisture) than areas to the 

west. The drift prairie physiographic region of North 

Dakota is classified in the wheatgrass—bluestem—

needlegrass category. Species characteristic of this 

region include slender wheatgrass, little bluestem, 

fringed sage, white sage, white prairie aster, side-oat 

grama, blue grama, purple coneflower, prairie 

Junegrass, blazing star species, silver-leaf scurf-pea, 

prairie rose, goldenrod species, needle and thread 

grass, and green needlegrass (Kuchler 1964). With 

influence from the adjacent tall-grass prairie, many 

notable grasses from this grassland type are present, 

including big bluestem, Indiangrass, and switchgrass. 

Prairie grasslands function similar to a living 

organism by responding to activities within the 

ecosystem. They evolved with natural disturbances 

such as fire and herbivore grazing, and changes 

or interruptions in these processes, coupled with 

variations in climate, alter species composition. 

The prairie forbs and grasses have developed 

biological adaptations that enable them to thrive with 

herbivore grazing. Manske (2000) states that grazing 

pressures actually increased grassland expansion 

through coevolution with mammals. The evidence of 

fire as a historical natural disturbance suggests that 

native people used fire in hunting, and often natural 

fires occurred with lightning strikes. Fire continues 

to serve as a valuable tool to rejuvenate the growth 

of native plants and reduce woody and exotic plant 

invasion. Another significant change after burning 

is the increase in the number of plant species, 

which likely attracts several species of indigenous 

wildlife as vegetation structure (height, density) is 

diversified and the range of potential food resources 

is increased. Several sources indicate that native 

grasslands devoid of grazing and fire deteriorate 

quickly (Anderson et al. 1970, Kirsch and Kruse 1973, 

Schacht and Stubbendieck 1985). 

Across North Dakota, these natural disturbance 

regimes are necessary to sustain ecosystems, but 

are mostly absent due to human interventions that 

modified the physical and biotic conditions of the 

landscape (Hobbs and Huenneke 1992). Domestic 

cattle replaced native grazers such as the American 

bison and prairie dog, which exhibit different grazing 

behaviors and affect vegetation differently (Schwartz 

and Ellis 1981). Uncontrolled fires were another 

natural process that maintained the biotic integrity 

of prairie grasslands, but are not currently a regular 

part of sustaining the ecosystem. Even though native 

remnants remain in the mixed-grass prairies, most 

tracks of land are extremely degraded (Johnson and 

Igl 2001). Rather than a diverse and varying habitat 

structure across the landscape, the current patches of 

grassland are relatively simple and uniform, and not 

necessarily advantageous to the indigenous wildlife 

that evolved within this ecosystem. 

Grasslands across Sullys Hill National Game 

Preserve cover 580 acres, including 252 acres 

of native sod and 328 acres of old cropland. For 

the purpose of this CCP, native sod is defined as 

grassland that has never been broken by mechanical 

means (that is, plowed). Conversely, old cropland 

areas were previously cultivated and reseeded to 

smooth brome and alfalfa for the purpose of ungulate 

forage. The distinction between grassland types is 

critical because the system potential (for example, 

what plants will be favored or discouraged under 

the given environmental conditions) and associated 

management options (the use of mechanical 

disturbances) differ between lands that have and 

have not been previously plowed. The big game 

prairie is native sod managed by the grazing of 

Rocky Mountain elk and bison since 1917 and 1918, 

respectively. These areas of native sod are isolated 

patches embedded within the big game forest of 

the refuge. According to the refuge’s “Fenced 

Animal Management Plan” (Veikley 1984), the elk 

population ranges from 15–20 animals in the winter 

to 20–25 animals in the summer. Similarly, the bison 

population ranges from 25–30 in the winter and 30–40 

in the summer. Grazing by these animals has been 

the primary management for these native sod areas 

in the big game prairie. Although invaded by smooth 
Chapter 3 — Refuge Resources and Description 27

brome and Kentucky bluegrass, these areas support 

several native grasses such as western wheatgrass, 

bearded wheatgrass, green needlegrass, and big 

bluestem, along with several native forbs including 

prairie smoke, goldenrod, white sage, and scarlet 

gaura. 

Another tract of native sod associated with Sullys 

Hill National Game Preserve is the south prairie (see 

figure 6, management units map). Historically, this 

area was under a management regime of idleness 

except for sporadic wildland fires, primarily caused 

by arson. In the past few years, prescribed fire has 

been consistently used in an attempt to reduce the 

smooth brome, Kentucky bluegrass, and woody 

species present. Baseline data collected in 2007 using 

the belt-transect method (Grant et al. 2004) indicates 

that current vegetative composition includes 31.4% 

smooth brome and Kentucky bluegrass groupings, 

nearly 7% silverberry and western snowberry 

groupings, and slightly more than 61% native grass 

and forb groupings. The primary native grass 

identified across this field is porcupine grass, as well 

as plains muhly, bearded wheatgrass, upland sedges, 

and big bluestem. Also prevalent are a diversity of 

forbs, notably wood lily, pasqueflower, prairie smoke, 

blanket flower, black-eyed Susan, northern bedstraw, 

goldenrod, and many more. The plant association 

sheet used for the baseline data is included in 

appendix F. The 328 acres of old cropland that occur 

at the refuge have been historically hayed annually 

as winter forage for the ungulates in the big game 

forest and prairie units. Dominant plant species in 

these fields are smooth brome and alfalfa. These 

areas were last seeded to these introduced species 

more than 15 years ago.

Wetlands

Wetlands are areas where saturation with water 

is the dominant factor determining the nature of 

soil development and the types of plant and animal 

communities living in the soil and on its surface 

(Cowardin et al. 1979). Wetlands are extremely 

productive and important to both migratory birds 

and other resident wildlife. They serve as breeding 

and nesting habitat for migratory birds and as 

wintering habitat for many species of resident 

wildlife. Humans also benefit from wetlands because 

these habitats improve water quality and quantity, 

reduce the effects of flooding, and provide areas 

for recreation. Wetlands associated with the refuge 

are located in the Prairie Pothole Region. They 

are characterized by numerous depressions that 

are relatively shallow and dominated by emergent 

plants. These are referred to as palustrine wetlands, 

and specifically in North Dakota, these wetlands 

occupy the millions of shallow basins that resulted 

from glacial scouring and the melting of buried blocks 

of glacial ice (Kantrud 1983). 

The refuge is located within the Devils Lake Basin 

and bordered by Devils Lake, proper. Unlike the 

other wetlands across the refuge, Devils Lake is a 

lacustrine wetland, meaning it typically includes 

large areas of open water with active, wave-formed 

shorelines and no persistent emergent vegetation in 

the central or deepest zones (Kantrud 1983). With 

the current record-high water levels of Devils Lake, 

over 200 acres of the refuge are underwater as of the 

writing of this document. 

Finally, several freshwater springs occur throughout 

the refuge with moderate out-flows. One spring was 

developed for use as a permanent watering site for 

big game in 1940, but is no longer functional for this 

purpose. These springs are perhaps an option for 

wildlife watering in the future.

Wildlife

Birds

Although prairie woodlands occupy only about 1% 

of the northern Great Plains (Girard et al.1989), 

their significance to the natural resources is 

disproportionate (Rumble and Gobeille 1998). These 

woodlands contribute to local and regional avian 

diversity (Knopf and Samson 1994) and serve as 

important breeding and migratory habitat (Moore 

et al. 1995, Rodenhouse et al. 1995). The forested 

areas of the refuge likely provide habitat for forest 

species (such as red-eyed vireo, rose-breasted 

grosbeak, veery, and ovenbird) that have shown 

regional or continental population declines. Collected 

baseline data identified 184 bird species across the 

prairie, woodland, and wetland communities of the 

refuge (see appendix F). However, considering 

these varying habitats, it is estimated that up to 

270 species may use the refuge for both breeding 

and as a stopover site. Several of the species that 

use the woodlands are considered forest-interior 

breeding birds and require large unfragmented 

blocks of forested habitat, which the refuge provides. 

A few birds characteristic of this habitat include 

ovenbird, pileated woodpecker, hairy woodpecker, 

black and white warbler, veery, and red-eyed 

vireo. The red-eyed vireo, yellow warbler, common 

yellowthroat, eastern wood peewee, ovenbird, and 

least flycatcher are the most frequently detected 

woodland species recorded during refuge baseline 

data collections. In addition, bald eagles frequent the 

refuge as a staging area during the spring and fall 

migration and typically use the edge of Devils Lake 

that borders the eastern section of the lower forest. 

The grasslands of the refuge likely provide limited 

habitat for grassland-dependent birds, especially 

those species with high area sensitivity. The largest 

contiguous block of grassland habitat is currently 

the south prairie, at 150 acres in size, with other 

blocks throughout the refuge ranging from 1–15 

acres. These latter areas are buffered by the 

woodlands that typically surround the grasslands 

throughout the refuge. Bird species characteristic 
28 CCP, Sullys Hill National Game Preserve, ND

of the contemporary mixed-grass prairie of the drift 

prairie region of North Dakota are the Savannah 

sparrow, clay-colored sparrow, and bobolink. Based 

on baseline data collected throughout the grasslands 

of the refuge, the most frequently detected grassland 

birds are the bobolink, grasshopper sparrow, and 

clay-colored sparrow. 

The wetlands of the refuge support several species of 

waterfowl as well as other wetland-dependent birds. 

Canada geese, mallards, wood ducks, blue-winged 

teal, hooded mergansers, northern shovelers, and 

gadwalls are all considered abundant or common 

at the refuge during the breeding season (USFWS 

2004). Several wading birds also use the refuge 

wetlands, most commonly the black-crowned 

night-heron and less commonly the great blue heron. 

In addition, double-crested cormorants and American 

white pelicans are considered abundant, especially on 

the wetlands contiguous with Devils Lake. 

Wild turkeys were brought to North Dakota more 

than a half-century ago through an introduction 

program spearheaded by the Izaak Walton League 

(Wilson 2004). At Sullys Hill National Game 

Preserve, turkeys were first introduced in 1989 

and again in 1998. In 1989, 24 Merriam’s turkeys 

were transferred from J. Clark Salyer National 

Wildlife Refuge, and in 1998, 16 eastern turkeys 

were transplanted from Judson, North Dakota. This 

species remains a prominent wildlife species in the 

big game forest of the refuge, with the population 

averaging 20–50 animals, dependent upon several 

variables such as climate and sex ratios. 

Mammals

Sullys Hill National Game Preserve is prominently 

known for its resident plains bison and Rocky 

Mountain elk, the preservation and protection of 

which is a purpose of the refuge. The following 

sections describe these and other mammals that use 

refuge resources. 

Bison

In eastern North Dakota, it is hypothesized that 

bison existed, at one time or another, within every 

square mile of the eastern part of the state. The 

examination of journals and diaries of explorers and 

adventurers to the area indicate that bison, before 

1880, were plentiful all the way up the Sheyenne 

River to Devils Lake. Although considered a 

creature of the open grasslands, there is evidence 

that bison used woodland and riparian areas in 

search of water and shelter from winter storms 

in the region. It is suggested that bison regularly 

moved between seasonal ranges, wintering in the 

aspen parklands or woodland areas and summering 

on the open prairie (Epp 1988, Moodie and Ray 

1976; Morgan 1980). Some theories disagree with 

the concept that all bison were this migratory, while 

other sources indicate that some herds migrated 

and some did not. A synthesis of historical records 

concludes that bison moved in response to local 

conditions of forage availability, influenced by 

weather, fire, and previous grazing. For example, 

Epp (1988) states that bison would remain in wooded 

areas for the duration of the year if their needs for 

forage, water, and shelter were met. Year-to-year 

variations in environmental conditions, including 

weather, fires, and human interference, would have 

driven the migratory behaviors of bison (Severson 

and Sieg 2006). Considering this information, it is 

evident that bison were present in the region of 

Devils Lake and likely would have used woodland 

habitats at least for protection during winter months, 

and possibly more frequently on a variable and 

sporadic basis.

Estimates of the number of North American bison, 

pre-European settlement, vary significantly, but 

bison likely occurred in the tens of millions (Shaw 

1995). A variety of theories exist as to the reasons 

for the rapid decline of bison, including the following: 

the mid-1800s commercial slaughter, American 

Indian hunting, trade pressures, the introduction 

of horses to native cultures, the division of the 

plains by railroads, and finally, newly introduced 

bovine diseases. Commercial slaughter of bison in 

the mid-1800s likely played the most significant 

role in the bison population reduction of the 1800s. 

Estimates of remaining bison in the late 1800s vary 

between approximately 600 and 1300. Formation 

of the American Bison Society in 1905 resulted in 

congressional establishment of six federally managed 

public bison conservation herds between 1907 and 

1919. Four of these herds are currently managed by 

the U.S. Fish and Wildlife Service, while both the 

Yellowstone and Wind Cave National Park herds, 

established in 1902 and 1913, are managed by the 

National Park Service (Boyd 2003, Halbert 2003). 

Six bison were introduced into the refuge in October 

1918 from the Portland City Park, Portland, Oregon. 

Herd structure included the herd matriarch and 

her offspring (two bulls and three cows). Based on 

historical documentation, it is believed that the herd 

matriarch was obtained by the Portland City Park 

from the Conrad herd around 1906 through a trader 

named B.H. Denison in Ravilli, Montana. In 1932, the 

first introduction since the establishment of these six 

occurred with a bull from Wind Cave National Park. 

Nine other introductions are recorded between 1941 

and 1997, including bison from the National Bison 

Range, Fort Niobrara National Wildlife Refuge, 

and Theodore Roosevelt National Park. Since 1980, 

herd numbers averaged 30 animals at the refuge, 

with the highest population of 40 occurring in 2006. 

Recent genetic testing on the herd indicates that 

there is possibly no hybridization with domestic 

cattle, making this the only Service herd with such 

potential based on current methods of testing. In 

2006, this herd was transported to Fort Niobrara 

National Wildlife Refuge in Valentine, Nebraska, 

for propagation into a “minimum viable population,” 
Chapter 3 — Refuge Resources and Description 29

which would include several hundred to a couple 

thousand animals. Subsequently, seven bison from 

the National Bison Range in Moiese, Montana were 

transferred to the refuge to start a new herd. Based 

on current methods of genetic testing and analysis, 

these new animals do not possess cattle hybridization 

and come from a herd that holds more unique alleles 

(an alternative form of a gene that is one member of 

a pair) than any other herd across the U.S. Fish and 

Wildlife Service. 

Rocky Mountain Elk

Records indicate that elk were also plentiful 

throughout the region before European settlement. 

According to Severson and Sieg (2006), they 

appeared nearly everywhere, specifically in habitats 

close to woodland cover, including the Red River 

Valley and its tributaries, such as the James River 

and Devils Lake. During the 1860s, it is recorded 

that elk were especially common along the wooded 

areas of the Sheyenne River and Devils Lake. Based 

on a review of early documentation of the region, 

elk were mentioned more frequently than any other 

animal except bison. Most sources agree that elk 

did not migrate and likely spent significant amounts 

of time in the wooded areas rather than in the 

open grasslands. By the 1880s, they appeared to be 

extirpated from the region east of the Missouri River 

(Severson and Sieg 2006).

Refuge records indicate that 15 elk were brought 

from Yellowstone National Park to the refuge in 

1917. Historical data specifies that subsequent 

introductions of elk did not occur until 1941, when a 

bull elk was brought in from Fort Niobrara National 

Wildlife Refuge in Valentine, Nebraska. It appears 

that approximately five other animals were brought 

in between 1949 and 1991, mostly bulls from Fort 

Niobrara. In 1993, three elk (two females and one 

male) were transferred from Teddy Roosevelt 

National Park, in Medora, North Dakota, to the 

refuge. Currently the refuge maintains about 20–25 

elk.

White-tailed Deer

Records specify that only a few scattered populations 

of white-tailed deer occurred in suitable habitat 

across eastern North Dakota. It is possible that the 

abundant elk populations may have been a factor 

in the limited number of deer (Severson and Sieg 

2006). According to Roger Johnson, a big game 

biologist, NDGF, pre-settlement deer populations 

were notably lower than current day numbers. As 

an example, currently deer numbers in the area 

average 2–3 animals per acre. Even 20 years ago, 

deer populations were less then one animal per acre 

(Roger Johnson, big game biologist, NDGF, Devils 

Lake, ND; personal interview, 2007). 

Historical data evidences that four white-tailed deer 

were introduced into the refuge around 1917 from 

Fargo, North Dakota. Later introductions occurred 

in 1947 with a buck from the Camp Grafton National 

Guard campus near Devils Lake, North Dakota, 

and a local buck from the Devils Lake area in 1952. 

Populations of deer have ranged from 10–50 animals 

since introduction, with current numbers around 

15–30.

Prairie Dogs 

Prairie dogs are native to North Dakota but 

primarily are found in western expanses of the state. 

The black-tailed prairie dog was introduced into the 

refuge in 1974. The current prairie dog town covers 

about 1.5 acres in the big game forest and prairie 

and includes several hundred dogs. Prairie dogs can 

significantly alter habitat and can quickly expand 

their range if they are not monitored and managed. 

Other Mammals

Sullys Hill National Game Preserve also supports 

several other less conspicuous mammals for 

which active management is not implemented. 

Representative species using the refuge include 

coyote, grey squirrel, red fox, eastern cottontail, 

badger, beaver, raccoon, striped skunk, fisher, 

muskrat, fox squirrel, weasel, mink, woodchuck, deer 

mouse, and meadow vole. Based on the checklist 

of state mammals (Wiehe and Cassel 1978), it is 

anticipated that more than 35 mammal species could 

occur across the refuge. Extremely limited data are 

available for these mammals in this area of North 

Dakota and specifically at the refuge. One study 

was completed in 1979–1980 on fox squirrel activity 

and time budgets on the refuge (Nelson 1981), and a 

current study is underway to census fishers across 

the refuge and in eastern North Dakota. 

Insects, Reptiles, Amphibians, and Fish

Inventories of other wildlife, such as invertebrates 

and reptiles and amphibians, are limited. The only 

known survey in this category was completed by 

Royer et al. (1998), who developed a comprehensive 

butterfly list for the refuge (see appendix F). 

Throughout the woodland and grassland habitats 

of the refuge 50 species were identified and it is 

speculated that up to 19 more species could likely 

occur. Royer et al. (1998) indicated that there is a 

remote possibility that a Dakota skipper could occur 

on the south prairie, perhaps among the purple 

coneflowers. 

Several species of fish also occur at the refuge in 

areas that interconnect with Devils Lake. Although 

fish surveys or inventories have not occurred on the 

refuge, common species present across Devils Lake 

include walleye, northern pike, yellow perch, white 

sucker, white bass, and black crappie. 
30 CCP, Sullys Hill National Game Preserve, ND

Tiger Swallowtail Butterfly

© Cindie Brunner

3.3 CULTURAL RESOURCES 

The following information concerning cultural 

resources is taken directly from the following 

document, “Sullys Hill National Game Preserve: 2003 

Archaeological Survey and Test Excavations, Benson 

County, North Dakota” (Jackson et al. 2004).

Human occupation of the northern plains is 

documented as early as 12,000 years ago, first 

by American Indians and much later by EuroAmericans. The various human adaptations to the 

northern plains environment that have taken place 

over time, in what is North Dakota today, have 

come in response to basic changes in climate and 

the movements of people, technology, and ideas. 

Prehistoric cultural traditions that reflect essential 

settlement-subsistence patterns and technological 

complexes have been defined on the basis of 

archeological investigations at sites in the northern 

plains, particularly North Dakota (Frison 1991, 

Gregg 1984, Lehmer 1971, Schneider 1982). Such 

cultural traditions are generally sequential, but often 

exhibit some temporal overlap. 

The cultural environment of what is now North 

Dakota is described within the framework of a 

regional cultural chronology that is continually being 

expanded and refined as archaeological and historical 

research produces new information on past human 

occupation of the area. It is organized into periods 

that are, for the most part, named for the cultural 

traditions that dominated those times. Cultural 

periods also imply differences in certain aspects 

of material culture, particularly basic technology, 

as represented by distinctive artifact types and 

assemblages. The project area is located in the 

Sheyenne River Study Unit of the “North Dakota 

Comprehensive Plan for Historic Preservation: 

Archeological Component” (Haury 1990). The 

reader is referred to this document for additional 

information on the cultural-historical setting of 

the refuge. More detailed information specific to 

the Devils Lake area is also available in recent 

archeological reports (Jackson and Toom 2002, Toom 

et al. 2000). A brief outline of the region’s cultural 

history of the project area follows.

The regional chronology, as it exists today, is useful 

for organizing and describing identified cultural 

manifestations. It is presented within a framework 

of five basic periods: (1) Paleo-Indian, (2) Plains 

Archaic, (3) Plains Woodland, (4) Plains Village, 

and (5) Historic. The names of the first four periods 

also refer to mainly prehistoric American Indian 

cultural traditions, with the Plains Village tradition 

extending into early historical times. The Historic 

period encompassed that span of time following the 

decline of the Plains Village tradition and the rise 

of the Plains Equestrian tradition, as a result of 

the introduction of the horse and Euro-American 

manufactured trade goods among native peoples. 

It subsumed American Indian lifeways during 

protohistoric and early historic times in the northern 

plains, from about A.D. 1780–1880 (State Historical 

Society of North Dakota 1990). Later in the 

Historic period, at the end of the Plains Equestrian 

tradition—A.D. 1880, the Euro-American tradition 

became dominant.

The dominant historical influence in the specific 

project area was the 1867 establishment of Fort 

Totten. It served as a military base to control and 

protect the Sioux residents of the newly formed 

reservation on the south shore of Devils Lake. 

Fort Totten functioned as a military fort until 

1890, and soon after that the post consolidated 

with the Catholic mission school and served as an 

industrial school for the reservation (DeNoyer 1910, 

Robinson 1966, Wertenberger 1967). The industrial 

school was closed in 1935 and the post served as a 

tuberculosis sanitarium until 1939 (Friends of Fort 

Totten Historic Site, no date). The fort then served 

as a community school until 1959 and in 1960 it was 

formally transferred to the State Historical Society 

of North Dakota as a state historic site. Fort Totten 

is listed on the National Register of Historic Places 

and the North Dakota State Historic Sites Registry.

Sullys Hill National Game Preserve was originally 

part of the old military reservation. In 1904 

these lands were proclaimed as a national park 

by President Theodore Roosevelt and removed 

from military jurisdiction. Congress established 

the area as a big game preserve in 1914, jointly 

administered as a national park and game preserve 

by the Departments of Interior and Agriculture. In 

1921, it was also made a bird refuge. The refuge was 

transferred from the National Park Service to the 

U.S. Fish and Wildlife Service in 1931.

The earliest archeological reporting in what is now 

Sullys Hill National Game Preserve was done by 

T.H. Lewis in 1886 (Lewis 1898). Contracted by 
Chapter 3 — Refuge Resources and Description 31

Alfred J. Hill of St. Paul, Lewis conducted “field 

surveys of rapidly disappearing antiquities” for 

the privately funded Northwestern Archaeological 

Survey (Keyes 1928). Three mound sites (32BE1, 

32BE2, and 32BE27) within the present-day refuge 

were originally reported by Lewis. Two of these 

mound sites (32BE1 and 32BE2) were formally 

recorded by the Smithsonian Institution River Basin 

Surveys in 1946 (Mallory 1966). All three mound 

sites were revisited by a 1989 University of North 

Dakota (UND) survey crew to document and update 

information concerning all of the mound sites in 

North Dakota reported by T.H. Lewis (Haury 1990).

The Irvin Nelson site (32BE208) was originally 

recorded by Mallory (1966) after prehistoric artifacts 

and human bone had been found in the yard of the 

refuge manager’s residence. Before construction 

of a new headquarters building and maintenance 

shop at the site location, auger test excavations 

were conducted by UND in 1979 (Fox 1979). Based 

on the positive results, a formal test excavation 

program was recommended. Those investigations 

were conducted by North Dakota State University 

(NDSU) personnel in 1980 (Fox 1982). The cultural 

materials collected from the site are currently being 

reexamined by UND (Toom 2002).

Archaeological investigations conducted in 1991 by 

the North Dakota Department of Transportation 

along Highway 57 resulted in the recordation of 

two sites (32BE45 and 32BE46) and one site lead 

(32BEX74) within Sullys Hill National Game 

Preserve (Christensen 1991, 1992). Only the site 

lead (32BEX74) is within the project areas reported 

herein. Lead site 32BEX74 was upgraded to an 

archaeological site and re-recorded as part of site 

32BE126.

In 1997, an emergency dike was slated for 

construction using fill from two borrow areas within 

the refuge. The removal of fill from the two borrow 

areas was carefully monitored, and the area to be 

impacted by dike construction was inspected for 

archaeological materials (Kinney 1997). Monitoring 

was conducted during the stripping operations until 

the excavators were below potentially culturebearing strata. No archaeological sites were found 

during the course of this work.

Service archeologist Rhoda Lewis conducted 

several cultural resource inventories before refuge 

improvements during the 1990s (Lewis 1995, 

1999a, 1999b, 1999c, 1999d). No archaeological sites 

were recorded over the course of these surveys. 

Four proposed project areas at the refuge were 

inventoried in 2002 by Lewis. The location of a new 

education and visitor center and an access road from 

Highway 57 were essentially the same locations 

as those investigated during the current survey 

project. The location of a residence and shop that was 

surveyed at that time is no longer a candidate for 

construction. Also, the stone pillared entrance gate 

to the refuge was recorded in 2002 as site 32BE114. 

It was recommended that subsurface excavations 

be conducted at the proposed education and visitor 

center location (Lewis 2002).

3.4 SPECIAL MANAGEMENT AREAS 

In addition to refuge status, lands may have 

additional designations which overlay refuge status. 

Wilderness

Although Sullys Hill National Game Preserve 

reflects some of the qualities desired in wilderness, at 

1,675 acres, the refuge does not meet the size criteria 

for wilderness designation, plus it has several miles 

of roads and trails within its boundary. 

N

Sullys Hill National Game Preserve was designated 

by the state as 1 of only 19 natural areas in North 

Dakota. Four of these 19 areas are national wildlife 

refuges, including Sullys Hill National Game 

Preserve. Areas given this designation have special 

qualities found only on undeveloped land. These 

qualities represent glimpses through a window in 

time on a portion of North Dakota’s presettlement 

landscape—a “living history.” This designation also 

signifies the existence of a diverse array of native 

plants and wildlife that belong together in finely 

tuned natural communities, places of inherent beauty 

and interest, outdoor classrooms for teaching life 

sciences and earth sciences, outdoor laboratories, 

and benchmarks against which to gauge landscape 

changes (Umber 1988). The refuge possesses all of 

these unique qualities.

3.5 VISITOR SERVICES

The Act of March 3, 1931 established recreation as 

one of the purposes of Sullys Hill National Game 

Preserve.

Children’s Activity

Scott Ralston/USFWS
32 CCP, Sullys Hill National Game Preserve, ND

HuntinG and fisHinG

The legislative purposes for Sullys Hill National 

Game Preserve do not allow hunting on the refuge. 

Currently, public fishing is not permitted on the 

refuge due to a lack of available resources to manage 

this use and its impacts to the refuge. In addition, 

the refuge fishery is minimal but is bordered by one 

of the most popular fishing areas in the state and the 

nation, Devils Lake. The refuge has used its limited 

fishery as an education tool to educate youth about 

the life cycles of fish and fishing techniques. 

Wildlife observation and PHotoGraPHy

Sullys Hill National Game Preserve hosts more 

than 60,000 visitors annually, most of which come to 

observe and photograph wildlife. The refuge provides 

outstanding opportunities due to the unique mix of 

prairie, forest, and wetland habitats that attract 

a rich diversity of resident and migratory wildlife. To 

accommodate these visitors, the refuge offers a 4-mile 

self-guided auto tour that travels down winding forest 

roads and eventually breaks into open prairie and 

savanna areas. Visitors on the auto tour can leave 

their vehicles to venture onto five observation 

platforms: the wetland, prairie dog town, Devils Lake 

vista, nature trail, and Sullys Hill overlooks. While on 

the auto tour, visitors have the opportunity to view 

and photograph plains bison, Rocky Mountain elk, 

white-tailed deer, turkey, and prairie dogs. 

The refuge features a mile-long nature trail and 

1.6 miles of trails for hiking and cross-country 

skiing. The nature trail observation platform allows 

visitors to observe a host of resident and migratory 

wildlife. The forests, interspersed with wetlands, 

provide opportunity to observe a host of bird 

species, including numerous warblers, wood ducks, 

kingfishers, hooded mergansers, and black-crowned 

night-herons. Birding opportunities are available 

all year. While warbler numbers peak in the month 

of May and in late October, bald eagles commonly 

stage on the refuge in late winter. Hardy species like 

pileated woodpeckers are also present in the winter. 

The fully accessible education and visitor center 

features a full wall of windows and an outside patio 

to observe a host of species frequenting the birding 

garden. Common species include rose-breasted 

grosbeak, American goldfinch, black-capped 

chickadee, and hairy woodpecker.

E

A 6,000-square foot education and visitor center was 

constructed in 2004. The center features a waterfowl 

photo gallery, a Rocky Mountain elk exhibit, 

and a birding garden. Facilities for learning also 

include two classrooms with dedicated audiovisual 

equipment, teaching aids, and instructional 

materials. This center has quickly become a regional 

conservation learning center for students and 

adults within a 90-mile radius of the refuge. Refuge 

staff, in cooperation with local teachers, provides 

educational presentations to over 5,000 students 

and other groups annually. The refuge also has a 

remote classroom to facilitate field-based learning 

opportunities. Currently, most of the environmental 

education is on-site.

I

The refuge hosts two annual events, “Sullys Hill 

Birding and Nature Festival” and “Winterfest”, with 

activities for both adults and children. The birding 

and nature festival has been attracting 1,200–2,100 

visitors from all over the country for the 3-day event. 

Winterfest is a 1-day youth-focused festival that 

attracts more than 100–200 participants each year. To 

plan and execute these festivals, refuge staff works 

closely with the Sullys Hill Wildlife Refuge Society, 

the refuge “friends group.” In addition to these 

special events, interpretive presentations and tours 

are provided upon request. The refuge also features 

an outdoor amphitheater to host interpretive 

programming.

The five observation platforms on the auto tour and 

nature trail include site-specific interpretive displays. 

The refuge also has two information and interpretive 

kiosks located at the refuge entrance and the 

education and visitor center. 

3.6 SOCIOECONOMIC ENVIRONMENT 

The goals and objectives of the CCP were developed 

after considering the socioeconomic conditions of the 

area surrounding the refuge.

GeoGraPHic and deMoGraPHic statistics

The population in Benson County, North Dakota was 

estimated at 6,997 in 2006. Since 2000, there has been 

a 0.5% gain in the county’s population. Although this 

number is low, this is actually better than the state of 

North Dakota, which saw an overall net loss of 0.1% 

in its population. There are 5 people per square mile 

in Benson County (U.S. Census Bureau 2006).

The majority of the land in the county is used for 

farming and livestock ranching. There are 567 farms, 

totaling 732,870 acres (53% of the county lands), with 

an average size of 1,294 acres. Major crops are corn, 

grains, soy beans, sunflowers, and sorghum grown 

on 558,127 acres. The remaining acres are used for 

various livestock grazing. The market value of the 

products produced on these farms totals over $55 

million (USDA 2002). 

The refuge is surrounded on three sides by the Spirit 

Lake Nation’s reservation boundary. The major 

race in the county is American Indian at 51.2%. The 

remaining residents are 48.1% White, 2.5% Hispanic, 

and 0.1% African American. (U.S. Census Bureau 
Chapter 3 — Refuge Resources and Description 33

2006). In 2000, 73.8% of county residents were 

high school graduates, while 10.9% had obtained a 

bachelors degree or higher.

C

The median household income in Benson County 

in 2004 was $28,058, with 22.4% (national average 

is 9.2%) of the population below the poverty level. 

Educational, health, and social services employ the 

majority of the county residents. The greatest source 

of income for the county is federal spending at $126 

million in 2004. The unemployment rate in the county 

is 7.4% (U.S. Census Bureau 2006). 

R

Sullys Hill National Game Preserve is one of the 

primary economic engines in the lake region for 

recreation and tourism. The Devils Lake region is 

well known for its fishing, hunting, bird watching, 

camping, history, culture, and other associated 

outdoor recreation. The refuge, in consort with 

myriad other outdoor adventures, provides a 

total and unique experience for the visitor, while 

generating important revenues for the local economy.

The refuge attracts 60,000 visitors annually. In a 2006 

review of visitation, guests from 44 states used the 

refuge, and 45% of the total visitors that year were 

from outside North Dakota. 

There have been many studies on the economic 

benefits of national wildlife refuges and the outdoor 

recreation industry. A 2006 report by the Outdoor 

Industry Foundation did a review of eight outdoor 

activities, including bicycling, camping, fishing, 

hunting, paddling, snow sports, trails and hiking, 

and wildlife viewing. The report states that these 

activities contributed $730 billion annually to the 

United States economy. The industry generates $289 

billion in retail sales and services across the country 

while supporting 6.5 million jobs. The sector that 

had the highest participation was wildlife viewing, 

with 66 million citizens. Sullys Hill National Game 

Preserve is most known for its wildlife viewing 

opportunities.

The “National Survey of Fishing, Hunting, and 

Wildlife Associated Recreation” has been completed 

every 5 years since 1955. In 2006, 87 million 

Americans 16 years old and older (38% of the U.S. 

population) enjoyed some recreational activity 

related to fish and wildlife. Dollars expended by this 

group in 2006 for wildlife-related recreation was 

$120.1 billion. The largest component of this survey 

was also wildlife watching, with the average wildlife 

watcher spending $628.00 annually on this activity. 

In the north-central region of the survey area, 

which includes North Dakota, 44% of this population 

participated in wildlife watching activities. The 

report states that $20.5 million was spent on wildlife 

watching in North Dakota.

Another study looked at the economic impact of 

birding ecotourism on communities surrounding 

eight national wildlife refuges in 1993–1994 

(Kerlinger 1994). Birder visitation at these refuges 

ranged from 17,000 to 200,000 annually. The average 

age of visitors was mid-40s to lower 50s. Family 

incomes and education levels were far greater than 

the national average. More than 70% reported they 

had attended some college. More than 50% of visitors 

were traveling with a spouse. Two measures of 

economic activity were calculated: total amount spent 

by visitors and total economic impact of visitors 

on the communities surrounding a refuge. The 

actual economic impact of visitors on communities 

surrounding each of the refuges ranged from slightly 

less than $1 million to $14 million. One refuge that 

had some similarities to Sullys Hill National Game 

Preserve was Salton Sea National Wildlife Refuge, 

which had an annual visitation of 60,000 (same as 

Sullys Hill National Game Preserve). The average 

amount spent on a visitor’s entire trip to Salton Sea 

was $670 per person and the average visitor was 

worth between $38 and $57 to the local community. If 

this figure is averaged at $47.5 per visitor and 60,000 

visitors to the refuge, the economic impact to the 

local community is $2.8 million in 1993–94 dollars. 

A 2004 report completed by Leistritz, Hodur, 

and Wolfe (Leistritz et al. 2004) looked at a local 

birding festival in Jamestown, North Dakota. Total 

expenditures for all participants averaged $235 

during the course of the 4-day event. Expenditures in 

the local Jamestown area were $162 per participant. 

Sullys Hill National Game Preserve is an important 

refuge for migratory birds, as well as large mammals 

such as plains bison and Rocky Mountain elk. This 

refuge is also an important location for tourism 

and a vital attraction that brings money into the 

surrounding communities. 

3.7 OPERATIONS

S

Historically, the refuge was a stand-alone station 

and had a manager and biological technician 

located on-site. Approximately 35 years ago, the 

refuge became part of the Devils Lake Wetland 

Management District Complex. The staff was cut in 

half, leaving only a manager assigned to the refuge. 

The overall budget is quite modest, including the 

salary for the manager and a very modest operating 

budget. The success of the refuge program is heavily 

dependent upon the “friends group” and other 

volunteers to conduct refuge programs. 

F

Facilities have remained fairly updated over the 

years. Overall, facilities are used to carry out habitat 

and wildlife management, as well as the popular 
34 CCP, Sullys Hill National Game Preserve, ND

environmental education, interpretation, and 

wildlife-oriented visitor services program. Current 

total visitation is 60,000 visitors annually. Refuge 

visitors are charged an entrance fee of $2.00 or may 

use their annual refuge pass. Most of this money 

remains at the refuge to maintain facilities and 

conduct visitor services programs. 

Facilities on site include the following: 

Q 6,000–square foot education and visitor center 

with office

Q 40-foot by 100-foot maintenance shop and 

storage facility

Q Three bedroom manager’s quarters

Q Two buildings for fire operations and one for 

biological equipment storage

Q Three bedroom bunkhouse for seasonal fire 

staff

Q Five overlooks

— Devil’s Lake Vista

— Sullys Hill overlook

— Wetland overlook

— Prairie dog town overlook

— Nature trail overlook

Q 4-mile asphalt auto tour route and parking lot

Q 28-foot by 32-foot remote classroom

Q Nature trail

Q Amphitheater

Q Fenced boundary including electric entrance 

gate with timer

Q Kiosks and interpretive signs

Q Entrance sign with lighting

Q Two remote self-contained restrooms

Q Hay pen

Q Fuel tanks

Q Two trailer pads with water and power (for 

volunteers)

PartnersHiPs

Sullys Hill National Game Preserve is able to 

accomplish much of the work and mission through 

the use of various partnerships including those with 

the Spirit Lake Nation, friends, volunteers, and 

supporting agencies.

The Sullys Hill Wildlife Refuge Society was 

North Dakota’s first refuge “friends group.” This 

organization is instrumental in facilitating special 

events such as the “Sullys Hill Birding and Nature 

Festival” and “Winterfest.” This group is also a 

cooperating association and supports the refuge in 

many ways, including advocacy, and staffing the gift 

shop and the education and visitor center.

The refuge receives much needed help through grants 

or matching money from nongovernmental associations, 

internships, and research; university partnerships; 

various volunteers; school system partnerships; and 

local and state agencies or organizations.

Black-crowned Night-heron

Scott Ralston/USFWS
4 Management Direction

Group on trail.

Scott Ralston/USFWS

This chapter describes the management direction the 

Service designed, with public coordination, to

achieve the vision for the Sullys Hill National Game 

Preserve as described in chapter 2. The chapter 

includes the following sections:

Q management focus

Q goals, objectives, strategies, and rationale

Q staffing and funding

Q step-down management plans

Q monitoring and evaluation

4.1 MANAGEMENT FOCUS

Sullys Hill National Game Preserve has a 

tremendous opportunity and the facilities to serve 

a conservation learning center for this part of the 

region. The refuge has a 6,000 square foot visitor 

center along with indoor and outdoor classrooms, 

a proposed amphitheater, and many opportunities 

for visitors to view and learn about native wildlife 

in North Dakota. The refuge is also managed by the 

Devils Lake Wetland Management District. The 

district has a mission of conserving prairie wetlands 

and grasslands in the Devils Lake Basin, one of the 

most important areas in the nation for nesting and 

resting waterfowl and other migratory birds. The 

Sullys Hill National Game Preserve will serve as 

an outreach tool for adults and children to learn and 

appreciate refuge resources, as well as gain a greater 

understanding of the importance of conserving 

wetland and grassland habitats in North Dakota and 

other parts of the Prairie Pothole Region.

For decades, the refuge has been very popular with 

the public, with annual visitation estimated at over 

60,000. Most come to view the resident wildife, 

including the bison and elk, and enjoy the refuge 

trails, education and visitor center, and auto tour. The 

refuge also hosts several annual events attended by 

thousands of individuals from all over the country. 

This combination of visitor facilities, activities, 

and events, combined with many opportunities 

to view wildlife, provides a unique combination 

that has resulted in a widespread impact on the 

environmental ethics and conservation values of 

citizens surrounding the refuge and across the 

country. There are opportunities to increase outreach 

to local schools whose students are the future 

landowners and leaders in this state. Working with 

teachers to develop curriculum that meet state and 

local standards will encourage schools to pursue the 

unique opportunities to use the refuge’s resources 

to teach math, science, and reading. Teachers could 

achieve their educational goals while their students 

are learning about nature hands on, not just in books 

or on the computer. These additions to public use will 

require more staff and volunteers than are currently 

conducting refuge programs. This plan proposes not 

only the conversion of the refuge manager position 

to a visitor services specialist, but the addition of an 

expert in environmental education. 
36 CCP, Sullys Hill National Game Preserve, ND

The refuge’s habitats are a unique combination 

of woodlands and prairie interspersed with some 

wetland areas. The refuge has mandated purposes 

as a big game preserve and as a refuge for migratory 

birds. The refuge maintains a captive herd of large 

ungulates, including bison and elk. These animals 

can impact refuge habitats if there are no time or 

space restrictions to grazing, and if the numbers of 

animals exceed the limits of habitats to recover and 

regenerate. This has negative impacts on not only 

the animals themselves, but also on the woodland and 

grassland birds which are dependent on these unique 

habitats. To address these impacts, exclusion fences 

will be constructed in the big game unit and ungulate 

numbers will be reduced. 

The native prairie areas will be enhanced through 

biological and mechanical means, including 

prescribed fire and control of invasive species. Some 

other grassland areas will be restored to a diversity 

of prairie native plants. The overall guidance for use 

of prescribed fire and management of wildland fire 

is found in the description of the fire management 

program (appendix G). All invasive species will 

be controlled throughout the refuge through 

chemical, biological, and mechanical integrated pest 

management techniques. 

The bison found on the refuge have been found 

to be genetically similar to the great native 

American plains bison herds. The refuge is part of a 

Department of Interior and U.S. Fish and Wildlife 

Service program to maintain the genetic health of 

these unique bison found here and on other big game 

refuges. This refuge will expand the monitoring of 

herd health and the receiving and transferring of 

bison to other refuges in this program. 

An increase of three full-time employees, some 

shared with the Devils Lake Wetland Management 

District, will have a noticeable impact on the ability 

to conduct site specific research; build and maintain 

partnerships; develop goal-oriented, step-down 

management plans; significantly expand the visitor 

services, outreach, and environmental education 

programs; ensure the safety of staff, visitors, wildlife, 

and facilities; and guide future management direction 

of this refuge. 

The planning team developed objectives in support of 

goals identified in chapter 2 to carry out the proposed 

action for management of the refuge. Strategies 

to achieve objectives are suggested. Rationale is 

included that supports these goals, objectives, and 

strategies. 

The National Wildlife Refuge System Administration 

Act of 1966 required the Secretary of the Interior, 

before permitting uses, to ensure that those uses 

are compatible with the purposes of the refuge. The 

CCP process requires a compatibility determination 

for all existing and proposed refuge uses. 

Compatibility determinations for the refuge include 

fishing, environmental education purposes, wildlife 

observation and photography, and environmental 

education and interpretation. The compatibility 

determination is found in appendix H.

4.2 GOALS, OBJECTIVES, STRATEGIES, 

AND RATIONALE

A goal is a descriptive, broad statement of desired 

future conditions that conveys a purpose but does not 

define measurable units.

An objective is a concise statement that indicates 

what is to be achieved, the extent of the 

achievement, whom is responsible, and when and 

where the objective will be achieved.

The strategies describe the actions needed to achieve 

the objectives.

The rationale for each objective provides context, 

such as background information, assumptions, and 

technical details. 

Prairie Habitat Goal

Maintain prairie plant communities representative of 

the historical mixed-grass prairies to support healthy 

populations of grassland-dependent migratory birds 

in balance with bison, elk and other indigenous 

wildlife.

Big Game Prairie Unit Objective 

Create a diverse vegetative composition and 

structure that contains ≥50% native grasses (cool 

and warm season), 5–15% native forbs, and ≤2% 

native shrubs. At the same time, control invasive 

cool-season grasses at ≤30%, and control invasive 

plant infestations to <10% coverage on the grazed 

prairie areas within the big game prairie. This 

managed native prairie will be used over the next 15 

years by grazing bison and elk while still providing 

habitat for migratory birds dependent on forest-edge 

habitat. 

Strategies

— Use prescribed fire, prescribed grazing, and 

various IPM strategies at appropriate times 

to enhance native plants while reducing the 

presence of invasive species. Allow prescribed 

fire to burn into woodland margins and from 

one native grass remnant to another, where 

possible.

— Mow and cut to remove brush and shrub for 

maintenance of subsequent prairie and savannalike areas. 

— Develop another water source for better 

dispersal of ungulates.
Chapter 4 — Management Direction 37

— Partner with the Natural Resource 

Conservation Service to establish “Natural 

Resource Inventory” survey points within 

the big game prairie to monitor the results of 

management. 

— Use fuel treatments (including prescribed fire 

and other mechanical treatments) to reduce 

hazardous fuels and minimize the threat to life 

and property.

— Manage overgrazing of grasslands by reducing 

ungulate populations (≤20 bison, ≤18 elk, and 

≤18 white-tailed deer).

Rationale

Prairie areas throughout North America continue 

to decline in quantity and quality, due in part to 

invasion by exotic plant species (Bragg and Steuter 

1995, Samson and Knopf 1994). Such degradation 

is likely a principal factor in declines of several 

grassland birds (Johnson and Igl 2001). Multiple 

invasive plants occur across the native prairie areas 

within the big game prairie region of the refuge. 

Smooth brome is a rhizomatous, sod-forming species 

that is also a prolific seed producer (Willson and 

Stubbendieck 1997). It often excludes other plant 

species, effectively altering the species composition, 

native species diversity, and biomass of native prairie 

areas (Willson et al. 1990, Willson and Stubbdieck 

1997). Kentucky bluegrass frequently impacts native 

prairie in a similar way once invasion occurs (Grace 

et al. 2001). Christian and Wilson (1999) indicate that 

certain introduced grasses not only displace native 

species and consequently reduce diversity, but they 

also alter pools and flows of energy and nutrients 

in the prairie ecosystem. These species tend to 

dominate and overtake native species, essentially 

degrading the habitat. Wilson and Belcher (1989) 

evidenced that Eurasian plant species in the North 

American prairie not only replace the native plant 

community but also impact species compositions 

at higher trophic levels (the position that a species 

occupies in a food chain). Smooth brome poses a 

particularly serious management problem on the 

drift prairie. Because it seems more difficult to 

control than other introduced cool-season grasses 

(Murphy and Grant 2005), smooth brome more 

significantly alters the quality and structure of a 

prairie (Blankespoor 1987) and can alter the soil 

environment to further its own invasion (Jordan et al. 

2008).

Invasive plants, such as leafy spurge, Canada thistle, 

and absinth wormwood, occur across prairie regions 

throughout the refuge. These species also threaten 

the prairie biodiversity, tending to form monotypic 

stands through rapid spread and growth (Bedunah 

1992, Hutchison 1992, Svedarsky and Van Amburg 

1996, Trammel and Butler 1995, Watson 1985, Wrage 

and Kinch 1981). State law mandates the eradication 

and control of these species. IPM practices have 

been implemented, such as biological controls for 

leafy spurge, mowing of invasive plant patches, and 

herbicide treatment. 

Another threat to the integrity of the refuge’s prairie 

is the expansion of woody species into native prairie 

and savanna-like areas resulting from suppression of 

fire. According to Murphy (2005), invasion of native 

prairie by shrub species like western snowberry 

and silverberry is a principal threat to native plant 

diversity in North Dakota. Long-term episodes of 

rest (such as limited grazing and burning on prairie 

areas) allow for the expansion of woody species. 

Burning and grazing are instrumental in maintaining 

prairie and producing optimal grassland bird 

habitat (Powell 2006). Bison are an appropriate 

herbivore for management of current-day northern 

mixed-grass prairie areas (Plumb and Dodd 1994). 

Historical references indicate that bison grazed 

heavily on a localized scale, and along with their 

wallowing, trampling, and rubbing activities would 

have created a vegetative mosaic across the prairie. 

Such use patterns regulated the occurrence of 

particular vegetation, altered vegetative structure, 

and produced ecosystem conditions to which other 

wildlife adapted (England and DeVos 1969). Grazing, 

at a minimum, is a tool to manipulate the grass 

community to reduce invasive plants, maintain vigor 

in the grasses, enhance forb production, and increase 

or decrease fuels for prescribed fire. Prescribed fire 

can also be used to stimulate and increase climax 

plant species and reduce invasive species (Franklin 

and Brand 1991). 

Across the native prairie areas of the refuge, staff 

will strive to implement management that will 

reduce invasion of exotic and invasive species and 

maintain and increase native species. Historically, 

grazing occurred throughout the year at varying 

intensities across the big game forest and prairie. 

Recently, the high numbers of bison held at the 

refuge resulted in overgrazing of the prairie areas. 

Such management left an increase in Kentucky 

bluegrass, which can be reduced with prescribed 

fire (Murphy and Grant 2005). In addition, using 

prescribed fire on these areas will likely also reduce 

the woody species encroachment of species like 

western snowberry, silverberry, and chokecherry 

into the prairie and savanna areas. Specifically on the 

big game prairie, prescribed fire will occur from one 

native grass remnant to another, often burning into 

the woodland margins in between. Combining bison 

and elk grazing management with appropriately 

timed prescribed fire will achieve the vegetation 

composition percentages indicated in the objective. 

Both of these management techniques will be 

necessary, especially as numbers of grazing ungulates 

will be decreased in this CCP. 

Monitoring plant species composition changes 

will be an integral part of management efforts 

to determine whether the refuge’s management 

practices (such as prescribed fire and grazing) and 
38 CCP, Sullys Hill National Game Preserve, ND

their associated timing (for example, late fall four- to 

five-leaf stage of smooth brome) benefit or harm 

native plant communities. For the big game prairie 

areas, the U.S. Department of Agriculture (USDA) 

NRCS will train the refuge staff, and in some cases, 

conduct monitoring according to the standards of the 

“Natural Resources Inventory.” The USDA, NRCS 

“Field Office Technical Guide for North Dakota” 

(1975) provided baseline information on expected 

species composition for the big game prairie. This 

information, along with input from Jeff Printz, State 

Range Conservationist for NRCS North Dakota, 

provided the percentages documented in this 

objective. 

South Prairie Unit Objective 

Increase native grass and forb grouping to >70%, 

decrease Kentucky bluegrass and smooth brome 

grass groupings each to <5%, and decrease shrub 

component to <5% on the 150-acre south prairie to 

provide habitat for grassland-nesting birds.

Strategies

— Recruit one GS-9 wildlife biologist to conduct 

surveys and other biological studies and 

management programs (same position 

described in woodland strategies). 

— Use prescribed fire, prescribed grazing, and 

various IPM strategies at appropriate times 

to enhance the native plants and reduce the 

prevalence of invasive plants.

— Use fuel treatments (including prescribed fire 

and other mechanical treatments) to reduce 

hazardous fuels and minimize the threat to life 

and property.

— Use mowing and prescribed fire to manage 

western snowberry and silverberry shrubs.

— Remove the tree belt on the north boundary 

of the south prairie (see figure 7, vegetative 

communities map).

— Use the belt-transect (Grant et al. 2004) method 

to monitor vegetative response to management 

(see current plant association sheet in appendix 

F).

— Use point counts to monitor singing male bird 

presence and densities to evaluate management 

actions.

— Use transects and protocol established by Dr. 

Ron Royer to monitor butterfly response to 

management (Royer et al. 1998).

Canada Geese

Scott Ralston/USFWS

Rationale

Grasslands are recognized as one of the most 

imperiled ecosystems across the globe. The bird 

species that use these areas have shown dramatic 

and consistent declines (Knopf 1994). According to 

Knopf (1995) and Rich et al. (2004), as an overall 

group, grassland birds show higher declines 

than birds of other North American vegetative 

associations. Breeding bird survey data from 

1966–1996 indicate that populations of 13 species 

of North American grassland birds declined 

significantly, and conversely, populations of only two 

species increased (Peterjohn and Sauer 1999). It is 

hypothesized that major contributing factors to this 

decline are grassland fragmentation and habitat 

loss. In this region, the native sod conversion to 

cropland directly impacted wetland and grassland 

birds by reducing and fragmenting the available 

breeding cover for grassland-nesting species (Batt et 

al. 1989, Sugden and Beyersbergen 1984). Further, 

many grassland- and wetland-dependent birds 

have few alternatives to the Great Plains (Igl and 

Johnson 1995); whereas birds associated with woody 

vegetation appear to have larger distributions across 

the continent (Johnson et al. 1994).

The background information regarding invasive 

plant species presented in the previous objective’s 

rationale also applies to this discussion. Specifically, 

most of the native prairie in the region is heavily 

invaded by a number of exotic invasive grasses 

(such as smooth brome and Kentucky bluegrass) 

and forbs (such as Canada thistle and leafy spurge). 

Across Service lands, these and other exotic species 

have greatly reduced the coverage of native grasses 

and forbs, leading to reduced species composition 

and structural (height-density) diversity that 

is generally equated to a reduction in use by 

breeding grassland-dependent birds. Invasion by 

greater-than-historical extent by certain native low 

shrub species (for example, western snowberry, 

silverberry) also prevails on native prairie areas. Due 

to past management, or lack thereof, these native low 

shrub species have greatly increased their coverage 

compared to the pre-settlement era when frequent 

fire and herbivore grazing would have kept woody 

species to a minimum. 

The refuge’s south prairie is still a fairly intact 

native prairie community, with notable invasion by 

invasive and introduced plants. Through targeted 
Chapter 4 — Management Direction 39

and science-driven management, refuge staff 

will continue to strive to reverse the declines in 

vegetative heterogeneity and to resist invasion 

by exotic cool-season grasses and other plants. 

The assumption is that maintaining this area to 

approximate pre-settlement conditions will likely 

provide favorable habitat for grassland-dependent 

birds such as bobolink, grasshopper sparrow, and 

Sprague’s pipit, to name a few. Prescribed fire 

occurred on this unit for 3 subsequent years, using 

the Willson and Stubbendieck (2000) model for 

smooth brome reduction. In addition, patches of 

silverberry were mowed as post-fire treatment 

to reduce encroachment. Future prescribed fire 

intervals will be based on data from several sources 

that recommend intervals of approximately every 

3–5 years (Higgins 1986, Johnson and Temple 1990, 

Kirsch and Higgins 1976, Miller 1971, Svedarsky and 

Van Amberg 1996, Wright and Bailey 1982), as well 

as whatever is necessary to maintain the optimal 

floristics (the composition of plant associations) 

and ecological functionality of this site, considering 

exotic plant invasion. Efforts will also be made to 

pursue grazing management as another treatment to 

maintain and improve this site. 

The south prairie supports both cool- and 

warm-season native graminoid species (such as 

greenneedle, blue grama, Junegrass, porcupine, 

little bluestem, and big bluestem) and forb species 

(such as purple coneflower, blanket flower, prairie 

lily, blazing star species, prairie coneflower, prairie 

turnip, and pasqueflower). Baseline data indicates 

that 24.43% of the unit is comprised of Kentucky 

bluegrass groups, and 7.08% is smooth brome 

groupings based on the belt-transect method 

(Grant et al. 2004). Groupings that were used are 

listed on the plant association sheet in appendix F. 

These two invasive grasses will continue to pose 

challenges in management, and properly timed fire 

and grazing activities are necessary to achieve the 

percentages listed in the objective. Native grass 

and forb type groupings occurred at 61.45% across 

the unit, and low shrub types occurred at about 7%. 

Maintaining or reducing this shrub percentage will 

also be a focus of management. Western snowberry 

and silverberry are native shrubs that sometimes 

dominate grasslands devoid of management such as 

prescribed fire and grazing at regular intervals. As 

indicated by the objective, the intent is to manage 

these shrubs at a level where they do not dominate 

or expand across this native prairie. According to 

NRCS range site descriptions applicable to this site, 

the small shrub component should make up <10% by 

weight and only a few percent (2%–3%) composition 

by cover (Jeff Printz, state range conservationist, 

USDA, NRCS, North Dakota; personal interview, 

1975). In addition, management to reduce smooth 

brome, Kentucky bluegrass, and small shrubs should 

enhance and ultimately increase the native grass and 

forb groupings to 70% as indicated in the objective.

The core area of this grassland is also intended for 

expansion by the removal of the planted tree row 

that borders the north end of the south prairie 

and south end of the western hayland (figure 7, 

vegetative communities map). With this removal, 

the size of this area will go from 150 acres to 

approximate 250 acres. According to Bakker’s (2003) 

synthesis of the literature, most pertinent research 

indicate that woody vegetation negatively affects the 

presence, abundance, and nesting success of nongame 

grassland birds. A few studies suggested that woody 

vegetation did not effect grassland birds; however, 

few demonstrated a positive association (Bakker 

2003). Regardless, patterns of area sensitivity 

probably vary for grassland birds (Davis et al. 

2006), and likely this native prairie area will provide 

appropriate habitat size and composition for certain 

grassland-dependent birds including grasshopper 

sparrow, Savannah sparrow, bobolink, Le Conte’s 

sparrow, sedge wren, spragues pipit, Nelson’s 

sharp-tailed sparrow, upland-nesting shorebirds, and 

various waterfowl. 

East Hayland Unit Objective 

Restore eastern hayland to diverse, multiple species 

seed mixtures that after establishment maintain >60% 

cover of native grassland groupings based on the belt 

transect method (Grant et al. 2004) by year 15.

Strategies 

— Prepare sites for seeding using multiple years 

of seedbed preparation (for example, cropping 

followed by multiple years of chemical fallowing 

using glyphosate-based herbicides). 

— Develop a seed mixture with a nearly equal 

cool- to warm-season grass and forb component. 

— Drill or broadcast the native flora mixture 

on-site.

— Carry out a variety of tools in post-seeding 

management, including clipping, prescribed 

fire, prescribed grazing, and necessary IPM 

strategies.

— Use fuel treatments (including prescribed fire 

and other mechanical treatments) to reduce 

hazardous fuels and minimize the threat to life 

and property.

— Use the belt-transect (Grant et al. 2004) method 

to monitor restoration. 

— Use point counts to monitor bird singing male 

presence and densities to assess the response to 

restoration.

— Establish transects to monitor butterfly 

response to restoration using Royer et al. (1998) 

protocol.

— Recruit partners to research the establishment 

of native vegetation and monitor the wildlife 

response.
40 CCP, Sullys Hill National Game Preserve, ND

Bluestem

Rationale

Both of the hayland units at the refuge are formerly 

cultivated areas and will therefore be referred to 

as “old cropland” throughout this document. These 

areas were reseeded to herbaceous mixtures that 

included species such as cool-season introduced 

grasses and legumes (intermediate wheatgrass, 

tall wheatgrass, smooth brome, and alfalfa or 

sweetclover), and primarily provided nesting cover 

for mallards and other ducks. This seed mixture 

has been referred to as dense nesting cover (DNC). 

Although a viable mixture and beneficial on multiple 

levels, this mixture requires intensive inputs to 

maintain long-term. First, DNC has a limited 

lifespan, providing attractive cover to nesting 

ducks for perhaps only 6–8 years after seeding and 

up to 15 years with certain management (Higgins 

and Barker 1982, Lokemoen 1984). At the end of 

the DNC lifecycle, the field is typically cultivated 

and farmed for 2–3 years and then reseeded. 

This leads to a rotation of seeding—managing—

farming—seeding and so on into perpetuity. Often 

times, these fields are not re-seeded at the prescribed 

frequencies, leaving decadent, invasive plant-infested 

uplands across the landscape that are limited in 

attractiveness to migratory birds. The need to 

repeat this rotation on a regular basis negatively 

impacts other ecological factors in the surrounding 

environment such as promoting soil erosion when the 

area is cultivated, and necessitating herbicide use to 

prepare the seedbed for each new seeding. 

In this CCP the refuge will reclaim the eastern 

hayland of old cropland by revegetating it with 

a diversity of native flora that, with modest 

management, is relatively resistant to invasion 

by introduced species. This is seen as a benefit to 

grassland and wetland birds because providing 

habitat that is closest to the historical vegetative 

condition likely provides habitat for more obligate 

grassland wildlife. According to Howell (1988) 

re-creating the elements found in the original 

communities quite possibly is the optimal method 

for ensuring continued species interactions and 

natural selection. As an example, Baird’s sparrows 

and Sprague’s pipits appear to use short, sparse 

grass structure, and mostly associate with native 

bunchgrasses, rather than the broad-leaved, 

introduced species used for DNC mixes (Madden 

et al. 2000). Further, according to Stewart (1975), 

and Kantrud and Higgins (1992), marbled godwits 

and willets typically select native grass cover over 

tame-grass cover. Native prairie areas that have not 

been cultivated typically possess a diversity of plant 

forms including short rhizomatous graminoids, taller 

bunchgrasses, a low shrub component, and finally a 

variety of forbs. This structural diversity is usually 

lower in fields dominated by introduced vegetation 

(most commonly, smooth brome, Kentucky bluegrass, 

and invasive plants such as wormwood or leafy 

spurge), which possess a more homogeneous height 

across a field (Wilson and Belcher 1989). Grasslandobligate birds adapt to the diverse native prairie 

structure, whereas DNC-type mixtures limit this 

diversity, likely attracting only bird species that key 

in on this tall, dense cover. 

Another notable benefit of using native seed 

mixtures to restore former cropland areas 

compared to using a DNC mixture is longevity. 

In theory, native seed mixtures should persist 

into perpetuity under appropriate management, 

including disturbances that emulate natural regimes 

at frequencies that sustained wildlife populations 

before human interventions. Management of refuge 

lands in North Dakota typically involves various 

tools to emulate the defoliation activities under which 

prairie plants evolved, including prescribed fire and 

rotational grazing. The frequency of certain activities 

depends on the particular habitat components; a 

pristine native prairie tract may require a burn 

every 3–5 years and intermittent, rotational grazing 

of domestic cattle. This is distinctly less activity over 

time than the rotation required to sustain 

DNC-seeded fields.

 Experimentation with native seeding that took 

place 10–20 years ago in the Drift Prairie and Red 

River Valley areas of North Dakota usually included 

3–5 native warm-season grasses. Current research 

indicates that this may not be an optimal mixture 

for successful establishment and management. 

Tilman et al. (1996) state that biological diversity is 

dependent on the functionality and sustainability 

of the ecosystem, leading to the idea that grassland 

restorations should attempt to include diverse seed 

mixtures. Guo et al. (2006) completed their research 

in North Dakota and indicate that the saturation 
Chapter 4 — Management Direction 41

rate for one of their studied sites was determined to 

be somewhere between 16 and 32 species. Inclusion 

of forbs in native mixtures appears to be necessary 

in attempts to restore variables such as nutrient 

cycling and energy flow (Pokorny et al. 2005). Sheley 

and Half (2006) indicate that seeding a wide range of 

forbs increases the likelihood that more niches will 

be filled and facilitates overall survival of the forbs. 

The use of multiple forbs may help to overcome 

temporal weather variations because at least some 

species should germinate and respond to the dynamic 

weather conditions that annually persist (Sheley and 

Half 2006). More specifically, varying numbers and 

combinations of species in differing developmental 

phases may be a requirement for a native-seeded 

area to achieve the best possible results. It is likely 

also that as a stand matures, a diverse mixture 

may play an important role in the below-ground 

community, providing a well-developed root system 

for sustainability over time (Guo et al. 2006). Further, 

another benefit to native flora establishment is 

the suggestion that species-rich seed mixtures 

may reduce invasive plants on restored grasslands 

(Blumenthal et al. 2003, Carpinelli 2001, Pokorny 

2002, Sheley and Half 2006, Tilman 1996). A study 

by Pokorny et al. (2005) determined that indigenous 

forbs resisted invasion by spotted knapweed better 

than grasses. The overall theory in the literature 

indicates that seeding a diverse seed mixture 

increases the inclusion of various functional groups 

among plant species. With extremely limited data on 

the reestablishment of native flora mixtures in North 

Dakota, there is a need to begin long-term research 

in this area. Ensuring science-based management 

for re-seeding these areas is paramount to the 

perpetuation of grassland resources. The staff of the 

Devils Lake Wetland Management District Complex 

will continue to monitor and study this concept on 

refuge lands, not only at Sullys Hill National Game 

Preserve, but throughout the district.

With the establishment of native seed mixtures, 

challenges exist with controlling invasive plants. 

In the event that the previously mentioned 

management techniques fail to control invasive 

plants such as Canada thistle, IPM strategies will be 

used to control the infestation. It is anticipated that 

smooth brome will persist as a problematic invasive 

species. The anticipated plan is to reduce the impacts 

of this species by following the model provided by 

Willson and Stubbendieck (2000). Similar protocol 

will be followed to reduce Kentucky bluegrass 

invasion. 

A final impelling force for the refuge staff to focus 

on using native plants to restore this hayland 

is the mandates in the Improvement Act. This 

includes an “Integrity Policy,” stating that refuges 

are to promote biological integrity, diversity, and 

environmental health and attempt the restoration of 

historical conditions on refuge lands. 

Western Hayland Unit Objective 

Provide habitat structure of >9.8-inch visual 

obstruction reading (VOR) (Robel et al. 1970) on 

the western hayland during the primary avian 

nesting season (approximately May 1–August 1), 

and continue to provide winter forage for refuge 

ungulates. 

Strategies 

— Use rotational haying so the same area is not 

hayed each year.

— Use a flushing bar on the swather to reduce 

negative impact on nesting bird species.

— Reseed area with warm-season grasses and a 

forb component such as alfalfa, purple prairie 

clover, or vetch.

— Monitor bird use of this hay field using Robel 

readings to identify the VOR using Robel et al. 

(1970) methodology.

— Use prescribed fire, prescribed grazing, and 

various IPM strategies at appropriate times 

to enhance the native plants and reduce the 

prevalence of invasive plants.

— Use fuel treatments (including prescribed fire 

and other mechanical treatments) to reduce 

hazardous fuels and minimize the threat to life 

and property.

Rationale

Currently, the primary vegetative cover of this 

hayland is smooth brome grass interspersed with 

alfalfa. Although this area lacks floristic diversity, 

the presence of perennial grass cover likely 

supports several species of birds that are considered 

generalists and may be more tolerant of forest 

edge effects. Species that may use this area include 

songbirds such as clay-colored sparrow, chipping 

sparrow, common yellow throat, as well as some 

species of waterfowl. By waiting until August 1 to 

carry out defoliation through haying, most of the 

ground-nesting birds should have completed nesting 

by this date, reducing one potential negative impact 

of this management activity. 

Reseeding the area with warm-season grasses will 

increase the opportunity to reduce smooth brome 

invasion. The addition of the legume component will 

increase the structure (height and density) to provide 

more attractive nesting cover for certain bird species, 

allowing for the attainment of the planned VOR. 

Woodland Habitat Goal

Manage for healthy native woodlands of various 

age classes and structure to provide habitat for 

migratory birds, in balance with bison, elk, and other 

indigenous wildlife.
42 CCP, Sullys Hill National Game Preserve, ND

Woodland Habitat Objective 1

Within 15 years of CCP approval, develop woodland 

restoration units with a target of 80 acres in the 

big game forest. Place emphasis on increasing the 

understory species composition to approximately 

500 bur oak seedlings/saplings per acre, 1000 green 

ash seedlings/saplings per acre, 200 American elm 

seedlings/saplings per acre, and 500 basswood 

seedlings/saplings per acre.

Strategies 

— Define and identify priority restoration units 

within the big game forest.

— Establish exclusion barriers to prevent ungulate 

browsing on these selected restoration units.

— Initiate scarification techniques within the 

restoration units, including prescribed fire, 

selective harvest efforts to stimulate copious 

sprouting, hand planting of native stock, and 

direct seeding of tree species.

— Use fuel treatments (including prescribed fire 

and other mechanical treatments) to reduce 

hazardous fuels and minimize the threat to life 

and property.

— Partner with the North Dakota Forest Service 

for monitoring the described understory 

species, approximately every 5 years, within 

the restoration units. 

— Use integrated pest management (IPM) 

strategies to control leafy spurge, wormwood, 

and Canada thistle that occur in the big game 

forest.

Rationale

Some populations of woodland birds who use prairie 

woodlands have declined in the past several decades 

(Peterjohn et al. 1995, Rodenhouse et al. 1995). 

Numerous forest-interior breeding species, as well 

as Neotropical migrants, are considered highly areasensitive and will respond negatively to fragmentation 

of woodland habitats (Robbins et al. 1989). It is 

evident that the total densities and species richness 

of forest-interior birds and Neotropical migrants are 

greater per area in large blocks of habitat; however, 

the presence of many individual species is dependent 

on localized vegetation structure, composition, or 

diversity (Finch 1991). As an example, the density of 

breeding birds in bur oak forests is related to several 

factors, including successional stage, canopy cover, 

and density of the shrub layer (Faanes and Andrew 

1983). Further, North Dakota woodlands that are 

comprised mostly of green ash are considered critical 

habitats for breeding birds in the state (Faanes 1984, 

Gaines and Kohn 1982, Hopkins et al. 1986). One study 

on green ash woodlands in South Dakota determined 

that closed-canopy stands possess greater densities 

of trees and shrubs than open-canopy stands, 

correlating with higher bird numbers in the closedcanopy stands (Hodorff et al. 1988). Based on research 

by Hodorff et al. (1988), the overall number of birds 

in closed-canopy stands of woodlands is significantly 

greater than in open-canopy stands. Birds likely use 

the dense, multiple layers for courtship and display 

stations, nesting sites, protection from predators, 

shelter from physiological stress, and additional 

substrates for food (Wiens and Rotenberry 1981). 

Closed-canopy stands with a diversity of size and 

age classes of trees likely perpetuate themselves, 

compared to the open-canopy stands with a sparse 

over-story and absent midstory (Hodorff et al. 1988). 

Overgrazing of woodland areas by cattle may result 

in negative impacts, most seriously, a reduction in 

vegetation height profiles that may cause a change 

in bird species composition (Medin and Clary 1990, 

Verner 1984). A primary impact of overgrazing is 

the creation of open-canopy stands that consist of a 

low shrub layer, a sparse overstory, and an almost 

complete absence of intermediate vegetation layers. 

A disappearing tree canopy reduces biological 

diversity, as wildlife such as birds that are dependent 

on the vegetative composition and structure are 

displaced (Irby et al. 2000). In addition, large 

openings may impact the nesting success of focal 

species (those with particular management concern) 

because these areas attract nest parasites such as the 

brown-headed cowbird, and egg/chick predators such 

as blue jays and common grackles. Faanes (1987) also 

determined that avian species diversity and foliage 

volume in the high-ground layer, consisting of taller 

grasses and forbs, larger woody seedlings, and young 

shrubs, were significantly correlated. Ironically, this 

layer is often the first to be impacted by overgrazing 

activity. In extreme situations, lack of successful 

reproduction and replacement by trees and shrubs 

may lead to the conversion of woodlands into grass/

forb communities (Dobkin 1992). 

Sullys Hill National Game Preserve represents 

a unique native woodland community in the drift 

prairie physiographic region of North Dakota. Many 

forest-interior breeding birds (such as broad-winged 

hawk, veery, and ovenbird) that are absent from more 

open, small woodlands of the surrounding region are 

present at the refuge. Many of these species are longdistance Nearctic-Neotropical migrants. A recent 

forest inventory at the refuge estimated that 

regeneration levels were below 1%, likely due to 

overgrazing by refuge ungulates (Harsel 2006). If 

this percentage is maintained or decreased, the native 

woodland habitat will continue to be degraded and 

possibly even lost. Several degraded areas within the 

big game forest primarily attract generalist types of 

bird species such as house wrens, blue jays, and 

cowbirds, rather than specific forest species. As a 

result, this associated objective describes a method 

to restore various blocks across the big game forest, 

with the intent that such an effort can increase the 

habitat functionality for forest-breeding birds. 

According to Hoover et al. (2001), a positive response 

is possible with exclusion of grazing by using fenced 
Chapter 4 — Management Direction 43

enclosures on riparian communities. They saw results 

within 2 years, especially in restoring understory 

vegetation. The size of the restoration units at the 

refuge will vary across the big game forest, totaling 

80 acres. It is estimated that restoration of 80 acres 

every 15 years will result in the entire big game 

forest being restored in less than a 100-year time 

period (acres of the big game forest are approximately 

467). This 80-acre restoration determination is 

reasonable based on the needs of browsing ungulates 

in balance with the necessary workload and efforts 

required for the restoration units. In addition, the 

restoration units will be large enough blocks to 

positively impact migratory bird habitat use.

Based on data gleaned from the “Forest Resource 

Management Plan” (Harsel 2006), it is estimated 

that ungulate exclusion from 80 acres of habitat 

throughout the big game forest will increase seedlings 

and saplings in the understory. If seedlings and 

saplings develop and persist, it is likely the efforts 

to create a multilayer, closed forest canopy in the 

restoration units are progressing. To establish a 

baseline, targeted numbers of seedlings and saplings 

were obtained from data collected in the lower and 

south forests of the refuge, which are ungrazed and 

possess trees of varying age classes throughout the 

layers of the canopy (Harsel 2006). Essentially, the 

lower and south forests of the refuge are considered 

the most optimal habitat for forest-breeding birds 

that can be attained within the native woodlands 

of the refuge. The refuge will partner with the 

North Dakota Forest Service to do the appropriate 

monitoring using protocols used in the Harsel (2006) 

management plan. 

Woodland Habitat Objective 2

Establish 5-year interval surveys to monitor the 

presence and density of birds in the ungrazed forests 

(lower and south forest units), the restoration areas 

outlined in objective 1, and current grazed areas 

of the big game forest using American redstart, 

red-eyed vireo, and ovenbirds as target species. 

This presence and density data across three survey 

areas will be used to evaluate the avian response to 

restoration efforts. 

Strategies

— Partner with a university, the U.S. Geological 

Survey, or the Habitat and Population 

Evaluation Team to develop survey protocol.

— Recruit one GS-9 wildlife biologist to conduct 

surveys and other biological studies and 

management programs. 

— Synthesize data and use the results to assess 

management efforts and identify further 

research needs.

— Recruit a graduate student to study ovenbird 

reproduction in the restoration units at least 5 

years into the restoration.

Rationale

Limited baseline data exists on woodland birds at 

the refuge, with the primary data being an inventory 

conducted 2003–2004 (Cutting 2004). Using results 

from this inventory, input from experts, and 

data from the literature, the listed target species 

were selected. These three birds are considered 

breeding species that use various layers of the 

forest. Specifically, the American redstart requires 

a closed overstory, dense midstory and understory, 

and well-developed undergrowth. Nests usually 

occur in an upright fork of a deciduous understory 

sapling, shrub, or tree (Sallabanks 1998). Baseline 

data results indicate that the American redstart was 

identified 54 times across the 2-year survey period 

in the woodland habitats across the refuge. The 

American restart is considered a species of “High 

Sensitivity” based on Herkert et al. (1993), indicating 

they are least tolerant of habitat fragmentation. 

Next, the red-eyed vireo is considered a species of 

“Moderate Sensitivity,” meaning they demonstrate 

an intermediate response to habitat fragmentation. 

This species occurred 227 times over the duration 

of the bird inventory at the refuge. The red-eyed 

vireo also nests in a forked tree branch and 

depends heavily on the midstory layer of the forest 

(Cimprich et al. 2000, Rosenberg et al. 2003). Finally, 

the ovenbird possesses a ‘High Sensitivity’ to 

fragmentation (Herkert et al. 1993) and was readily 

detectable across the woodland habitat of the refuge, 

with 169 individuals recorded over the two seasons 

of the survey. The ovenbird is considered a ground 

nesting bird and therefore uses the forest floor and 

associated materials to build its nest (Van Horn and 

Donovan 1994). The assumption is that if restoration 

units provide habitat for these three species, it is 

likely other forest birds will benefit as well. 

Yellow warbler in oak tree.

Scott Ralston/USFWS
44 CCP, Sullys Hill National Game Preserve, ND

As indicated in the objective, the surveys will be 

established in three areas of the refuge that are 

under varying management regimes. First, the actual 

woodland restoration units described in objective 1 

will be surveyed. Next, the portions of the big game 

forest that are not part of the restoration units which 

will still be grazed by bison, elk, and deer will be 

surveyed. Finally, the lower forest unit that is not 

under active management or undergoing restoration 

will be surveyed. Collecting data from these three 

areas should allow for comparison of results, while 

considering certain spatial, temporal, and climatic 

variables. To expand this monitoring effort, a 

graduate student will be recruited to determine 

the avian reproduction response in the restoration 

units. This project will not occur until 5 years after 

restoration has been implemented, and the target 

species will be the ovenbird. Such a project should 

give immediate feedback on the success of restoring 

understory and closed canopies when considering 

avian reproduction on the forest floor.

Antler in marsh marigolds.

Aaron Mize/USFWS

Wildlife PoPulation ManaGeMent Goal

Carry out management practices that ensure healthy 

populations of Rocky Mountain elk, plains bison, and 

other indigenous wildlife species that exemplify the 

genetic integrity of historical prairie wildlife.

Wildlife Population Management Objective 1 

Maintain the purpose of the refuge as a big game 

preserve by retaining a bison herd size of ≤20 

animals, an elk herd size of ≤18 animals, and a 

white-tailed deer herd size of ≤18 animals to 

improved habitat conditions while maintaining public 

viewing and interpretive opportunities. 

Strategies

— Use the draft carrying-capacity study 

and associated model developed by Bertie 

and Sweitzer (2008) to maintain ungulate 

populations within carrying-capacity levels. 

— Use prescribed fire and grazing to manage 

grassland areas to maintain refuge floristics 

(see prairie habitat and woodland habitat 

objectives) and provide optimal forage for 

grazing bison and elk.

— Adaptively manage ungulate populations based 

on monitoring the ungulate-induced habitat 

impacts (methods for monitoring habitat and 

migratory birds are documented under prairie 

and woodland objectives). 

— Transfer and reduce bison herd based on the 

Service-wide meta-population management 

plan as outlined in the document, “A 

Framework for Bison Conservation in the 

Department of the Interior.” 

— Reduce elk and deer at appropriate intervals to 

maintain the populations stated in the objective.

Rationale

Large ungulates such as bison, elk, and deer often 

impact their associated ecological systems through 

disturbances (horning, rubbing, wallowing), grazing, 

and nutrient deposition (Campbell et al. 1994, 

Coppedge and Shaw 1997). These and other activities 

of native ungulates are a natural part of large, open 

ecosystems; however, in relatively small, fenced, or 

semi-isolated areas such as Sullys Hill National Game 

Preserve, these activities may cause damage when 

ungulate densities are too high (Howell et al. 2002, 

Zeigenfuss et al. 2002). In small confined systems, 

detailed information on ungulate movements, habitat 

use, behavior, and diets can provide critical data for 

estimating habitat carrying capacity (Norland et 

al. 1985). Behavior is considerably more important 

in closed systems compared to large free-range 

situations because large ungulates may habitually 

damage habitat in these relatively small enclosures. 

Monitoring data will provide management guidelines 

for determining appropriate populations of ungulates, 

balanced with other multiple-use management 

directives. 

In the past, ungulate populations at the refuge were 

based on the refuge’s “Fenced Animal Management 

Plan” (Veikley 1984). This document states that, 

dependent on the time of the year (winter versus 

summer), bison numbers should range from 25–40 

animals, elk from 15–25 animals, and white-tailed 

deer from 10–30 animals. These estimates were 

based on the best professional judgment at the time. 

Currently, to ensure that ungulate numbers within 

the big game forest and prairie are in balance with 

the needs of other wildlife at the refuge, including 

migratory birds, refuge staff partnered with the 

University of North Dakota to conduct population 

management research. Results of this study provide 

a multi-species model of the carrying capacity 

for the three large ungulates at the refuge and 

recommendations for management of herd sizes 

under different scenarios of weather and public 

viewing. In addition, the refuge also received 

detailed habitat GIS layers to provide baseline data 
Chapter 4 — Management Direction 45

on refuge floristics, which also serve as an aid for 

habitat management decisions (Bertie and Sweitzer 

2008).

Briefly, the model uses data on diets and seasonal 

annual forage requirements for each ungulate, along 

with the annual forage production for the different 

plants consumed by bison, elk, and white-tailed 

deer as inputs. The outputs of the model provide 

population size scenarios predicted to be within 

overall carrying capacity. A primary reason for 

initiating this study was to study overbrowsing 

throughout the forest habitat, and determine 

methods for improving forest regeneration in the big 

game forest. The “standard livestock” model seemed 

somewhat liberal in considering forest recovery; 

therefore, four different management scenarios 

for recovery were developed. The estimates for 

recovery were labeled “standard,” “moderate,” 

“management,” and “recovery” and were determined 

by using forage production estimates for unfavorable 

years. These categories were based on USDA 

NRCS data on range site use. These categories, as 

defined for the Bertie and Sweitzer (2008) model, are 

listed as standard = 70% use, moderate = 50% use, 

management = 30% use, and recovery = 10% use. The 

intent is that the majority of the grazed areas of the 

big game forest will be in recovery mode, meaning 

that the habitat is practically undisturbed and only 

key forage species are grazed (Bertie and Sweitzer 

2008).

Based on the results of running the preliminary 

model, keeping 70% of the big game forest in the 

recovery category allows for 15 elk, 5 deer, and 19 

bison. Since the described model focused more on 

the woodland habitat, there are under-use concerns 

for the big game prairie. Grasslands devoid of 

appropriate management will deteriorate, as 

described in rationales under the prairie habitat goal. 

A study by Norland et al. (1985) indicates that the 

major detrimental effect of maintaining the bison 

herd at the Teddy Roosevelt National Park to a base 

level was the underuse of certain plant communities. 

Excessive accumulation of litter may suppress the 

native grass stands and create an environment more 

conducive to Kentucky bluegrass, smooth brome, 

and woody plant establishment. Further, bison may 

actually avoid areas of excessive litter build-up 

despite the presence of adequate forage (Norland 

et al. 1985). As documented in the prairie habitat 

objectives, fire will be employed as a tool to control 

litter build-up, which according to Norton et al. 

(1985), might increase the attractiveness of these 

areas to bison. On areas of the big game prairie, 

prescribed fire will be used to maintain the native 

prairie vegetation and manipulate bison distribution. 

Further, the placement of mineral blocks (listed in 

the next objective) will be focused on prairie areas to 

attract ungulates to those areas.

The herd sizes listed in the objective were developed 

after considering the concerns for underuse of the 

prairies and overuse of the forests, and factoring in 

the Bertie and Sweitzer (2008) model. The indicated 

population sizes will allow for adaptive management 

of the ungulates based on the planned monitoring 

documented in all of the biological objectives. As an 

example, one strategy of decreasing brainworm on 

Sullys Hill National Game Preserve is to drastically 

decrease or eliminate the deer population. This 

objective allows for the reduction of deer depending 

on the herd health issues discussed in the following 

objective. In addition, if prairie areas are showing 

signs of underuse, the bison population could be 

increased to 20 animals using the described methods 

for attracting them to the prairie areas. If monitoring 

determines that the forested areas are still showing 

limited regeneration, bison numbers could be 

reduced (see woodland habitat objective for proposed 

monitoring). The associated monitoring will drive 

the management of the ungulates, and this objective 

provides the flexibility to respond to both habitat and 

herd health needs.

Wildlife Population Management Objective 2 

Reduce the prevalence of brainworm and lungworm 

in elk so no animals exhibit clinical infection 

externally over the life of this CCP. Also, reduce 

and where possible, eliminate introgression risks of 

CWD, brucellosis, and any other nonendemic disease 

of wild native ungulates or cattle. 

Strategies

— Determine alternatives to current winter 

feeding operations.

— Reduce ungulate populations to within 

habitat carrying capacities and monitor 

habitat conditions (indicated in the prairie and 

woodland objective sections) to adaptively 

manage ungulate populations. Specific species 

(such as bison and elk) will be preferentially 

conserved over another native species (deer) in 

keeping with the refuge purposes.

— Use elevated feeders to keep food off the 

ground in years where feeding is necessary.

— Rotate feeding grounds to varying sites across 

the big game forest and prairie.

— Remove accumulated manure as needed around 

feeding grounds.

— Use medicated mineral blocks and other 

methods of treatment for nematode parasites.

— Recruit a graduate student to conduct a study 

on lungworm to determine its significance in elk 

and find measures for reducing its impact.

— Communicate regularly with NDGF and the 

Service’s Wildlife Heath Office to identify 

and reduce the risk factors related to CWD 

infection and reduce the risk of introduction of 

other nonendemic diseases.
46 CCP, Sullys Hill National Game Preserve, ND

— Keep gates closed in the winter when cattle 

guards fill with snow, to reduce co-mingling 

with ungulates outside the refuge.

— Conduct opportunistic CWD surveillance 

through sampling found-dead or euthanized 

cervids. 

— Submit CWD samples under the NDGF’s 

direction to ensure appropriate coordination for 

prevention of this disease.

— Reduce feral dog and cat entrance into the refuge. 

— Conduct a herd health surveillance program in 

coordination with the Wildlife Health Office. 

— Monitor brucellosis status at the refuge through 

sampling of euthanized or recently deceased 

bison, and also bison relocated to other sites.

— Introduce new animals into the refuge that are 

compliant with all state and federal regulations, 

at appropriate intervals to maintain the overall 

genetic health of the herds. 

— Eliminate or drastically reduce the population 

of white-tailed deer.

Rationale

As of 2004, disease testing on ungulates residing 

in Sullys Hill National Game Preserve became 

more frequent with the hiring of a regional wildlife 

veterinarian. During this same time period, there 

were heightened concerns about CWD. Dr. Tom 

Roffe and refuge staff have conducted 14 complete 

necropsies (post mortem examinations) on elk, and 1 

complete necropsy on a bison. Overall, the 22 CWD 

samples collected from elk and 31 samples collected 

from white-tailed deer have been negative. 

Elk necropsy results positively indicate that 

lungworm occurs regularly in animals at the refuge. 

Two classes of lungworm have been identified in 

refuge elk, Dictyocaulus (likely species hadweni) and 

Protostronglyus. Dictyocaulus has a direct lifecycle 

(does not require an intermediate host) and can infect 

bison, deer, and elk. Adult Dictyocaulus live in the 

lungs, producing eggs which are coughed up and 

then swallowed. They are excreted through feces, 

mature in about a 1-week time period into a third 

stage (L3), and are then consumed by the host during 

foraging. The maturation period from L1 to L3 can 

be extended by cooler temperatures. In addition, L3 

larva can invade the fungus Pilobolus spp. Fungal 

sporulation can disperse Dictyocaulus L3 larvae up 

to 10 feet, thereby widening the infected area. After 

ingestion by the host ungulate, L3 larvae mature 

into L4 larvae, which migrate to the lungs through 

blood and lymphatic vessels, mature into adults, and 

the cycle is completed. Because Dictyocaulus has a 

direct life cycle, management strategies that enhance 

animal density, fecal contamination, and repeated use 

of the same ground increase this parasite’s impact 

on host populations (Dr. Tom Roffe, region 6 chief, 

wildlife health, USFWS, Bozeman, MT; personal 

interview, 2007).

Protostrongylus also infects deer, elk, and other 

ungulates but requires an intermediate gastropod 

(typically snail) host to complete its lifecycle. Adult 

Protostrongylus live in the lungs, migrate to the 

stomach, and are excreted in the L1 stage through 

feces. Once on the ground, they must contact and 

penetrate the intermediate host, where they mature 

to L3. Infective L3 larva reenter the host when 

the infected gastropod is ingested during grazing. 

Once released from the snail, L3 larvae penetrate 

the intestinal wall, migrate through the lymphatic 

system while maturing to L4, and eventually make 

their way to the lungs through blood and lymph 

vessels. Because of the requirement for specific 

intermediate hosts, Protostrongylus distribution is 

limited by the distribution of specific species of snails. 

Management strategies that affect both host and 

snail distributions can reduce this parasite. Because 

most intermediate hosts require moist environmental 

conditions, dry environments tend to have less 

Protostrongylus. In addition, Protostrongylus tends 

to be more pathogenic (disease-causing) in sheep 

than in other wild ungulates (Dr. Tom Roffe, region 

6 chief, wildlife health, USFWS, Bozeman, MT; 

personal interview, 2007).

Lungworm infections generally are asymptomatic 

to the casual observer. Their primary pathological 

impact is airway obstruction and minor tissue 

damage from migrating L4 larvae. Adult, egg, and 

larval irritation of airways results in accumulation 

of exudate (fluid found in lesions or areas of 

inflammation). Symptoms are directly related to the 

total parasite burden, with clinical cases generally 

only observable with large numbers of worm 

accumulations. Minor infections can be unapparent 

while the animal is at rest, but the animal is subject 

to exercise intolerance. Secondary bacterial 

infections can occur, complicating verminous 

pneumonia with bacterial pneumonia as well (Dr. 

Tom Roffe, region 6 chief, wildlife health, USFWS, 

Bozeman, MT; personal interview, 2007). 

In wild unrestricted wildlife herds, lungworm is 

generally not significant because densities are low 

enough that the wildlife is less likely to forage in 

areas during the approximate 1-week time period 

of maturation of the larva from L1 to L3. Where 

wildlife movements are restricted, or environmental 

carrying capacities exceeded (resulting in regrazing 

of contaminated areas), lungworm infestations can 

rapidly increase and cause clinical disease in the 

host (Dr. Tom Roffe, region 6 chief, wildlife health, 

USFWS, Bozeman, MT; personal interview, 2007). 

Lungworm infection is diagnosed by detecting 

larvae in feces using Baermann’s sedimentation 

method. Fresh (<24 hours old) fecal material can 

be collected in early spring and shipped, chilled, 

to a diagnostic lab to determine if lungworms are 

present, which class of lungworm constitute the 

infection, and how much is present. Management 

methods to reduce infestation include redistributing 
Chapter 4 — Management Direction 47

wildlife across larger landscapes, eliminating feeding 

programs, altering habitats to minimize intense 

focal aggregations, and other similar measures. 

Treatment, using medicated blocks, has been tried 

in free-ranging bighorn sheep but has not proven 

effective (Dr. Tom Roffe, region 6 chief, wildlife 

health, USFWS, Bozeman, MT; personal interview, 

2007). 

Of the nine Sullys Hill National Game Preserve 

elk sampled between January 2004 and February 

2007, five had positive results for lungworm at low 

levels. Four of the five came from a single January 

2006 culling sample. None of 4 bison sampled in 

January 2005, or 40 bison sampled in November 

and December 2006, had detectable lungworm 

infections. These data suggest bison, at this point, 

are not affected by the species of lungworm on 

site. Lungworm species, however, tend to be host 

specific, and therefore, further investigation of the 

prevalence and quantitative parasite burdens in elk 

are warranted. Because of the small habitat base and 

historical use of winter grain feeding at Sullys Hill 

National Game Preserve, both elk and bison should 

be monitored. Wildlife health, and parasitic problems 

in particular, will be best managed by maintaining 

ungulate populations within winter habitat carrying 

capacity, manipulating habitat to increase forage for 

grazing ungulates, encouraging wildlife dispersal 

across the refuge, and eliminating winter grain 

feeding (Dr. Tom Roffe, region 6 chief, wildlife health, 

USFWS, Bozeman, MT; personal interview, 2007). 

Brainworm/meningeal worm (Parelaphostrongylus 

tenuis) also appears to persist at the refuge. This 

nematode parasite occurs in parts of the cranium of 

its host (Anderson and Prestwood 1981). The normal 

definitive host for P. tenuis is the white-tailed deer, 

while several other ungulate species demonstrate 

susceptibility to infection by this parasite. The host 

becomes infected when they ingest a gastropod 

infected with third-stage larvae (L3) of P. tenuis

(Anderson 1963, 1965). The larva travels from the 

stomach to the cranium approximately 40 days after 

initial ingestion. Worms continue to mature and 

migrate into the cranium, staying in the subdural 

space or entering the venous sinuses. Worms mate 

and eggs are deposited in the veins and travel to 

the lungs where they hatch into L1 larvae. These 

larvae cross the bronchial tree, are swallowed by the 

host and are passed out with the feces. The period 

between initial infection and the first diagnostic stage 

is typically 82–92 days but can be 115 days or more 

(Anderson and Prestwood 1981, Samuel et al. 1992).

Maskey and Sweitzer (2004) estimated that P. tenuis 

prevalence in the white-tailed deer population at 

the refuge was at 83.3% based on their assessment 

of 17 deer heads and fecal samples. Environmental 

conditions such as temperature and rainfall, along 

with deer density likely effect the prevalence of this 

parasite at a particular site (Behrend and Witter 

1968, Gilbert 1973, Karns 1967, Schmitt et al. 1989). 

There is no evidence that P. tenuis is a significant 

pathogen of white-tailed deer, as deer typically 

tolerate infection very well. The most serious 

implication of P. tenuis infection in white-tailed 

deer is lung damage caused by eggs and larvae that 

may make deer more susceptible to other minor 

infections. 

P. tenuis causes fatal neurological disease in 

hosts other than white-tailed deer, including elk. 

Neurological disease in other hosts is the result of 

prolonged migration through neural tissue which 

causes tissue destruction. Worms can also invade 

and damage the central spinal cord canal (Anderson 

and Prestwood 1981). Signs of neurological disease 

include loss of fear, blindness, holding head to one 

side, walking aimlessly or in circles, weakness 

in hindquarters, and paralysis (Anderson 1965, 

Carpenter et al. 1973, Olson and Woolf 1978). Elk 

calves are especially susceptible to fatal infection 

(Anderson 1965, Samuel et al. 1992, Woolf et al. 1977). 

P. tenuis may limit host populations; although there 

is no documentation of extirpation caused by this 

parasite (Carpenter et al. 1973, Raskevitz et al. 1991).

Since refuge staff began consistently recording elk 

mortality incidences in 2001, approximately eight elk 

had clinical signs or pathology, or both, consistent 

with P. tenuis or Dictyocaulus spp. infection. Several 

of these observed animals possessed a declining 

body condition, loss of fear, and a slow, stiff gait. 

On necropsy, several elk had remnant chronic 

pleuritis and fibrous nodules throughout the lungs 

(chronic pneumonia). Lungworm has been frequently 

observed during necropsy and brainworm occurs 

frequently across the refuge (Maskey and Sweitzer 

2004). Refuge staff will assess the impact of these 

parasites and carry out management to reduce their 

prevalence across the refuge. The goal is to have elk 

free of clinical disease. Necropsies and consistent 

field monitoring of ungulate populations for clinical 

disease will be important components of this effort. 

If less invasive management strategies do not reduce 

brainworm prevalence, more dramatic measures like 

Winter on Devil’s Lake.

USFWS
48 CCP, Sullys Hill National Game Preserve, ND

the reduction and elimination of white-tailed deer 

will be necessary.

At the time of this CCP, CWD has not been detected 

in North Dakota. Specific details of this disease 

and the refuge’s contingency planning for possible 

infection are documented in the associated step-down 

plan. Annual surveillance will continue to occur at the 

refuge in cooperation with NDGF.

North Dakota is currently a certified brucellosis-free 

state. Testing on bison at the refuge has occurred 

since the early 1980s on dispatched bison, with 

samples being sent in to the USDA Animal and 

Plant Health Inspection Service. More recently, 

the Regional Wildlife Health Office has processed 

samples, with results being provided to the North 

Dakota Bureau of Animal Health. All sampled refuge 

bison tested negative for brucellosis. 

North Dakota is also currently considered a bovine 

tuberculosis-free state. During necropsies on bison, 

lungs will be examined for any indication of this 

disease, and any transferred bison will be tested in 

accordance with North Dakota Bureau of Animal 

Health regulations. 

Several of the strategies address changes in feeding 

operations at the refuge, which directly impact the 

overall health of the ungulates. Currently, winter 

feeding includes a mixture of grains and hay fed to 

animals from approximately November to April. 

Based on necropsies conducted, elk and bison on 

the refuge possess more than an adequate amount 

of fat reserves for optimal health. Considering this, 

winter feeding will be reduced to grassland hay 

only, except for short periods when grain feed will 

be used as a tool in animal handling operations or 

during an extreme winter. Such an effort should 

not only reduce the occurrence of digestive tract 

problems such as acidosis, but also reduce parasitic 

worm ingestion. The hay, because of its roughage, 

is excellent for good ruminant digestive health, and 

in comparison to the grain, is most similar to the 

grassland plants that animals ingest throughout the 

spring, summer, and fall at the refuge. Concerns 

related to winter survival without grain can be 

addressed by considering the physiology of digestion. 

Aside from the digestible energy in hay, energy is 

provided through volatile fatty acids produced by 

rumen flora fermentation. These fatty acids in turn 

are absorbed into the blood stream and are optimal 

sources for energy in ruminants. In addition, one 

byproduct of rumen fermentation is heat, which helps 

keep the animals warm in the winter (Dr. Tom Roffe, 

region 6 chief, wildlife health, USFWS, Bozeman, 

MT; personal interview, 2007).

Wildlife Population Management Objective 3 

Retain a bison herd at Sullys Hill National 

Game Preserve that meets the standards of the 

“Management of Bison in the National Wildlife 

Refuge System” document (Jones and Roffe, 2008) 

and actively participate in the meta-population 

management of bison genetics. 

Strategies

— Report annually on statistics of the herd and 

transfer needs. 

— Make decisions on meta-population 

management annually with input from the 

Regional Wildlife Health Office.

— Attend the annual refuge bison coordination 

meeting. 

— Participate in continued genetic testing.

— Establish infrastructure at the refuge for safely 

handling animals for herd health and transfer 

purposes.

Rationale

With the recent transfer of the refuge’s original 

bison herd to Fort Niobrara National Wildlife 

Refuge, Sullys Hill National Game Preserve is 

already an active participant in the Service-wide 

plan to manage bison across the Refuge System as 

a meta-population. It is recognized that Sullys Hill 

National Game Preserve will play a small role with 

limited habitat and its intentions to maintain a small 

herd. However, the Department of Interior supports 

the importance of such small herds with the recent 

announcement by Secretary Kempthorne stating 

that small bison herds are especially valuable to the 

Department for environmental education. The bison 

currently in residence have no detectable cattle 

hybridization and are from the National Bison Range 

herd, which possess several private alleles unique to 

the National Wildlife Refuge System. The surplus 

bison from the current herd can serve as a source of 

genetic material to other Service herds that can use 

the augmentation for diversity purposes. Similarly, 

as needed, Sullys Hill National Game Preserve staff 

will work with the Regional Wildlife Health Office 

to bring in new genes from appropriate herds to 

reduce inbreeding issues and maintain germ plasm 

(a collection of genetic resources) that may be most 

beneficial to the overall meta-population. Additional 

details can be found in the Service-wide metapopulation initiative entitled, “Management of Bison 

in the National Wildlife Refuge System” (Jones and 

Roffe 2008).

Refuge limitations to participation in metapopulation management may be caused by the 

absence of permanent facilities for round-up and 

transfer. For past genetic testing and recent transfer 

of the original herd, staff set up temporary corral 

systems and baited the animals into the facilities. 

This is costly and labor intensive and likely will not 

meet the overall objectives in the future as needs 

arise to carry out further genetic testing, animal 

transfer, and herd health management. As the 
Chapter 4 — Management Direction 49

meta-population initiative progresses, this will be 

addressed and funding found to obtain the necessary 

infrastructure.

Wildlife Population Management Objective 4 

Manage the black-tailed prairie dog population to 

provide appropriate environmental education and 

outreach opportunities while protecting habitats by 

maintaining a town size of 1.5 acres. 

Strategies

— Develop a prairie dog management plan.

— Survey population regularly to identify average 

annual recruitment levels. 

— Reduce the population as necessary to maintain 

a size of 1.5 acres.

Rationale

The established prairie dog town at the refuge has an 

estimated population of several hundred. This species 

was introduced to the refuge in 1974, primarily as a 

tool for interpretation and education. Across North 

Dakota, the historical range for prairie dogs is west 

and south of the Missouri River (Sidle et al. 2001) and 

not necessarily in the wetter mixed-grass and tallgrass prairies of the state. The original acreage for 

the town at Sullys Hill was 1.5 acres, and currently 

the town has expanded to nearly double this size. With 

very few natural predators, the town will continue to 

expand, with possible adverse impacts to surrounding 

woodland and prairie habitats, and cultural resources. 

A step-down plan will be developed to address this 

issue and balance the size of the dog town with 

outreach needs and habitat preservation. 

Black-tailed prairie dog pups.

Scott Ralston/USFWS

EnvironMental ducation nterPretation

and outreacH Goal

E , I , 

Deliver quality, interactive environmental education 

programming to regional schools, communities, 

organizations, Spirit Lake Nation, and local 

governments to garner support and appreciation 

for Sullys Hill National Game Preserve, North 

Dakota’s wetland and grassland resources, and 

the conservation role of the U.S. Fish and Wildlife 

Service. 

Appendix H contains a compatibility determination 

for the environmental education and interpretation 

uses for Sullys Hill National Game Preserve. 

Environmental Education, Interpretation, and 

Outreach Objective 1 

Develop wetland and grassland conservation 

education programs for 7,500 elementary and high 

school students within the Devils Lake Watershed, 

fostering an environmental ethic to aid future 

conservation efforts within the Devils Lake Wetland 

Management District Complex.

Strategies

— Rename the current GS-11 series 025 park 

ranger position to visitor services manager.

— Recruit one GS-9 environmental education 

specialist to develop and implement programs 

and work with local schools, teachers, and 

refuge visitors.

— Develop environmental education programs 

with the help of the GS-9 wildlife biologist 

(position identified in woodland strategies).

— Recruit additional volunteers to assist with 

environmental education programs.

— Develop a wetland and grassland conservation 

curriculum and use existing environmental 

education team trunks. Emphasize current 

wetland and grassland conservation issues, 

dependent wildlife species and ecological 

functions of these habitats. Structure the 

curriculum with multiple lessons that build 

upon previous lesson plans.

— Develop a partnership with a local teacher to 

serve as a dedicated environmental educator. 

— Focus the curriculum evenly on wetland 

science and conservation; grassland science and 

conservation; and the Sullys Hill National Game 

Preserve, the Refuge System, plains bison 

conservation, and general wildlife conservation 

programming.
50 CCP, Sullys Hill National Game Preserve, ND

— Design all environmental education programs 

to engage students in the learning process 

by incorporating the use of all five senses: 

sight, hearing, touch, smell, and taste. Design 

programs to use the outdoor classroom of the 

refuge when practical.

— Develop a set of lesson plans that teachers will 

be able to use in their classrooms. Focus on 

topics such as wetlands, grasslands, forests, 

migratory birds, fisheries, and big game and 

include all necessary teaching aids such as 

a teacher’s guide, student workbooks, video 

presentations, props, and testing materials. 

Make these lesson plans available for loan 

to teachers with preference given to those 

teachers that will teach on-site at the Sullys 

Hill education and visitor center. 

— Develop a partnership with the Spirit Lake 

Nation to assist with environmental education 

programming including an educational kit 

that details the Spirit Lake Nation’s culture, 

traditional uses of natural materials, and 

natural resource conservation. 

— Monitor the success of these programs by 

including pre- and post-testing (including 

asking simple questions at the end of a session 

to gauge understanding), teacher incorporation 

of materials into existing curriculum, and 

student participation. 

— Plan and begin regular off-site programming 

to local schools within a 90-mile radius of the 

refuge.

— Use refuge waters that support a viable fishery 

to provide environmental education programs 

on fish species and their lifecycles, along with an 

introduction to fishing techniques.

— Establish a refuge lending library and teacher 

resources website to allow local teachers to 

know what materials are available and to 

check them out. Use these systems to monitor 

materials used and receive feedback.

— Recruit local students to participate in Youth 

Conservation Corps (YCC).

— Ensure that all education programs presented 

at the refuge by partners support the refuge’s 

environmental education themes.

— Design environmental education programs to 

meet state and local education standards.

Rationale

The children of today are tomorrow’s landowners 

and like many adults, lack the general knowledge of 

wetlands and grasslands and how they function. They 

often do not recognize the environmental benefits 

these systems provide and do not understand 

that these critical habitats support many of our 

continent’s migratory bird populations. Additionally, 

students are generally unaware of the perils facing 

the wetland and grassland habitats of the Prairie 

Pothole Region. The educational experience offered 

at Sullys Hill National Game Preserve contributes 

to the long-term effort to conserve wetland and 

grassland habitats within the Devils Lake Wetland 

Management District Complex.

In addition, today’s life is electrified with computers, 

televisions, and video games that reduce children’s 

sensory experience of nature. Nature is about smelling, 

hearing, tasting, and seeing (Louv 2006). The challenge 

is to link these modern modes of conservation 

education with outdoor education and hands-on 

learning (Hudson 2001). Children have to experience 

nature directly in order to learn and develop in 

healthy and appropriate ways (Rivkin 1995). “Time in 

nature is not leisure time; it’s an essential investment 

in our children’s health” (Louv 2006).

Sullys Hill National Game Preserve will provide the 

opportunity for students to experience and learn 

from nature through educational programs and firsthand experiences with their natural surroundings. 

The refuge provides opportunity for students to 

complement the traditional indoor classroom and 

truly experience science and conservation biology in 

actual wetland and grassland habitats.

Environmental Education, Interpretation, and 

Outreach Objective 2 

Sullys Hill National Game Preserve will serve to 

educate students and refuge visitors of all abilities 

about the values of wildlife and habitat conservation. 

Seventy-five percent of refuge visitors and students 

that participate in programs at the refuge will be 

able to understand the conservation role of the Devils 

Lake Wetland Management District Complex and the 

Refuge System.

Strategies

— Recruit local students annually to participate 

in YCC. Expose students to the management 

of public lands for wildlife and people. 

Headquarter the program at Sullys Hill 

National Game Preserve but allow participants 

to work on waterfowl production areas (WPAs) 

and refuges across the Devils Lake Wetland 

Management District Complex.

— Recruit volunteers annually, in partnership 

with the Sullys Hill Wildlife Refuge Society, to 

assist with various refuge education activities.

— Involve in refuge activities the students from 

Cankdeska Cikana Community College that 

are interested in wildlife management and 

environmental education. Use the Service’s 

Student Career Experience Program to provide 

broad experiences and opportunities for future 

employment.

— Serve as a critical environmental education 

outlet for the Devils Lake Wetland 
Chapter 4 — Management Direction 51

Management District Complex. Develop 24 

media releases per year for the general public 

on the importance of wetland and grassland 

conservation, dependent wildlife species 

(specifically waterfowl), and the critical role of 

the Service in this arena.

— Continue to conduct annual events in 

partnership with the Sullys Hill Wildlife Refuge 

Society and others. Such events include the 

Birding and Nature Festival, Winterfest, and 

participation in the Chautauqua Program.

— Use various techniques to evaluate whether 

students and visitors are able to better 

understand the conservation role of the Devils 

Lake Wetland Management District Complex 

and the Refuge System.

— Involve the Spirit Lake Nation fire personnel in 

all fire-specific training provided at the refuge.

— Provide electricity and water to the remote 

classroom.

Rationale 

Many students and refuge visitors have an 

awareness of the need for wildlife conservation; 

however, they lack a complete understanding of 

the role of the U.S Fish and Wildlife Service in 

wildlife conservation. Additionally they often do not 

recognize their personal role in the conservation of 

our nation’s natural resources.

Sullys Hill National Game Preserve will provide 

an opportunity for the public to engage with 

wildlife and expand their appreciation for natural 

resource conservation and develop their own 

environmental ethics. The refuge programming 

will provide opportunities for students and visitors 

to gain knowledge of how their actions protect or 

harm habitats (particularly wetland and grassland 

habitats), associated wildlife, and why that should 

matter to them. Opportunities will be presented on 

avenues to participate with the Refuge System in the 

conservation of wildlife and habitats, even on their 

own properties. 

Environmental Education, Interpretation, and 

Outreach Objective 3 

Educate adults in the agricultural community on 

conservation opportunities associated with farming 

in the Prairie Pothole Region and farming technology 

that will benefit the environment and promote 

natural resource conservation.

Strategies

— Partner with NDSU Extension, NRCS, 

agricultural chemical companies and others to 

conduct one annual information exchange with 

agricultural producers. The exchange will focus 

on such topics as grassland/livestock/waterfowl 

interactions, invasive species management, and 

farming “Best Management Practices.”

— Dedicate one portion of the habitat diorama 

display to be placed in the education and visitor 

center to interpret agricultural landscapes.

— Work with partners to develop information 

packets on “Best Management Practices” to be 

used for interactions with farming/ranching and 

wildlife/agricultural producers.

— Hold presentations for area landowners 

on refuge and waterfowl production area 

management and regulations.

Rationale

The Devils Lake Wetland Management District 

Complex has a mission of preserving and restoring 

the native wetlands and grasslands within the 

Devils Lake Basin. They accomplish this primarily 

by acquiring wetland and grassland easements from 

willing sellers. Although this program has been very 

successful in protecting thousands of acres of habitat, 

the easement program’s conservation role is regularly 

overlooked and misunderstood. The refuge has the 

potential to not only provide information to the local 

communities and students about habitat conservation, 

but could also create a bridge to potential landowners 

who might otherwise be unaware these compensated 

programs exist. Developing this mutual awareness, 

knowledge, and appreciation for protecting these 

natural resources while understanding the challenges 

of farmers and ranchers, will create a greater 

appreciation of each other’s needs and should 

ultimately aid in future wetland and grassland 

protection and restoration efforts within the Devils 

Lake Wetland Management District Complex.

V

Provide captivating visitor services facilities and 

activities for visitors of all abilities, community 

groups, youth groups, and the members of Spirit 

Lake Nation to provide enjoyment that results 

in a greater understanding and support of the 

preservation of native habitats and landscapes of 

North Dakota’s Prairie Pothole Region and the 

mission of the Refuge System. 

Appendix H contains compatibility determinations 

for the fishing and wildlife observation and 

photography uses for Sullys Hill National Game 

Preserve. 

Visitor Services Objective 

Annually, 60,000 visitors, including 7,500 youth 

and adult students, will visit and explore Sullys 

Hill National Game Preserve. This experience will 

create a greater awareness and understanding of 

the national wildlife refuge system while fostering a 

personal environmental ethic and developing skills to 

further understand wildlife and engage with nature. 
52 CCP, Sullys Hill National Game Preserve, ND

Strategies

— Work with volunteers and other partners to 

develop a year-round educational program that 

will highlight the Refuge System’s priority 

visitor services of wildlife observation and 

photography techniques, hunting, fishing, 

interpretation, and environmental education. 

Use a website and media to provide public 

advance notice of programming. Include birding 

walks, plant identification tours, photography 

field trips, guided hay rack rides, elk bulging 

tours, and fishing and hunter education courses 

in typical programming.

— Develop and maintain, through partnerships, 

an interactive habitat diorama display to be 

located in the education and visitor center. 

Include static and dynamic components to 

engage and educate visitors of all ages and 

abilities. Cover grassland, wetland, agricultural, 

and forest landscapes. 

— Staff the education and visitor center yearround providing consistent hours of operation (up 

to 48 hours per week). Accomplish this through 

added staff and the expanded use of partners, 

volunteers, seasonal staff, and the YCC program.

— Provide environmental education materials 

in the education and visitor center bookstore. 

The bookstore will be administered by the 

Sullys Hill Wildlife Refuge Society through a 

cooperative agreement with the Service. The 

materials must meet the mission of the Service 

and be approved by the refuge manager. 

— Develop a remote camera and video system 

that will allow students in the education and 

visitor center to observe wildlife on the refuge. 

Link this system to the website for the general 

public to view from remote locations.

— Maintain the trail system for year-round use for 

hikers, snowshoers, and cross-country skiers 

(see figure 8, visitor services map). Develop 

a “tear sheet” map for navigation as well as 

an interpretation tool. Properly sign the trail 

system to correlate with the “tear sheet.”

— Maintain the auto tour network for year-round 

use (see figure 8, visitor services map). Develop 

a “tear sheet” map for navigation as well as a 

self-guided interpretive tool. Properly sign the 

auto tour to correlate with the “tear sheet.” Use 

the “tear sheet” to also direct visitors to the 

refuge’s four observation platforms. 

— Complete a chip and seal on refuge roads to 

ensure visitor safety and assist in maintenance.

— Maintain two newly constructed informational 

kiosks at the entrance and the education and 

visitor center to inform and orient visitors (see 

figure 8, visitor services map).

— Finish updating the refuge brochure and 

distribute it to visitors at key locations within 

the refuge.

— Maintain the five observation platforms (Devils 

Lake vista, wetland, Sullys Hill, nature trail, 

and the prairie dog town overlooks) along 

the auto tour and nature trail with proper 

interpretive panels (see figure 8, visitor 

services map). 

— Replace the temporary outdoor amphitheater 

adjacent to the education and visitor center 

with one that is accessible and consists of 

a covered stage and permanent seating for 

250 people with space to include additional 

temporary seating (see figure 8, visitor services 

map).

— Replace an accessible trail and overlook that 

was lost to Devils Lake flooding. Provide an 

opportunity for visitors of all abilities to enjoy 

nature by locating this trail and overlook 

adjacent to the education and visitor center 

and outdoor amphitheater and providing a link 

to these facilities (see figure 8, visitor services 

map).

— Continue to monitor public use of the refuge 

and facilities. Collect and record weekly 

auto tour and trail system use data. Record 

education and visitor center use through a 

guest book and by education and visitor center 

staff and volunteers. Document classroom use, 

including the number of visitors and topics 

presented, and monitor to ensure the refuge is 

achieving its vision, goals, and objectives.

— Construct a patio and seating area for the 

outdoor birding garden.

— Install counters on single- and double-lane 

portions of the auto tour route and at trail 

heads for accurate use data.

— Increase the daily recreation fee to $3.00 ($20.00 

calendar year annual pass) and collect through 

an automated booth.

— Develop a vehicle radio transmitter system for 

audio interpretation of the auto tour.

— Update and install directional signage for trails 

and auto tour route.

Rationale 

Over the last century, the percentage of people living 

in the United States in urban areas rose from 39% 

to more than 73% (National Aeronautics and Space 

Administration 2000). This urbanization results in a 

general disconnect between humans and the natural 

world. Surprisingly, adults have more opportunities 

to interact directly with nature than children, yet 

children have more access to information about the 

environment through nature shows, computer games, 

and graphics (Hudson 2001). 

Sullys Hill National Game Preserve will expand 

opportunities for visitors and students to experience 

wildlife and nature first-hand. The refuge will serve 

as a vehicle to foster an environmental ethic through 
Chapter 4 — Management Direction 53

Figure 8. Sullys Hill National Game Preserve visitor services map.
54 CCP, Sullys Hill National Game Preserve, ND

the opportunities of wildlife observation, photography, 

interpretation, and environmental education.

Protection and Maintenance Goal

Refuge visitors, staff, and volunteers will have a safe, 

protected, and well-maintained environment in which 

to learn about, work with, understand, and appreciate 

the importance of protecting the unique natural and 

cultural resources of Sullys Hill National Game Preserve.

Protection and Maintenance Objective 1 

One hundred percent of all refuge visitors, 

volunteers, and staff will report feeling safe 

when visiting or working on the refuge. These 

same visitors will fully comprehend the laws and 

regulations in place for their protection and the 

protection of the refuge’s wildlife, lands, facilities, 

and cultural resources (throughout the 15-year CCP). 

Strategies

— Recruit one GS-9 park ranger for law 

enforcement duties to provide regular routine 

patrols and provide for visitor and staff safety, 

and facilities and resource protection. This 

position will be shared with the Devils Lake 

Wetland Management District Complex.

— Pursue a cooperative agreement with local 

law enforcement agencies to add resources 

that will help achieve a high-visibility law 

enforcement presence to deter vandalism and 

other inappropriate behavior on the refuge 

and protect refuge visitors, staff, volunteers, 

facilities, lands, and wildlife.

— Maintain and update the refuge’s signage, 

as needed, to protect and orient visitors and 

identify areas closed to public use.

— Provide proper signage and an outreach 

program that will clearly warn visitors of the 

dangers of approaching wildlife.

— Perform a background check for volunteers 

to ensure a safe setting for environmental 

education programs, facilities, and visitors. 

— Develop a visitor safety section for the visitor 

services plan.

— Develop interpretive programs, materials, and 

signage to provide visitors with information 

on how to view wildlife safely without causing 

harm to the wildlife or themselves.

— Conduct arson patrols to prevent wildland fires 

during peak fire seasons.

— Install security, including camera surveillance, 

and fire alarm systems.

Rationale 

There are few resources available to provide a safe 

environment for staff, volunteers, visitors, wildlife, 

facilities, and cultural resources. If management of 

Sullys Hill National Game Preserve includes plans 

to invite visitors; increase the number of staff and 

volunteers; maintain and protect facilities; and 

protect wildlife, habitat, and cultural resources, then 

the Service is required to provide a minimum level 

of safety. Providing a minimum level of safety is the 

most fundamental responsibility of refuge managers 

(National Wildlife Refuge System Improvement Act 

1997).

Protection and Maintenance Objective 2 

All refuge equipment and facilities will be maintained 

at a level that will adequately support and will not 

hinder visitor, habitat management, and protection 

programs while ensuring the safety of all staff and 

visitors. 

Strategies

— Recruit one full-time maintenance worker, 

WG-6, to maintain the refuge infrastructure, 

including the education and visitor center, 

roads, snow removal, plumbing, carpentry, 

electrical, masonry, painting, groundskeeping, 

enclosure fence, and general operations.

— Conduct routine boundary fence checks and 

control feral animals that harm native wildlife.

Rationale 

There is no dedicated maintenance staff for Sullys 

Hill National Game Preserve. The refuge does 

receive some help from the two Devils Lake Wetland 

Management District Complex maintenance staff. 

The refuge has over $18 million in real property 

assets, not including personal property, that needs 

regular daily maintenance. Some of the facilities that 

need routine and consistent maintenance include the 

following: 

Q A 6-mile, 7-foot-high big-game exclusion fence

Q Sullys Hill overlook interpretive platform

Q Devils Lake interpretive overlook

Q wetland overlook

Q prairie dog overlook

Q two residences

Q 4-mile paved auto tour route

Q 1.2 mile interpretive trail

Q 3,120-square foot fire maintenance shop

Q 32-foot by 28-foot environmental classroom

Q 380-foot accessible nature trail

Q amphitheater

Q 1,600 square foot fire storage building

Q kiosks, entrance signs, interpretive signs

Q 6,094 square foot education and visitor center

Q 6,900 square foot shop/cold storage building
Chapter 4 — Management Direction 55

Protection and Maintenance Objective 3 

Within 2 years of initiation of this plan, generate 

additional entrance fees and increase payment 

compliance to 90% to ensure resources are available 

for maintenance and safety of visitor facilities.

Strategies

— Use random recreation fee compliance patrols 

conducted by on-site law enforcement officer 

(GS-9 park ranger).

— Install an automatic fee collection booth 

eliminating the unreliable volunteer fee program.

— Increase entrance fee initially to $3.00 per visit 

($20.00 annually) and then increase as needed 

over the next 15 years.

Rationale

Entrance fees have been collected through an honor 

system with only an estimated 40% of visitors 

actually paying the $2.00 fee. Given that 60,000 

visitors come to the refuge each year, that is a 

significant loss of revenue. In addition, the fee has 

not increased for years, while visitor services have 

continued to expand, including the construction of the 

new education and visitor center and classrooms. If 

fee compliance were improved along with a nominal 

increase in the entrance fee, additional revenue could 

be generated to provide the resources necessary to 

maintain visitor facilities and fund additional law 

enforcement support. 

Protection and Maintenance Objective 4 

Adverse effects to significant cultural resources 

are avoided, or when necessary, are mitigated in 

compliance with Section 106 of the National Historic 

Preservation Act 100% of the time.

Strategies

— Identify significant cultural resources that 

would be potentially affected by an undertaking 

and preserve them when possible.

— Conduct monitoring patrols to protect 

inventoried sensitive areas and known sites.

— Evaluate cultural resources to fulfill compliance 

with historic preservation laws.

— Consult the regional archaeologist to ensure 

proper implementation of Section 106 into all 

applicable refuge projects.

— Complete cultural resource surveys in high 

probability areas first. 

— Complete a comprehensive cultural resource 

survey of the refuge in partnership with other 

agencies and organizations.

— Organize and protect historical documents and 

information.

— Maintain all buildings, structures, objects, 

and sites designated as “historic properties” 

as defined in Section 106 of NHPA. Protect 

all significant cultural resources from refuge 

activities and vandalism.

Rationale

Federal laws and policies mandate the identification 

and protection of cultural resources. Ideally, a 

comprehensive inventory of the refuge’s cultural 

resources will be useful for ensuring their protection. 

However, these inventories are costly and timeconsuming and require special abilities, such as those 

of an archaeologist to complete. Although the refuge 

does not have such an inventory, it is still necessary 

to protect these resources. To meet this requirement, 

a cultural resources investigation must be completed 

on any site proposed for excavation, before any 

action that may disturb the site. 

4.3 STAFFING AND FUNDING

One full-time person is assigned to Sullys Hill 

National Game Preserve. This person primarily 

has a background in outdoor education. The overall 

budget for the refuge is quite modest ($116,000) 

and primarily pays the salary of this one staff 

person. Most of the current work is carried out by a 

volunteer workforce. 

Table 2 lists this position along with 3.5 new full-time 

equivalent positions (specifically assigned to Sullys 

Hill National Game Preserve) that are needed for full 

implementation of the CCP. 

4.4 PARTNERSHIPS

A major objective of this CCP is to maintain and 

expand existing partnerships and pursue others with 

individuals and groups who share common interests 

with the refuge. These efforts will target neighboring 

landowners, volunteers, private organizations, 

schools, sporting groups, the Spirit Lake Nation, and 

county, state, and natural resource agencies. These 

partnerships will be fundamental to achieving the 

goals and objectives outlined in this plan—through 

sharing of ideas, understanding each others’ needs, 

acquiring new resources for expanded programs, 

and creating a better understanding of the purposes 

of the refuge and its vision—while finding ways 

to complement and support appropriate partner 

programs and activities. 

4.5 STEP-DOWN MANAGEMENT PLANS

Specific monitoring and evaluation activities will be 

described in step-down management plans. This CCP 

is intended as a broad umbrella plan that provides 

general concepts and specific wildlife, habitat, 

endangered species, visitor service, and partnership 

objectives over the next 15 years.
56 CCP, Sullys Hill National Game Preserve, ND

Table 2. Current and proposed staff for Sullys Hill 

National Game Preserve.

Current Staff

Proposed 

Position

Management/

Visitor 

Services Staff

park ranger, 

GS-11

Change 

the title of 

this current 

position to 

visitor services 

manager

Environmental 

Education 

Specialist

None GS-9 

environmental 

education 

specialist

Biological Staff None GS-9 wildlife 

biologist

Administrative 

Staff

None No change

Maintenance 

Staff

None WG-6 full-time 

maintenance 

worker

Law 

Enforcement 

Staff

None GS-9 park 

ranger (shared 

position with 

Devils Lake 

Wetland 

Management 

District 

Complex)

The purpose of a step-down management plan is to 

provide greater detail to managers and employees 

who will carry out the strategies described in the 

CCP. Step-down management plans provide greater 

detail for implementing specific actions authorized 

by the CCP. Table 3 presents those plans needed for 

Sullys Hill National Game Preserve, their current 

status, and the next revision date. 

4.6 MONITORING AND EVALUATION

Adaptive management is a flexible approach to 

long-term management of biotic resources. It allows 

for management to be shaped and directed over 

time by the results of ongoing monitoring activities 

and other discovered information. More specifically, 

adaptive management is a process by which projects 

are implemented within a framework of scientifically 

driven experiments to test the predictions and 

assumptions outlined within a plan. On-the-ground 

observations of responses to management by 

habitats and wildlife are also factored in. Analysis of 

results helps managers determine whether current 

management should continue “as-is” or whether it 

should be modified to achieve desired conditions. 

Changes and adjustments to management and 

operations are considered using the best information 

currently available.

To apply adaptive management, specific survey, 

inventory, and monitoring protocols will be adopted 

for Sullys Hill National Game Preserve. The habitat 

management strategies will be systematically 

evaluated to determine management effects on 

wildlife populations. This information will be used to 

refine approaches and determine how effectively the 

objectives are being accomplished. If monitoring and 

evaluation indicate undesirable effects for target and 

nontarget species or communities, the management 

projects would be altered accordingly. Subsequently, 

the CCP would be revised. 

Observers in the birding garden.

Scott Ralston/USFWS
Chapter 4 — Management Direction 57

Table 3. Step-down management plans for Sullys Hill National Game Preserve

Plan/Proposal

Completed Plan,

Year Approved

New or Revised Plan, 

Completion Year

Disease Management Plan 2006 2012

 Chronic Wasting Disease Plan 2004 2012

Black-tailed Prairie Dog Management Plan — 2009

Big Game Management Plan 1984 2011

Habitat Management Plan — 2011

 Integrated Pest Management Plan 2005 2011

 Prescribed Burning (Annual) 2007 2011

 Forest Plan — 2011

 Grassland Plan — 2011

 Migratory Bird Plan — 2011

Wildlife Inventory and Monitoring Plan — 2010

Visitor Services Plan 1993 2010

 Sign Plan — —

Refuge Safety Plan — 2009

 Law Enforcement Plan — —

 Occupant Emergency Plan — —

Fire Management Plan 2002 2009

Spill Prevention Control and 

Countermeasures Plan

2002 2012

Bugling Elk

Glossary

accessible—Pertaining to physical access to areas and 

activities for people of different abilities, especially 

those with physical impairments.

adaptive resource management—The rigorous 

application of management, research, and monitoring 

to gain information and experience necessary to assess 

and modify management activities; a process that uses 

feedback from research, monitoring, and evaluation of 

management actions to support or modify objectives 

and strategies at all planning levels; a process in 

which policy decisions are implemented within a 

framework of scientifically driven experiments to test 

predictions and assumptions inherent in management 

plans. Analysis of results helps managers determine 

whether current management should continue “as is” 

or whether it should be modified to achieve desired 

conditions. 

Administration Act—National Wildlife Refuge System 

Administration Act of 1966.

alternative—A reasonable way to solve an identified 

problem or satisfy the stated need (40 CFR 1500.2); 

one of several different means of accomplishing refuge 

purposes and goals and contributing to the Refuge 

System mission (Draft Service Manual 602 FW 1.5). 

alleles—An alternative form of a gene that is one 

member of a pair.

alluvial—Relating to, found in, or composed of sand, 

silt, clay, gravel, or other matter deposited by flowing 

water.

amphibian—A class of cold-blooded vertebrates 

including frogs, toads or salamanders.

annual—A plant that flowers and dies within 1 year of 

germination.

baseline—A set of critical observations, data, or 

information used for comparison or as a control.

belt-transect method—An ecological survey method 

which divides the area being surveyed into long, 

narrow, rectangular plots, which is further divided into 

regular blocks. 

biological control—The use of organisms or viruses to 

control invasive plants or other pests.

biological diversity, also biodiversity—The variety of 

life and its processes, including the variety of living 

organisms, the genetic differences among them, and 

the communities and ecosystems in which they occur 

(Service Manual 052 FW 1.12B). The National Wildlife 

Refuge System’s focus is on indigenous species, biotic 

communities, and ecological processes. 

biotic—Pertaining to life or living organisms; caused, 

produced by, or comprised of living organisms.

canopy—A layer of foliage, generally the uppermost 

layer, in a vegetative stand; midlevel or understory 

vegetation in multilayered stands. Canopy closure (also 

canopy cover) is an estimate of the amount of overhead 

vegetative cover.

biotic—Pertaining to life or living organisms; caused, 

produced by, or comprised of living organisms.

carbon sequestration—The capture and secure storage 

of carbon that would otherwise be emitted or remain in 

the atmosphere.

cervids—Any of various hoofed mammals of the family 

Cervidae.

Code of Federal Regulations (CFR)—The codification 

of the general and permanent rules published in the 

Federal Register by the executive departments and 

agencies of the federal government. Each volume of 

the CFR is updated once each calendar year.

compatibility determination—See compatible use. 

compatible use—A wildlife-dependent recreational 

use or any other use of a refuge that, in the sound 

professional judgment of the director of the U.S. Fish 

and Wildlife Service, will not materially interfere 

with or detract from the fulfillment of the mission 

of the Refuge System or the purposes of the refuge 

(Draft Service Manual 603 FW 3.6). A compatibility 

determination supports the selection of compatible 

uses and identified stipulations or limits necessary to 

ensure compatibility. 

comprehensive conservation plan (CCP)—A document 

that describes the desired future conditions of 

the refuge and provides long-range guidance and 

management direction for the refuge manager to 

accomplish the purposes of the refuge, contribute to 

the mission of the Refuge System, and to meet other 

relevant mandates (Draft Service Manual 602 FW 1.5). 

concern—See issue. 

cool-season grasses—Grasses that begin growth 

earlier in the season and often become dormant in 

the summer. These grasses will germinate at lower 

temperatures. Examples of cool-season grasses at the 
60 CCP, Sullys Hill National Game Preserve, ND

refuge are western wheatgrass, needle and thread, and 

green needlegrass. 

coulee—A valley or drainage landform such as a pond 

or creek.

cover, also cover type, canopy cover—Present 

vegetation of an area.

cultural resources—Sites, buildings, structures and 

objects that are the result of human activities and are 

over 50 years old. They include prehistoric, historic, 

and architectural sites, artifacts, historical records, and 

traditional cultural properties—including traditional 

use areas for American Indians—that may or may not 

have material evidence. 

dense nesting cover (DNC)—A composition of grasses 

and forbs that allows for a dense stand of vegetation 

to protect nesting birds from the view of predators, 

usually consisting of one to two species of wheatgrass, 

alfalfa, and sweetclover.

ecosystem—A dynamic and interrelating complex of 

plant and animal communities and their associated 

nonliving environment; a biological community, 

together with its environment, functioning as a 

unit. For administrative purposes, the Service has 

designated 53 ecosystems covering the United States 

and its possessions. These ecosystems generally 

correspond with watershed boundaries and their sizes 

and ecological complexity vary.

ecotonal—Transitioning between two plant 

communities, such as forest to prairie.

emergent—A plant rooted in shallow water and having 

most of the vegetative growth above water such as 

cattail and hardstem bulrush. 

endangered species, federal—A plant or animal species 

listed under the Endangered Species Act of 1973, as 

amended, that is in danger of extinction throughout all 

or throughout a significant portion of its range. 

endangered species, state—A plant or animal 

species in danger of becoming extinct or extirpated 

in a particular state within the near future if factors 

contributing to its decline continue. Populations 

of these species are at critically low levels or their 

habitats have been degraded or depleted to a 

significant degree. 

endemic—Occurs naturally in a certain region or 

whose distribution is relatively limited to a particular 

locality.

environmental assessment (EA)—A concise public 

document, prepared in compliance with the National 

Environmental Policy Act, that briefly discusses 

the purpose and need for an action and alternatives 

to such action, and provides sufficient evidence and 

analysis of impacts to determine whether to prepare 

an environmental impact statement or a finding of no 

significant impact (40 CFR 1508.9). 

extirpation—The extinction of a population; complete 

eradication of a species within a specified area.

exudate—Fluid found in lesions or areas of 

inflammation.

fauna—All the vertebrate and invertebrate animals of 

an area. 

federal trust resource—A trust is something managed 

by one entity for another who holds the ownership. 

The Service holds in trust many natural resources for 

the people of the United States of America as a result 

of federal acts and treaties. Examples are species listed 

under the Endangered Species Act, migratory birds 

protected by international treaties, and native plant or 

wildlife species found on a national wildlife refuge. 

federal trust species—All species where the federal 

government has primary jurisdiction including 

federally endangered or threatened species, migratory 

birds, anadromous fish, and certain marine mammals. 

flora—All the plant species of an area. 

floristics—The composition of plant associations.

forb—A broad-leaved, herbaceous plant; a 

seed-producing annual, biennial, or perennial plant 

that does not develop persistent woody tissue but dies 

down at the end of the growing season.

fragmentation—The alteration of a large block of 

habitat that creates isolated patches of the original 

habitat that are interspersed with a variety of other 

habitat types; the process of reducing the size and 

connectivity of habitat patches, making movement of 

individuals or genetic information between parcels 

difficult or impossible.

“friends group”—Any formal organization whose 

mission is to support the goals and purposes of its 

associated refuge and the National Wildlife Refuge 

Association overall; “friends” organizations and 

cooperative and interpretive associations. 

germ plasm—A collection of genetic resources for an 

organism.

geographic information system (GIS)—A computer 

system capable of storing and manipulating spatial 

data; a set of computer hardware and software for 

analyzing and displaying spatially referenced features 

(such as points, lines and polygons) with nongeographic 

attributes such as species and age. 

goal—A descriptive, open-ended, and often broad 

statement of desired future conditions that conveys a 

purpose but does not define measurable units (Draft 

Service Manual 620 FW 1.5). 

graminoid—Grasses or grasslike plants such as sedges 

and rushes.

grassland tract—A contiguous area of grassland 

without fragmentation.
Glossary 61

habitat—A suite of existing environmental conditions 

required by an organism for survival and reproduction; 

the place where an organism typically lives and grows. 

habitat disturbance—Significant alteration of habitat 

structure or composition; may be natural (for example, 

wildland fire) or human-caused events (for example, 

timber harvest and disking).

habitat type, also vegetation type, cover type—A land 

classification system based on the concept of distinct 

plant associations. 

Improvement Act—National Wildlife Refuge System 

Improvement Act of 1997. 

indigenous—Originating or occurring naturally in a 

particular place.

integrated pest management (IPM)—Methods of 

managing undesirable species such as invasive plants; 

education, prevention, physical or mechanical methods 

of control, biological control, responsible chemical use, 

and cultural methods. 

introduced species—A species present in an area 

due to intentional or unintentional escape, release, 

dissemination, or placement into an ecosystem as a 

result of human activity.

invasive plant, also noxious weed—A species that 

is nonnative to the ecosystem under consideration 

and whose introduction causes, or is likely to cause, 

economic or environmental harm or harm to human 

health. 

issue—Any unsettled matter that requires a 

management decision; for example, a Service initiative, 

opportunity, resource management problem, a threat 

to the resources of the unit, conflict in uses, public 

concern, or the presence of an undesirable resource 

condition (Draft Service Manual 602 FW 1.5).

lacustrine—Of or pertaining to a lake.

management alternative—See alternative. 

mesic—Of, pertaining to, or adapted to an 

environment having a balanced supply of moisture.

meta-population—A group of spatially separated 

populations of the same species which interact in some 

way.

migration—Regular extensive, seasonal movements 

of birds between their breeding regions and their 

wintering regions; to pass usually periodically from one 

region or climate to another for feeding or breeding.

migratory birds—Birds that follow a seasonal 

movement from their breeding grounds to their 

wintering grounds. Waterfowl, shorebirds, raptors, and 

songbirds are all migratory birds.

mission—Succinct statement of purpose or reason for 

being, or both.

mitigation—Measure designed to counteract an 

environmental impact or to make an impact less 

severe. 

mixed-grass prairie—A transition zone between the 

tall-grass prairie and the short-grass prairie dominated 

by grasses of medium height that are approximately 

2–4 feet tall. Soils are not as rich as the tall-grass 

prairie and moisture levels are less.

monitoring—The process of collecting information to 

track changes of selected parameters over time. 

moraine—Unconsolidated debris deposited by a glacier.

national wildlife refuge—A designated area of land, 

water, or an interest in land or water within the 

National Wildlife Refuge System, but does not include 

coordination areas; a complete listing of all units of 

the Refuge System is in the current “Annual Report 

of Lands Under Control of the U.S. Fish and Wildlife 

Service.”

National Wildlife Refuge System (Refuge System)—

Various categories of areas administered by the 

Secretary of the Interior for the conservation of 

fish and wildlife, including species threatened with 

extinction; all lands, waters, and interests therein 

administered by the Secretary as wildlife refuges; 

areas for the protection and conservation of fish and 

wildlife that are threatened with extinction; wildlife 

ranges; game ranges; wildlife management areas; and 

waterfowl production areas. 

National Wildlife Refuge System Improvement Act of 

1997 (Improvement Act)—Sets the mission and the 

administrative policy for all refuges in the National 

Wildlife Refuge System; defines a unifying mission 

for the Refuge System; establishes the legitimacy and 

appropriateness of the six priority public uses (hunting, 

fishing, wildlife observation, wildlife photography, 

environmental education, and interpretation); 

establishes a formal process for determining 

appropriateness and compatibility; establishes the 

responsibilities of the Secretary of the Interior for 

managing and protecting the Refuge System; requires 

a comprehensive conservation plan for each refuge 

by the year 2012. This Act amended portions of the 

Refuge Recreation Act and National Wildlife Refuge 

System Administration Act of 1966.

native species—A species that historically occurred 

or currently occurs in that ecosystem; does not include 

species that are present in an ecosystem as a result of 

an introduction.

necropsy—A postmortem examination.

Neotropical migrant—A bird species that breeds north 

of the United States and Mexican border and winters 

primarily south of this border.

nongovernmental organization—Any group that is not 

composed of federal, state, tribal, county, city, town, 

local, or other governmental entities.
62 CCP, Sullys Hill National Game Preserve, ND

noxious weed, also invasive plant—Any living stage 

(including seeds and reproductive parts) of a parasitic 

or other plant that is of foreign origin (new to or not 

widely prevalent in the U.S.) and can directly or 

indirectly injure crops, other useful plants, livestock, 

poultry, other interests of agriculture, including 

irrigation, navigation, fish and wildlife resources, or 

public health. According to the Federal Noxious Weed 

Act (PL 93-639), a noxious weed (such as an invasive 

plant) is one that causes disease or has adverse effects 

on humans or the human environment and, therefore, 

is detrimental to the agriculture and commerce of the 

U.S. and to public health.

objective—Concise target statement of what will be 

achieved, how much will be achieved, when and where 

it will be achieved, and who is responsible for the 

work; derived from goals and provides the basis for 

determining management strategies. Objectives should 

be attainable and time-specific and should be stated 

quantitatively to the extent possible. If objectives 

cannot be stated quantitatively, they may be stated 

qualitatively (Draft Service Manual 602 FW 1.5). 

palustrine—Relating to a system of inland, nontidal 

wetlands characterized by the presence of trees, 

shrubs, and emergent vegetation (vegetation that 

is rooted below water but grows above the surface). 

Palustrine wetlands range from permanently saturated 

or flooded land (as in marshes, swamps, and lake 

shores) to land that is wet only seasonally.

patch—An area distinct from that around it; an area 

distinguished from its surroundings by environmental 

conditions.

perennial—Lasting or active through the year or 

through many years; a plant species that has a life span 

of more than 2 years.

plant community—An assemblage of plant species 

unique in its composition; occurs in particular locations 

under particular influences; a reflection or integration 

of the environmental influences on the site such as soil, 

temperature, elevation, solar radiation, slope, aspect, 

and rainfall; denotes a general kind of climax plant 

community, such as ponderosa pine or bunchgrass. 

prescribed fire—The skillful application of fire to 

natural fuels under conditions such as weather, fuel 

moisture, and soil moisture that allow confinement 

of the fire to a predetermined area and produces the 

intensity of heat and rate of spread to accomplish 

planned benefits to one or more objectives of habitat 

management, wildlife management, or hazard 

reduction. 

priority public use—One of six uses authorized by 

the National Wildlife Refuge System Improvement 

Act of 1997 to have priority if found to be compatible 

with a refuge’s purposes. This includes hunting, 

fishing, wildlife observation, wildlife photography, 

environmental education, and interpretation.

proposed action—The alternative proposed to best 

achieve the purpose, vision, and goals of a refuge 

(contributes to the Refuge System mission, addresses 

the significant issues, and is consistent with principles 

of sound fish and wildlife management). 

public—Individuals, organizations, and groups; officials 

of federal, state, and local government agencies; Indian 

tribes; and foreign nations. It may include anyone 

outside the core planning team. It includes those who 

may or may not have indicated an interest in Service 

issues and those who do or do not realize that Service 

decisions may affect them. 

public involvement—A process that offers affected 

and interested individuals and organizations an 

opportunity to become informed about and to express 

their opinions on Service actions and policies. In the 

process, these views are studied thoroughly and 

thoughtful consideration of public views is given in 

shaping decisions for refuge management. 

purpose of the refuge—The purpose of a refuge is 

specified in or derived from the law, proclamation, 

executive order, agreement, public land order, donation 

document, or administrative memorandum establishing 

authorization or expanding a refuge, refuge unit, or 

refuge subunit (Draft Service Manual 602 FW 1.5). 

raptor—A carnivorous bird such as a hawk, a falcon, or 

a vulture that feeds wholly or chiefly on meat taken by 

hunting or on carrion (carcasses).

refuge—Sullys Hill National Game Preserve.

refuge purpose—See purpose of the refuge.

Refuge System—See National Wildlife Refuge System.

refuge use—Any activity on a refuge, except 

administrative or law enforcement activity, carried 

out by or under the direction of an authorized Service 

employee. 

rest—Free from biological, mechanical, or chemical 

manipulation, in reference to refuge lands.

restoration—Management emphasis designed to move 

ecosystems to desired conditions and processes, such 

as healthy upland habitats and aquatic systems. 

riparian area or riparian zone—An area or habitat that 

is transitional from terrestrial to aquatic ecosystems 

including streams, lakes, wet areas, and adjacent 

plant communities and their associated soils that 

have free water at or near the surface; an area whose 

components are directly or indirectly attributed 

to the influence of water; of or relating to a river; 

specifically applied to ecology, “riparian” describes the 

land immediately adjoining and directly influenced by 

streams. For example, riparian vegetation includes all 

plant life growing on the land adjoining a stream and 

directly influenced by the stream.
Glossary 63

riverine—Living in or on the bank of a river. While 

riparian is primarily to refer to the living things on 

the banks of the river, riverine refers to living things 

occurring on the banks or in the river.

scarification—To slit or soften the outer coats of seeds 

to speed up germination. Fire can be used to scarify.

scoping—The process of obtaining information from 

the public for input into the planning process. 

scouring—Removal of earth or rock by the action of 

running water or wind-eroding material.

sediment—Material deposited by water, wind, and 

glaciers.

Service—See U.S. Fish and Wildlife Service.

shelterbelt—Single to multiple rows of trees and 

shrubs planted around cropland or buildings to block or 

slow down the wind.

shorebird—Any of a suborder (Charadrii) of birds, 

such as a plover or a snipe, that frequent the seashore 

or mud flat areas.

spatial—Relating to, occupying, or having the 

character of space.

step-down management plan—A plan that provides 

the details necessary to implement management 

strategies identified in the comprehensive conservation 

plan (Draft Service Manual 602 FW 1.5). 

strategy—A specific action, tool, or technique or 

combination of actions, tools, and techniques used to 

meet unit objectives (Draft Service Manual 602 FW 

1.5).

threatened species, federal—Species listed under the 

Endangered Species Act of 1973, as amended, that are 

likely to become endangered within the foreseeable 

future throughout all or a significant portion of their 

range. 

threatened species, state—A plant or animal species 

likely to become endangered in a particular state 

within the near future if factors contributing to 

population decline or habitat degradation or loss 

continue. 

trophic level—The position a species occupies in a food 

chain.

trust resource—See federal trust resource.

trust species—See federal trust species.

U.S. Fish and Wildlife Service (Service, USFWS, 

FWS)—The principal federal agency responsible 

for conserving, protecting, and enhancing fish and 

wildlife and their habitats for the continuing benefit 

of the American people. The Service manages the 

93-million-acre National Wildlife Refuge System 

comprised of more than 530 national wildlife refuges 

and thousands of waterfowl production areas. It also 

operates 65 national fish hatcheries and 78 ecological 

service field stations, the agency enforces federal 

wildlife laws, manages migratory bird populations, 

restores national significant fisheries, conserves and 

restores wildlife habitat such as wetlands, administers 

the Endangered Species Act, and helps foreign 

governments with their conservation efforts. It also 

oversees the federal aid program that distributes 

millions of dollars in excise taxes on fishing and hunting 

equipment to state wildlife agencies.

U.S. Geological Survey (USGS)—A federal agency 

whose mission is to provide reliable scientific 

information to describe and understand the earth; 

minimize loss of life and property from natural 

disasters; manage water, biological, energy, and 

mineral resources; and enhance and protect our quality 

of life.

ungulate—A hooved animal such as a white-tailed deer 

or bison.

vision statement—A concise statement of the desired 

future condition of the planning unit, based primarily 

on the Refuge System mission, specific refuge 

purposes, and other relevant mandates (Draft Service 

Manual 602 FW 1.5). 

visual obstruction—Pertaining to the density of a plant 

community; the height of vegetation that blocks the 

view of predators and conspecifics to a nest. 

visual obstruction reading (VOR)—A method of 

visually quantifying vegetative structure and 

composition.

wading bird—A bird with long legs that enable it to 

wade in shallow water; wading birds include egrets, 

great blue herons, black-crowned night-herons, and 

bitterns.

waterfowl—A category of birds that includes ducks, 

geese, and swans.

watershed—The region draining into a river, a river 

system, or a body of water.

wetland management district—Land that the Refuge 

System acquires with Federal Duck Stamp funds 

for restoration and management primarily as prairie 

wetland habitat critical to waterfowl and other wetland 

birds. 

wildland fire—A free-burning fire requiring a 

suppression response; all fire other than prescribed fire 

that occurs on wildlands (Service Manual 621 FW 1.7). 

wildlife-dependent recreational use—Use of a refuge 

involving hunting, fishing, wildlife observation, 

wildlife photography, environmental education, or 

interpretation. The National Wildlife Refuge System 

Improvement Act of 1997 specifies that these are the 

six priority general public uses of the Refuge System. 
64 CCP, Sullys Hill National Game Preserve, ND

woodland—Open stands of trees with crowns which do 

not usually touch, generally forming 25–60% cover.
Appendix A

Key Legislation and Policies

This appendix describes the guidance for the 

National Wildlife Refuge System and other policies 

and key legislation that guide the management of 

Sullys Hill National Game Preserve.

N

“The mission of the Refuge System is to 

administer a national network of lands and waters 

for the conservation, management, and where 

appropriate, restoration of the fish, wildlife, and 

plant resources and their habitats within the 

United States for the benefit of present and future 

generations of Americans.” (National Wildlife 

Refuge System Improvement Act of 1997)

Goals

Q Fulfill our statutory duty to achieve refuge 

purposes and further the System mission. 

Q Conserve, restore where appropriate, and 

enhance all species of fish, wildlife, and plants 

that are endangered or threatened with 

becoming endangered.

Q Perpetuate migratory bird, inter-jurisdictional 

fish, and marine mammal populations. 

Q Conserve a diversity of fish, wildlife, and plants. 

Q Conserve and restore, where appropriate, 

representative ecosystems of the United States, 

including the ecological processes characteristic 

of those ecosystems. 

Q Foster understanding and instill appreciation of 

fish, wildlife, and plants, and their conservation, 

by providing the public with safe, high 

quality, and compatible wildlife-dependent 

public use. Such use includes hunting, fishing, 

wildlife observation and photography, and 

environmental education and interpretation. 

Guiding Principles

There are four guiding principles for management 

and general public use of the Refuge System 

established by Executive Order 12996 (1996):

Q Public Use—The Refuge System provides 

important opportunities for compatible 

wildlife-dependent recreational activities 

involving hunting, fishing, wildlife observation 

and photography, and environmental education 

and interpretation.

Q Habitat—Fish and wildlife will not prosper 

without high-quality habitat, and without 

fish and wildlife, traditional uses of refuges 

cannot be sustained. The Refuge System will 

continue to conserve and enhance the quality 

and diversity of fish and wildlife habitat within 

refuges.

Q Partnerships—America’s sportsmen and 

women were the first partners who insisted 

on protecting valuable wildlife habitat within 

wildlife refuges. Conservation partnerships 

with other federal agencies, state agencies, 

tribes, organizations, industry, and the general 

public can make significant contributions to the 

growth and management of the Refuge System.

Q Public Involvement—The public should be 

given a full and open opportunity to participate 

in decisions regarding acquisition and 

management of our national wildlife refuges.

L

Management actions on national wildlife refuges are 

circumscribed by many mandates, including laws and 

executive orders, the latest of which is the Volunteer 

and Community Partnership Enhancement Act of 

1998. Regulations that have the greatest effect on 

refuge management are listed below. 

American Indian Religious Freedom Act 

(1978)—Directs agencies to consult with native 

traditional religious leaders to determine appropriate 

policy changes necessary to protect and preserve 

Native American religious cultural rights and 

practices.

Americans with Disabilities Act (1992)—Prohibits 

discrimination in public accommodations and 

services.

Antiquities Act (1906)—Authorizes the scientific 

investigation of antiquities on federal land and 

provides penalties for unauthorized removal of 

objects taken or collected without a permit.

Archaeological and Historic Preservation Act 

(1974)—Directs the preservation of historic and 

archaeological data in federal construction projects.
66 CCP, Sullys Hill National Game Preserve, ND

Archaeological Resources Protection Act (1979), 

as amended—Protects materials of archaeological 

interest from unauthorized removal or destruction 

and requires federal managers to develop plans and 

schedules to locate archaeological resources.

Architectural Barriers Act (1968)—Requires federally 

owned, leased, or funded buildings and facilities to be 

accessible to persons with disabilities.

Clean Water Act (1977)—Requires consultation with 

the U.S. Army Corps of Engineers (404 permits) for 

major wetland modifications.

Endangered Species Act (1973)—Requires all federal 

agencies to carry out programs for the conservation 

of endangered and threatened species.

Executive Order No. 3596 (1921)—Establishes Sullys 

Hill National Game Preserve “as a refuge and 

breeding ground for birds.” 

Executive Order 11988 (1977)—Requires federal 

agencies to provide leadership and take action to 

reduce the risk of flood loss, minimize the impact of 

floods on human safety, and preserve the natural and 

beneficial values served by the floodplains.

Executive Order 12996, Management and General 

Public Use of the National Wildlife Refuge System 

(1996)—Defines the mission, purpose, and priority 

public uses of the National Wildlife Refuge System. 

It also presents four principles to guide management 

of the Refuge System.

Executive Order 13007, Indian Sacred Sites 

(1996)—Directs federal land management agencies to 

accommodate access to and ceremonial uses of Indian 

sacred sites by Indian religious practitioners, avoid 

adversely affecting the physical integrity of such 

sacred sites, and where appropriate, maintain the 

confidentiality of sacred sites.

Federal Noxious Weed Act (1990)—Requires 

the use of integrated management systems to 

control or contain undesirable plant species and an 

interdisciplinary approach with the cooperation of 

other federal and state agencies.

Federal Records Act (1950)—Requires the 

preservation of evidence of the government’s 

organization, functions, policies, decisions, 

operations, and activities, as well as basic historical 

and other information.

Fish and Wildlife Coordination Act (1958)—Allows 

the U.S. Fish and Wildlife Service to enter into 

agreements with private landowners for wildlife 

management purposes.

Migratory Bird Conservation Act (1929)—Establishes 

procedures for acquisition by purchase, rental, 

or gifts of areas approved by the Migratory Bird 

Conservation Commission.

Migratory Bird Hunting and Conservation Stamp Act 

(1934)—Authorizes the opening of part of a refuge to 

waterfowl hunting.

Migratory Bird Treaty Act (1918)—Designates 

the protection of migratory birds as a federal 

responsibility; and enables the setting of seasons 

and other regulations, including the closing of areas, 

federal or nonfederal, to the hunting of migratory 

birds.

National Environmental Policy Act (1969)—Requires 

all agencies, including the Service, to examine the 

environmental impacts of their actions, incorporate 

environmental information, and use public 

participation in the planning and implementation 

of all actions. Federal agencies must integrate 

this Act with other planning requirements, and 

prepare appropriate documents to facilitate better 

environmental decision making [From the Code of 

Federal Regulations (CFR), 40 CFR 1500].

National Historic Preservation Act (1966), as 

amended—Establishes as policy that the federal 

government is to provide leadership in the 

preservation of the Nation’s prehistoric and historical 

resources. 

National Wildlife Refuge System Administration 

Act (1966)—Defines the National Wildlife Refuge 

System and authorizes the Secretary of the Interior 

to permit any use of a refuge, provided such use is 

compatible with the major purposes for which the 

refuge was established.

National Wildlife Refuge System Improvement Act of 

1997—Sets the mission and administrative policy for 

all refuges in the National Wildlife Refuge System; 

mandates comprehensive conservation planning for 

all units of the Refuge System.

Native American Graves Protection and Repatriation 

Act (1990)—Requires federal agencies and museums 

to inventory, determine ownership of, and repatriate 

cultural items under their control or possession.

Refuge Recreation Act (1962)—Allows the use of 

refuges for recreation when such uses are compatible 

with the refuge’s primary purposes and when 

sufficient funds are available to manage the uses.

Rehabilitation Act (1973)—Requires programmatic 

accessibility in addition to physical accessibility 

for all facilities and programs funded by the 

federal government to ensure that any person can 

participate in any program.

Rivers and Harbors Act (1899)—Section 10 of this 

Act requires the authorization of U.S. Army Corps 

of Engineers prior to any work in, on, over, or under 

navigable waters of the United States.
Appendix A — Key Legislation and Policies 67

Volunteer and Community Partnership Enhancement 

Act (1998)—Encourages the use of volunteers to 

assist in the management of refuges within the 

Refuge System; facilitates partnerships between the 

Refuge System and nonfederal entities to promote 

public awareness of the resources of the Refuge 

System and public participation in the conservation 

of the resources; and encourages donations and other 

contributions.

Appendix B

Preparers

This document is the result of the extensive, collaborative, and enthusiastic efforts by members of the 

planning team shown below.

Team Member Position Work Unit

Jim Alfonso

Cami Dixon

Mark Ely

Paul Halko

Roger Hollevoet

Deputy project leader

Wildlife biologist

Geographic information system 

(GIS) specialist

Wetland District Manager

Project leader

Devils Lake Wetland Management District Complex, 

Devils Lake, ND

Devils Lake Wetland Management District Complex, 

Devils Lake, ND

USFWS, Region 6, Lakewood, CO

Devils Lake Wetland Management District Complex, 

Devils Lake, ND

Devils Lake Wetland Management District Complex, 

Devils Lake, ND

Laura King Planning team leader Division of Planning, Region 6, Cayuga, ND

Elizabeth Cross Editor TBC Solutions

Many organizations, agencies, and individuals provided invaluable assistance with the preparation of this 

CCP. The Service acknowledges the efforts of the following individuals and groups towards the completion 

of this plan. The diversity, talent, and knowledge contributed dramatically improved the vision and 

completeness of this document.

Contributor Position Work Unit

Dr. Brad Andres Wildlife biologist USFWS

Kristine Askerooth Wildlife biologist USFWS

Sean Bertie Graduate student UND, Grand Forks, ND

Rick Coleman Assistant regional director, 

Refuge System USFWS

Paul Cornes Refuge supervisor USFWS

Carrie Duafala Wildlife biologist Spirit Lake Nation, St. Michael, ND

Marty Egland Outreach specialist NDGFD

John Esperance

Sheri Fetherman

Chief, Comprehensive and Land 

Protection Planning

Chief, Division of Education and 

Visitor Services

USFWS

USFWS

Lorin Fornes Forest technician ND Forest Service
70 CCP, Sullys Hill National Game Preserve, ND

Contributor Position Work Unit

Jim Garrett Natural resource management

instructor Cankdeska Cikana Community College

Jackie Jacobson Outdoor recreation planner USFWS

Bob Harsel Forest management specialist ND Forest Service

Rod Krey Former refuge supervisor USFWS

Vern Lambert Education specialist Spirit Lake Nation

Rachel Lauhban Wildlife biologist USFWS

Joe Maxwell

Former refuge manager, Sullys

Hill National Game Preserve, 

transferred July 2006

USFWS

Russ McDonald Planner Spirit Lake Nation

Andrew Morin Fish and wildlife director Spirit Lake Nation

Neil Niemuth Wildlife biologist USFWS

Myra Pearson Tribal chairwoman Spirit Lake Nation

Jeff Printz State range conservationist NRCS

David Redhorse Former Native American liason USFWS

Dr. Tom Roffe Region 6 chief, wildlife health USFWS

Rick Schroeder Wildlife biologist USGS

Michael Spratt Chief, Division of Refuge Planning USFWS

Craig Stange State forester NRCS

Dr. Rick Sweitzer Professor UND, Grand Forks, ND

Craig Tanner

Refuge manager, Sullys Hill 

National Game Preserve,

arrived April 2007

USFWS

Meg Van Ness Regional archaeologist USFWS
Appendix C

Public Involvement

In 2006, Sullys Hill National Game Preserve 

initiated its planning process. A notice of intent was 

published in the Federal Register on May 23, 2006. 

A newsletter, comment and mailing list forms, along 

with a postage paid envelope, were mailed to over 

320 individuals on the initial refuge planning mailing 

list. A public scoping meeting was held at the refuge 

education and visitor center in Fort Totten, North 

Dakota, on June 29, 2006. This meeting was attended 

by 10 community members who provided verbal and 

written comments. 

In April 2006, the Service sent a letter to the North 

Dakota Game and Fish Department (NDGF) and 

several American Indian tribes to invite them to 

participate in the planning process. Staff from 

various divisons of NDGF participated in biological 

workshops and the vision and goals workshop. 

Members of the Spirit Lake Nation (chairwoman 

and several tribal members) participated in public 

meetings and planning workshops. 

When the scoping period ended on August 1, 

2006, the planning team received over 183 written 

comments. Comments received identified biological, 

social, and economic concerns regarding refuge 

management. 

On June 26, 2008, the Service published a notice of 

availability announcing the draft comprehensive 

conservation plan and environmental assessment 

was available for a 30-day review. Hard copies of the 

document and/or a planning update, summarizing 

the plan, were mailed to 238 federal, state, and 

local agencies, organizations and citizens. The 

document was also posted on the region 6 website. 

A public meeting was announced in the planning 

update and through state and local media outlets. 

Eleven people attended a public meeting held 

on July 22, 2008, in Fort Totten, North Dakota, 

which included a presentation and an opportunity 

for people to ask questions and offer comments. 

Meeting attendees complimented the staff on 

developing such an innovative plan and looked 

forward to its implementation. No other substantive 

public comments were received. A summary of the 

comments and responses can be found at the end of 

this appendix.

The mailing list for federal, state, local organizations, 

governments, tribes, other agencies, schools and 

universities, media, and national organizations 

follows:

FEDERAL OFFICIALS

U.S. Representative Earl Pomeroy, Washington DC

Rep. Pomeroy’s Area Director, Bismarck, ND

U.S. Senator Kent Conrad, Washington DC

Sen. Conrad’s Area Director, Bismarck, ND

U.S. Senator Byron Dorgan, Washington DC

Sen. Dorgan’s Area Director, Minot, ND

Sen. Dorgan’s Area Director, Bismarck, ND

FEDERAL AGENCIES

USFWS Ecological Services, Bismarck, ND

USFWS Habitat and Population Evaluation Team, 

Bismarck, ND

USGS–Northern Prairie Wildlife Research Center, 

Jamestown, ND

TRIBAL OFFICIALS

Spirit Lake Tribal Council, Fort Totten, ND

Three Affiliated Tribes, New Town, ND

Turtle Mountain Band of Chippewa, Belcourt, ND

STATE OFFICIALS

Governor John Hoeven, Bismarck, ND

Lance Gaebe, Governor’s Office, Bismarck, ND

Representative Thomas Brusegard, Gilby, ND

Representative Lois Delmore, Grand Forks, ND

Representative William Devlin, Finley, ND

Representative Eliot Glassheim, Grand Forks, ND

Representative Gil Herbel, Grafton, ND

Representative Dennis Johnson, Devils Lake, ND

Representative Joyce Kingsbury, Grafton, ND

Representative David Monson, Osnanbrock, ND

Representative Jon Nelson, Wolford, ND

Representative Eugene Nicholas, Cando, ND

Representative Darrell Nottestad, Grand Forks, ND

Representative Louise Potter, Grand Forks, ND

Representative Jo Ann Rodenbiker, Rock Lake, ND

Representative Arlo Schmidt, Maddock, ND

Representative Ken Svedjan, Grand Forks, ND

Representative Gerald Uglem, Northwood, ND

Representative Don Vigesaa, Cooperstown, ND
72 CCP, Sullys Hill National Game Preserve, ND

Representative Amy Wamke, Grand Forks, ND

Representative Lonny Winrich, Grand Forks, ND

Senator Duane Espegard, Grand Forks, ND

Senator Michael Every, Minnewauken, ND

Senator Ray Holmberg, Grand Forks, ND

Senator Duane Mutch, Larimore, ND

Senator Harvey Tallackson, Grafton, ND

Senator Ryan Taylor, Towner, ND

Senator John Traynor, Devils Lake, ND

Senator Thomas Trenbeath, Cavalier, ND

STATE AGENCIES

NDGF, Bismarck, ND

State Historical Society, Bismarck, ND

Pembina State Museum, Pembina, ND

North Dakota Department of Transportation, Devils 

Lake, ND

North Dakota Tourism Division, Bismarck, ND

North Dakota State Water Commission, Bismarck, 

ND

North Dakota Forest Service

Devils Lake Basin Joint Water Board, Devils Lake, 

ND

Lake Region Human Service Center, Devils Lake, 

ND

LOCAL GOVERNMENT

Nelson County Commission Chair Jack Davidson, 

Lakota, ND

Towner County Commission Chair Terry Johnson, 

Cando, ND

Grand Forks County Commission Chair Constance 

Triplett, Grand Forks, ND

Benson County Commissioner Chair Dwain Brown, 

Minnewaukan, ND

Walsh County Commission Chair Tork Kilichowski, 

Grafton, ND

Ramsey County Commission Chair Joe Belford, 

Devils Lake, ND

Ramsey County Housing Authority, Devils Lake, ND

ORGANIzATIONS

Sullys Hill Wildlife Refuge Society, Devils Lake, ND

Prairie Wetlands Resource Center, Bismarck, ND

Grand Cities Bird Club, Grand Forks, ND

Fort Totten State Historical Society

The Wildlife Society, Bismarck, ND

Audubon Society, Washington DC and Fargo, ND

ND Natural Resources Trust, Devils Lake, ND

Ducks Unlimited, Bismarck, ND

The Nature Conservancy, Minneapolis, MN

Sierra Club, Bismarck, ND

North American Nature Photography Association

Animal Protection Institute

Beyond Pesticides

Wildlife Management Institute

Defenders of Wildlife, Washington DC

The Wilderness Society, Washington DC

National Trappers Association

Fund for Animals

Bird Watchers Digest

Devils Lake Area Foundation, Devils Lake, ND

Grand Forks Convention and Visitors Bureau, Grand 

Forks, ND

Devils Lake Chamber of Commerce, Devils Lake, 

ND

Devils Lake Visitor Bureau, Devils Lake, ND

UNIVERSITIES, COLLEGES, AND 

SCHOOLS

Lake Region State College, Devils Lake, ND

North Dakota State University, Fargo, ND

The University of North Dakota, Grand Forks, ND

Edmore Public School, Edmore, ND

St. Josephs School, Devils Lake, ND

Minnewauken Public School, Minnewauken, ND

Midkota High School, Glenfield, ND

Prairie View Elementary School, Devils Lake, ND

Central Middle School, Devils Lake, ND

Lake Region Special Education, Devils Lake, ND

Neche School District, Neche, ND

Lakota Elementary, Lakota, ND

Warwick Public School, Warwick, ND

Nash Public School, Grafton, ND

Cando Elementary, Cando, ND

Sheyenne Elementary School, Sheyenne, ND

Fordville-Lankin High School, Fordville, ND

Four Winds School, Fort Totten, ND

Edmore Public School, Edmore, ND

Devils Lake Public School, Devils Lake, ND

Ely Elementary School, Rugby, ND

Langdon Middle School, Langdon, ND

Minnie H School, Devils Lake, ND

Carrington Elementary School, Carrington, ND

Adams Public School, Adams, ND

MEDIA 

KZZY/KQZZ Radio

Grand Forks Herald

Devils Lake Journal

KDLR/KDVL Radio

North Dakota Living

INDIVIDUALS

194 private individuals

COMMENTS AND RESPONSES 

ON THE DRAFT CCP AND EA

Comment 1—Ban all prescribed fire on this refuge. 

Response 1—Fire is an integral process in the 

northern mixed-grass prairie, as these grasslands 

evolved with interacting grazing and fire 

disturbances and climatic variability. Without these 
Appendix C — Public Involvement 73

disturbances, nutrient cycling is not achieved and not 

available to growing plants. Grasslands are not as 

healthy and diverse, and invasive species and noxious 

weeds, become established. The most efficient and 

effective way to maintain healthy grasslands is to 

attempt to mimic the natural processes through 

prescribed fire, grazing, and rest.

Comment 2—How will the refuge maintain the herds 

of elk, bison, and deer?

Response 1—As a big game preserve, the refuge is 

completely surrounded by a large electrified fence. 

This concentrates large ungulates, such as elk, 

deer, and plains bison. These large ungulates are 

voracious grazers and if allowed to increase, can have 

a catastrophic impact on refuge habitats. In addition, 

a large concentration of ungulates can facilitate 

the spread of disease, which can be transmitted to 

other native wildlife. The Service does remove some 

animals from the refuge population. A small number 

of elk and deer are harvested by the Service. This is 

in coordination with periodic animal health checks, 

for such things as brain and lungworm, which can 

only be conducted through a necropsy. The plains 

bison are transferred to other refuges as part of 

a program to maintain the genetic integrity of a 

unique group of bison that most closely resembles 

the genetics of the native plains bison. There are 

no similar opportunities for transferring deer and 

elk due to policies and concerns related to diseases 

inherent in these animals. The refuge’s purposes are 

as a big game preserve and as a refuge for migratory 

birds. Maintaining the ungulate population at 

proposed sizes will meet the game preserve purpose, 

while conserving supporting habitats not only for 

these animals, but for even more imperiled migratory 

birds dependent on the refuge’s woodland and 

grassland habitats.

Section 7 Biological Evaluation

Appendix D
76 CCP, Sullys Hill National Game Preserve, ND
Appendix D — Section 7 Biological Evaluation 77
78 CCP, Sullys Hill National Game Preserve, ND

Jeffrey K. Towner, field supervisor

Ecological Services

Bismarck, ND
Environmental Compliance

Appendix E

Environmental Action Statement

U.S. Fish and Wildlife Service, Region 6 

Lakewood, Colorado

Within the spirit and intent of the Council on 

Environmental Quality’s regulations for implementing 

the National Environmental Policy Act and other 

statutes, orders, and policies that protect fish and 

wildlife resources, I have established the following 

administrative record.

I have determined that the action of implementing 

the “Comprehensive Conservation Plan–Sullys 

Hill National Game Preserve” is found not to have 

significant environmental effects, as determined by 

the attached Finding of No Significant Impact and 

the environmental assessment as found with the 

draft comprehensive conservation plan.
80 CCP, Sullys Hill National Game Preserve, ND

Finding of No Significant Impact

U.S. Fish and Wildlife Service, Region 6 

Lakewood, Colorado

Three management alternatives for Sullys Hill 

National Game Preserve were assessed as to their 

effectiveness in achieving the refuges’ purposes and 

their impacts on the human environment. 

Q Alternative A, the “no-action” alternative, 

would continue current management. 

Q Alternative B, would begin to address reduced 

forest regeneration by managing the uncontrolled 

browsing of bison, elk, and white-tailed deer. 

Ungulates would be maintained, as per the 

“Fenced Animal Management Plan” (25-40 bison; 

15-25 elk; 10-30 white-tailed deer). Native 

prairie would be enhanced through prescribed 

fire and grazing, and controlling invasive 

species. Visitors would be provided seasonal 

opportunities to view wildlife and learn about 

the refuge and additional on-site educational 

programs would be provided. There would be 

an increased law enforcement presence during 

peak visitor-use days. 

Q Alternative C, would begin to address forest 

regeneration, enhance native prairie, and 

restore selected haylands to native vegetation. 

Invasive species would be treated and areas 

restored. Ungulate populations would be 

maintained at ≤20 bison, ≤18 elk, and ≤18 whitetailed deer to control disease, overgrazing, 

and overbrowsing. Herd health programs 

would take a more active disease surveillance 

and treatment approach, including timely 

introduction of ungulates to maintain genetic 

health, particularly bison. Visitor services 

programs would be offered year-round along 

with law enforcement presence. There would 

be an increase in both on-site and off-site 

environmental education programs. A formal 

wetland and grassland conservation curriculum 

would be developed in cooperation with local 

teachers. Refuge staff would work with the 

Spirit Lake Nation schools and agencies to 

encourage students to pursue careers in refuge

management. 

Based on this assessment and comments received, 

I have selected alternative C as the preferred 

alternative for implementation. The preferred 

alternative was selected because it best meets the 

purposes for which the Sullys Hill National Game 

Preserve was established and is preferable to the 

“no-action” alternative in light of physical, biological, 

economic, and social factors. The preferred alternative 

will continue to provide public access for wildlifedependent recreation at Sullys Hill National Game 

Preserve (wildlife observation, photography, 

environmental education, and interpretation). 

I find that the preferred alternative is not a major 

federal action that would significantly affect the 

quality of the human environment within the meaning 

of Section 102(2)(C) of the National Environmental 

Policy Act of 1969. Accordingly, the preparation of 

an environmental impact statement on the proposed 

action is not required. 

The following is a summary of anticipated 

environmental effects from implementation of the 

preferred alternative:

Q The preferred alternative will not adversely 

impact endangered or threatened species or 

their habitat.

Q The preferred alternative will not adversely 

impact archaeological or historical resources.

Q The preferred alternative will not adversely 

impact wetlands nor does the plan call for 

structures that could be damaged by or that 

would significantly influence the movement of 

floodwater.

Q The preferred alternative will not have a 

disproportionately high or adverse human 

health or environmental effect on minority or 

low-income populations.

Q The state of North Dakota has been notified 

and given the opportunity to review the 

comprehensive conservation plan and 

associated environmental assessment.
class amphibia

Appendix F

Species List

Below is a list of resident and migrant wildlife 

species that occur or have the potential to occur on 

or adjacent to Sullys Hill National Game Preserve. 

Following the wildlife list is a plant list that includes 

species mentioned throughout this CCP, as well as 

species confirmed and likely to occur at the refuge. 

Refuge baseline and anecdotal data were used where 

possible to develop these lists; however much of the 

information used to develop the lists was obtained 

from various sources that provided species lists 

and occurrences for North Dakota, including Wiehe 

and Cassel (1978), Iverson et al. (1967), McLaren 

(2001), Hoberg and Gause (1992), and Royer et al. 

(1998). The amphibians, reptiles, mammals, and fish 

are listed in taxonomic order following Banks et al. 

(1987). Bird species are listed in taxonomic order 

based on the “Check-list of North American Birds” 

(American Ornithologists Union 2005). 

 ANIMALS

class aMPHibia

Order Common Name Scientific Name

Caudata

Anura

Anura

Anura

Anura

Anura

Tiger salamander

Canadian toad 

Great Plains toad

Northern leopard frog

Western chorus frog

Wood frog

Ambystoma tigrinum

Bufo hemiophrys

Bufo cognatus

Rana pipiens

Pseudacris triseriata

Rana sylvatica

class rePtilia

Order Common Name Scientific Name

Testudines

Testudines

Squamata

Squamata

Squamata

Squamata

Squamata

Common snapping turtle

Western painted turtle

Common garter snake

Plains garter snake

Redbelly snake

Smooth green snake

Western hognose snake

Chelydra serpentina

Chrysemys picta belli

Thamnophis sirtalis

Thamnophis radix

Storeria occipitomaculata

Opheodrys vernalis

Heterdon nasicus

class aves

Order Common Name Scientific Name

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

American black duck

American pidgeon 

Blue-winged teal

Bufflehead

Canada goose

Canvasback

Common goldeneye

Common merganser

Gadwall

Anas rubripes

Anas Americana

Anas discors

Bucephala albeola

Branta Canadensis

Aythya valisineria

Bucephala clangula

Mergus merganser

Anas strepara
82 CCP, Sullys Hill National Game Preserve, ND

class aves continued

Order Common Name Scientific Name

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Anseriformes

Galliformes

Galliformes

Galliformes

Galliformes

Podicipediformes

Podicipediformes

Podicipediformes

Podicipediformes

Pelicaniformes

Pelicaniformes

Ciconiiformes

Ciconiiformes

Ciconiiformes

Ciconiiformes

Ciconiiformes

Ciconiiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Falconiformes

Gruiformes

Gruiformes

Gruiformes

Charadriiformes

Charadriiformes

Charadriiformes

Green-winged teal

Hooded merganser

Lesser scaup

Mallard

Northern pintail

Northern shoveler

Redhead

Ring-necked duck

Ruddy duck

Tundra swan

Wood duck

Gray partridge

Ring-necked pheasant

Sharp-tailed grouse

Wild Turkey

Eared grebe

Horned grebe

Pied-billed grebe

Western grebe

American white pelican

Double-crested cormorant

American bittern

Black-crowned night-heron

Great blue heron

Great egret

Green heron

Turkey vulture

American kestrel

Bald eagle

Broad-winged hawk

Cooper’s hawk

Golden eagle

Merlin

Northern goshawk

Northern harrier

Osprey

Peregrine falcon

Red-tailed hawk

Sharp-shinned hawk

Swainson’s hawk

American coot

Sora

Virginia rail

American avocet

American woodcock

Black tern

Anas crecca

Lophodytes cucullatus

Aythya afinis

Anas platyrhynchos

Anas acuta

Anas clypeata

Aythya Americana

Aythya collaris

Oxyura jamaicensis

Cygnus columbianus

Aix sponsa

Perdix perdix

Phasianus colchicus

Tympanuchus cupido

Meleagris gallopavo

Podiceps nigricollis

Podiceps auritus

Podylimbus podiceps

Aechmophorus occidentalis

Pelicanus erythrocephalus

Phalacrocorax auritus

Botarus lentiginosus

Nycticorax nycticorax

Ardea Herodias

Ardea alba

Boturides striatus

Cathartes aura

Falco sparverius

Haliaeetus leukocephalus

Buteo platypterus

Accipitor cooperii

Aquila chrysaetos

Falco columbarius

Accipiter gentiles

Circus cyaneus

Pandion haliaetus

Falco peregrinus

Buteo jamaicensis

Accipitor striatus

Buteo swainsoni

Fulica Americana

Porzana carolina

Coturnicops noveboracensis

Recurvirostra americana

Scolopax minor

Sterna niger
Appendix F — Species List 83

class aves continued

Order Common Name Scientific Name

Charadriiformes California gull Larus californicus

Charadriiformes Common tern Sterna hirundo

Charadriiformes Forster’s tern Sterna forsteri

Charadriiformes Franklin’s gull Larus pipixcan

Charadriiformes Greater yellowlegs Tringa melanoleuca

Charadriiformes Killdeer Charadrius vociferous

Charadriiformes Lesser yellowlegs Tringa flavipes

Charadriiformes Marbled godwit Limosa fedoa

Charadriiformes Ring-billed gull Larus delawarensis

Charadriiformes Solitary sandpiper Tringa solitaria

Charadriiformes Spotted sandpiper Actitis macularia

Charadriiformes Upland sandpiper Bartamia longicauda

Charadriiformes Wilson’s snipe Gallanago delicate

Columbiformes Mourning dove Zenaida macroura

Columbiformes Rock dove Columba livia

Cuculiformes Black-billed cuckoo Coccyzus erythropthalmus

Cuculiformes Yellow-billed cuckoo Coccyzus americanus

Strigiformes Eastern screech owl Otus asio

Strigiformes Great horned owl Bubo virginianus

Strigiformes Northern saw-whet owl Aegolius acadicus

Strigiformes Snowy owl Nyctea scandiaca

Caprimulgiformes Common nighthawk Chordeiles minor

Apodiformes Chimney swift Chaetura pelagica

Apodiformes Ruby-throated hummingbird Archilochus colubris

Coraciiformes Belted kingfisher Ceryle alcyon

Piciformes Downy woodpecker Picoides pubescens

Piciformes Hairy woodpecker Picoides villosus

Piciformes Lewis’ woodpecker Melanerpes lewis

Piciformes Northern flicker Colaptes auratus

Piciformes Pileated woodpecker Dryocopus pileatus

Piciformes Red-bellied woodpecker Melanerpes carolinus

Piciformes Red-headed woodpecker Melanerpes erythrocephalus

Piciformes Yellow-bellied sapsucker Sphyrapicus varius

Passeriformes Alder flycatcher Empidonax alnorum

Passeriformes American crow Corvus brachyrhynchos

Passeriformes American goldfinch Carduelis tristis

Passeriformes American redstart Setophaga ruticilla

Passeriformes American robin Turdus migratorius

Passeriformes American tree sparrow Spizella arborea

Passeriformes Baltimore oriole Icterus galbula

Passeriformes Bank swallow Riparia riparia

Passeriformes Barn swallow Hirundo rustica

Passeriformes Bay-breasted warbler Dendroica castanea

Passeriformes Black-and-white warbler Mniotilta varia

Passeriformes Black-billed magpie Pica hudsonia

Passeriformes Blackburnian warbler Dendroica fusca

 
84 CCP, Sullys Hill National Game Preserve, ND

class aves continued

Order Common Name Scientific Name

Passeriformes Black-capped chickadee Poecile atricappila

Passeriformes Blackpoll warbler Dendroica striata

Passeriformes Black-throated green warbler Dendroica virens

Passeriformes Blue-headed vireo Vireo solitarius

Passeriformes Blue jay Cyanocitta cristata

Passeriformes Bobolink Dolichonyx oryzivorus

Passeriformes Bohemian waxwing Bombycilla garrulous

Passeriformes Brewer’s blackbird Euphagus cyanocephalis

Passeriformes Brown creeper Certhia americana

Passeriformes Brown-headed cowbird Molothrus ater

Passeriformes Brown thrasher Toostoma rufum

Passeriformes Canada warbler Wilsonia Canadensis

Passeriformes Cape May warbler Dendroica tigrina

Passeriformes Cedar waxwing Bombycilla cedrorum

Passeriformes Chestnut-sided warbler Dendroica pensylvanica

Passeriformes Chipping sparrow Spizella passerina

Passeriformes Clay-colored sparrow Spizella pallida

Passeriformes Cliff swallow Petrochelidon pyrrhonota

Passeriformes Common grackle Quiscalus quiscula

Passeriformes Common redpoll Carduelis flammea

Passeriformes Common yellowthroat Geothlipis trichas

Passeriformes Dark-eyed junco Junco hyemalis

Passeriformes Eastern bluebird Sialia sialis

Passeriformes Eastern kingbird Tyrannus forficatus

Passeriformes Eastern phoebe Saynoris phoebe

Passeriformes Eastern wood-pewee Contopus virens

Passeriformes Eastern towhee Pipilo erythrophthalmus

Passeriformes European starling Sturnus vulgaris

Passeriformes Evening grosbeak Coccothraustes vespertinus

Passeriformes Field sparrow Spizella pusilla

Passeriformes Fox sparrow Passerelia iliaca

Passeriformes Golden-crowned kinglet Regulus satrapa

Passeriformes Golden-winged warbler Vermivora chrysoptera

Passeriformes Grasshopper sparrow Ammodramus savannarum

Passeriformes Gray catbird Dumetella carolinensis

Passeriformes Gray-cheeked thrush Catharus minimus

Passeriformes Great crested flycatcher Myiarchus crinitus

Passeriformes Hermit thrush Catharus guttatus

Passeriformes Horned lark Eremophila alpestris

Passeriformes House finch Carpodacus mexicanus

Passeriformes House sparrow Passer domesticus

Passeriformes House wren Troglodytes aedon

Passeriformes Indigo bunting Passerina ciris

Passeriformes Lark sparrow Chondestes grammacus

Passeriformes Least flycatcher Empidonax minimus

Passeriformes Le Conte’s sparrow Ammodramus leconteii
class aves continued

Order Common Name Scientific Name

Passeriformes Lincoln sparrow Melospiza lincolnii

Passeriformes Magnolia warbler Dendroica magnolia

Passeriformes Marsh wren Cistothorus palustris

Passeriformes Mountain bluebird Sialia currucoides

Passeriformes Nashville warbler Vermivora ruficapilla

Passeriformes Nelson’s shart-tailed sparrow Ammodramus nelsoni

Passeriformes Northern cardinal Cardinalis cardinalis

Passeriformes Northern mockingbird Mimus polyglottos

Passeriformes Northern rough-winged swallow Stelgidopteryx serripennis

Passeriformes Northern shrike Lanius excubitor

Passeriformes Northern waterthrush Seiurus noveboracensis

Passeriformes Olive-sided flycatcher Contopus cooperi

Passeriformes Orange-crowned warbler Vermivora celata

Passeriformes Orchard oriole Icterus spurius

Passeriformes Ovenbird Seiurus aurocapillus

Passeriformes Palm warbler Dendroica palmarum

Passeriformes Philadelphia vireo Vireo philadelphicus

Passeriformes Pine siskin (Carduelis pinus

Passeriformes Purple finch Carpodacus purpureus

Passeriformes Purple martin Progne subis

Passeriformes Red-eyed vireo Vireo olivaceus

Passeriformes Red-winged blackbird Agelaius phoeniceus

Passeriformes Red-breasted nuthatch Sitta canadensis

Passeriformes Rose-breasted grosbeak Pheuticus ludovicianus

Passeriformes Ruby-crowned kinglet Regulus calendula

Passeriformes Rusty blackbird Euphagus carolinus

Passeriformes Savannah sparrow Passerculus sandwichensis

Passeriformes Scarlet tanager Piranga olivavea

Passeriformes Sedge wren Cistothorus platensis

Passeriformes Snow bunting Plectrophenax nivalis

Passeriformes Song sparrow Melospiza melodia

Passeriformes Sprague’s pipit Anthus spragueii

Passeriformes Swainson’s thrush Catharus ustulatus

Passeriformes Swamp sparrow Melospiza georgiana

Passeriformes Tennessee warbler Vermivora peregrina

Passeriformes Tree swallow Tachycineta bicolor

Passeriformes Veery Catharus fuscescens

Passeriformes Vesper sparrow Pooecetes gramineus

Passeriformes Warbling vireo Vireo gilvus

Passeriformes Western kingbird Tyrannus verticalis

Passeriformes Western meadowlark Sturnella neglecta

Passeriformes White-breasted nuthatch Sitta carolinensis

Passeriformes White-throated sparrow Zonotrichia laucophrys

Passeriformes White-winged crossbill Loxia leucoptera

Passeriformes Willow flycatcher Empidonax traillii

Passeriformes Wilson’s warbler Wilsonia pusilla

Appendix F — Species List 85
86 CCP, Sullys Hill National Game Preserve, ND

class aves continued

Order Common Name Scientific Name

Passeriformes Yellow-headed blackbird Xanthocephalus xanthocephalus

Passeriformes Yellow-rumped warbler Dendroica coronata

Passeriformes Yellow-throated vireo Vireo flavifrons

Passeriformes Yellow warbler Dendroica petechia

class MaMMalia

Order Common Name Scientific Name

Insectivora

Insectivora

Insectivora

Insectivora

Chiroptera

Chiroptera

Chiroptera

Chiroptera

Chiroptera

Chiroptera

Chiroptera

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Carnivora

Artiodactyla

Artiodactyla

Artiodactyla

Artiodactyla

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Arctic shrew

Masked shrew

Northern short-tailed shrew

Pygmy shrew

Big brown bat

Hoary bat

Little brown bat

Long-eared myotis

Red bat

Silver-haired bat

Western small-footed myotis

Badger

Coyote

Ermine

Fisher

Gray fox

Least weasel

Long-tailed weasel

Marten

Mink

Raccoon

Red fox

Striped skunk

American elk

Bison

Pronghorn

White-tailed deer

Beaver

Deer mouse

Eastern chipmunk

Fox squirrel

Franklin’s ground squirrel

Gray squirrel

House mouse

Meadow jumping mouse

Meadow vole

Muskrat

Northern grasshopper mouse

Northern pocket gopher

Sorex arcticus

Sorex cinereus

Blarina brevicauda

Sorex hoyi

Eptesicus fuscus

Lasiurus cinereus

Myotis lucifugus

Myotis evotis

Lasiurus borealis

Lasionycteris noctivagans

Myotis ciliolabrum

Taxidea taxus

Canis latrans

Mustela erminea

Martes pennanti

Urocyon cinereoargenteus

Mustela nivalis

Mustela frenata

Martes americana

Mustela vision

Procyon lotor

Vulpes vulpes

Mephitis mephitis

Cervus elaphus

Bison bison

Antilocapra americana 

Odocoileus virginianus

Castor canadensis

Peromyscus maniculatus

Tamias striatus

Sciurus niger

Mus musculus

Spermophilus franklinii

Sciurus

Zapus hudsonius

Microtus pennsylvanicus

Ondatra zibethicus

Onychomys leuchogaster

Thomomys talpoides
Appendix F — Species List 87

class MaMMalia continued

Order Common Name Scientific Name

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Rodentia

Lagomorpha

Lagomorpha

Lagomorpha

Lagomorpha

Norway rat

Prairie dog

Prairie vole

Richardson’s ground squirrel

Southern red-backed vole

Thirteen-lined ground squirrel

Western harvest mouse

White-footed mouse

Woodchuck

Eastern cottontail

Nuttall’s cottontail

Snowshoe hare

White-tailed jackrabbit

Rattus norvegicus

Cynomys ludovicianus

Microtus ochrogaster

Spermophilus richardsonii

Clethrionomys gapperi

Spermophilus tridecemlineatus

Reithrodontomys megalotis

Peromyscus leucopus

Marmota monax

Sylvilagus floridanus

Sylvilagus nuttallii

Lepus americanus

Lepus townsendii

class osteicHtHyes

Order Common Name Scientific Name

Salmoniformes Northern pike Esox lucius

Cypriniformes Common carp Cyprinus carpio

Cypriniformes Fathead minnow Pimephales promelas

Cypriniformes White sucker Catostomus commersoni

Siluriformes Black bullhead Ameiurus melas

Perciformes Yellow perch Perca flavescens

Perciformes Walleye Stizostedion vitreum

class insecta

Order Common Name Scientific Name

Lepidoptera Aphrodite fritillary Speyeria aphrodite

Lepidoptera Banded hairstreak Satyrium calanus

Lepidoptera Black swallowtail Papilio polyxenes

Lepidoptera Callippe fritillary Speyeria callippe

Lepidoptera Canadian tiger swallowtail Pterourus canadensis

Lepidoptera Checkered skipper Pyrgus communis

Lepidoptera Checkered white Pontia protodice

Lepidoptera Clouded sulphur Colias philodice

Lepidoptera Common branded skipper Hesperia comma

Lepidoptera Common sooty wing Pholisora catullus

Lepidoptera Common wood nymph Cercyonis pegala

Lepidoptera Compton tortoise shell Nymphalis vaualbum

Lepidoptera Coral hairstreak Harkenclenus titus

Lepidoptera Delaware skipper Anatryone logan

Lepidoptera Dreamy dusky wing Erynnis icelus

Lepidoptera Dun skipper Euphyes vestris

Lepidoptera Dusted skipper Atrytonopsis hianna

Lepidoptera Eastern tiger swallowtail Pterourus glaucus
88 CCP, Sullys Hill National Game Preserve, ND

class insecta continued

Order Common Name Scientific Name

Lepidoptera Edwards’ hairstreak Satyrium edwardsii

Lepidoptera European cabbage butterfly Artogeia rapae

Lepidoptera Eyed brown Satyrodes eurydice

Lepidoptera Garita skipperling Oarisma garita

Lepidoptera Gorgone checkerspot Charidryas gorgone

Lepidoptera Gray comma Polygonia proge

Lepidoptera Great spangled fritillary Speyeria cybele

Lepidoptera Hackberry butterfly Asterocampa celtis

Lepidoptera Harris’ checkerspot Charidryas harrisii

Lepidoptera Hobomok skipper Poanes hobomok

Lepidoptera Hop merchant Polygonia comma

Lepidoptera Inornate ringlet Coenonympha inornata

Lepidoptera Juvenal’s dusky wing Erynnis juvenalis

Lepidoptera Least skipper Ancyloxypha numitor

Lepidoptera Little wood satyr Megisto cymela

Lepidoptera Long dash Polites mystic

Lepidoptera Meadow fritillary Clossiana bellona

Lepidoptera Melissa blue Lycaeides melissa

Lepidoptera Milbert’s tortoise shell Aglais milberti

Lepidoptera Monarch Danaus plexippus

Lepidoptera Mourning cloak Nymphalis antiopa

Lepidoptera Mustard white Artogeia napi oleracea

Lepidoptera Northern cloudy wing Thorybes pylades

Lepidoptera Northern pearl crescent Phyciodes tharos

Lepidoptera Northern pearly eye Enodia anthedon

Lepidoptera Orange sulphur Colias eurytheme

Lepidoptera Ottoe skipper Hesperia ottoe

Lepidoptera Painted lady Vanessa cardui

Lepidoptera Pawnee skipper Hesperia pawnee

Lepidoptera Pearl crescent Phyciodes tharos

Lepidoptera Peck’s skipper Polites peckius

Lepidoptera Red admiral Vanessa atalanta

Lepidoptera Regal fritillary Speyeria idalia

Lepidoptera Roadside skipper Amblyscirtes vialis

Lepidoptera Saepiolus blue Plebejus saepiolus

Lepidoptera Silver-bordered fritillary Clossiana selene

Lepidoptera Silver-spotted skipper Epargyreus clarus

Lepidoptera Silvery blue Glaucopsyche lygdamus

Lepidoptera Silvery checkerspot Charidryas nycteis

Lepidoptera Sleepy dusky wing Erynnis brizo

Lepidoptera Spring azure Celastrina argiolus

Lepidoptera Striped hairstreak Satyrium liparops

Lepidoptera Tawny crescent Phyciodes batesii

Lepidoptera Tawny-edged skipper Polites themistocles

Lepidoptera Uhler’s arctic Oeneis uhleri

Lepidoptera Variegated fritillary Euptoieta claudia
Appendix F— Species List 89

class insecta continued

Order Common Name Scientific Name

Lepidoptera Viceroy Basilarchia archippus

Lepidoptera Western tailed blue Everes amyntula

Lepidoptera White admiral Basilarchia arthemis arthemis

PLANTS

Plants are listed in alphabetical order by common name, 

and introduced species are noted with an “I.”

Common Name Scientific Name

Absinth wormwood Artemisia absinthium–I

Alum root Heuchera richardsoniii)

Alfalfa Medicago sativa–I

Alumroot Heuchera richardsonii

American basswood Tilia americana

American elm Ulmus americana

American plum Prunus americana

Aspen Populus spp.

Awned wheatgrass Agropyron subsecundum

Beaked hazel Corylus cornuta

Beggarticks Bidens spp.

Big bluestem Andropogon gerardii

Black-eyed susan Rudbeckia hirta

Blanket flower Gaillardia aristata

Blue-eyed grass Sisyrichium campestre

Blue flax Linum perenne

Blue grama Bouteloua gracilis

Boxelder Acer negundo

Breadroot Psoralea esculenta

Buffaloberry Shepherdia argentea

Bulrush Schoenoplectus spp.

Bushy vetchling Lathyrus venosus

Bur oak Quercus macrocarpa

Burreed Sparganium spp.

Canada anemone Anemone canadensis

Canada goldenrod Solidago canadensis

Canada thistle Cirsium arvense–I

Caragana Caragana arborescens

Cattail Typha spp.

Chokecherry Prunus virginiana

Cleavers Galium aparine

Common bladderwort Utricularia vulgaris

Common dandelion Taraxacum officinale–I

Common milkweed Asclepias syriaca

Common reed Phragmites australis

Common yarrow Achillea millefolium

 
90 CCP, Sullys Hill National Game Preserve, ND

PLANTS continued

Plants are listed in alphabetical order by common name, 

and introduced species are noted with an “I.”

Common Name Scientific Name

Coontail Ceratophyllum demersum

Coralroot Corallorhiza spp.

Cottonwood Populus deltoids

Cow parsnip Heracleum sphondylium

Crested wheatgrass Agropyron cristatum

Daisy fleabane Erigeron philadelphicus

Dogbane Apocynum cannabinum

Dotted blazing star Liatris punctata

Downy paintbrush Castilleja sessiliflora

Duckweed Lemna spp.

Fall rosette grass Dichanthelium wilcoxianum

False dandylion Agoseris glauca

False gromwell Onosmodium molle

Floodman’s thistle Cirsium flodmanii

Foxtail barley Hordeum jubatun

Fringed puccoon Lithspermum incisum

Goat’s beard Tragopogon dubius

Goldan Alexander Zizia aurea

Golden aster Chrysopsis villosa

Goldenrod Solidago spp.

Green ash Fraxinus pennsylvanica

Green foxtail Setaria veridis–I

Green milkweed Asclepias viridiflora

Green needlegrass Nasella viridula

Groundplum milkvetch Astragalus crassicarpus

Harebell Campanula rotundifolia

Hawksbeard Crepis runcinata

Heath aster Aster ericoides

Hedge nettle Stachys palustris

Hoary puccoon Lithospermum canescens

Hooker’s oat grass Helictotrichon hookeri

Intermediate wheatgrass Agropyron intermedium–I

Juneberry Amelanchier alnifolia

Kentucky bluegrass Poa pratensis–I

Lamb’s quarters Chenopodium album–I

Large beardtongue Penstemon grandiflorus

Lead plant Amorpha canescens

Leafy spurge Euphorbia esula–I

Lichens Lycopodium spp.

Little bluestem Schizachyrium scoparium

Marsh marigold Caltha palustris

Marsh muhly Muhlenbergia racemosa

Maximilian sunflower Helianthus maximiliani
Appendix F — Species List 91

PLANTS continued

Plants are listed in alphabetical order by common name, 

and introduced species are noted with an “I.”

Common Name Scientific Name

Meadow rue Thalictrum spp.

Meadow-sweet Spirea alba

Mustard spp.–I

Needlegrass Hesperostipa curtiseta

Northern bedstraw Galium boreale

Northern hawthorn Crataegus rotundifolia

Pasque flower Anemone patens

Pin cushion cactus Coryphantha vivipara

Pineapple weed Matricaria matricarioides–I

Plains muhly Muhlenbergia cuspidata

Pliant milkvetch Astragalus flexuosus

Poison ivy Toxicodendron redicans

Pondweeds Potamogeton spp.

Porcupine grass Hesperostipa spartea

Prairie cordgrass Spartina pectinata

Prairie coneflower Ratibida columnifera

Prairie goldenrod Solidago missouriensis

Prairie junegrass Koeleria macrantha

Prairie sagewort Artemisia frigida

Prairie sandreed Calamovilfa longifolia

Prairie smoke Geum triflorum

Prairie wild rose Rosa arkansana

Purple coneflower Echinacea angustifolia

Purple prairie clover Dalea purpurea

Redoiser dogwood Cornus stolonifera

Red raspberry Rubus idaeus

River-bank grape Vitis riparia

Rushes Juncus spp.

Scarlet gaura Gaura coccinea

Sedges Carex spp.

Showy lady’s slipper Cypripredium reginae

Sideoats grama Bouteloua curtipendula

Silky wormwood Artemisia dracunculus

Silverberry Elaeagnus commutate

Silverleaf scurfpea Psoralea argophylla

Slender penstemon Penstemon gracilis

Sloughgrass Beckmannia syzigachne

Smartweed Polygonum spp.

Smooth brome Bromus inermis–I

Smooth sumac Rhus glabra

Softstem bulrush Schoenoplectus validus

Sow thistle Sonchus arvensis–I

Stiff goldenrod Solidago rigida
92 CCP, Sullys Hill National Game Preserve, ND

PLANTS continued

Plants are listed in alphabetical order by common name, 

and introduced species are noted with an “I.”

Common Name Scientific Name

Stiff sunflower Helianthus rigidus

Stinging nettle Urtica dioica

Sun sedge Carex heliophyila

Swamp vervain Verbena hastata

Sweet clover Melilotus spp.

Switchgrass Panicum virgatum

Tall cinquefoil Potentilla arguta

Thimbleweed Anemone cylindrica

Three-square bulrush Schoenoplectus americanus

Toothed evening primrose Calylophus serrulatus

Virginia creeper Parthenocissus quinquefolia

Western ragweed Ambrosia psilostachya 

Western snowberry Symphoricarpos occidentalis

Western wild rose; 

Woods’ rose Rosa woodsii

Western wheatgrass Agropyron smithii

White birch Betula spp.

White sage Artemisia ludoviciana

Wild bergamot Mondara fistulosa

Wild licorice Glycyrrhiza lepidota

Wild onion Allium stellatum

Wild sarsaparilla Aralia nudicaulis

Wood anemone Anemone quinquefolia

Wood lily Lilium philadelphicum

Yellow coneflower Ratibida columnifera
Appendix G

Fire Management Program

The Service has administrative responsibility 

including fire management for Sullys Hill National 

Game Preserve, which covers approximately 1,675 

acres.

THE ROLE OF FIRE

In ecosystems of the Great Plains, vegetation has 

evolved under periodic disturbance and defoliation 

from grazing, fire, drought, and floods. This periodic 

disturbance is what kept the ecosystem diverse and 

healthy while maintaining significant biodiversity for 

thousands of years.

Historically, natural fire and Native American 

ignitions have played an important disturbance role 

in many ecosystems by removing fuel accumulations, 

decreasing the impacts of insects and diseases, 

stimulating regeneration, cycling nutrients, and 

providing a diversity of habitats for plants and 

wildlife.

When fire or grazing, or both, are excluded from 

prairie landscapes, fuel loadings increase due to a 

build-up of thatch and invasion of woody vegetation. 

This increase in fuel loadings leads to an increase in a 

fire’s resistance to control which threatens firefighter 

and public safety as well as federal and private 

facilities.

However, fire when properly utilized, can:

Q reduce hazardous fuels build-up in both 

wildland urban interface (WUI) and non-WUI 

areas;

Q improve wildlife habitats by reducing density 

of vegetation and/or changing plant species 

composition;

Q sustain and/or increase biological diversity;

Q improve woodlands and shrub lands by reducing 

plant density;

Q reduce susceptibility of plants to insect and 

disease outbreaks;

Q improve quality and quantity of livestock 

forage; and

Q improve the quantity of water available for 

municipalities and activities dependent on 

wildlands for their water supply.

WILDLAND FIRE MANAGEMENT POLICY 

AND GUIDANCE

In 2001, an update of the 1995 “Federal Fire Policy” 

was completed and approved by the Secretaries of 

Interior and Agriculture. The 2001 “Federal Wildland 

Fire Management Policy” directs federal agencies to 

achieve a balance between fire suppression to protect 

life, property, and resources and fire use to regulate 

fuels and maintain healthy ecosystems. In addition, it 

directs agencies to use the appropriate management 

response for all wildland fire regardless of the 

ignition source. This policy provides eight guiding 

principles that are fundamental to the success of the 

fire management program:

1. Firefighter and public safety is the first priority 

in every fire management activity.

2. The role of wildland fires as an ecological 

process and natural change agent will be 

incorporated into the planning process.

3. Fire management plans (FMPs), programs, 

and activities support land and resource 

management plans and their implementation.

4. Sound risk management is a foundation for all 

fire management activities.

5. Fire management programs and activities 

are economically viable, based on the values 

to be protected, costs, and land and resource 

management objectives.

6. FMPs and activities are based on the best 

available science.

7. FMPs and activities incorporate public health 

and environmental quality considerations.

8. Federal, state, tribal, local, interagency, and 

international coordination and cooperation are 

essential.

The standardization of policies and procedures among 

federal agencies is an ongoing objective.

The fire management considerations, guidance, 

and direction should be addressed in the land use 

resource plans (for example, the CCP). FMPs are 

step-down processes from the land use plans and 

habitat plans, with more detail on fire suppression, 

fire use, and fire management activities.
94 CCP, Sullys Hill National Game Preserve, ND

MANAGEMENT DIRECTION

The Devils Lake Wetland Management District 

Complex office and the Eastern North Dakota 

Fire District will protect life, property, and other 

resources from wildland fire by safely suppressing 

all wildfires. Prescribed fire, as well as manual 

and mechanical fuel treatments, will be used in 

an ecosystem context to protect both federal and 

private property and for habitat management 

purposes. Fuel reduction activities will be applied 

in collaboration with federal, state, private, and 

NGO partners. In addition, fuel treatments will be 

prioritized based on the guidance for prioritization 

established in the goals and strategies outlined in 

the “U.S. Fish & Wildlife Service National Wildlife 

Refuge System Wildland Fire Management Program 

Strategic Plan 2003–2010” and “Region 6 Refuges 

Regional Priorities FY07–11.” For WUI treatments, 

areas with community wildfire protection plans 

(CWPPs) and communities at risk (CARs) will be 

the primary focus. The following CARs are located 

near the refuges and were identified in the Federal 

Register (8/17/2001): Ft. Totten, North Dakota; St. 

Michael, North Dakota; Tokio, North Dakota; and 

Crow Hill, North Dakota.

The development of CWPPs is an ongoing process. 

As of October 9, 2007, the four communities listed 

above have developed CWPPs or CWPP-equivalent 

documents required by the Bureau of Indian Affairs.

All aspects of the fire management program will be 

conducted in a manner consistent with applicable 

laws, policies, and regulations. Sullys Hill National 

Game Preserve will be included in the “Eastern 

North Dakota Fire District Fire Management Plan” 

to accomplish the fire management goals described 

below. Prescribed fire and manual and mechanical 

fuel treatments will be applied in a scientific 

way under selected weather and environmental 

conditions.

F

The goals and strategies of the “U.S. Fish & Wildlife 

Service National Wildlife Refuge System Wildland 

Fire Management Program Strategic Plan” are 

consistent with Department and Service policies, 

National Fire Plan direction, the President’s Healthy 

Forest Initiative, the 10-Year Comprehensive 

Strategy and Implementation Plan, National Wildfire 

Coordinating Group guidelines, initiatives of the 

Wildland Fire Leadership Council, and Interagency 

Standards for Fire and Aviation Operations.

The “Region 6 Refuges Regional Priorities FY07–11” 

are consistent with the refuges vision statement for 

region 6, “to maintain and improve the biological 

integrity of the region, ensure the ecological 

condition of the region’s public and private lands 

are better understood, and endorse sustainable use 

of habitats that support native wildlife and people’s 

livelihoods.” The fire management goals for Sullys 

Hill National Game Preserve are to use prescribed 

fire and manual and mechanical treatments to (1) 

reduce the threat to life and property through 

hazardous fuels reduction treatments; and (2) meet 

the habitat goals and objectives identified in this 

CCP.

Fire Management Objective

The objective of the fire management program is 

to use prescribed fire and manual and mechanical 

treatment methods to treat between 100 and 500 

acres over a 5-year average.

Strategies

Strategies and tactics that consider public and 

firefighter safety, as well as resource values at risk, 

will be used. Wildland fire suppression, prescribed 

fire methods, manual and mechanical means, timing, 

and monitoring are described in more detail within 

the step-down FMPs.

All management actions will use prescribed fire, 

manual or mechanical means to reduce hazardous 

fuels, restore and maintain desired habitat 

conditions, control nonnative vegetation, and control 

the spread of woody vegetation within the diverse 

ecosystem habitats. The fuels treatment program 

will be site specific and follow the most recent 

interagency burn plan template.

Prescribed fire temporarily reduces air quality by 

reducing visibility and releasing components through 

combustion. The refuges will meet the Clean Air 

Act emission standards by adhering to the “North 

Dakota State Implementation Plan” requirements 

during all prescribed fire activities.

FIRE MANAGEMENT ORGANIzATION, 

CONTACTS, AND COOPERATION

Qualified fire management technical oversight for 

the refuges will be established by region 6 of the 

Service, using the fire management district approach. 

Under this approach, fire management staff will be 

determined by established modeling systems based 

on the fire management workload of a group of 

refuges, and possibly that of interagency partners. 

The fire management workload consists of historical 

wildland fire suppression activities as well as 

historical and planned fuels treatments.

Depending on budgets, fire management staffing 

and support equipment may be located at the 

administrative station or at other refuges within 

the district and shared between all units. Fire 

management activities will be conducted in a 

coordinated and collaborative manner with federal 

and nonfederal partners.
Appendix G — Fire Management Program 95

On approval of this CCP, new FMPs will be 

developed for the Eastern North Dakota Fire 

District. The FMPs may be prepared as a (1) FMP 

that covers each individual refuge and wetland 

management district; (2) FMP that covers the area 

identified within this CCP; (3) FMP that covers the 

Fire Management District; or (4) interagency FMP.

Compatibility Determinations

Appendix H

Refuge Name: Sullys Hill National Game Preserve

County: Benson County, North Dakota

Establishing and Acquisition Authorities:

Migratory Bird Conservation Act, Executive Order 

7168

Purposes

“All the lands that are now reserved or may 

hereafter be included within the boundaries of the 

... Sullys Hill National Park Game Preserve ... 

are hereby further reserved and set apart for the 

use ... as refuges and breeding grounds for birds.” 

(Executive Order 3596, December 21, 1921)

 “As a big game preserve, refuge, and breeding 

grounds for wild animals and birds ... provided, 

that the said game preserve is to be made 

available to the public for recreational purposes in 

so far as consistent with the use of this area as a 

game preserve ... provided further, that hunting 

shall not be permitted on said game preserve.” (46 

Stat. 1509, act of March 3, 1931)

National Wildlife Refuge System Mission

The mission of the System is to administer a national 

network of lands and waters for the conservation, 

management, and where appropriate, restoration 

of the fish, wildlife, and plant resources and their 

habitats within the United States for the benefit of 

present and future generations of Americans.

Description of Use: Fishing

What is the use? Is the use a wildlife-dependent public 

use?

Fishing is one of the six wildlife-dependent public 

uses specified in the Improvement Act.

Where will the use be conducted?

The use will be restricted to Sweet Water Lake 

and those areas of Fort Totten Bay (Devils Lake) 

accessible by refuge lands.

When will the use be conducted?

Fishing will be permitted only during special events 

for environmental education purposes.

How will the use be conducted?

All of the access to fishing opportunities will be walkin only. 

Why is this use being proposed?

Fishing is one of the six wildlife-dependent, priority 

public uses specified in the Improvement Act. It can 

be allowed at the refuge without interfering with 

the migratory bird and big game resources. It also 

provides an opportunity to educate youth on the 

benefits of and how to enjoy natural resources in an 

environmentally conscience manner.

Availability of Resources

Resources involved in the administration and 

management of the uses: Minimal. Fishing will be 

part of the environmental education program on 

Sullys Hill National Game Preserve and will be 

administered by the refuge staff.

Special equipment, facilities, or improvements 

necessary to support the uses: Minimal.

Maintenance costs: Minimal.

Monitoring costs: None.

Offsetting revenues: None.

Anticipated Impacts of Use

Short-term impacts: There will be temporary 

disturbance to wildlife near the activity. 

Long-term impacts: None.

Cumulative impacts: There will be no direct or 

indirect cumulative impacts anticipated with this use.

Determination

Fishing is a compatible use at Sullys Hill National 

Game Preserve.

Stipulations Necessary to Ensure Compatibility

Fishing will be offered only on a special youth 

event basis. Fishing will be allowed primarily for 

environmental education purposes to complement 
98 CCP, Sullys Hill National Game Preserve, ND

the existing outdoor education program. Fishing 

techniques and regulations will comply with NDGF 

regulations and must be observed while fishing at the 

refuge. Refuge will determine days or seasons when 

fishing is open.

Justification

Fishing is a legislated, wildlife-dependent, priority 

public use. No long-term or significant adverse 

impacts on wildlife resource are expected from the 

primary or supporting uses.

Mandatory 10- or 15-Year Reevaluation date: 

2023

Description of Use: Wildlife Observation 

and Photography

What are the uses? Are the uses wildlife-dependent 

public uses?

The uses will be continuation of existing public use 

programs and activities of and related to wildlife 

observation and photography. Wildlife observation 

and photography will be the primary uses. Vehicle 

access, walk-in-access (including the hiking trail), 

snowshoeing, and cross-country skiing will be 

supporting uses.

Wildlife observation and photography are two of the 

six wildlife-dependent public uses specified in the 

Improvement Act.

Where will the uses be conducted?

The uses will occur over the entire refuge, with the 

exception of the area closed to the public surrounding 

the residences and shop. Vehicle access will be 

restricted to the auto tour route. Walk-in access will 

be restricted to existing refuge trails and not allowed 

in areas closed to foot traffic (big game enclosure 

area and other limited access area). 

When will the uses be conducted?

Wildlife observation and photography will be allowed 

year-round. However, access into the refuge will be 

limited during inclement weather and from sunrise 

thru sunset conditional on the refuge being open.

The refuge manager will open and close the auto tour 

route as road conditions allow. 

How will the uses be conducted?

The refuge will be open for wildlife observation 

and photography. Their supporting use (access) 

will be controlled and regulated through brochures, 

the education and visitor center desk, and through 

information posted at the kiosks. The auto tour route 

and the hiking trail will be maintained by refuge staff.

Why are these uses being proposed?

Wildlife observation and photography are two of 

the six wildlife-dependent, priority public uses 

specified in the Improvement Act. These uses and 

their supporting access-related uses can be allowed 

at the refuge without interfering with the migratory 

bird and big game resources. They also provides an 

opportunity to educate visitors on the benefits of 

National Wildlife Refuges.

Availability of Resources

Resources involved in the administration and 

management of the uses: This use will require 10% of a 

full-time GS-9 park ranger, 20% of a seasonal biological 

technician, and 50% of a YCC crew (3–4 members) 

for 3 months. Maintenance employees will spend 

approximately 2% of their time associated with this 

use.

Special equipment, facilities, or improvements 

necessary to support the uses: This use requires 

the maintenance of the auto tour, trail system, four 

viewing platforms, two restrooms, eight waste 

barrels, and directional signage.

Maintenance costs: YCC $4,435; biological technician 

$1,915; two maintenance staff $2,529; ranger $8,165. 

Materials: $500. 

Total: $17,544. 

Monitoring costs: Minimal, traffic counter data 

collection random law enforcement patrols.

Offsetting revenues: Recreational fee collection. 

Anticipated Impacts of Use

Short-term impacts: There may be temporary 

disturbance to wildlife near the activity. Direct 

short-term impacts may include minor damage from 

traffic to refuge roads and trails when wet and muddy.

Long-term impacts: None.

Cumulative impacts: There will be no direct nor 

indirect cumulative impacts anticipated with these uses.

Determination

Wildlife observation and photography, along with 

their supporting uses and stipulations are compatible 

uses at Sullys Hill National Game Preserve.

Stipulations Necessary to Ensure Compatibility

Stipulations regarding the public use program will be 

made available in published refuge brochures. Dates, 

closed areas, and other information will be specified.

Justification

Wildlife observation and photography are legislated, 

wildlife-dependent public uses. No long-term or 

significant adverse impacts on wildlife resource are 

expected from the primary or supporting uses.
Appendix H — Compatibility Determinations 99

The refuge contains unique habitats and supports 

wildlife populations—particularly migratory 

birds, waterfowl, upland game birds, and big game 

animals—in excess of what can be observed on 

neighboring private lands. These uses promote 

an appreciation for the natural resources at the 

refuge. In addition, these uses support conservation 

programs at the refuge.

Mandatory 15-year Reevaluation Date: 2023

Description of Use: Environmental 

Education and Interpretation 

What are the uses? Are the uses wildlife-dependent 

public uses?

The uses will be continuation of interpretative 

and environmental education programs at current 

and increased levels. The refuge will be used as 

an outdoor classroom and tour site for visiting 

school and nonprofit groups. Interpretation 

and environmental education are two of the six 

wildlife-dependent public uses specified in the 

Improvement Act.

Where will the uses be conducted?

Environmental education and interpretation will 

take place over the entire refuge. However, most 

activities will be on the auto tour route, and the 

refuge education and visitor center and its facilities 

will be used in presenting programs. In addition, the 

refuge’s hiking, snowshoeing, and ski trails will be 

incorporated into the overall program.

When will the uses be conducted?

These activities will primarily be held during the 

daytime, most frequently while school is in session 

(September–May). Less frequently, nonprofit groups 

and other groups will be hosted throughout the year.

How will the uses be conducted?

Refuge staff and volunteers will provide the 

instruction and host classroom tours in most cases. 

Someone other than refuge personnel may lead 

activities.

Why are these uses being proposed?

Interpretation and environmental education are two 

of the six wildlife-dependent, priority public uses 

specified in the Improvement Act. These uses can be 

allowed at the refuge without interfering with the 

migratory bird and big game resources. 

Availability of Resources

Resources involved in the administration and 

management of the uses: This use requires 50% of a 

full-time GS-9 park ranger, 25% of a seasonal biological 

technician (6 months), and 50% of a YCC crew (3–4 

members) for 3 months. Maintenance employees will 

spend approximately 5% of their time associated with 

this use. A private cleaning contractor will also be 

required.

Special equipment, facilities, or improvements 

necessary to support the uses: None.

Maintenance costs: Cleaning contract $1,617; YCC 

$4,435; biological technician $2,395; two maintenance 

staff $6,322; ranger $40,826. 

Materials: $5,000.

Total: $60,595.

Monitoring costs: Minimal; visitor use data collection.

Offsetting revenues: Volunteer program, grants, 

recreational fee collection.

Anticipated impacts of use

Short-term impacts: There may be temporary 

disturbance to wildlife near the activities.

Long-term impacts: These activities will increase 

local support of the refuge and increase knowledge of 

stewardship of natural resources to students young 

and old.

Cumulative impacts: There will be no direct nor 

indirect cumulative impacts anticipated with the 

continuation of these uses.

determination

Interpretation and environmental education are 

compatible uses at Sullys Hill National Game 

Preserve.

Stipulations necessary to ensure compatibility

Anticipated impacts are assumed to be light; 

however, stipulations will still be necessary to ensure 

that wildlife resources are adequately protected. 

Disturbance is almost an unavoidable impact of the 

interpretive and environmental education programs. 

However, it is through these activities that visitors 

will receive an understanding of proper etiquette 

while visiting the refuge and the impact people 

have on habitat and wildlife. This information and 

refuge-specific regulations will be available through 

visitor contacts, brochures, and kiosks. Periodic law 

enforcement will ensure compliance with regulations 

and area closures. 

Justification

Interpretation and environmental education are 

legislated, wildlife-dependent priority public uses. 

Other than minor disturbance, these uses will have 

no impact on resources. These uses will contribute 

to the mission of the Refuge System by increasing 

knowledge and support of the stewardship of natural 

resources.
100 CCP, Sullys Hill National Game Preserve, ND

The refuge contains unique habitats and supports 

wildlife populations—particularly migratory birds, 

upland game birds, and big game animals—in excess 

of what can be observed on neighboring private 

lands. These uses promote an appreciation for natural 

resources and support for conservation programs at 

the refuge.

Mandatory 15-year Reevaluation Date: 2023
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