(navigation image)
Home American Libraries | Canadian Libraries | Universal Library | Community Texts | Project Gutenberg | Children's Library | Biodiversity Heritage Library | Additional Collections
Search: Advanced Search
Anonymous User (login or join us)
Upload
See other formats

Full text of "Final environmental impact statement and proposed resource management plan for the Grass Creek Planning Area in the Bighorn Basin Resource Area, Worland District, Worland, Wyoming"

BLM LIBRARY 




l.S. Department of the Interior 

ureau of Land Management 
Worland District Office 

Bighorn Basin Resource Area 



June 1996 



FINAL 

Environmental Impact Statement 
Grass Creek Planning Area 
Resource Management Plan 

Volume 2 of 2 (Comment Letters) 




The Bureau of Land Management is responsible for the balanced management of the public lands and 
resources and their various values so that they are considered in a combination that will best serve the 
needs of the American people. Management is based upon the principles of multiple use and sustained 
yield; a combination of uses that take into account the long term needs of future generations for renewable 
and nonrenewable resources. These resources include recreation, range, timber, minerals, watershed. 
fish and wildlife, wilderness and natural, scenic, scientific and cultural values. 









4* 



BLM/WY/PL-96/021 +1610 



=0 ■ t/tlcV 

6>ti 



lb, => 



FINAL ;fL 



ENVIRONMENTAL IMPACT STATEMENT 

and 

PROPOSED 
RESOURCE MANAGEMENT PLAN 

for the 

GRASS CREEK PLANNING AREA 

in the 

BIGHORN BASIN RESOURCE AREA 

WORLAND DISTRICT 

Worland, Wyoming 



prepared by: 

U.S. Department of the Interior 

Bureau of Land Management 

Worland District Office 



% 



June 1996 \fa%, 




£»s /<, /ff4 






Wyoming State Director ^Date 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


1. GENERAL -- BLM's Legal Authority 


1.1 


Wyoming and U.S. Constitutions 


1.2 


Private Lands Along the Bighorn and Greybull Rivers 


1.3 


Private Lands and BLM Requirements in an Allotment 


2. GENERAL - The Draft and Final EIS Documents 


2.1 


Information Provided by Commentors on the Draft EIS 


2.2 


Language, "May, Might, Possibly, Where Appropriate" 


2.3 


Glossary, References, and Index 


2.4 


Level of Detail, CRM, HRM, Updating the Plan 


2.5 


Document Format, Management Common, Alternatives and Assumptions 


2.6 


Plan Monitoring and Evaluation Requirements 


3. GENERAL -- Ecosystem Management 


3.1 


Ecosystem Conservation, Native Biological Diversity 


3.2 


Ecosystem Boundaries, Greater Yellowstone Ecosystem 


3.3 


Measuring Biological Diversity 


3.4 


Ecosystem Management Across Jurisdictional Boundaries 


4. GENERAL -- The National Environmental Policy Act 


4.1 


Custom and Culture 


4.2 


Public Hearing Request and Comment Period Extension 


4.3 


Involvement of Local People in Planning, Response to Scoping 


4.4 


Previous Grazing EIS Favored, Adopting Existing Management 


4.5 


Range of Alternatives 


4.6 


Impacts of BLM Decisions on Adjacent Private and State Lands 


4.7 


Response to Public Comments, Form Letters, Out-of-State Views 


4.8 


Cumulative Impacts, Other Kinds of Impacts and Relationships 


4.9 


No Action Alternative For Grazing, Estimates Mistaken For Decisions 


4.10 


No Action Alternative For Oil and Gas Leasing 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


5. GENERAL - Socioeconomics 


5.1 


Supporting Local Economic Productivity 


5.2 


BLM Program Funding Related to Economic Benefits of Activities 


5.3 


Economic Projections in the Draft EIS, Rounded Numbers 


5.4 


Value of an AUM Compared to Recreation 


5.5 


Beneficial Impacts of Businesses 


5.6 


Adverse Economic Effects Related to Land Use Restrictions 


6. GENERAL -- Wild and Scenic Rivers 


6.1 


South Fork of Owl Creek 


6.2 


Wild and Scenic River Review Process 


7. GENERAL - Wilderness 


7.1 


Opposition to Designating More Wilderness 


7.2 


Conservationists' Wilderness Alternative 


8. AIR QUALITY MANAGEMENT 


8.1 | Dust Control 


9. CULTURAL, PALEONTOLOGICAL, AND NATURAL HISTORY RESOURCES 


9.1 


Paleontology of the Willwood Formation, Interpretive Signs 


9.2 


The Need to Protect Sensitive Resources From Too Much Use 


9.3 


Sheepeater Cultural Site 


9.4 


New Agreement To Streamline Cultural Resource Process 


9.5 


Disturbance Near Petroglyphs 


9.6 


Hobby Collection of Fossils 


10. FIRE MANAGEMENT 


10.1 


Benefits of Fire 


10.2 


Use of Fire to Improve Sage Grouse Habitat 


11. FORESTLAND MANAGEMENT 


11.1 


Forestland Management Objectives 


11.2 


Anticipated Harvest Levels and Forestland Health 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


11. FORESTLAND MANAGEMENT (Continued) 


11.3 


Requirements For Wildlife Security Areas, Aspen Distribution 


11.4 


Importance of Old-Growth Forests 


11.5 


Firewood Cutting Along Rivers and Desert Drainages 


12. LANDS AND REALTY MANAGEMENT -- Access 


12.1 


Improving Public Access, Map 24, BLM's Transportation Plan 


12.2 


Condemnation 


12.3 


Access and Road Construction 


13. LANDS AND REALTY MANAGEMENT -- Landownership Adjustments 


13.1 


Lands For Agricultural Development 


13.2 


Lands For Suburban Expansion and Other Community Needs 


13.3 


Desert Land Entries 


13.4 


Land Exchange in the Wild Horse Area, Reduction of County Tax Base 


13.5 


Public Involvement 


14. LANDS AND REALTY MANAGEMENT -- Rights-of-Way 


14.1 


Impacts to Transportation Facilities 


14.2 


Underground Routing, Costs to Relocate Lines, Restrictions 


14.3 


Protection of Existing Rights, Corridors in Timbered Areas 


14.4 


List of Pending Rights-of-Way, Preexisting Projects, Altamont 


14.5 


Distribution Facilities 


14.6 


Construction Near Riparian Areas 


14.7 


Corridors and Concentration Areas 


15. LIVESTOCK GRAZING MANAGEMENT 


15.1 


Wetlands, Riparian Areas 


15.2 


Suitability, Adjustments/Reductions, Actual and Authorized Use 


15.3 


Goals to Address Overgrazing 


15.4 


Livestock AUM Gains Through Management 


15.5 


Responsibility For Fencing Costs 



Number 



15.6 



15.7 



15.8 



15.9 



15.10 



15.11 



15.12 



15.13 



15.14 



15.15 



15.16 



16.1 



16.2 



16.3 



16.4 



16.5 



16.6 



16.7 



16.8 



16.9 



16.10 



16.11 



16.12 



16.13 



16.14 



16.15 



16.16 



New Table 24 
Index of Comments and Responses 



Topic 



15. LIVESTOCK GRAZING MANAGEMENT (Continued) 



Current 1990 Grazing Levels, Enhancing Livestock Production 



Use of 1990 as a Base Year, Drought and Nonuse 



Allotment Categorization Process 



Utilization, Key Areas 



Utilization and Wildlife Population Objectives 



Subjective Visual Management Approach 



Bias Against Grazing, Compatibility with Other Objectives 



Restrictions on Water Development to Benefit Elk 



Fencing Around Water, Grazing on Bighorn River Public Lands 



Range Management Concepts, Terminology 



Chemical Spraying as a Vegetative Treatment 



16. MINERALS MANAGEMENT -- Oil and Gas 



Making Areas Off-Limits to Development, 100% Open to Leasing 



Justification For Restrictions, Resources to be Safeguarded 



Controlled Surface Use and Sage Grouse 



Controlled Surface Use and Big Game 



Waiver of No Surface Occupancy Requirements, Environmental Review 



Impact Analysis and Mineral Exploration and Development Costs 



Benefits to Wildlife from Produced Water 



Effect of Restrictions on Development 



Standard Lease Terms and Conditions Favored Over Other Restrictions 



Composition of the Planning Team, Geological Expertise 



Natural Gas Development Underestimated 



Lease Stipulations and Parameters For Their Use, Mitigation 



Justification For Restrictions, Consideration of Less Restriction 



Existing Lease Rights 



The Costs and Benefits of Administering Mineral Development 



Historical Evaluations in Oil Fields 



iv 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


16. MINERALS MANAGEMENT - Oil and Gas (Continued) 


16.17 


Variations Among Alternatives Because of Restrictions 


16.18 


Visual Resource Management Policy on Split-Estate Lands 


16.19 


Mandate to Lease Entire Planning Area 


16.20 


Standard Lease Terms and Conditions Favored Around Existing Fields 


16.21 


Minerals Occurrence Potential and Use of Restrictions 


17. MINERALS MANAGEMENT - Locatable/Salable Minerals 


17.1 


Mineral Resources and Impacts, Coal and Phosphate Classifications 


17.2 


Titanium and Zircon Deposits, Development Potential 


17.3 


Mineral Withdrawals Favored, Geologic Basis For Withdrawals 


18. OFF-ROAD VEHICLE MANAGEMENT 


18.1 


Restrictions, Effects on Public Access 


18.2 


The Need For Enforcement 


18.3 


Access and Vehicle Limitations in the Red Canyon Creek Area 


19. RECREATION MANAGEMENT 


19.1 


Recreation Facilities at Wardel and Harrington Reservoirs 


19.2 


Recreation Projections Too High For Red Canyon Creek 


19.3 


Recreation Projections Too High Overall 


19.4 


Surface-Disturbances For Recreation, Agricultural Practices 


19.5 


Projections on Decline of Primitive Recreation 


20. VEGETATION MANAGEMENT 


20.1 


Strategy on Transplanting Protected Plants 


20.2 


Scientific Names 


20.3 


Definition of Good Condition Range 


20.4 


Achieving Proper Functioning Riparian Areas, Checklist Method 


20.5 


Ecological Condition as a Value Judgement, Updated Information 


20.6 


Desired Plant Community Objectives, When to Use 


20.7 


Noxious Weeds, Use of Livestock to Control Weeds 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


20. VEGETATION MANAGEMENT (Continued) 


20.8 


Native Biological Diversity 


20.9 


Definition of Trend 


21. VISUAL RESOURCE MANAGEMENT 


21.1 


Highlighting Historic Oil Industry Features 


21.2 


Visual Resource Classes 


22. WATERSHED MANAGEMENT 


22.1 


Rebuilding Sediment Control Structures 


22.2 


Watersheds Considered in Ecosystem Management Plans 


22.3 


Soil Erosion Estimates 


23. WILD HORSE MANAGEMENT 


23.1 


Wild Horse Herd Area 


23.2 


Elimination of Herd Area, Federal-State-Private Jurisdiction 


23.3 


Wild Horse Management During Drought 


24. WILDLIFE MANAGEMENT 


24.1 


Predation on Wildlife Reduced by Good Habitat Management 


24.2 


Information, Clarifications, Corrections, Biological Assessment 


24.3 


Wildlife Sightings, Wildlife Maps Disputed, Habitat Protection 


24.4 


WGFD Wildlife Population Objectives 


24.5 


Fish and Wildlife Habitat and Rangelands Should Be Emphasized 


24.6 


Predator Control Measures 


24.7 


The Preferred Alternative Favors Wildlife 


24.8 


Aquatic Biology and Biologists 


24.9 


Ferrets, Wolves as an Experimental Population 


24.10 


Grizzly Bear Contingency Measures 


24.11 


Bighorn Sheep Recovery, Restrictions on Domestic Sheep Grazing 


24.12 


Habitat Fragmentation 


24.13 


Requirements For Management of Candidate Species 



VI 



New Table 24 
Index of Comments and Responses 


Number 


Topic 


25. SPECIAL MANAGEMENT AREAS 
General 


25.1 


ACECs Considered to be Like Wilderness Areas 


25.2 


ACEC Designation Criteria 


26. SPECIAL MANAGEMENT AREAS 
Badlands Proposed ACEC 


26.1 


New ACEC Proposal Considered 


27. SPECIAL MANAGEMENT AREAS 
Fifteenmile Creek Watershed Proposed ACEC 


27.1 


Cooperative Enterprises For Watershed Improvement 


27.2 


Geologic Erosion, Grazing Management Incentives, CRM 


27.3 


Naturalness Affected by Construction of Sediment Control Structures 


28. SPECIAL MANAGEMENT AREAS 
Meeteetse Draw Rock Art Proposed ACEC 


28.1 


Supervision of Recreational Use 


28.2 


Bentonite Mining Claims in the Area 



Vli 



GRASS 

Cj K..I. Jill,.... 3.. 

&» 263, (filJt, Wy S2426-Q263 



I 



55 M 20 AH 8= 5Q 
SIM V.'ORLANO U.O. 



January 17,1995 



Mr. Bob Ross 

BLM RMP Team Leader 

BmU9 

Worland, WY 8240 UHI9 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Ross, 



TbfpurposeoflhiskateruloopposemorerestrictMmson Wyoming's public lands. Your 
document is filled with restrictions that your agency Is not authorized to impose. We speak 
with the atiflhcrity oflhe Constitution of the Untied States of America and that of the great state 
of Wyoming, 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
nur land belong to our state as well. Prudent management of our resources, is sound business 
practice, and our businesses operate with that in mind now. We have managed the affairs of our 
state quite well ... if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose (his document in its entirety. 

Additional comments: 



Name: ^ 

Mailing address:.. 
City, State & ZJP:J 

^ o 



oHS-qs 



QZASS 

£,.*, *?..<- JHi* 

&x 263, £V"# ^^ 82426-0263 



95 JAM 20 m 8=51 
8LMWORLAK0 0,0. 



January 17, 1995 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Worland, WY 82401-0119 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Rosr, 

The purpose of this letter is to oppose more restrictions on Wyoming's public lands. Your 
document is filled with restrictions that your agency is not authorised to impose. We speak 
with roe authority of the Constitution or the United States of America and that of the great state 
of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to our state as welL Prudent management of our resources, la sound business 
pr*ctice,mdc*H-busiiras«opcrstewimthat^ We have managed the affairs of our 

stale quite well ... if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in its entirety. 

Additional comments: 



Name: At £ ■ 
Maibng address: J 
City, State & ZIP £ 



Signed: 



A € d^dJtl 



/~ /?- ?s~ 




2 3 1995 DEPARTMENT OF THE ARMY 
s of BMGINMft*. OMAHA district 



January 17, 1995 




Planning Division 



Mr. Bob Ross, Team Leader 
U.S. Bureau of Land Management 
P.O. Box 119 
Worland Wyoming 82401-0119 



Dear Mr. Ross: 



Draft 



Thank you for the opportunity to review the 
Environmental impact: statement lor the Grass Creek Resource Area 
Resource Management Plan in Big Horn, Hot Springs Park and 
Washakie counties in northwestern Wyoming. We offer the 
following comments. 

The Corps of Engineers' primary responsibility in reviewing 
environmental documents of other agencies is to ensure that 
Section 404 of the Clean Water Act is adequately addressed. Your 
document makes only brief mention of wetlands in conjunction with 
cattle grazing. It is not clear where these wetlands are located 
or what, if any, impact the proposed management plan will have on 
these wetlands. If the management plan proposes any work in 
wetlands or waters classified as waters of the United States, a 
Section 404 permit may be reguired. For a detailed review of the 
permit requirements, final project plans should be sent to: 

Mr. Matthew Bilodeau 

U.S. Array corps of Engineers 

Cheyenne Regulatory Office 

504 West l?th Street, Suite 280 

Cheyenne, Wyoming 82001-4348 

If you have any questions, please contact Ms. Jeanette Coniey 
Of our staff at (402) 221-3133. Thank you for the opportunity to 
review this proposal. 



VftyM. 



Robert S. Nebel 
Chief , Environmenta 1 

Analysis Branch 
Planning Division 



Grass Roots Alliance For State Sovereignty 
Box 263 Greybull, WY 82426-2063 



[Same as Letter #11 



Additional comments: 

The U.S. Contituition states that the US Govt must buy Wy land if they with to 
control Every aspect of Wy. [Blacked out portion.) We do not with to sell. 



Name: Frank Waitc 

Mailing address: xxxxxxxxxxxxxxxxxxxx 

City, State & ZIP: xxxxxxxxxxxxxxxxxx 



Signed: /s/ Frank Waile 



Date: 1-19-95 



297 




Grass Roots Alliance 
Box 263 Greybull, WY 82426-2063 



[Same as Letter ffl] 



e r e i g n t y 



Additional comments: 

Wyo. State lands should be under the control of Wyo people. Not the 
[environmental] extremists of Calif and the eastern stales who you seem to represent in the 

entirety. 



Name: Mr. & Mrs. C. Robert Walton 
Mailing address: xxxxxxxxxxxxxxxxxxxx 
City, State & ZIP: xxxxxxxxxxxxxxxxxx 



Signed: 



/s/ Carolyn S Walton 
til CRWalton 



Date: 
Name: 
Address: 
Phone: 



OPEN HOUSE COMMENTS 

ON THE 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

FOR THE 

BLM GRASS CREEK RESOURCE MANAGEMENT PLAN 

23 January 1995 - Thermopolis, WY 
Jim Skaggs 

XXXXXXXXXJCXXXXXXXXXXX 
XXXXXXXXXXXXJUCXXXX 



Comment: 

We need to make sure there is public access to Public lands on the National Forest or 
B.L.M. Lands for Hunting & Fishing as well as for Stock Permitees. 
Example Cottonwood Upper Owl Creek and 

The Road Now be for the County Commission and all other areas of Lock out Need 
to be of major concern to your planning 

Oil & Gas Exploration should be expanded where possible 

Envieromential Concerns should take in to consideration Local Customs as well as the 
human factor i.e. what excess hard ships will be caused by your final deccissions 



Date: 
Name: 
Address: 
Phone: 



OPEN HOUSE COMMENTS 



DRAFT ENVIRONMENTAL IMPACT STATEMENT 

FOR THE 

BLM GRASS CREEK RESOURCE MANAGEMENT PLAN 

23 January 1995 -- Thermopolis, WY 
Bill Hill 

XXXXXXXXXXXXXXXXXXXXX 
XXXXXXXXX XXXXXXXJCX 



Comment: 

Of critical concern is the management of the 15 mile drainage. This is one the most 
unique areas on earth, however erosion is incredible . We must do what we can to control 
erosion through grazing, vehicle, & structural & vegetative means. Development of 
cooperative enterprises with the NRCS, BLM, private &. state concerns must be intensified. 
I suggest that we work together to find economical & practical means to address the 
watershed concerns of 15 mile & it's tributaries. I think historical evidence exists that the 
drainage could be different (better) [page 2J than it is. I realize that the drainage will never 
be tamed, but at least we could do belter than we are. The Big Horn Basin WY "RCFD 
Council hears continual concern about the erosive capability of 15 mile. Wc are currently 
working with some land managers in South Dakota that may provide some practical ways & 
means to address land management issues on 15 mile. We stand ready to work with other 
partners partners in the Grass Creek Resource area to address some of the issues. 



QRJSS 



£.... «?..(. Jlh..,. 



8 



(30?) 765. 2244 



January 17, 1995 



BEC E I V E D 



BUlUUOFUjDIIAJIAaEMEK- 



Mr. Bob Ross 

ULM RMP Team Leader 

Box 119 

Worland, WY B240I-0II9 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Ross, 

The purpose of this letter is to oppose more restrictions on Wyoming's public lands. Your 
document is filled with restriction", thai your agency is not authorised to impose. We speak 
with the authority of uie Constitution of me United States of America and thai of Hit great stale 
of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to oar state an welL Prudent management of our resources, is sound business 
practice, and cur businesses operate with mat in mind now. We have managed the affairs of our 
state quite well . . . if you do not agree with this, look at the eastern states. 

This plan docs not consider the needs of the citizens or businesses of Wyoming, yet vou 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We appose this document in Its entirely. 

Additional comments: 



$&**& 



-D.te:/-/7- 



298 



qiass 

q e.,i. jilt. 

&, 263, Q^L/f. Wy 8243(*02(*-i 



3.. 



9 



($&?)?65-2244 



January 17, 1995 



JAN 2 4 1995 



BUREAU Of UMm«ASf! 



Mr. Bob Ross l 

BLM RMPTejm Leader 

Box 119 

Worluid, WY R2401-01 19 



Re: Gntss Creek Resource Area Draft Land Ow Plan 



Mr. Bob Rom, 

Th«purpo«affliMkUerisuioppcBcn»rerestricti^ public lands. Your 

document is filled wifli restrictions that your agency is nut authorized to impost. We speak 
with &e autborilj of die Oxadtutkin or (he United States of America and thai of the great state 
of Wyoming. 

The resources in Wyoming belong to Wyomng, and therefore, the contro! and usage of 
our land belong to oar slate as well Prudent management of our resources, is sound business 
practice, and our busawsses operate mm that m mind now. We have managed the affairs of our 
state quite well . . . if you do not agree with this, took at the eastern states, 

This plan does not consider (he needs of the cinaens or businesses of Wyoming, yel you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

Wc appose this document in its entirety. 

Additions! comments: 



Nam*: 



Matting address; 





Grass Roots Alliance 
Box 263 GreybuH, WY 82426-20© 



(Same as Letter #1] 



For State Sovereignty 



Additional comments: 

I am totaly against adding wilderness areas to the country. I used to run a few sheep 
on land surrounded by BLM. 1 think there were about three people in charge of BLM at the 
time. Wc got along fine Now, a couple of years ago, while surveying on a canal right of 
way, a pickup load of BLMers came charging over the sage, and demanding to know what 
we were doing. Cut your organization down to half a dozen— you will do a better Job! 



Name: 

Mailing address: xxjlxxxxxxxxxxxxxxxxx 

City, State &. ZIP: xxxxxxxxxxxxxxxxxx 



Signed: IsJ Jonathan Davis 



G RASS 



Grass Roots Alliance Por State Sovereignty 
Box 263 GreybulJ, WY 82426-2063 

[Same as Letter #1] 

Additional comments: 

The BLM spends its time &. Money planning but your management skills are totally Void. 



Name: 

Mailing address: 

City, State & ZIP: 

Signed: (a/ William F. Craft Date: Jan 23/95 







RECEIVED 




© 




JAN 2 G ©95 


' 


U.S.Dfipartmnnt 
d4 Transportation 


BU 


EAU OF LARD BAKAGEM 


Eh! ; 



Federal Highway 
Administration 



12 



H16 Evans Avcnje 
Clieyenris, WY 83001-376-1 

January 23 , 1995 

Draft EIS, Grass Creek, 
Resource Area Rasourcs 
Management Plan 



Mr. Bob Roes 

Team Leader 

Bureau Of Land Management 

P.O. Box 119 

Worland, Wyoming 82401-0119 

Dear Mr. Ross : 

We have reviewed the above referenced Draft: EIS and aslc that: you 
more adequately discuss impaccs to transportation facilirics 
including State highways within the area. This would include any 
potential increases in traffic volumes, maintenance of existing 
facilities, changes in philosophy concerning highway easements, 
etc. 

IE we can be of any further assistance, please, call Rod Vaughn at 
772-2012, ext . 48 . 



RODNEY p. J VAUGHN, P.E. 
FREDERICK A. BEHRENS, P.E. 

Division Administrator 



299 



13 



Grass Roots Alliance 
Box 263 GreybuU, WY 82426-2063 



[Same as Ixtter #].] 



For State Sovereign! 



Additional comments: 

No More-restrictions on Wyo public lands. 
Let We Citizens of Wyo, Manage this Affairs, 

Name: Charley D Helling 

Mailing address: xxxxxxxxxxxxjuucxxxxx 

City, State & ZIP: xjtxxxxxxxxxxxxxxxx 

Signed; /si Charley 1) Helling Date: 1/24/95 




QRJSS __ 

& 1 --" ~&777~. ~J7T~777. J7, 1777. 1777 rwii 

£* 263. ffaL£ Wy S242&.0S63 (307)765-2244 



January 17, 1995 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Woriand, WY 824QI-G1I9 



Re; Gnu CtMk Resource Aiea Draft Land Use Plan 



Mr. Bob Ross, 

The purpose of Mb letter b to oppose more ratric&M <m Wywntag^ pihttc kmis. Yout 
rf«wraent is fUW witfc restrietioMs that yoar agency is not authorised to impose. We speak 
with me mtmxitj of the Oaisnaiiaouof foe United states ofAmerit» arid that of ft* great state 
of Wyoming. 

T^nsMwrcMnWywn^bek^ 
Wkindqea^toatirsotteMWBtt, Pnidentmon^einentofairresonre^lssouiidbaitoess 
pmdKe,aMourbo*B M »«sopM^wtot»tinmMid«m. WetawnMnasedmcffiurs of our 
stole quite well . . . if you da noil agree wim this, took at the eastern states. 

TWs phut does flat consider the needs of the citizens or bwfcawe* of WwtnJn&yetyui 
woHldrniposemisonmastfwodMisoivaJueourpuhlkbuids. Any restrictions deemed 
necessary should come from the state of Wyonmg. 

We appose mis document in its entirety. 

Additional comments; 



M 




GRASS 



S. 



(307) 763-2244 




§,.*4 R..t. <4thm*,4 3.. 

&r 263, Q*iUl, W\J 82426-0263 



January 17, 1995 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Worland, WY 81401-4119 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Ross, 

The purpose of flus letter is to oppose more rcsirkiinm on Wyoming's public lands. Your 
it is filled frith restrictions that your agonry is not authorized to impose. We speak 
with the authority of the Constitution of (he United States of America and that of the great state 
of Wyoming. 

The resources in WyouBng belong to Wyoming, and therefore, the control and usage of 
our land belong to our state as well Prudent management of our resources, Is sound business 
practice, and our businesses operate wim that m mind now. We have managed foe affairs efour 
state quite well . . . if you do not agree wim this, look at me eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this 

Additional comments: 



frame-. "JJurtr\ 
Maihng address:^ 
City, Stale * ZIP: 



11 



x .1\QkiM> -AnJjA^ 



gziss 



g,.,. #../. .4ii,. 

tSu 263, Q^lJf. Wy 82426-0213 



16 



(30?) 765-2244 



January 17,1995 



RE C E I V E D 



JAN 2 6 1995 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Woriand, WY 82401-6119 



Re: Grass Creek Resource Arem Draft Land Use Plan 



Mr. Bob Rait,, 

The purpose of fins letter h to oppose more restrictions on Wyoming's public lands. Your 
document is filled with restrictions that your agency is not authorized to impose. We speak 
with the authority or the Constitution or the United States of America and dial of the great slate 
of Wyoming. 

The resources in Wyominfi belong to Wyoming, and therefore, the control and usxrc of 
our land belong to our sure as welL Prudent management of our resources, is sound business 
practice, and cur businesses operate without in mind now. We have managed the affairs of our 
state quite well . . . if you do not Agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in its entirety. 

Additional comments: 



Name: Oob 
Mailing address: 
Chy, Stole & ZIP: 




srf-Qs 



300 



g,.,. tt..t. jiii.. 

&x 263, Cjr^-H, MM 82426 0263 



IT 



(307 ) 765-224' 



January 17, 1993 



JAN27B95 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Worisnd, WY S2401-01 19 



Re: Grass Creek Resource Area Draff Land Use Plan 



Mr. Bob Ross, 

Tbepurpo^orthisteflerMtooppascnwrcreslrirtionsan Wyoming's public lands. Your 
document is filled with restrictions thai your agency is not authorized to impose. We speak 
with the authority of the Constitution or the United Slates of America and that of the great state 
of Wyoming. 

Use resources hi Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to our state as well Prudent management or our resources, is sound business 
practice, and our businesses operate with that in mind now. We have managed the affairs of our 
state quite well... if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in its entirety. 

Additional comments: 




1 8 



GRASS 



ce For State Sovereignty 



Grass Roots Allia 
Box 263 Grcybull, WY 82426-2063 



[Same as Letter #1] 



Additional comments: 

Wyoming & its citizens would be just as well off, if this Thing you are doing to the Grass 

Creek aera was Left Undune. 

Name: Edgar F. Harwood 

Mailing address: xxxxxxxxxxxxxxxxxxxx 

City, State & ZIP: xxxxxxxxxxxxxxxxxx 



Signed: /si Ed Harwood 



Date: Jan 2.1-1995 



GKJSS 



&* 263, (fa&Jt Wy 82426-0263 



3#, 



Si.t 



n 



(307) 763-2244 



January V), 1995 



JAN 2 7 095 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Woriand, WY 82401-01 19 



Re: Gnus Creek Resource Area Draft Land Use Plan 



Mr. Bob Row, 

The purpose of mis letter is to oppose more restrictions on Wyoming's public lands. Your 
document is fiEed with restrictions that your agency is not authorized to impose. We speak 
wtmtteainlMrityoflheComtimtimoftheUriiied States or America and mat of the great state 
of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to our state as wefl. Prudent management of our resources, is sound, business 
practice, and our businesses operate with that in mind now. We have managed the affairs of our 
state quite well . . . if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose mis on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in its entir ety. 



Mailing addrcss;_ 
City, State & ZIP: _ 



Tl^ttas \J/£f ?#"*■<<-« 



Bp^ Z/t^BW 



Q&ASS 



20 



Q r . ti t?..t* jtlhm 

Bo* 263, QrmfL,«$, Wy 82426 0263 



(307J 763-2244 



January 17, 1995 



RECEIVED 



JAN 2 7 15 



Mr- Bob Ross 

BLM RMP Team Leader 

Bos 119 

Woriand, WY 82401-01 19 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Ross, 

The purpose of mis letter is to oppose more restrictions on Wyoming's public lands. Your 
docoment is filled with restrictions that your agency b nol authorized to impose. We speak 
whlimeauu^rtryoruwCcnsthnnonofu^ and thai of the great state 

of Wyoming, 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong lo OUT State as welL Prudent management of our resources, is sound business 
practice, and our businesses operate with mat in mind now. We have managed me affairs of our 
slate quite well . . . if you do not agree with this, look at the eastern states. 

This plan does not consider (he needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in its entirety- 
Additional comments: 




Name: 

MnQfatf; KKfrwH^ 

City. State & ZIP: 



L 

301 



Signed-, 4t£i*ad Cf ofV^r-rnLd D.l«: /'/1 rf /& > 




United States Department of the Interior 






BUREAU OF MINES 

-■wunujil WtM OjKBLluu. CcaEr 
P. Ci Box 25086 
■Mildirifi 20, Dmvti Fcdui Cu.ki 
>nvw, Ulor.do 80225 



January 24, 1995 



Boh Ross, Team Leader, Bureau of Land Management, P.O Box 119 Worland 
WY 8240] 0119 

Supervisory Physical Scientist 

Review of Draft Resource Management Plan and Environmental Impact Statement 
for the Grass Creek Resource Area, Worland District, Big Horn, Hot Springs, 
Park, and Washakie Counties, Wyoming 



As requested by Robert Bennett, Acting State Director, Bureau of Land Management, personnel 
of the U.S. Bureau of Mines reviewed the subject document to determine whether mineral 
resources or mineral -production facilities would be adversely impacted by the proposed project. 
The document addresses four alternatives for managing the public lands and resources in the 
Cirass Creek Resource Area of northwestern Wyoming. 

The document is very well written and, for the most part, mineral resources and mineral- related 
issues have been covered in detail. However, we have several comments concerning text 
discussions and specific minerals. All mineral resources occurring in the Grass Creek Resource 
Area should be identified in the Affected Environment section. Chapter 3. Phosphates, zeolites, 
geothermal, and coalbed methane resources occur in the Resource Area and are discussed 
elsewhere in (he text (p. 192. table 15, appendices 2 and 4, map C, etc.). yet are not included in 
rJic Minerals sectior. of Chapter 3. Available maps and literature indicate that brick clay, 
common clay, and uranium resources also occur in the Resource Area, yet these commodities 
arc not listed or discussed in the document. Any impacts, or lack 'hereof, to all production 
facilities (i'or example the bentonite mills at Lucerne and Worland) should be identified and 
mitigation measures discussed. 



If you have questions concerning this r 
ext. 299. 



dew, please contact Jeanne Zelten at (303) 236-0428. 



/ 



J^&& 



Mark H, Hibpshman 



RECEIVED 



JAN 3 1995 



m, 



January 26, 1995 



Mr. Bob Ross 

"foam Leader - BMP draft CIS 

BLM - Grass Creek Resource Area 

P.O. Box 119 

Worland, WY 62401 



Dear Mr, Ross: 



Thank you for sending the draft EI5 on the Grass Creek Resource Area Resource 
Management Plan. I appreciate the opportunity to comment. My comments are directed 
toward cultural resources. I strongly support most ot the management objectives and actions 
for the rock art sites, particularly at Legend Rock and Meeteetse Draw, outlined tor the 
preferred alternative. I strongly support expanded use of these areas for scientific and 
educational purposes, and designation of the Meeteetse Draw area as an ACEC is an excellent 
protective measure. 

However, I am not without concern, particularly with the proposal to develop 
interpretive trails in the Meeteetse Draw rock art area. I am ell for public education and 
interpretation. HnwRunr, this also has a major adverse effect. Without proper staffing and 
supervision, major degradation and vandalism of these sites can occur. The Meeteetse Draw 
area is isolated; access is difficult, end the rock art sites are spread out. If the public were 
directed to these sites, there is no doubt that serious vandalism would occur. I can only 
wonder, with current staffing levels, whether BLM has the resources to adequately patrol and 
supervise the area. 

The Castle Gardens Rock Art site is no better example of the degradation that can 
occur without proper site supervision. This site is open to the public with directional signs, 
trails and chain link fencing around some panels. The fencing has served as little protection. 
It has been cut, broken and bent so Lhat people can crawl inside enclosures. Holes have been 
cut into the fencing for picture taking. Human traffic in front of the fence has caused so much 
erosion that concrete footings on fence posts are now exposed and artifacts are washing out 
from deposits at the base ot panels- Areas that have not been fenced are covered with graffiti 
and bullet holes. Entire panels or figures have been chiseled out of the rock. Castle Gardens 
is one of the saddest things I have ever seen. And there is every possibility that increased 
public access to Meeteetse Draw could result in the same type of degradation. 

Perhaps the best option and balance for the Grass Creek Resource Area is to restrict 
additional public develapmont to the Legend Rock site. This site has already been proposed 
for development as a state park, but funds for proper supervision have been lacking. The 
state wisely chose not to open the site, unless a full-time supervisor could be arranged. No 
rock art site should ever be opened to the public unless a full-time supervisor can be present. 
There are also many advantages of enhanced development at Legend Rock. The site is already 



22.2 



very well known and frequently visited. A cooperative arrangement with the state of 
Wyoming could bR negotiated to lead tours and supervise the site. Like Castle Gardens, this 
site has already suffered some pretty severe vandalism, and further degradation could be 
prevented. Information from the Meeteetse Draw area could be incorporated into interpretive 
exhibits and educational materials distributed at Legend Rock. 

In between Legend Rock, Medicine Lodge Creek and Castle Gardens, areas in and 
around the Grass Creek Resource area afford plenty of opportunities for public visitation and 
education regarding values of Native American rock art, without opening up the rock art in 
Meeteetse Draw, which has undergone much less vandalism. Public use of the Meeteetse 
Draw area is minimal now, and it should he kept that way in the best long-term interest of tho 
resource. 



Thank you again for the opportunity to comment. 



Sincerely, 




/JjSlie Francis, Ph.D. 
eologist 



q&jiss 



g — e..i. ju,. 

&* 263. Cr*l-Jf, lift/ 82426-0263 



m 



(30?}?65-S2A4 



January 17, 1995 



s:i:wcj 



BUREAU OF UNO HANA6EMENT 



Mr. Bob Ross 

BLM RMP Team Leader 

Bos 119 

Worland, WY 82401-0119 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr, Bob Ross, 

The purpose of this letter is to oppose more restrictions on Wyoming's pubtk lands. Your 
dueument is fillet) with restrictions that your agency is not authorized to impose. We speak 
with the authority of the Constitution of flic United Stales of America and thai or (he great stale 
of Wyoming. 

The resources m Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to our state as welL Prudent management of our resources, is sound business 
practice, and our businesses operate with tliat in mind now. We have managed the affairs of our 
state quite well . . . if you do not agree with tins, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the stale of Wyoming, 

We oppose this document in its entirely- 
Additional comments: 



tyjd A. Rtner 



City, Stale & ZIP:_ 



7 Mc 



£Z-t± 



302 



Nature W^ Wyoming Natural Diversity Database 
Cpn&tTVQHCy l6CMGrandAv8., Suile2 - Laramie. Wyoming 82070 



m 




RtCEIVEC 
S5FE8-3 m 8 
bLM WORUNDl 



1 February 1995 



Walter Fertig, 
HYNDU Botanist 



Bob Ross 

Team Leader 

PO Box 119 

Grass Creek Resource Area 

Norland, WY 82401-0119 



Dear 



Ross 



Thank you for the opportunity to comment or, the Draft 
Environmental Impact statement for the Grass Creek Resource Area 
Resource Management Plan. I » s botanist employed by the Nature 
Conservancy and can offer the following comments on the Special 
Status Vegetation section (pp 134-135} of the plan: 

1. Two species are listed as occurring in the Planning Area 
which, based on the legal descriptions given, are 
actually found in the Cody Resource Area of the Worland 
District. These species are Aromatic pussytoes 
f Antennaria aromatje a) and Wyoming tansymustard 
( Descurainia torulo sa) . Neither species was found in 
the Grass creek Resource Area during floristic surveys 
of the owl Creek Mountains (the only likely area of 
habitat) in 1991-92 (see Jones and Fertig 1992 and 
Fertig 1992 reports). Both should be listed as "known 
to occur outside the planning area, has potential to 
occur in the planning area". 



Rocky Mountai 



twinpod f Physari? . s.ribnn'iana var. 

a US Fish and Wildlife Service category 
2C species, is omitted from Tabic 11. Six populations 
of this Wyoming endemic taxon are known from the 
foothills of the Owl Creek Mountains, within the 
planning area (see Fertig 1992 report). This species 
was added to the USFWS candidate list in the 3 
September 1993 Notice of Review- 

The federal status Of two species in Table 11 is 
incorrect. Persistent sepal yel lowcress f Rorioaa 
calvcina ) is listed as a 2C candidate in the 1993 
Notice of Review. William's waferparsnip (Cymapterus 
w ill jams j i ) was recommended for listing as a 2C, but 



24.2 



was not included at that rank in the 1993 Notice. 
Recent status surveys have shown it to be more abundant 
than once suspected and it is currently listed as a 3C 
species. 

4. Other recommended status changes: The Notice of Review 

is currently being revised by USFWS and is expected to 
be published in late 1995. contracted ricegrass 
(Or yzop sis co ntracta ) and yellow springbeauty 
( Clavtonia lanceolata var. f lava ) have been recommended 
for downlisting from category 2C to 3C. Confirmation 
with USFWS is needed to make sure that these proposed 
changes will actually be accepted. 

5. Although unfamiliar to most users of the Plan, it would 

be helpful to include scientific names with the common 
names for plant species listed in Table 11. This would 
avoid undo confusion resulting from the use of a non- 
standard common name, as in the case of "Moll's aster" 
( Aster mollis ) . (There is no person named "Moll", the 
mollis in the name means "soft" and refers to the hairs 
on the plant's leaves). 

One final comment on the preferred alternative for 
management of candidate T & E plants (page 53) : 

6. The strategy of transplanting protected plants onto BLM 

lands should be reassessed. Transplanting rare 
species, especially those adapted to dry, rocky, barren 
sites or specific soil types, is difficult, and in the 
case of the species listed in Table 11, has never been 
attempted . Tn my experience, rare plant species 
usually have little difficulty establishing themselves 
on suitable sites and may already be occupying most or 
all areas of suitable habitat available to them. 
Transplanting seems like an unnecessary and costly 
strategy with a low probablity of success, 

A preferable strategy would be to assess potential 
land management conflicts on a species-by-species basis 
and work with permitees and other interested parties in 
resolving conflicts at specific sites. In most cases, 
these rare plant species occur on barren, rocky slopes 
with no water and little forage (and thus are not 
likely to be adversely affected by most range uses) . 
Mineral development activities could be allowed 
provided that plant habitat is not disturbed by roads 
or pipelines and well pads are located off-site. This 
strategy is more in keeping with the intent of the 
directives in BUI Manual 6840 requiring the agency to 
"manage USFWS candidates in such a manner that these 
species and their habitats are conserved and to ensure 
that agency actions do not contribute to the need to 
list these species as Threatened or Endangered". 



24.3 



Thank you again for soliciting comments on the draft. 
Sincerely, 

waiter Fertig *^> 
Heritage Botanist 



References: 

Fertig, w. 1992. Sensitive plant species surveys and revised 
species checklist, Grass Creek Resource Area, BLM. 
Unpublished report prepared for the BLM Grass Creek Resource 
Area. 100 pp. 

Jones, R. and W. Fertig. 1992. Checklist of the vascular plant 
flora of the Grass Creek Resource Area, north-central 
Wyoming. Unpublished report prepared for the BLM Grass 
Creek Resource Area, 20 pp. 

US Fish and Wildlife Service. 1993. Plant taxa for federal 
listing as Endangered or Threatened species; Notice of 
Review. Federal Register 58: 51144-51190. 



Jeff Carroll, BLM state botanist 
Marian Atkins, Grass Creek RA 




Grass Roots Alliance 
Box 263 Cireybull, WY 82426-2063 



[Same as Ixtter #\] 



Sovereignty 



Additional comments: 

I don't think that I could have said it better myself. Please, Mr Ross, 
don't take this as personal, because it's not The BLM along with countless other Federal 
agencies have forgotten that "we the people" pay their salaries-they work-you work-foi us. 

Name: David Bayert 

Mailing address: xxxxxxxxixjuolxxxxxxx 

City, State & ZIP: xxxxxxxxxxxxxxxxxx 

Signed: Is/ David 0. Bayert Date: 2-8-95 



303 











■S 






^ 








February 5, 1995 


FB-9B95 


IT 


niUUOFUNDUIIAKM 








I'.r, writing this r»if«ifa* to tfte E.I. 8. on the 


»«• &•««> f «™"- «•«■ 


i no»« hmmI «.«rt» to «... m r„ era ,o tftt 


*»? «r$Mtlint ItQ the Wild Kwse Range; I.E. the additional 


allotment of the Tat man Mt . area. 


I" :t was ny unferrtunfeftg vtw H« tutting wii ef 


33 f 130 SCita w*i allot til, that the res^on tfttftan fit, was 


nob in.:lud».i i ,1 t!i#t area w&i DecwUBe of the damaae being 


den. -.,-. th. ,r„, ...y „.« M u limn, mi IM Darn w< 


to he thcJLKMsd (raflt tSi* Tatnian ftfftft. Now it- seems that 


you are spying ,-u>u can't build fences that will keep in* 


l»ora»B out af Tatman, so y©y want to give up and let the 


IWr*9« fe«K -.nto = n area that 10 y*8TS BOO your biologist 


&«'. d the/ uer* aeatroyinj, wihat happens nev.t ? 10 years 


from rrnu you're going to say that you isn't .iuiri the 


IWIM In tm « ? ,„d»a r.n E e MM VM n»d U )1M M 


another SOfflOO ?cret" Under that type at manascasnt. why 


avon have a r;-nge for their? Just l«t tha(S roam free as 


Shay ware in She baplnnlnd. 


I do not SB9 in the L.J.ii. where you have ac'dressen 


She af'f.-ct of the sflfilUotm; 3n,ooo> a-:r«s en the wllBUfe 


in this arec. :deer, antelope and various bifd&i, or the 


effect on the springs and water hole?. 


If you do iitf&vt on »nj»r Sting the are* to mora 


than BG,COO+ aeraa Of the B,tifctlng range, instead of 


fixing the fftr.ee, tfien i think t !■ « t j,cu should take the 



30,000'- a^rejae that yr,i< want fro add tTatfflftfi Mt.3, ma 


26.2 


delate. Bftll seas i-sreags from til* &rigin«j ai U'tfMtflt. 




«m „,n *o «xu Ml „ r„ s , cl»i« tu< s»y »«,■( 




use the Ssufcft am) of th* range anyway. This would hold 




the allotment to the original acr-eaB« °' 80, ©vO* acres. 




ii ».t.K. 1. n« ol., wtt, ftmem, to MU «M 




lisr-WMi :i, an aUatafl artta, then rfij 30 enrcugri the falsa 




prffltWWa of even having m alloted acrsace tot tne rtfflftM? 




Instaad ot enlarging their rangp, ii 1 - The BuisSing 




pr obi ems of fences and water hoi be and ad id* fcy the 




■:oni:ern= of previous horse managers and biologists, and 




keep the horses ;n their original allotment. 




It) In rega v cl to reservnirs in the flvt, Ten, anti 




Fifteen mile araa, I believe wc are getting Che ahorx ai'id 




0i U„ rtlct in thl. •>•>. The BiMinj water kolM wer. 




mostly [tiBflp nscf- in the 'BO'a anrf '60's. ^t this finte, 




tl, B) w,ro d.™ B d to t, r,„.„ a ry »« |M .ur*iv,l of 




■viSdli ftt ;.no livestock-. Now, 4W yea'? iatc-, thr,- ar9 in 




»ed shape and most if not all, R»»J vejiair. 




If they uaffi viable 40 years acci, wHy =rcn't fch#y 




now? 'four eceslatiiWi* are that this rEsBrvoi.-j and thecf' 




rfafl» eire all sii-rd i.n. If they are ell Biltod in, that 




-:-i-;i. to me that the previous managers (.new -.■i.-it they wjru 




doing when these ehacJ! dama w^r'e built. The. ha.? stopueii 




tl'ie £,iltation flaw until thuy were fiilfd, and now need to 




h'T rebuilt. They must hav« worked, or they wouldn't Uk 




.iltas iiu 




All of the best g'razino in the world 1 ? of no use, 




ii wtir ls»M ««ll»l*. 




In the Elk Creek arian, erotiiori is d res! problMi. 




»'<" •«"> '««». Eli »«* '« « w» ol ™= =^M «* »« 









river , and deiiroasinrj the fish mo poiftFvtlSl . The oheck 
aams in kftta area afe all silted in, pr^vinu that they 
woned when originally installed. B.L.H.'s attitude laawi 
"o nip to be if sofflethina works, don't fix it when it Viss 
done what it m% designed f'i.r. Check dam's weru instaMed 
to stop siltation and wfien they were filled to overflowing 
with silt, tney were abandc-neu if.stHs.d of being built Oacb 
up to prevent mare siltation, and rn^w they tm just Dig 
guliies afiti w*th»*. 

Ut'ien these wheel- dams werr; ab5rK)pjTiQci, the w.vter 
went to the reservoirs which were then filled with Silt 
and finally had the dams breached. 

In the Five mi le area a new Wtttr hole was: fenced 
of i with a pipe running to # waterer in the unlch b»lw«. 

the outlet pipe. This has t.ern repnrred, but &,L*H«'a 
rwporvBa has been not to (in t:te problem, n'.it to allow *lw 
1 l vest oil; permittee to opwi the f encpC enclcisnir* 1 to hin 
cattle, thereby destroying the veaetatiw; nrmtnd the water 
Kola, ann trompinc dnwn cna ponn eeoe^. fijain, rtwi'* ii . 
3©»B>thlhg that has the potential to ii work, just so on t^. 
bigger and Getter plfir.s, 

If thi s type of oppr.it; on goes on i.n tliii area, 
■which I'm fam:l-.at witu, th^n I'm surg it coe= ..in aM over 
the entrlra resovircp area. It's littie wonder that your 
Ceparcnent receives little or no support from the f«op\f 
of yotjr diitri'Tt. 

E.I.S; I object to the U3& of the term "rlesionated" ro*d<s 
and feel the use of "«xiating" road? meuleJ replace it. ; 
was told at the 6r eybui i iiieet inti, when I MtkCd wtio wc<uld 
deterrnini" whi ch raaiO* w-l.m! d He ses: crated as roads th*t 



2@.3 



could be used by vehicles, I was told that this would be 
done by E.L.M. personnel and not by the Public. Vc WS 
this fttink*, as b.L.M. could sut out public Lr d vel to trta 
whola area if they so desirco. 

The problem of access to S.L.M. lands is alrowdy 
one that should ba a top priority to all L.L.rl. 

tmnageMHt. Road iio^urtes tiy b.L.M. officials sugojiBtetl 

in the E.I.S, s.jonds to mu like just ant- more way thai 

public lands. 

In my opinion, b.L.M. is taking away the potlHcB 
fights to use these lands, a small piece at a tune. If 
you tk'h't net your way this year, you know that if you 
~;&ep nibbling away, you will get what you want in the end. 
E&eh i'I Itbeae E.I.S. lake away a litri? mor# oi r ur 

ritiht;;. fi.L.n. aaks for r<sin«»rit« trcw ttw publK on how 
to manage thest- iantin jrwj if tl-.e/ itht- eonMnltB; 3cn't 
"fjfc" with tl« p.,;,;y rj.L.n. is trying t-_. put* thrown, 
MSfl cflfflHaarvtB are circumvented in one way or another until 
the public is so Jed up with the way B.L.M. operates, that 
they will no longer attend a comnErit nttwting or offfir ftflV 
r.ore suggeiti..ifi5 on how E.L.M. il'.ouM operate. 
'.'.'/ Uarciell Rerorvoir I am 5t.-0r.glj apainel any !ki> 
Jbe facil it tes or camping si tea nemy estaDl ishea at 
either Wurdell or Harrif>iiton Kas«rv?iri,. Uartlell is now 
too over run with speed boatu pulling water skiers, that 
it's almost lepossibl* to fish! Tour boats on a rs^rvo^r 
of this list Mini that one of these ie passing you e-'ery 
two minutes. This body of water is already so heavily 
used by water skiers and jet skiers, that problems are 
- -nring &e*watfl E»e» and t; sherMn. Te d*1 iDerately 



2S.4 



».-<o«? 






304 



aeofi fisherman Cmt ificIittfBfli, forced oM the uater by the 


26.5 


F5»»d boat? '.ominci *$ '".lose t'-.st tfta wak" at t«* SMt 




threatens Sa CftpSllB Small f 1 shine, Cra't. DsbHi left l,y 




tttfl patftiflfi held by these pBffip^a -<'.? an eya-sara BAG ■ 




liazirG. Alcohol plays fl tijq pact in the problems and 




H#ving camp sites would, Iri my opinion, only enlarge tnis 




pioi-lti", at no er.ioi csment of boatinp laws -is- ■.-« rsntly 




being e*m*S oijt. S#ififl J- Fish, tft» Sh*»-iff's D&pd.-tmerit;, 




and P.l.H. have .ill been told of this pr*Ql.«ilt, yet no one 




do be anything flbsut it. B.L.fl.'s answsr was tt> aPaniJon 




ths fishing on Wardsll and aw HrfWr frig-few '--■■■ fishing, and 




leave Wa.-QSil to the SpftftCI tH>«ttt. TfiK ©My problem 15, 




there aren't any fish in Harrington Raacrvwr! 




finally, in conclusion, lat nte qu-.te eome c-i /our 




monetary figures ffoai pages 204 - -l" in fha v^; ft set- 




F*sour:e Ar<5a R*»w«*iS-t Management Plan Draft fn/iconmental 




U P K% SfcatMlf* tnteutfcw KW, urn* paring and 




rt*»««tt«J» 




Alt A t3'9, 42.1, 2C>3 t:7,3S0,3S3 




Al t S 140, 7 10, 'IFj.; 1 &M0S, i.:0 








These fl^-e Mis dollar amounts sha^ those two tact-si's 




WOUld out into tiie L*t«il ■Uonomj'. f ro.Ti thW flfiHTM 




under AH A R&.ieation, this would provide A4\ ■■■! uhal 




g*«siilj ttag*, Undyr Alt B, HS - /., «nf] under Alt G, 106%. 




!n _.ijr Lnjdhfnft foe the; ytar a !!t9fl ~ £0(55., does recreation 




r«li» u»» ;m. mrantign ii, .. W 4itur. U»i or., 5 ,„, 




««■? i. rttar «t>, 1>1 wet, aniUr *M '0 Man:* 





erasing Is 64 cent* to &; ,06 apB' '■ on Ri 
8i"f**ncfjffiBritT If not, why not'"' 

THanfe you Tor tal.ing tae time to road m> 
and ©fa sot va tiffin*. ' will be looking forward to 1 
tha final Draft gf this E.I.5. 



26.6 



Ewi J K»ltt* 




27 



Bureau of Land Management 
Worland District Office 
P.O. Box 119 
Worland, Wy. 82401 

TO Bob Ross, 

After having reviewed the Draft EIS for the Grass Creek Resource Area, I have came 
to the conclusion that the BLM is not going to administer the commercial forest within their 
jurisdiction based upon the principles of multiple use and sustained yields. 

Using the BLM's timber stand Rotation of 160 years the 14,000 acre commercial 
forest will produce 1,312,500 board feet of timber annually. The present BLM EIS calls for 
a harvest of 400,000 board feet annually. In addition to the 14,000 acres of Commercial 
forest there is 45,000. acres of WoodLand managed for other uses. The EIS also states that 
1300 acres have been distrubed by Logging or fire in the past 100 years. Also what kind of 
management will the BLM have done, that by 2005 85% of the commercial forest will be 
Mature or overmature, Leading to infestations of bugs, root disease, and mistletoe. At 
which Time Forest structural diversity, and associated wildlife habitat and biological diversity 
would decline. Also increasing the risk of a catastrophe fire leading to the possible loss of 
public and private resources, 
[page 2) 

Also the socioeconomics of the area would increase if commercial forest Land was 
managed as such. It is my belief that the BLM is just planning to sell enough Timber so that 
Steve Christy, District Forester can justify his job. If the remaincr of this EIS is wrote in 
this manner then the BLM is not managing public Lands to the interest of the public but to 
the Intrests of the Federal Government and the bureaucatic system it has made. 

So at this time 1 ask thai you (BLM) revise the final EIS to manage commercial 
forested Land as commercial forest land. 

Sincerely, 

III William K. Wilson 
William K. Wilson 
Monument Wood Products 
TenSleep, Wy 82442 
(307) 366-2630 

P.S. I also am forwarding my comments to the Local and STATE Elected officals and to 
the South Big Horn Basin Multiple Use Association. 




28 



February 21 , 1995 



Bob Ross, Team Leader 

Grass Creek Resource Management Plan 

Bureau of Land Management 

P.O. Box 119 

worland, Wyoming 82401-0119 

Dear Sir: 

This is a letter to comment on the Grass Creek Resource 
Area Resource Management Plan Draft Environmental Impact 
Statement (EIS), September, 1994. 

I bei i eve that the definition of Ecosystem Management on 
paqe 8 of the EIS should be clearly defined as Ecosystem 
Conservation in order to properly evaluate how the proposed 
alternatives would meet the goal of maintaining ecosystem 
integrity. A generally accepted definition of Ecosystem 
Conservation is that of protecting the integri ty of natural 
ecological systems with a complete complement of native bio- 
logical diversity and perpetuating natural disturbance 
regimes on a regional scale over a time-frame of millennia. 
Certainly Ecosystem Management cannot happen without Ecosystem 
Conservation. Acceptance of this definition will more 
sharply focus on the inadequate nature of the proposed 
3lt.prnat.ives in this proposed document . 

None of the proposed alternatives are acceptable . 
Acceptance of the above definition of Ecosystem Conservation 
does not mean no commodity production can take place , but it 
does mean that business-as-usual on the public lands is over. 
I t does mean that management for a complete complement of 
native bio.l ogical diversity becomes of paramount concern and 
that commodity use can take place only to the extent that ft 
does not negatively affect this complete complement of native 
biological diversity. Obviously, this includes the viable 
presence of the large carnivores. 



305 



28.2 



Certainly it will mean less commodity usos over all 
such as less livestock grazing (none in some cases such as 
riparian areas), less timber harvest, leas oil and gas activity, 

no more roading, etc., but it does not necessarily mean none 
of these activities- It win. mean elimination of feral horses 
since we already have a National Feral Horse Range in the near- 
by Pryor Mountains of Montana. The extent of commodity uses 
must remain questions for the professional wildlands ecological 
scientist to answer as he or she evaluabes any of these proposed 
uses, including recreational impacts, with the ecological 
integrity of the Greater Yellowstone Ecosystem of which the 
Grass Greek Resource Area is part. 

T suggest that the B'oreau of Land Management rework this 
document to include Alternate vc E - Ecosystem Conservation , 
as defined in this letter. 

I appreciate this opportunity to comment. 



dUA rui 




RESOURCE PROVIDERS COALITION 

Darrel) Barnes 

District Manger 

Bureau of Land Management 

PO Box 119 

Worland. WY 82407-0119 



Dear Mr. Barnes: 

The Wyoming Resource Providers Coalition (WRPC), on behalf of the multiple-use 
groups aud the citizens of the Worland BLM District, is requesting a public hearing on 
the Grass Creek Resource Area Resource Management Plan (GCRMP). A public 
hearing would show BLM interest and concern for the Grass Creek area and give the 
people affected by the Draft Environmental Impact Statement (DEIS) the chance to 
publicly comment. 

The WRPC and other groups and individuals have been working on the GCRMP DEIS 
lo prepare comments, but this document will impact such a large number of people that 
just providing written comments is not enough. The Worland BLM office has held open 
houses, for which we are all thankful, bui the benefits of open houses in the past seem to 
have had little effect on the outcome of previous documents, 

The GCRMP proposes to severely increase restrictions on oil & gas without providing 
any justifications for doing so and docs not give credence to successful operations iu 
sensitive areas. There is no allowance for sulviug problems dealing with sensitive areas 
through tnjtigatiuu or other cooperative processes. The agriculture industry is going to 
experience a 35 percent reduction in useable allotments, and once again there is no 
justification. This unnecessary reduction will cause severe hardship on the livestock 
industry in the Grass Creek area and throughout Wyoming. Wilh the increase in 
restrictions and reduced access for commodity development, where are the citizens of the 
Grass Creek area going to turn to continue making a living',' 

The economic! in the DEIS do not really give the true socioeconomic impacts to the 
various communities. The DK1S does not fully consider the customs and culture that 
have evolved over the years. The people of the Grass Creek <trea depend on the public 
lands to survive, and these lands arc a very important part of the customs and culture of 
this area. Public comment via open houses and written response is not enough. Because 
this document will affect so many, the need and necessity of a public hearing is readily 
apparent. To change or impact the current philosophy of the BLM, the public needs to 
be in a public arena, where they can present their case and the BLM can present its. 

The WRPC and its members arc extremely concerned about the outcome of the 
GCRMP. therefore, we are. requesting a public hearing to be held in Thermopolis, 
Wyoming during the middle, of March. Thermopolis should be the hearing site since this 



P.O. Box 701 ■ Laramie . Wyoming 82070 - (307) 745-0996 



29.2 



community will be severely affected by lie current and/or any future outcomes of 
GCRMP, Due to time restrictions, the WRPC would appreciate a response to this 
request by the first of the month. I look forward to hearing from you. 

Sincerely, 



OJ^fJJL 



Dallas Skeets Valdez 
State Coordinator 

cc: State Director, Alan Pierson 
Governor Jim Geringer 
Senator Craig Thomas 
Senator Alan Simpson 
Representative Barbara Cubin 
Big Horn Co. Commissioner Chairman, Don Russell 
Hot Springs Co. Commissioner Chairman, Jean Owsley 
Park Co. Coutniissioner Chairman, John Winningcr 
Washakie Co. Commissioner Chairman, Bill Glanz 



Wyoming State Legislature 



pMiC'Kltnii Wymn-AD 



February 27, L99 r ] 




Uarrell !i*mes, District Man; 
Bureau of Land ybinngoment 
P. 0. Box 119 
WorUsd, WY 82407-0119 

Un.-ir Hr. Barnes: 

I an wicitiK as ChaiCTUKi of 
Committee Co rtiqocat a pub] 1 
M«n*j»«Bent Flan. 

The puhl-ir coTnmont liuaritift will give people involved and concerned aboi 
£h« propuacd plan to be- bet tit I informed hy your agency , and •xprui 
their concerns. The PUpQKunity for this Involvement will help thi 



JBtne Ageteuleut 
.flting on eh. o*i 




iiiieTaeioi 



cf this req-^flst. 



SylviJr S. Cams 
State Repru) 



306 



eat Wyomifiij* !■ 



2/22/95 

I J Mr. Darrell Barnes, 

[" Worland BLM 

[ POB 1 1 9 

I Worland, Wyo. 62407 




Wyoming State 
IE 'Razing Board 



31 



Hr. 



o. r t"i f ■" 




I am writing you in my capacity as chairman of the worland state 
Grazing Board, our nine man Board is chartered by Wyoming Statute 
9-4-401, to represent the interest of the BLH permittees who hold 
Section 3 grazing permits in your District. 

We have reviewed the Draft Grass Creek RMP/EIS, and while we 
appreciate Lhe efforts of your range staff to provide some 
additional management flexibility on some subjects over the old 
crass creek Plan, we do have a number of concerns about certain 
portion's of the new Draft document. In particular, I would like 
to express dismay over the information displayed in Appendix 3, 
Table 3-5, COMPARISON OF STOCKING LEVELS, ACTUAL USB, AND 
SUITABILITY BY ALLOTMENT. Although the Draft does not explain the 
source of the data base on suitability in this Table, we 
understand from your employee Jim Cagney that the data in this 
Table did not come from recent studies, but in fact came froai the 
BLM's Grass Creek Plan developed in the early 1980's. 

we have been advised by recognized expert sources from both 
outside the Bureau and from within, that the suitability data 
from the old Grass Creek Plan was determined by the Bureau itself 
to be unreliable and that as a result of that internal 
determination by the Bureau, that the criteria used to develop 
this estimate of suitability was removed from BLM's Technical 
Handbooks as an approved method on this subject. 

'Those of us in the family ranching business are range managers by 
definition, we understand the concepts of suitability as it is 
intended by the Science of Range Management, and we and our BLM 
range conservationist consider these concepts during the 
development of our allotment plans. The on the ground management 
oi our allotments reflects these and other principals of 
vegetation and livestock management. 



31.2 



But the information in Table 3-5 is at best, an unreliable 
estimate with respect to the suitability of the allotments in the 
Table, and at worse, are wrong. Neither the public nor the 
ranchers are well served by information in this Table because it 
portrays a situation that is not supported by a procedure that 
represents the state of the art on this subject. 

On behalf of our permittees, I am asking you to remove this 
Table, and all references in the Draft to this Table, from the 
Final Grass creek RMP. Please also provide a narrative in the 
Final RMP that fully explains to the public the technical reasons 
why this Table is being removed from the RMP. I am also asking 
you to provide written assurance to me that no Bureau employee 
will consider or use in any way, the information from this Table 
in the development of new allotment plans, or in the revision of 
existing plans. The norland State Grazing Board will continue to 
convey to our permittees the importance of considering the 
current state of the art concepts of suitability in the 
development of allotment grazing plans, we would like your 
assurances that your employees will do likewise. 

on another matter, I would like to offer the support of the 
worland State Grazing Board to the request you recently received 
to hold a public Hearing on this Draft Plan. A public Hearing 
would provide an appropriate forum for permittees and others to 
convey to the Bureau a level of detail not usually conveyed in 
written comments on a document of this type. It would also allow 
the public, local politicians, and the Bureau an opportunity to 
themselves hear the concerns of their neighbors. 

Thank you for considering these concerns. Please contact me at. 
your earliest convenience with your response to the items in this 
letter. Please also send a copy of your response to Dick Loper at 
the Lander address shown above. 



J£uJ<S?-^L 



Frank Rhodes, Chairman 
Hamilton Dome, Wyo . 82427 



IbCEIVtD 




32 



March 3, 1995 



Mr. Bob Roes, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worland, WY. 82401 

Dear Mr. Ross, 

1 have read your draft Grass Creek Resource Management Plan and 
want to express ay support for alternative C. 

I am pleased to see that under all alternatives except B you 
propose to close roads in forested areas after they have served 
their intended purpose, i.e. forest products harvests. The main 
objection I have to building new roads is that politically and 
practically they are often difficult to close and thus remain open 
to vehicular access, resulting in a net loss for wildlife. Please 
hold your ground on this one. 

I hope you will continue to address non-point soil erosion problems 
as you have proposed in the plan. Watersheds contained within the 
Resource Area, particularly the Fifteemaile, provide a considerable 
amount of sediment to the Bighorn River . This sediment i s 
contributing to decreased fish habitat and water quality within the 
lower Bighorn River and upper Bighorn Lake- 

Although I cannot specifically locate it in your plan, I have heard 
some concern expressed in the newspaper by an individual alluding 
to the affects of predators on sage grouse. I hope you are not 
duped into more predator control on our public lands. Excessive 
predation to wildlife can usually be traced to lack, of quality 
habitat. Keep the habitat intact through proper land management 
practices and wildlife populations will respond favorably. 

I want to complement you on a thorough and well thought out plan. 
Although I favor alternative C, I would endorse your preferred 
alternative as a strong second choice, 



"^ 



James T. Peters 




FAX NO, 13075467823 



Statec Department of the Interior 

NATIONAL PARK SERVICE 

BIGHORN CAP YON NATIONAL RECREATION AREA 

20 HIGHWAY 14A EAST 

LOVELL, WYOMING 83431 



A3S15 

March 3, 1395 

Mr. Bob Rosa, Team Leader 
Buroau of Land Management 
P.O. BOX 119 
Worland, wy. $2401 

Dear Mr. Roes, 

The following comments represent ; 
Park Service. 

Hfttiohol Natural Landmarks (potential) are adequately addreKKpri and we 
nupport the preferred alternative. 

We wish to bring to your attention that there may be areas that, were asEiEted 
in part through too Land and Water Conservation Fund (L1WCF) grants 
program that may be impacted by the Graan Creek Resource Area Management. 
Plan. We recommend, that you contact the State Liaiaon Officer who i* 
responsible for the administration of the LftWCP in Wyoming to determine ir 
the areas are subject to provisiona of section 6(F) of the L1WCF Act, as 
amended. Hie name is Gary Stephenson, Administrative aervices Divj«on, 
Department of Commerce, Barrett Building, Third floor North, 2301 Cuntrnl 
Avenue, Cheyenne, Wyoming 82002. Mr. Stephenson or John Sedgwick, Grants 
Offtoer (aame address), at (307] 777-6530 will be able to auuiat or inform you 
of the proper procedure for compliance under the LiWCF Act, if neceecary, 

Wc are generally pleased with the «tep« you have propoeed to reduce erosion 
and the amount of waterborne sediment which ultimately ende up in Bighorn 
Lake, We thank you for the opportunity to comment on your draft Graaa 
Creek Area iteaource Management Plan. It IS a comprehensive document which 
should serve as a useful guide in managing the natural and cultural 1 
under your care- We support your preferred alternative. 




maolidated response from th» National 



<&<:*&£ 



n.il Recreation Area 



307 



HMD Of roomy COUBSOU 

lolu J liamnjtr CLurmjn 
lairio t Junoslont. lire Chiiroui 
JJl £it3ctkv Swim baannwe; 
9c 7. 3iurdulJ, DsmmisnoBtr 
It) E tfopdr Comamniirr . 



m si 




34 



gURUUCFUWDKASABaiEKT J 

Darrell Barnes. District Manager 
Bureau of I .and Management 
PO Box 119 
Worland. Wyoming 82407 



RK: Gross Creek Resource Area Management Plan DEIS 



Dear Mr, Barnes' 



Tbfi Park County Commissioners, on behalf of Ihc citizens of Park County, request that a 
public hearing be held concerning the (irass Creek Resource Area Management Plan DEIS prior 
to April 7, 1995. Wa believe thai public hearings can provide critical input and identify issues, 
concerns, and information that might not otherwise be provided through small group discussions, 
individual meetings, open houses, and written testimony. Public hearings, even with the limitations 
that migh! be inherent to the hearing process, allow individuals an opportunity GO consider 
information, concerns and comments provided by other members of the public, and encourage 
discussion ami the resolution of problems. 

Thank you for your consideration in this mailer Wc believe thai through the public hearing 
process we can resolve differences and implement a plan for the Grass Creek Area that is supported 
by the citizens of Park County and results in the best possible management of our public lands. 

Sincerely, 

BOARD OF COUNTY COMMISSIONERS 

PARK COUNTY, WYOMING 




Charles w, Johnstone, Commissioner 
Jill ShOeXloy Siifeihs, Commissioner 
Jay R. Moody, Commissioner 



■3u; ■'.AT-Mo-l.bM.MO 



wiiuam -ai-i* OuUH Own 

ALICE LASS. UrnntH 
VALE 'JOHN- OEVT Mvnbti 
HAHOLO COE, Mwnb* 
STEVE TROLLEY Wwnb. 



WASHAKIE COUNTY COMMISSIONERS 
Dnilum i 

p.o •. ^RECEIVED 

WORLAMD. WYOMING B2401 

95 MR -9 AH 8:38 
BLM WORLAND D.O. 



5 



Phanf.)307> 347-6491 
F*» Phon. (3071 347-9366 



rch 7, 1993 



: ,#"■ ' 



Bureau of Lana 1*rtJ0^reWint'.^r~": , .'-V.: 
Joseph T. vessel* 'u:;' ?•'■''::■..■ '■'•'' ' - : „ 

Grass Creek fi-tj' H)ftia(ife'r-i 

P. Q. Bo* ! 19 ' :'•!":'. :il 

Worland, WY B&kill"::'. :' .:".; ;''"• 

Re: Grass C'Mk; M^tjW*K=nr . BJiji 







' *'•' 



urtiffrpus calls 



Eecnemic loic^r t. S' . 

He- »ili look f^rr-.i.^ ; ii" r -"" 



wyM .i copy of tne 



?rie '-&«s "■■&•*(< M"*n«Berttit Plan. 
*^^^9 : ''t*rtt¥lcl. by the Bureau 
r.lrtu^hl o«rW>ji' ; ;'bo*»tnt P»riorl" 








I" 

:JH.4$ 



CHIEF WASHAKIE 



36 



3/9/95 



ROBERTS HO ME CARP. 



[(xxx) xxx-xxxx] 
[xxxxx (xxx)xxx -xxxx] 



XXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXXXXX 



I request that BLM protect Red Canyon, Bighorn River and The Badlands from oil 
Dclvcopment. Also the Badlands should be designated ACEC because of its beautiful views. 

Protect All Areas included in Conservationists Alternative including lands outside the 
WildErness Study. 

Do You have kids? Do You want them to be able to enjoy Wilderness Areas? I do 
and 1 want my kids to enjoy theses areas also, lets protect them! 

Sincerely 
Mary Roberts 



37 



Bob Ross, Team leader 3/8/95 

Bureau of Land Management 

Box 119 

Worland, Wy. 82401 

Dear Mr. Ross: 

I was deeply distressed, as a 37 year resident of the State of Wyoming to read of the 
draft management plan for the Grass Creek Resource Area which allows for 100% of the 
area to be leased for oil and gas development, and without adequate protect (in terms of 
mangement) for the 3 areas designated ACEC. 

I have, as a former Summer employee of the U.S.F.S., alwa ys defended and 
promoted the concept of multiple use of public resources, but your plan (that permits almost 
uncontrolled oil and gas development) falls short of that concept. 

Specific changes in your proposed plan that would protect and promote the larger 
public interests should include: 

one - Protection from oil development in the Absaroka Foothills, Badlands, Bighorn 
River, and Red Canyon Creek -SRMA areas 

two - Badlands (SRMA) should be designated ACEC (scenic area-and fragile soils). 

three - Greater protection management) should be included in your plan in areas 
outside of your proposed plan that presently constitute significant use and value to 
recreationalists, education potential (archeological sites, etc.) and scientific research 
(geological, elc), 

I have, as a retired Educator in Wyoming Public Schools, always defended the role of 
management and protection of public lands by the BLM and other Government Agencies. I 
sincerely hope this support and faith has not, over the years, been misguided. 

Thank you for the opportunity to express my concern and input over this critical 
issue. 

Sincerely Yours, 

/s/ Gerald J. Kresge 

Gculi! J. Ktmr* 

"T'Piinflflfflriii HffHT*rn*f 



308 



tiCitVIO- 



If UU Of UM MIMOIEKT 



38 



March 9, 199J 

Bob Rr*s, Team Leader 
Bureau of Land Management 
P.O.Box US 
Woriand. Wyoming 81401 

Dear Mr. Ross; 

We are concerned wilt the new plans allowing the possibility of pi and oil development in the Grass 
Creek Resource Area of Wyoming. We believe the Badlands Special Recreation Management Area 
should be designated an ACEC (Area of Critical Environmental Concern) also, and we are worried that 
even this ACEC designation does not have sulridcni 'teeth' lo truly protect these special areas. 

We urge that the Badlands. The Bighorn River area, the Red Canyon Cnsi area, and the Absaroka 
Foothills area all be protected from oil, gas, or other nrining devdopmeol One hopes that our nccd-and- 
greed for oil docs not destroy for all eternity these ipeeial segments of our amroraneni, 

We urge lhat ihc Conservationists' Artemobve to the BLM plan be heeded, uxaudtng for binds outside the 
WOdemess Study areas, and that these ideas be taken into account in long range plans for any oil. gas, or 
mineral development, other land use, at coniirmed overuse by grazing. 

Thank you for bearing our views 







M AUcn and larnily 



HECEIVEP 



Ml* 1 31995 

Dear Mr . Roes : 



39 



10 March 1995 



ThHKe are coaiments for the Bureau of Land Management ' « 
Grass Creek Resource Area. Changes to the plan should include: 

1) The Absaroka Foothills, Badlands, Bighorn River and Red Canyon 
Creak Special Management Areas (SRMA) should be protected from 
oil development. 

2) The Badlands SRMA should also be designated on Area of 
Critical Environmental Concern (ACEC] because Of its spectacular 
scenic beauty and fragile soil. 

3) Protect all areas included in the Conservationlgt ' Alternative 
to the BLM's wilderness Proposal Including lands outside 
Wilderness Study Areas. 

Thank-you fo^ your attention to this important matter. 



yaiciivso^ 



Ml 81 



Mirrf. 10 JlW 



■ami BF uap g-irt"" 



40 



Bob Ross 

Bureau of Land Management 

POBox 119 

Wnrland Wyoming 82401 

Mr. Ross: 

I am writing to you concerning the Bureau's management plan lor Grass Creek Resource 
Area. I am very concerned about the plan and strongly disagree with its com ems. Put in 
general terms, the fact that it allows for 100% of the area lo be leased for oil and gas 
development poses a serious danger to the environment and therefore to ourselves. 
Specifically, I would ask that you seriously consider making the following changes in your 
management plan: 

• The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas should be protected from oil development. 

■ The Badlands Recreation Management Areas should also he designated as an Area of 

Critical Environmental Concern because of its unique, natural beauty and very 
fragile soil. 

• All areas included in the Conservationists' Alternative to the Bureau's Wilderness 
Proposal should be protected, including lands outside Wilderness Study Areas. 

• Define goals to deal with overgrazing problems in the resource and plan for those 
goals to be met in the next five years. 

Thank you for considering my thoughts, t hope that you will keep in mind that our 
environment is not an endless resource, and that its depletion and destruction has a 
powerful affect on us. In the short run it may seem easier CO rip up the earth to gain oil, 
gas, limber, etc., but in the long run we'll suffer from ruining 
with. 

Sincerely, 



the land wc must live C 



Qjj-uJrt 




41 



March 10, 1995 



Bob Ross, Team Leader 
Bureau of Land Mgt 
P.O. Box 119 
Worfand, Wyo 82401 

Mr. Ross 

We are writing to ask for che following changes in the BLM Bighorn Basin Plan- 
Grass Creek Resource area. 

We would like the following changes made in the management Plan: 

1 . Trie Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek 
Special Recreation Management Areas should be protected from oil development. 

2. The Badlands SRMA should also be designated an ACEC because of its 
spectacular scenic & extremely fragile soils. 

3. Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal - including lands outside Wilderness Study areas. 

4. Finally provide more definite goals to address the problems of overgrazing in 
the resource area &. provide a timeline to accomplish those goals in the next 
five years. 

(over) 
Please respond to let us know what action you are taking. 

/V Mrs. M. Temple 

I si (Mr.) C Temple 
fit Mrs. S.M. Temple 

XXXXXXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXXXX 



When oil companies develop an oil Seld-they put up signs that say "Keep Out" Poison gas 
area. This means that is no longer public land because no one can use the land including the 
wildlife. 



309 



4?' 



Sydney Walter 

XXXXXXXXXXXXXXXXXXXXXXXXX 

xxxxxxxxx xxxxxxxxxxxxxxxx 

3-11-95 
Dear Mr Ross- 

The Grass Creek Resource Area deserves comprehensive protection. 1 hope you will 
protect all areas included in fhe Conservationists' Alternative to the BLM's Wilderness 
Proposal, including lands outside the WSA's. Especially, the Absaroka Foothills, Badlands, 
Bighorn River & Red Canyon Creek SRMA's should be protected from oil development. 
The Badlands SRMA should be designated ACEC. Definite goals to address overgrazing in 
the resource area should be developed & implemented. 

/s/ S. Walter 



RECEIVED 



MR 1 AB95 



eUKAUOFLAMDIUNMElUT 



nob Rose, Team Leader 

BLM 

P.O. Box 119 

Norland, wyo. 82401 

Kr. ROBHl 

I am writing concerning Chs BLM's draft management 
plan for the Grass Creek Resource Area of the nigHorn 
Basin. Tn my opinion there are many serious problems vith 
this plan, especially since this is the land of all of the 
people to be protected far into the future for all of the people 
not to be a money-mafcer for the few. 

I believe the BLM should withdraw the Absaroka foothills, 
Badlands Red Canyon CreeK, and Bighorn River Special Recreation 
Kanaqement areas as well as the proposed Mecteetse Draw, 
Upper Owl creek and Fifteenmile ACaC's from all oil and 
gas leasing due to the sensitive nature of these areas and 
the inadequac y of the proposed stipulations. 

The BLM ahould protect ajjl areas included in the 
Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside the Wilderness Study Areas. 

The BLM ahould provide more definite goals to address 
the problems of overgrazing in the resource area, and provide 
a timeline to accomplish those goals in the next five years. 
The BLM should also improve range condition to encourage 
ecosystem health and biodiversity. 

And last, the BLM should definitely limit off-road 
OHV use to EXISTING ROADS AND TRAILS as proposed, but p_rohib .it 
their use from roadless areas, ACEC's and WSA's. And the 
e nforcement of motorized use restrictions should be increased 
to prevent further degradation of highly erodible soils. 

Thank you for seriously considering these vital issues! 



-fflgi*. yf yl\^ 



44 



March 10, 1995 

Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming 

Mr. Bob Ross, Team Leader 

Re: The BLM's Bighorn Basin Plan 

1. I think the Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
special Recreation Areas should be protected from oil development. 

2. The Badlands SRMA should be designated an ACEC because of it's fragile soils and 
spectacular views. 

3. In the Conservationists' Alternative *~to the BLM's Wilderness Proposal, protect all 
areas outside the Wilderness Study Area 

Thank you very much 



/s/ Greg Schiller 
xxxxxxxxxxxxxxxxxx 
xxxxxxxxx xxxxxxxxx 



MAR 1 A 1995 



BUEAU OF LAND UAIIAIEMENT , 



Bob Ross, T>am Leader 
Bureau of Land Manaqamt-nt 
P Q BDX I 19 
Worland, Wyoming 82'*0l 



March 11, 1995 
McLane Downing 



45 



Subject: Bighorn Basin Draft Management Plan 



in the draft plan 



'ould like the following c 

Protect the Absarotta Foothills, Badlands, Bighorn River, and Red 
Canyon Creek Spocial Recreation Management Areas from oil and gas 
development . 

Designate the Badlands Special Recreation Management Aroa as an A 
of Critical Environmental Concern. 



Uti'ii'e the Conservationists' Alter nat 
Proposal . 

Include goals and a timetable for addressing 
resource a red. 



truly yours 



the BLM Wi ldorness 



310 



Bohert h. schntkier, p.e. (Cu. c-9431) March 9j. 

Civil Engineer 



Bob Ross, Team Leader 
Bureau of Land Management 
PO Box 11 9 
Worland, Wyoming 



AS 




101 1 CalleLeiuo 

Sama Fc. ta Mexico 87501 

(505)983-1013 



Dear Mr. Ross: 

BLM's Bighorn Basin Plan, calling for massive oil and gas developments, if implemented 
would permit virtually uncontrolled oil and gas development in this most beautiful part of 

your state. The following changes need to be made: 

1 ) The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas (SRMA) should be permanently protected from 

oil development; 

2) The Badlands (SRMA) should also be designated an ACEC because of its spec- 
ular scenic and extremely fragile soils; 

3) Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal, including lands outside Wilderness Study Areas; 

4) Provide more definite goals to address the problems of overgrazing in the 
resource area and provide a timeline to accomplish those goals in the next 

five years. 



Sincerely yours, 



J>. 



Robert R. Schneider, PE 



47 



12 Mar 95 

Mr. Ross, 

[ am writing to you in regards to the draft management plan for the Grass Creek 
Resource Area. 

I believe the Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek, 
Special Recreation Management Areas (SRMA) should be protected from oil development. 
In addition the Badlands SRMA should be designated an ACEC because of its uncommon 
scenery and its extremely fragile soil. 

Protection of all the area included in the Conservationists Alternative to the BLM's 
"Wilderness proposal including lands outside the Wilderness Study area. 

Finally, more definitive goals need to be made to address the problems of overgrazing 
in the resource area and provide a timeline to accomplish those goals in the next five years. 



Sincerely, 

lil Timothy E. Cowley 

XXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXXXX 



I MAR I 51996 



48 



March 14, 1995 

Bob Ross 
Team Leader 
Box 1 19 
Worland. WT 82401 

Dear Bob, 

I am writing this letter to comment on the Draft Management Plan for Grass Creek. I 
must say that I was very disappointed that no alternative was developed that didn't 
include leasing all the resource area for oil and gas development. In fact I can't see 
much difference betwen the preferred alternative and the others. 

It seems to me that a Conservation Alternative could be developed that includes these 
points: 

Off-road vehicles need to be limited to existing roads and trails and specifically excluded 
from roadless areas, ACECs and VVSAs. You certainly wtll find support among livestock 
interests fort such a condition. 

Improve range conditions by incorporating time limitations on use. There are serious 
problems out there with erosion. 

Withdraw several areas from all oil and gas leasing. Some areas are |ust too sensitive 
especially in light of the inadequate protection offerred by the proposed stipulations. 
These areas include the ACECs of Meeteetsee Draw. Upper Owl Creek and Flfteenmile 
Creek. Also, Badlands Red Canyon Creek. Absoraka foothills and the Bighorn River 
Special Recreation Management Area should bt withdrawn. 



Thanks for your canst deration of rhcee points. 




49 



Phillip M Floyd family 
xxxxxxxxxxxxxxxx xxxx xx 
xxxxxxxxxxxxxxxxxxxxxx 

Please make the following Changes in your draft management plan Tor the Grass Creek 
Resource Area. 

1. Having been to these following areas numerous times they should be protected 
from oil development. Absaroka foothills, Badlands Bighorn River & Red 
Canyon Creek (SRMA). 

2. Badlands SRMA should be designated ACEC for both scenic & geologic 
reasons 

3. Support and protect all areas in Conservationists Alternative to HLM 
Wilderness Proposal-outside of WSA 

Thankyou, /s/ Philip M Floyd family 



311 



§0 



2-13-95 

Bob Ross 

Team Leader 

Bureau of Land Management 

P.O. Box 119 

Worland, WY 82401 

Dear Mr. Ross, 

Regarding your draft management plan for (he Grass Creek Resource Area I would 
like to make the following comments: 

1. The Absaroka Foothills Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas should all be protected from oil development. The Badlands 
area is especially fragile because of its thin (and sometimes on a crust) soils. 

2. Please provide goals and a timetable to meet them regarding overgrazing within 
the resource area. 

3. Protect all areas included in the Conservationist's Alternative to the BUVTs 
Wilderness proposal including lands outside Wilderness Study Areas. 

Sincerely, 

Is! Gary Simpson 

Gary Simpson 

xxxxxxxxxxxxxxxxxxxxx 

XXXXXXXXXKXXXXXXXXXXX 



51 



Norma Cole 

Rt 86 Unit 17 Bi 8 

MonticeUo, KY 42633 

Mr Bob Ross, Team Leader 
Bureau of Land Managment 
POBos 119 
Worland, Wyoming 82401 

Dear Mr. Ross 

I just finished reading Elinor Pruitt Stewarts letter in which she details the beauty of 
the Bighorn Basin as a settler in the early 1900's. Much of the pristine beauty she describs 
must surely be lost, but that doesn't man we should destroy what's left. T oppose 100%, 
latere faire system of development of oil & gas reserves - surely a less destructive method 
could be developed. I feel that it is the duty of Land Managing to manage not destroy - 

Sincerely 

til Norma Cole 



B2 



March K, 1995 



John Spezia 

XXXXXXXXXXXXXX 

xxxxxxxxxxxxxx 
xxxxxxxx 



Bob Ross, 

I am writing in regards to the BLM Bighorn Plan that is allowing a 100% 
leasing of all the area to gas & oil. 

I have spent a fair amount of time in this area to know now fragile and 
important it is to the wildlife & local communities. 

*- Your Grass Creek plan to lease all the area for oil & gas seems unreasonable. 

2- You should protect the SRMAs of the Badlands, the Absaroka Foothills, Red 
Canyon and the Bighorn River itself. 

3- There should be no. oil development in each of the above areas and the 
Badlands themself should be designated an ACEC to protect its special qualities & 
fragilities. 

4- Consider wilderness are periphery impacts 

5- Develop a better AMP for grazing without damaging the resources & riparian 
areas. 

Sincerely, 

/s/ John Spezia 




53 



March I? ,1995 

Bureau of Land Management 

P.O. Box 119 

Borland , Wyoming. 82401 

Gentlejnen: 

Wo are writing to aak that you act to 

protect the Grass Creek Resource Are* from 

encroachment by Oil and Gas development. 

This Beautiful area of Wyoming must 

be preserved for future generatina to «njoy. 



Doro 

2o 



lol&l 

U.^O^yrJt 1A 



Dorothy Mic] 



77)AcJltA 



312 




f OF WYOMING 



RECEIVED 



m\ 5 BBS 



m 



eU«AU OF LAND UAKMEHENT 



Department of Environmental Quality 

Harschlar Building » 122 WesT 2 5th Street » Cheyenne. Wyoming 82002 



4 D« I NITRATION ArtANDONKDMNtK " AIH QUALITY INDUSTRIAL Si~ING '.AkO OUAUTY 
aOTfJTT.ITM (307: 77»-«1« 130717777331 IMTJT777MS [3071777-77511 

FAX 777.7602 I AX H4-07M FAX 7777BBJ FAX 777 <i937 FAX (134-0739 



FAX 777-5973 



■land. District. Office 



RE: Criio Craak Honoured Area., Cooourco Eanagamont Plan Draft BIS 

Dear Mr Rose; 

Phil Ogle of the Water Quality Division [MOD) reviewed the. above referenced 
Environmental Impact Statement [FAS) and provided comments, which are presented 
in the following paragraphs. Tiiank you for the opportunity to comment. 

The wqd agrefin that u would be beat to select a management plan alternative that 
will reduce the amount of erosion and sedimentation below estimated 1390 levels. 

Bcooyotw* and Ecosyatea Management , page fl: watersheds should be considered in 
ecosystem management plans for the Resource Area to factor in Wit*? quality and 
riparian area management. All of the waterBheds within the Grass Creek Resource 
Area drain to the Big Horn River an important water 



in the Big Horn 






ally. 



Davalopaant of Mitigation Needs, page B and labia 3 pagoa 78-B3: no specific 
management practices or mitigation measures are listed for use when eurface 
disturbance activities are allowed. Some indication that measures will be put 
in place to control orooion and Eedimentntion during surface disturbance and that 
areas will be revegetated toll owing the disturbance should be given in the 
document . 

Tabl« 10 BSE AND CI.ASSlrrca.TIOH OP STREAMS TM TUB PLANNING ARRA, pog* 129; the 

-JEO classification, tor several streams in the table, is incorrect. The correct 
classifications according to chapter I of the Wvorr.ir.a. W ater Quality Rules and 
■i pecu lations are a3 follows: 

Fivemile Crash 3 

Tenmile Creek 3 

Fifteenmile Creek 3 

Gooseberry Creek. 2 
(Above and below Wyoming 120) 

Coal Draw 2 

Sand Draw 3 



54.2 



Mr. Ross 
March 14, 1995 



yifteaaaila t»at< 
make the Fi f teei 
(ACBC> . The i22i 
Creek 



•d Proposad ACBC, page 151: WQD agrees with the proposal to 
e Creek Watershed an Area of Critical Environmental Concern 
■rvorainc Water Quali ty A»geesment indicates that Fitteervr.i'.e 
ly partially supporting uses as a notigame fishery and for livestock 
and wildlife watering. The stream is being impactad hy aediment/silt , salinity, 
total dissolved Bolide, pesticides, and nutrients . The DEQ stream clarification 
for FifLeanmile Creek and tributaries is presented below for your information: 

Fif taenmile Creek 3 



Crooked Creek 
Dry Cottonwood Creek 
Rock Waterhol« Creek 
Wilson Spring Creek 



Sincerely , y 

Director \S 



^WA 



Departmunt of Environmental Quality 
DH/PRO/b/SllfiS.ltr 

CC: Mary Adamy 

File 95/90-OBla 



ii 



March 13 '95 
xxxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXX 

Bob Ross, Team Leader 
Bureau of Land Management 
P. O. Box 119 
Worland, Wyoming 82401 

Dr. Mr. Ross: 

I am writing regarding the recently released draft management plans for the Grass 
Creek Resource Area. 

This plan, as proposed, has a laizze faire system of management which allows for 
100% of the resource area to be leased for oil and gas development. 

Although the plan designated 3 arcs of critical environmental concern the management 
in these area is not strict and carefully enforced in order to protect the area. 

I would like to request these changes in the management plan: 

(1) The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 
2) 

Recreation Management Areas should and must be protected from oil development 

(2) The Badlands SRMA should be designated as an Area of Critical Environmental 
Concern. The spectacular scenery &. fragile soils of this area make it a candadate for 
ACEC. 

(3) Protect all areas included in the Conservationists ' Alternative to the Bureau of 
Land Management's Wilderness Proposal, including lands outside Wilderness Study Areas. 

(4 Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish these goals in the next five years. 
Please give this your conscientious attention. 

We realize there are conflicting solutions pulling at you. But wc know you care. We 
are counting on you. This is a critical time. 

Sincerely, 
/s/ Dorothy Coxey 
Teacher, Mother, One who Cares 



56 



3-13-95 

Dear Mr. Ross, 

We are concerned about the BLM plans for the Grass Creek Resource Area in 
Wyoming We do not believe in opening this are for almost unlimited oil and gas 
development. The BLM is entrusted with preserving this land for future generations, not in 
benefitting corporate profits! 

We strongly support protection of all areas included in the Conservationists' Alternative to 
the BLM's Wilderness Proposal including lands outside Wilderness Study Areas. 

Sincerely Yours, 
/s/ Robert E. Hess 

Robert Mess 
xxxxxxxxxxxxxxx xxxxxxxxxxx 



313 



•RECEIVED 



MKI6BG6 



17 



Sob ROSS, Team Leader 
Bureau of Land Management 
P. O. Box 119 
Worlatld. Wyoming 82401 



Dear Mr. Ross: 



1 have spoilt some lime in Wyoming and know that the Grass Creek Resource Area is 
located in one of the most beautiful parts of the stare. With the eastern slopes or the Absaroka 
Mountains, some or the most extensive and impressive badlands in Wyoming, and some magnificent 
rock art, Grass Creek should he considered a jewel of the Bighorn Basin. The diversify of 
Wyoming's habitat— from arid deserts to lush mountain forests— can be viewed from this unique 
resource area. 

It is most disturbing that the current management plan is proposing a laizze faire system of 
management which allows for IQ0S8 of the resource area to be leased for oil and gas development. 
Please consider making the fallowing changes to the management plan u> better protect this 
resource: 

The Absaroka Foothills. Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas {SRMA) should he protected from oil development. 

The Badlands SRMA should also be designated an ACF.C because of its spectacular 
scenic and extremely fragile soils. 

Protect ail areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next live years. 

As the Team Leader for a prominent government agency.it is your responsibility to protect 
the resource for succeeding generations. Should the current plan be adopted, irreparable damage 
to our environment may occur. Please use your authority wisely, 



Qafaij, ft .oiCfi-nancJ 

Betsy A. Leonard 

Environmental Education Specialist 




58 



Bob Ross 

Bureau Of Land Management 

Box 119 

Worland, Wyoming 82401 

Mr . Ross , 

I am writing to you concerning the management plan for Grass Creek 
and the proposed laizze fairc system of management which allows for 
100% of trie resource area to leased for oil and gas development. 
Tn fact, not of the alternatives consider leasing less than 100% of 
the resource area for oil and gas development. 

Although the plan designates three Areas of Critics! Environmental 
Concern {ACF.C), the management in these areas is not BUrtlaiently 
Stringent to better protect the area. 

I suggest the fo: lowing changes: 

1. The Absaroka Foothills, Badlands, Bighorn River, m and Red 
Canyon Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

2. The Badlands SFiMA should also be designated an ACEC because 
of its spectacular scenic and extremely fragile soils. 

3 . Protect all areas included in the Conservationists ' 
Alternative to the BLM'S Wilderness Proposal including lands 
outside Wilderness Study Areas. 

4. Provide more definite goals to address the problems of 
overgrazing in the resource area, and provide a timeline to 
accomplish those goals in the next years. 

If you have any questions or comments T may b«= reached at r.ho 



David Worthington 



yincerely, 

David Worth inqton 



59 



Andrew Jones 

XXXXXXXXXXXJtXXXXXXX xxxx 
xxxxxxxxxxxxxxxx 

Dear Mr. Ross; 

I urge you to limit oil development in the Bighorn Basin 8c support the 
Conservationists' Alternative 10 wilderness designation. 

Sincerely 

1st Andrew Jones 



@© 



March 15, 1995 

Dear Friends, 

Your plans for the Grass Creek Resource Area will mean uncontrolled oil and gas 
development in all that most scenic part of the Bighorn Basin. And I protest! 

I view the whole scenic area as an area of Critical Environmental Concern. Certainly 
I am concerned, is there no end your your ever-increasing encroachments on the national 
lands? 

All the SRMA need to be protected from your oil developments, including those lands 
outside the Wilderness Syudy areas. Then there is the continuing problem of overgrazing in 
the resource areas that you allow. I would like to know when you plan to hall overgrazing. 

Please address my concerns for Wyoming and what is left of its forests and plains and 
badlands and deserts. I care. Sincerely, 

/s/ Norman Johnson 



314 



1 



PAUL SZECSEY 



Protect the Absaroka Foothills, Badlands Bighorn River and Red Canyon From 
Oil Developn. 

Badlands SRMA should also be designated ACEC 

Protect all areas included in the Conservationist's Alternative to the BLM 

Wilderness Proposal including lands outside wilderness study areas. 

Provide more definite goals lo address the problems of overgrazing in the 

Resource Area, and provide a time line to accomplish those goals in the next 

five years. 

Thank you for your consideration. 



/s/ Paul Szecsey 



March 15, 1995 



m I 7 686 



■UBUV OF UWD UJUf EMENT 



62 



U Karch 1995 



Bureau of Land Manaj-emenc 

P.O. Box 119 

Worland, UyniainE 82401 

Desr Mr. Koss; 

He are writing you regarding yc 
for rhp. Gt*«S Creek Resource At 

this plan will permit, virtually 

of the most baautlfui pares of Wyoming. Th 
and auch areas are disappearing. Your plan 



cclei 



led ■ 



nfL 



he Bighorn Basin, if 

rolled oil and gas d- 

beauty belong 

ly adds anoth 



IsaagHtaat plan 
implemented, 



. that vou make changes in your nanaRemeiU plan Co help preserve the 
Creek Area. We propose that the Absaroka Foothills, aadlatids, Bighorn 
and Sed Canyon Creek Special Recreation Management Areas (SRMA) be 
: t (id from oil development. The Badlands SRMA should also he designated 
ia of Critical Environmental Concern because ol its scenic value and 
iely fragile galls- We want you Cfl protect all areas included in tlte 
vationists' Alternative to the 3LM'a Wilderness 1'roposal including 
outside Wilderness Study Areas. Lastly, ue would propose that you 
le more def ir.lt e goals to address the problems of overgrazing in the 
xe area and provide a timeline to accomplish these goals in the next 



help pr< 



cooperation 


to address the 


above 


loping Aneri 


ca'a scenic net 


it ago 



' Thomas I.. Bpanch 



PumelH A. Branch 



RECEIVED | 



m I 7H6 



S/£ 



March 14, 1995 



Bob Boss, Team Leader 
Bureau of Land Manage, 
i' Box 119 
Vorland, WT 82401 



De 



.r Mr. Robs, 



I have some cymments on the draft management plan for 
the Grass Creek Resource Area in the Bighorn Basin. I ftm 
afraid tnat if it is implemented it will allow uncontrolled 
oil and K as development Which will result in irr* parable harm 
to nature. 

Mankind seems bent on conquering every niche on the face 
at tne planet. However, thousands of people are now realising 
that such uncontrolled development is a mistake, and are willing 
to fight, for wilderness. Wilderness on a big scale is essential 
for large ecosystems to exist. The Yellowstone ecosystem should 
connect/out in every direction with other large ecosystems, like 
a giant spider. In a sense, Yellowstone is the heart of all the 
ecosystems of the West. It should connect to the vest to Central 
Idaho. To the East it should connect to the Bighorn River and 
the Badlands- To the north it should connect to the Bob Marshall 
Wilderness and the Glacier National Park. 



or this 
managera 


reason 
ent pis 


I 6 


ncourag 


1 you to mftka 


the following 


: Images 


HOTECT the Abse 
Red Canyon Cr 
from oil Aev« 


rokfl 
«ek 


Poothi 
Special 
ent. 


lis, Badlands, Bighorn 
Re c r a at ion Management 


River 


and 
(SRMA) 


ESIGWATi 
fragil 


the Be 
ity. 


aim 


da SRMA 


" 


an ACEC d 


o to its 


ecolo 


Sical 



PROTECT all areas included in the 
to the BLM' s Wilderness Proposa 
the Wilderness Study areas. 




Gracing in the resourc 



nated, and 



84 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming 82401 

Dear Mr, Ross; 

I am disappointed to see the ELM has not been sensitive to conservation in the 
Bighorn Basin plan. Conservation is not dead in the 90's. Many of us still want to see the 
beaty and diversity of our land and wildlife protected from the endless exploitation by 
economic interests, 

The leasing of the area (100% ! !) for oil and gas development is unacceptable. The 
Absaroka Foothills, Badlands, bighorn River and Red Canyon Creek Rec Mgmt Areas should 
be protected from oil development. 

In addition we are requesting the Badlands should receive a higher level of protection 
due to it's beauty and sensitivity of environment. 

We are further asking you to protect all areas included in the Conservationists 
Alternative to the BLM plan including lands outside the Wilderness Study Areas and to 
address issues of overgrazing in the sensitive areas. 

Please include conservation in your agenda & your plans. 

Sincerely 

Rodd &. Alison McAIpine 



315 



65 



March 13, 1995 



Bob Ross, Team Leader. 

BLM. 

P.O. Box 119 

Worland, Wyoming 82401 

Dear Mr. Ross: 

I grow up in Montana and am familiar with the Bighorns & Absaroka Range. I think 
your management plan is faulty. The Absaroka Foothills, Badlands, Bighorn River, and the 
Red. Canyon Cr. SRMA should be protected from all oil development. The Badlands 
SRMA should be an ACEC. listen to the Conservationists' Alternative & protect all lands 
on their list. 

Furthermore, overgrazing should be stopped by heavy fines or suspension of grazing 
privileges. Some areas should not be grazed at all. A timeline should be established to 
eliminate all grazing abuses within 5 years. 

Sincerely, 

1st Joseph L. DeFlyer 

XXJCXXXXXJtXXXXXX 
XXXXXXXXXXXXXXXXXXXXX 



is 



Robert Turner, E51592 

XXXXXXXXXXXXXXXXXXXXX 
XXXJCXXXXXXXXXXXXX 

March 12, 1995 

Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross & other members of the management plan team, 

I am writing to ask that you reconsider your draft for management of the Grass Creek 
Resource Area in the Bighorn Basin. The plan as currently written will allow for 
uncontrolled oil and gas development in every part of the resource area. I hope that you will 
revise the plan to set aside some of the area as protected from oil &. gas exploration and 
drilling. I do not feel it is necessary to pen up the entire region for resource exploration. If 
a few areas are reserved for their wild and scenic values, the oil & gas that may be there 
will still be there in the future when less invasive techniques of prospecting and extraction 
may be invented. But if these areas are opened up to drilling with attendant additional road 
building, the recreational and biological preserve potentials will be compromised forever. 

This is a very beautiful part of Wyoming. I have only been there once, and while I 
am currently unable to travel, I intend to return to the Bighorn Basin in the next decade as 
part of an extensive photographic scenic survey of the West. I hope that the areas that are 
highlighted in the resulting book will see an increase in recreational use. We have many 
protected mountain and forest locales, but protection of arid lowland and foothills, most of it 
BLM land, has been given short shift. The BLM needs to acknowledge, in every part of the 
West, that these arid and seinni-arid regional have scenic, recreational, and biological preserve 
potential that needs to be given a value as important as, if not more so than, the mineral 
resources that may be there. 

As for cattle grazing, I am not against that use, so long as the number of cattle arc 
kept limited to prevent overgrazing and excessive competition with native fauna, and that 
measures are taken to protect riparian corridors. Any area with fragile soil should get 
special protection from commercial grazing. I hope that the management plan, when it is 
instituted, will have specific goals in it addressing the problem of overgrazing in the resource 
area, with a timeline to accomplish these goals in the next Five years. 

T ask thai the team give careful attention to the Conservationists' Alternative to the 
BLM's Wilderness Proposal, protecting some additional lands outside the Wilderness Study 
Areas. The Special Recreational Management Areas should be protected from oil 
development, and the Badlands SRMA should be designated an Area of Critical 
Environmental Concern because of its scenic and extremely fragile soils. 

Thank you for your attention to my views on this matter. 

Yours truly, l&l Robert Turner 



■* -RECEIVED 



m I 7BB6 



67 



Dear Dob Ross. 

I'm writing this letter in response to the Bureau of Land Management's proposing 
management of the Grass Creek Resource Area in Wyoming. This area has a lot of 
interesting landscapes like mountain forests all the way to arid deserts. I'm concern about the 
possibility of 100% gas and oil development in this area. I would like to see the Absaroka 
Foothills, Badlands, Bighorn River, and Red Canyon Creek Special Recreation Management 
Area (SRMA) be protected from oil and gas development. The Badlands SRMA should also 
be designated an Area of Critical Environment Concern (ACEC) because the area has 
spectacular scenic and extremely fragile soils. Another important area to protect is all the 
areas included in the Conservationists' Alternative to the BLM's Wilderness Proposal 
including lands outside the Wilderness Study Areas. I see one other problem and that is the 
overgrazing of the Grass Creek Resource Area. Maybe you could provide more definite goals 
to address the problems of overgrazing and provide a timeline to accomplish those goals in 
the next five years. The Grass Creek Resource Area is a special place and I think it is worth 
protecting. Thank you for your time. 



68 



Sir. I ask that you protect all areas included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal including lands outside Wilderness Study Areas. Please also 
provide definite goals lo address the problems of overgrazing in the resource area, and 
provide a timeline to accomplish those goals in the next 5 years. Please write us you plans. 
Sincerely fsJ Kim & Donald Fontcnot 



316 





RECEIVED 






WR20 B95 


1 


1UJUAU Of LAUD 6JMUQEMEHT 

MUNB.mMK 






Mr, Boo Ross, Team Leader 
Bureau of Land Management 
P.O. Box 11 9 
Worland, WY 82401 

re: Grass Creek Resource Area 

March 15, 1995 
Dear Mr. Ross, 



I feel the draft management plan for the Grass Creek Resource Area Is flawed. 
Oil and gas development interests are weH served with the proposed 1 00% of the area 
teasing plan. Conservation interests have been Ignored. I recommend the following 
changes in the management plan: 

#1 . Protect the Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek 
Special Recreation Management Areas (SRMA) from oil development. 

#2. Designate the Badlands SRMA as an Area of Critical Environmental Concern 
because of its spectacular scenery and extremely fragile soils. 

#3. Protect all areas included In the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

#4. Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next five years. 



Sincerely, 
Page M. Spahr 



70 



Pear Leader Ross 

I urge you to take the following changes in your management plan; 

1 The Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek Special 
Recreation Management Areas (SRMA) should be protected from oil development. 

2 Badlands SRMA - should be designated an ACEC because of its scenic &. fragile soils. 

3 Please protect all areas in Conservationists' Alternative to BLM's Wilderness Proposal 
including lands outside Wilderness Study Areas. 

4 Provide definite goals to address problems of overgrazing in resource area & timeline to 
do this in the next five years. 

Thank you - Sincerely /s/RE Denmark 



71 



xxxxxxx 

XXXXXXX 

xxxxxxx 



Bob Ross 
B.L.M. 
Worland 
Wyoming 

Dear Mr. Ross. 
I am writing to comment on BLM's Bighorn Basin Plan. 
I ask for the following changes. 

1 The Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek SRMA 
should be protected from oil development. 

2 The Badlands SRMA should be designated an ACEC. 

3 Protect all areas in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Areas. 



Thankyou 



a/ Susan E. Cox 



72 



[Figurative Letterhead with inscription: 

' 'WHEN WE TRY TO PICK OUT SOMETHING BY 
ITSELE, WE FIND TT HITCHED TO EVERYTHING 
ELSE IN THE UNIVERSE. '- John Mult* 



Sue Nash 

XXXXXXXXXXXXXX 

xxxxxxxxxxxxxx 

xxxxxx 

Bob ROSS, Team Leader 
BLM 

P.O.Box 119 
Worland Wyoming 
82401 



Re: Draft Management Plan for the Grass Creek Resource Area. 

I am appalled that the management plan allows leasing 100% of Lhe resource area for 
oil and gas development— and further that the management of the three ACEC's is not 
sufficiently stringent to protect these areas, 

I am asking that the following changes be made to the management plan: 

(1) The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas (SRMA) must be protecled from oil development. 

(2) The Badlands SRMA must also be designated an ACEC because of its spectacular 
scenic value and its extremely fragile soils. 



pg-2 
(3) 

(4) 



The plan must protect all areas included in the Conservationist's Alternative to the 
BLM's Wilderness Proposal, including lands outside Wilderness Study Areas. 
Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next five years. 



Thank you for your serious consideration of these wildlife and wilderness 
conservation concerns from all members of the pubbc who are the owners of this land- 
Sincerely, 

Id Sue Nash. 



317 



73 



XXXXXXXXXXXJUCX 
xxxxxxxxuxxxxx 
March 17, 1995 

Bob Ross 

Team Leader of I-and Management 

Dear Mr. Ross, 

I, as a public citizen and member of the Sierra Club, am so concerned of the 
releasing of public lands to oil companies. They will be devastated. We must protect them. 
That is why they were set aside so they would qoj be used by private individuals or 
companies. 

Please consider this 

Yours truly 

/sJ Doris Dicricr 



BOB ROSS TF.AM LEADER 
BUREAU OF LAND MANAGEMENT 
P. O. BOX 119 
WORLAND, WrOHING B2401 



DEAR MR. ROSS, 



MW20B96 



74 



BUREAU OF UXD KASAflEMfNI 



RE:GRASS CREEK ! 

MY UNDERSTANDING IS.B.L.M'S PLAN FOR THE GRASS CREEK RESOURCE 
AREA, 15 TO BE 100» LEASED. FOR OIL GAS DEVELOPMENT, I HAVE 
BEEN IN THE AREA IN 1981, 120 S. FROM CODY ON A RETURN TRIP 
FROM YELLOWSTONE, THIS AREA IS STILL CLEAR IN MY MIND, AS 
BEAUTY BEYOND DESCRIPTION, THE ENTIRE SHOSHONE, IS A PLACE OF 
SCF.NTC BEAUTY. 

THAT'S WHY IT JUST BOGGLES ONES MIND TO THINK, THE AREAS 
RESOURCES WOULD BE ALLOWED TO BE RAVAGED BY AN OIL OR CAS CO . . 

1 WOULD URGE YOU TO IMPLEMENT AN ALTERNATIVE PLAN, PROTECTING 
ALL SPECIAL RECREATION MANAGEMENT AREAS, FROM OIL fi GAS, AND 
DESIGNATE THE BADLANDS (SRMA) TO ACEC STATUS. 

RESPECTFULLY 

WE THANK YOU FOR YOUR- TIME: 

MR.S MRS. ROBERT E. VOGEL " 



75 



Dear Mr. Ross, 

I feel that the Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek 
special Rec. Areas should be protected from oil development. Areas like this must not be 
destroyed for such a temporary gain as a few car drives. 

Also, overgrazing is a problem in the Grass Creek Resource Area- This needs to be 
solved. A timeline of goals needs to be made, so that the problem will be eliminated in the 
next 5 years. 

Thank you, 

hi Karen Malley 











RECEIVED 




76 


Mffi20896 


HI 


BUREAU Of LAKDIMMEN 


rlarrh IS, 1932 


Soft Seas 


Bureau of L^nd Wanageinoct 


P.O. Box 119 


Worland, WY ai.401 


Dear Mr. Ross; 


1:;:,,^ '° '" k " * hc ' *»•"».*«••. i» «t» *l*. Hem 


The Hb.,rok« Fo.th.lK, »«dl«r«l», E.i,horr, Rw.r Bid Rod 


Th» Bidl.nO. SRHP. .hould b. d..i D r,,t.d .h fir.. ,,, CrUtiC.l 


Environmental Concern becaw of Us soertaclv ^-„.,- Z 
e«tn.»,,ly f r » B ,l. soil.. *""'"* »C.nic and 


Protect all area; included In tha renwrvat 


"""""""'■ »• «!■ BUI', Uildern..» Proposal incluCmo »nd« 
out. idf th. Ulldan-naa,. Study Or.as. 5 ' *" d ^ 


Provido mora, dsfinite goal, to .jddrcu. th. prodlem. of 




Siyt(3ty, 


4^{ \a-A 


Sidney Hi rsFi 



318 




77 



March 17, 1995 



Mi Bob Robs 
BLM 

PO Box 119 
Worlaad WY B2401 



Dear Mr Robb, 



I an writing to you concomi-ng the mansgaaent oC the Grass Creek 
Sasouict Area, and similar nroan in general. I am concerned 
about the e£rects of large ocala oil and gas development in the 
area. 

As the unspoiled natural areas of our nation become more rare, 
tneic uses for other than resource extraction increase in value. 
This is simple economics. Whether for recreation, wildlife 
habitat, waterohed concerns, or whatever, the corporations that 
seek to profit from our public lands do not have a monopoly on 
our diminishing resources. 

Quite simply, we do not need the oil. Wo want it, yes. But 
energy conservation and alternative energy sources are mere 
economical and cost effective and less damaging to the world. 
iou won't hear that from an oil company or a car manufacturer in 
their denial of the need for ch ange. But it is s fact. 
Ultimately, wo will have to find alternatives to oil and gao as 
the diminishing supply drives up the cost . Will our natural 
heritage survive in the meantime? Ad a taxpayer and part owner 
in our public lands, I have a vested intereet in your answer to 
that question. 

.clan offered by such 
litor the ongoing 



I ask that you consider carefully the inf 

groups as Sierra Club, whom: job it is to uuiuwi «**■ uayuiua 

state of our natural resources. And if in doubt, err on the side 

of conservation and not the short tern dosiras of the Greed 

Lobby. 

Thank you for your time. 




Andrew J. Lewis 



RECEIVED 



H&20B95 



BUaEAUOfLWMWHA««EHT 



78 



March 15, 1995 

Bob Ross, Team Leader 
Bureau of Land Management 
P. 0. 11 9 
Worland, Wyoming 82401 



Dear Mr. Ross 

I am writing in regard to the draft management plan for the Grass 
Creek Resource Area. Your proposed plan is unacceptable as it 
stands today. I strongly urge you to make the following changes: 

a) The Absaroka Foothills, Badlands, Bighorn «wr and Red Canyon 
Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

b) The Badlands SRMA should be designated an Area of Critical 
Environmental Concern because of its spectacular scenic qualities 
and extremely fragile soils. 

c) All area's included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal (including lands outside of WSA's) should 
be protected. 

d) Provide more definite goals to address the problems of 
overgrazing in the resource area, and provide a timeline to 
accomplish those goals within the next five years. 

I hope that you will take these steps to avoid the decimation of this 
unique and beautiful region by uncontrolled oil and gas exploration. 
Thank you for your attention in this matter. 




79 



To; Bob Rots, Team Leader 

Bureau of Land Management 

Please address the following changes in the BLM's Bighorn Basin Plan 

- Tne Absaroka Foothills, Badlands, Bighorn River, & Red Canyon Creek Special 
Recreation Management Areas (SRMA) should be protected from oil development 

•The Badlands SRMA should also be designated an ACEc because of its spectacular scenic 
& extremely fragile soils 

- Protect all areas included in the Conservationists' Alternative to the BIJvl's Wilderness 
Proposal including lands outside Wilderness Study Area 

- Provide more definite goals to address the problems of overgrazing in the resource area, & 
provide a timeline to accomplish those goals in the next five years. 

Thank you for your attention on these matters. 

Sincerely, 

li! Sue Stcrnhagen 
SUE STERNHAGBN 

XXXXXXXXXXXXXXX 

xxxxxxxxxxxxx 

XXXXJC 

xxxxxxxxxxxxxx 



R E C EIVED 



WR20B96 



80 



IUIFJUJ CF UNO lANMEMEirT 



Karch 1?, 1995 



Vr. Bob ^so, HIM Tear- Loaflcr 

flox 119 

WorLiTiii, UT B2401 

Dimr Mr. Rosa: 

Re: No oil/gas leasing Orass CrenV Resource Area 

Since change in polities} on-rel tho safety and protection of »en»itiva 
environmental arcae is at staic. The Contract with America is attaching 

our hard won environmental liivs ard assaulting our trreer. lavo. 

Only by carefully protecting tbo Graya Creek Resource Area can wa hold 

tha lino again tit tfea .Invidious invasion of the "WIkg Ukr" antl-enviroiwiant, 

greedy, money frrabbers. 

On tha positive side, improving rango conditions will enoouragO tscoayntem 
health «iuJ biodiversity, of for gra&tor value than ciouey. 



9/W 



Ester Jchanni 



319 



<§> 



Bob Ross, Team Leader 
Dear Bob- 

The draft of the mangement plan for the Grass Creek Resource Area mast be 
modified to protect these beautiful lands, 

No oil development in Bighorn River, Absaroka Foothills, Red Canyon & Badlands 

Badlands is particularly sensitive to exploytation. 

These lands are our God given right and should be regarded as such and no! subjected 
to profit taking by oil, mining and grazing interests. 

Sincerely, 

lit Dan Barberis, 

xxxxxxxxxxxxxx 

XJUtXXXAXXXXXXXXXXXXX 



82 



XXXX X XXXXXX XXXX XX 
xxxxxxxxxxxxxxxxxx 



March 15, 1995. 



Dear Mr. Ross, 

I am requesting the following changes in the mangement plan for the Grass Creek 
Resource Area, since you have not area planned to be free of uncontrolled oil and gas 
development: - 

Protect from oil development the Absaroka Foothills, Badlands, Bighorn River and 
Red Canyon SRMA. 

The Badlands SRMA should also be designated an ACEC because of its spectacular 
scenic value and extremely fragile soils. 

AH the areas in the Conservationists' Alternative io the BLM's Wilderness Proposal, 
including lands outside Wilderness Study Areas, should be included in this protection. 

Come on, you guys, give us a break! 

Sincerely /«/ P.V. Tattcrsall 



M«?0I996 



itldEAU Of LAND KASHfltlitNT 



is 



March 15, 1995 



t'r. Bob Ross 

Bureau of Land ManaBCTTit 

P.O. Box 119 

Worland, Wyoming S24Q1 



1»ar Mr. Ross: 

ii/e are very concerned that the Bureau of Land Managements gsa <v 
oil development plans for r.he Bighorn Basin in Wyoming will destroy 
t'.hG environment, and wildlife in ''.hat area. 

Please do all you can to protect the Bighorn, the Absaroka 
Foothills, ntiri both the Red. Canyon Creek and thn Bacila«ds Special 
^ccreati on ['a^a^ement areas Prortj pas and oil development. 

Wsj sU/r^est that hhfl Bureau of Land Management provide mors 
definite Koals to control over^rsv.i pp; in. these areas (and those 
lqnda outside Wilderness Study araaa) a"d a def ini .te/time (perhaps 
5 years) to accomplish these goals. 

I'.'e will be anxiously awaiting the results of your team's work. 



Sincerely, 

(Mrs , Ann KllngHiiifin ) 



fiyu , tddvuLuJ Kim) , 

t 




RECEIVED 



MAR 2 I 895 



84 



March 17, 1995 



of Land Management 



Mr. Bob ROSS 
Team Leader, Burea 
P.O. BOX 119 
Worland, wy 82401 

Dear Mr. Ross: 

I am writing in regard to the BLM's recently proposed draft 
management plan for the Grass Creek Resource section of the Bighorn 
Basin. This is an area of unique and outstanding natural beauty 
and is a national treasure that should be, as much as possible, 
preserved for the enjoyment of present and future Americans. 

In effect, however, the proposed management plan would open 
this entire area to oil and gas development — without any effective 
restraints on likely environmental degradation. It does not appear 
that the proposed ACECs will be adequately protected under the 
plan. 

I join with others in urging the following changes in the 
proposed management plan: 

l.) Ban oil development in the Absaroka Foothills, Badlands, 
3iqhorn River, and Red Canyon Creek SRMAS ■ 

2 . ) in view 
vulnerability — dee 

3 . ) Set aside for protection a , 1 1 areas recommended in the 
"Conservationists' Alternative to the BLM's Wilderness Proposal," 
including those lands so recommended that are outside the initial 
Wilderness study Areas. 

4.) And, establish more definite strategies and goals so as to 
prevent overgrazing in the resource area, and set up realistic 
timelines for accomplishing such goals during the next five years. 

I feel strongly that this particular scenic, national heritage 
should be protected --for the benefit and enjoyment o£ all its 
owners — the American people — and not given away or sold off on the 
cheap to business and industrial interests that care only about a 
short-term profit. 



320 



85 



PAUL MOSS 
xxxxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXXXXXXXX 



Dear Mr. Ross: 

I would like to make the following comments on BLM's draft management plan for 
trie Grass creek Resource Area: 

1 The Badlands SRMA should be protected from oil development and also should he 
designated an Area of Critical Concern because of its spectacular scenery and extremely 
fragile soils. 

2 AU areas included in the Conservationists' Alternative to the BLM's Wilderness Proposal 
should be protected, including lands outside Wilderness Study Areas. 

3 The Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek Special 
Recreation Management areas should all be protected from oil development. 

4 More definite goals should be provided to address the problems of overgrazing in the 
resource area, and a timeline should be provided to accomplish these goals in the next 5 
years. 



Thank you for your consideration of these comments. 



Sincerely, 
W Paul Moss 





•RECEIVED 


I 




MW2 I B95 




BtlRLAUO: l/<r.f:'.-v;.bi\ 





86 



Bob Ross, Team Leadei 
Bureau of tnnd rtgtuiw 

P.O.Box 119 
Vorl.ind. v WW 



hen; 



I have studied the draft mananenent: plan nnrf would 
tike to ask for the following changes. 
Please designate the 3artlnnds STecl.il Recreatl.on 
Area .is an Ar«a of Critical F.nvirnnmHntal Conrern 
hoca-jsc of it's beauty and it's fragile aolln. 
Protect the Abaarokn Fnothills, the nighorn River, 
Che UAdlands, and the KvA CanyonCreek Special Rec- 
reation Management Areas from oil development. 
Provide more definite Kuala to addreoa over- 
grazing in the area and a ciaellne to accomplish 
tlieee goals within 5 years. 

"roteec all areas included in the ConaervatlonistB 
Alternative to the El.M's Wilderness t'ronoaal tncl-- 
uding landa outside tli« V'ildur^esa SCtuly Arr-.fls . 

Thank you, 



R.E C E l V E 




mi\ B95 


WT 


EAU GF LAND MMUIEM 



87 



Bob Ross. Team Leader 
Bureau ot Land Management 
P.O. Box 119 
Worland. Wyoming 82401 

Dear Mr. Ross: 

I am writing in regards lo the Grass Creek Resource Area in Wyoming. The Grass 
Creek area is most likely one ol the most diverse area of different climates and 
landscapes in the West It deserves a decent amount of protection to preserve its 
condition for generations to come and enjoy. 

I believe that the recent BLM management plan for the Grass Creek Area is too 
lenient on environmental protection. It allows for 100% of the resource area to be 
leased tor oil and gas development There are also no alternatives left to look to tor 
more protection, since they all demand that 1 00% of the Area is to be slated for oil 
and gas drilling. 

I suggest that the following actions should be taken to protect Grass Creek; 

The Absaroka Foothills, Badlands. Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas be totally protected tram oil development (Note that 
the title of these areas is Recreation Management Areas ) Also, the Badlands SRMA 
should be designated an Area of Critical Environmental Concern, since rt contains 
very special scenic places and very fragile soils. 

All the areas in the Conservationist 1 s Alternative to the BLM's Wilderness Proposal 
lands outside the wilderness study areas should be protected. 

Finally there should be a definite plan to deal with the overgrazing problems in the 
resource area, and deadlines should be set to accomplish the plan In the next five 
years 

I hope these suggestions will be of help to you and the ecology of the Grass Creek 
Resource Area. Thank you very much Tor your time. 

Sincerely. 
Mr. Shine Ling 



J^/i'Vie. 




RECEIVED 



wr2 i m 



ir;iAUOn,VMr)^V-".;tGif;.H'l 



88 



March 18. I QU 5 



Mr Bob Ross 

Team Leadei 

Bureau of Land Managemeni 

P.O.Box 1 1*5 

Worland, Wyoming 82401 

Dear Mr Ross 

I am Writing to you as a concerned citizen for one of the mnsr precious and 
spectacularly beautiful areas ufour great country, the Absaroka l-oothills. Badlands. Red 
Canyon Creek and Bighorn River These areas are our National Treasures and should be 
protected Instead, they are in danger of being exploited by oil and gas developers. I urge 
you to protect all areas included in the Conservationists' Alternative to the Rl.M's 
Wilderness Proposal including lands outside Wilderness Study Areas Also, a plan with a 
realistic implementation timeline is needed to stop overgrazing We can't afford to lose 
this most precious of legacies Plea.se do all you can to help! 



1 hank you for y 



10 this most urgent national priority 1 



L ^U*i&^'>^' 



321 



89 



March 18, 1995 



Dear BLM, 



Concerning your plans for the Bighorn Basin's Grass Creek Resource Area: 
It is my understanding that you plan to allow oil and gas leasing virtually anywhere in 
the area. I believe some areas should be protected, such as the Badlands SRMA. 
Also, arc you preventing overgrazing? 
Sincerely, John H. Peck 

P.S. No reply needed, and please do ngj put me on your mailing list to get stuff. 



SO' 



XXXXXXXXXXXXXXX 
XIXXXXXXXXXXXXX 

March 18, 1995 



Dear Mr. Ross: 



I am writing concerning the draft management plan for the Grass Creek Resource 
Area of the Bighorn Basin. I am concerned that too little is being done to protect the natural 
environment of this area. The draft management plan is much t;x) heavily biased towards oil 
and gas development. 

I support the conservationists' alternative to the BLM wilderness proposal and feel the 
management plan should be changed to protect all areas in the conservationist's alternative 
including lands outside the Wilderness Study Areas. 1 would like the Absaroka Foothills, 
Badlands, Bighorn River and Red Canyon Creek Special Recreation Managment Areas closed 
to oil development. The Badlands Special Recreation Managment Area should also be 
designated an Area of Critical Environmental Concern because of its scenic and fragile soils. 
I would also like the problems of overgrazing in the resource area to be actively worked with 
mure definite goals and deadlines for reaching these goals in the next five years. 

Sincerely, 

tsi Gary L Wester! und 



RE C E I V E D 



M»2?BS5 



m 



March 17, 1995 



Mr. Bob Koss, Team Leader 
Bureau of Land Management 
PO Box 1 19 
Worland, Wy. 82401 

RE: Grass Creek Resource Area draft management plan 

Dear Mr, Rose: 

As a visitor to the beautiful state of Wyoming, I read with 
disappointment of the proposed management, plan for the Grass Creek 
Resource area. The long term, and I emphasize long term, economic 
and natural health of this State does not lie in extractive 
industries but in protecting deserving areaB from development. 
Areas of critical environmental concern at the mini mum should be 
afforded protection from gas and oil drilling and its attendant 
despoliation. 

I would ask that all the SRMA and ACEC areas should be deleted from 
use for oil or mineral extraction and development to preserve their 
beauty and delicate environment. In particular, the Badlands SRMA 
should be designated as a ACtiC. 



The long term health and future of the Stat. 
not juat short term extractive needs. 



ust be ■ 




Deceived 



mzzm 



■U EMi tit LAND BMUSEMENT 



92 



BLM 

P.O. Box 119 
Wcrhnd. WY S2401 



Dear Bob Ross, 



) am writing in regards to protest the current management plan for the Grass Resource 
Area of th-e Bighorn Basin. This unique and lital habitat is in danger of being irreversibly 
damaged. I urge you to reconsider the management nlar and take into ccnsioeraiior the 
fefcwfoj revues::; 

-Prsls;: fltt Absaroka FasthiUs, Esdlands, Bighorn Rim, and SRW from til development 

-Oesignate the Badlands SRNV\ as an ACEC 

-Protect all land included In the Coriseratfanists'Afcrnatlvi !c the SUM* W8d«R»SS 

Proposal including the lands outside the Wilderness Study Areas 

■Address !hc Issues ;f overgrazing in the resoles area, s;! goals to remedy ih; 

problems, ana accomplish tnem within 5 years 

Inedestrucnon of this land for tie short term benefits of oil. gas and ceet WWW ce a great loss to 
my g«neration and all generations tc come. As a non-voting citizen, my only miss is through 
letters, l believe (hat the reouests staled in this fetter are siatemems that many would support - 
so please, reconsider your plan, Thank you. 



Sincerely. 



322 



93 



Mar 20, 1995 
xxxxxmxxxxx 
xjuxxxxxxaju 
xjlxxxxxxxxxx 

Dear Mr Ross. 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Managment Areas should be protected from oil development. The Badlands 
SRMA should also be designated an ACEC because of its spectacular scenic value and 
extremely fragile soils. The BLM should protect all areas included in the Conservationists' 
Alternative to the BLM Wilderness Proposal including lands outside Wilderness Study Areas. 
The above changes should be made to the managment plan for the Grass Creek Resource 
Area. 

Sincerely, /$/ Shelley Ellis 



HW22B96 

BUHCAUfJf UWD MrMiEMEHT 



94 



Bob floss, Taara luuriur 
BuruHu oF Land Manseeme 
P . n . B x 119 
WorlonB, rtyotninc, 62101 



Oflsr Mr . Has: , 

rent draft ,TiQnaccmo--t pish c =r t"c Grass Crack rinsouroo Arcn. 1 = 
Implohiunttsd, it will p«rmlt virtually utlDBNtrel AKd oil and can ce- 

vu lupment in this arcj. 1 have travclioc intensively in Wyoming, 

cuOStioll i« undoubtedly cne o* the most beautiful in the stete. 

pun i"=i mineral dsvelapnent, «oul3 be «n unpardonable or i Tie Egainst 
nature. The f ollcwinc il-ari^a* should be mede to your p'. an: 

1. Th« Absal-oka Foothill«, Sedltindtf, Bighorn llvar , onO Fed 
Canyon (J reek Spec vs 1 Pecrest i or. "anapsment Areas ( SRMA ) irust 
be pratec:«d Fron ail development, «nd th»i Badlanc- SRMA also 
Should Lie dttwIgnat^B os Areo of Critical Environmental Con- 
corn (ACEC) seceuce of iic cpecr.ocular poonnry H*r. o>^rwi:fly 
•r«ioilff coil;;. 

2. All iin-Bn included ii zhm Conserver. i onistc Alteraosive to 
t.hn BLM' 1 ?: Wilderness Proposal, including uulsk'u the Wilder- 
ness Stuciy Aree. chculd fc- protectee. 

3. Ma"! deM n: re goals en aOrireon the problem of ov«ryruiiig 
In the rEanurce area should be provided, as well as a tl Tie 
tub la to accomplish the Boats within the naxt Five ["] years. 



S i ncer a 1 y , 



RECEIVED 



mi 22 ! 



95 



Elise Auerbjch 



D Of UNO VAHASE«NT 



Mr, Boh Ruw 

Bureau or 1-and Management 
P.O Bo* 119 

Worland, Wyoming 82401 



Dear Mr. Ross: 

J am writing to you to express my deep concern over the Bureau Of Und 
Management's draft management plan for the Grass Creek Resource Area in 
the southwestern quarter of Bighorn Basin in Wyoming. The plan culls for 
unco nun Med oil and gas development in the Grass Creek Resource Area. 1 
heliuve if this plan is implemented, ii will result in irreversible destruction 10 
ihis unique and beautiful area, which encompasses impressive badlands as 
well as Important rock art. 

1 am very concerned thai the draft management plan allows 100% of Uie 
resource area to be leased for oil and gas development. I think It is very 
important to protect many areas of scenic value and ecological importance. 1 
iherelore propose Irta following changes to the management plan: 

1, The Absaroka Foothills, Badlauds, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas should be protected frum oil 
development. 

2. All areas included in Ihe Conservationists' Alternative to the BLM's 
Wilderness Proposal should be protected, including lands outside wilderness 
study areas. 



3. The plan should Include more definii 

environmental damage caused by overgrazing in the 

should provide a timlinc lo accomplish those goals in Hie 



address the problems of 






I believe thai ibe Grass Creek Resource Area, because it is public land, 
belongs to the American People and should be managed for the good of Ihe 
general public and for fulure generations, and not just for the shon-term 
profits of some greedy oil and gis developers. Thank you very much for your 
attention. 



hJ^_ CLiu_^___ 



96 



Dear Leader Ross; 3/95 

I am writing to express my concern about the BLM draft management plan for Gr ass Creek 
Resource AfWi 1 would like to ask for the following changes: 

1) The Absaroka Foothills . Badlands . Biehom River and £cd Canyon (SRMA should be 

prelected from oil development. 

2) The Brands (SRMA) should be protected and rj esipna\ed an ACEC because of its 
spectacular scenic and extremely fragile soils. 

3) Protect ALL areas included in the Conservationists' Alliance to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Area . s - 

4) Provide more definite goals to address the pjob jsrris of Qyer g ra/.inE in the resource ar ea. 
and provide a timeline to accomplish those goals in the next £ years. 

Thank you, 

/s/ lohn Pampcrin 



323 



8>7 



BLM Team Leader, 



3/21 



In your management plan for the Grass Creek Area, I think you need to protect more 
areas (along with the Meeteetse Draw & Upper Owl Creek) from the damages that 
accompany oil & gas exploration and unrestricted ORV use. 

These places have greater value as they are than they have for what can the taken out 
of them. Plus, the more they are used with out thoughtful restrictions, the more it eventually 
costs us tax payers to fix the damage. 

We all need to learn how to enjoy the public lands without messing them up. 

Extractive industries and ORV users don't seem to have these concerns for protecting 
the resource. Put it in your plan please . 



Tks 



/s/ Gene Bail 



98 



To Whom It May Concern - 

I am writing today in support of the Absaroka Foothills, Badlands, Bighom River, & 
Red Canyon Creek Special Recreation Managment areas being protected from oil 
development. The Badlands should be designated an Area of Critical Enviroment Concern. 
There should be protection of the areas included in the Conservationists Alternative to the 
Bureau of Land Managements' Wilderness Proposal, also lands outside Wilderness Study 
Areas. Lastly, there needs to be goals regarding the problems of overgrazing with a timeline 
of good accomplishment of some in the next five years. 

Sincerely - 

/s/ Pat Woellui 
Sierra Club member 



RECEIVED 



m i a i 



BUREAU OF UUDBAMMEIENT 



§g 



March 21, 1995 



Bnfa Ross 

Team Leader 

bureau cf Land Managpment (BLM) 

P.O. Box 119 

Wo r land, Wyoming 

82401 

Mr. Ross, 

Trie proposed plan to make 100% of the Grass Creek Resource area 
available to lease fnr oil and gas development was recently 
brought to my attention. The lack of adequate protection for 
special management areas here was also brought to my attention. 

The BLM draft management plan does not seem to consider leasing 
ar.y less than lOOfc of the resource area for oil and gas 
development . The plan also does not address the adequacy of 
protection levels for special management areas or Areas of 
Critical Envi ronmental Concern [ACEC) . 

My understanding is the BLM is more knowledgeable about certain 
aspects of land management, like leasing government property for 
grazing, mining, or drilling. Attention to environmental issues 
is also very important. 

To show your concern for the Crass Creek Resource Area, 
include the following changes in the draft management plan in 
croer to protect the area from uncontrolled oil and gas 
development: 

1. The Absaroka Foothills, Badlands, Bighorn River, ana Red 
Canyon Creek Special Recreation Management Areas (SRMA) should 
DC protected from oil development. 

2. The Badlands SRMA should also be designated an ACEC because of 
its spectacular scenic and extremely fragile soils. 

.1. Protect all areas included in the Conservationists ' 

Alternative to the SLM's Wilderness proposal including lands 
outside Wilderness Study Areas. 

t>. Provide more definite goals to address the problems of 

overgrazing in the resource area, and provide a time line to 
accomplish those goals in the next five years. 

If there is a chance that the BLM could look past the prospect of 
oil and gas leasing revenues and include environmental protection 
in the plan, our environment will be better protected, the BLM 
will have served as a custodian with a conscience for the Bighorn 
Basin, and the maintenance of one of the moat beautiful parts of 
Wyoming will have been sustained, nut destroyed. 

el y. 



7* 



1 



Bob Ross 
BLM 

P.O.B. 1 19 
Worland, Wy 82401 

Hear Sir, 

It has come to my attention that the management plan for Grass Creek Resource Area 
provide insufficient protection to the land and its resources. As a citizen of the United 
States, it is my wish to see tins parcel, and all other held in the common trust, protected to 
the fullest extent possible. 

The following changes should be considered and integrated into the management plan: 

1) The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Managment Areas should be fully protected from oil development. 

2) Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal, includin g lands outside Wilderness Study Areas. 

4) Provide more definitive goals to address the problems of overgrazing in the 
resource area, and provide a timeline to accomplish these goals over the next five years. 

I remind you that your primary duty as a government is to the people of the United 
Stales, rjoj to extractive, exploitative industries. Thank you for your attention to this matter. 

Sincerely, 

/&/ Andrea E Gruszecki 

xxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXX 



324 



March 19. 1995 BUMWJ 




101 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worland, WY 82401 

Dear Mr. Ross, 

I am writing to recommend that you make the following changes in the 
draft management plan for the Grass Creek Resource Area in Wyoming: 

• Protect the Absaroka Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas from oil development, 

• Designate the Badlands SRMA an Area of Critical Environmental Concern 
because of its spectacular scenic and extremely fragile soils; 

• Protect all areas included in the Conservationists" Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas; 

• Provide more definite goals to address the problems of overgrazing in the 
resource area, and provide a timeline to accomplish those goals in the next 
five years 



Thank you for your consideration of these items. 



Sincerely, 



D.JDeProspero 




United States Department of the Interior 

FISH AND WILDUFE SERVICE RECEIVEC] 
ECOLOGICAL SERVICES .-„,... . 

4000 Morrie Avenue S3HAR23 '•» 8= 53 

Cheyenne, Wyoming 82001 yt_h i'/th\L/wJQ U 



102 



ES-6141J 

MEJ/W. 02(gcrmpba. com) 



March 19, 1995 



Subject: 



Area Manager, Bureau of Land Management, Grass Creek Resource Area, 
Worland, Wyoming 
Attn: Marian Atkins 

Wyoming Field Supervisor, Ecological Services, Cheyenne. Wyoming 

Draft Environmental Impact Statement on the Grass Creek Resource Area 
Resource Management Plan (Draft Statement) and Biological Assessment 
(Assessment) for Draft Statement 



Thank you for the opportunity to review the subject documents. The U.S. Fish and Wildlife 
Service (Service) was forced to delay its response to the Assessment pending receipt of 
information contained in the Draft Statement. We apologize for any inconvenience. My staff 
has reviewed the Assessment, as well as the Draft Statement and offers the following 
comments. 

OIL AND GAS 

The Service is concerned with designating nearly the entire area open to oil and gas 
development rather than identifying certain sensitive and valuable areas as administratively 
withdrawn. While the analysis and development of site specific protective stipulations is meant 
to occur later in the process, typically, the analyses that occur prior to leasing decisions are 
based on inadequate data and are generally deficient in cumulative effects analyses, if done at 
all. Often the stipulations attached to oil and gas leases are insufficient to adequately protect 
fish and wildlife resources. For example, traditional timing restrictions provide little long- 
term protection for wildlife, since the restrictions are usually imposed only during exploration 
and development, while the impacts to wildlife continue to occur through production. The 
Service did note the Draft Statement's explanation that Controlled Surface Occupancy (CSO) 
constraints place limitations on the operation and maintenance of facilities. Since most 
references to CSOs applied to the exploratory phase and required more than 20 percent direct 
surface disturbance, we are uncertain of the extent of protection actually provided by this 
stipulation. Please provide us with more details on the CSO stipulation. 

The Service also remains concerned with the use of No Surface Occupancy (NSO) stipulations 
in place of administratively unavailable designations. Stipulations, including NSO, may be 



102.2 



waived or modified without appropriate review, thus precluding adequate evaluation of the 
environmental consequences. Furthermore, courts have recognized that the issuance of a lease 
represents an irretrievable and irreversible commitment of resources. The Service contends 
that such commitment necessitates adequate review and assessment of impacts that, perhaps, 
should be avoided to fully protect the environment. The discussion of environmental 
consequences resulting from gas and oil activities (page 191 of the Draft Statement) better 
addresscs impacts of restrictions to the cost of exploration and development rather than 
environmental consequences of the action. The Service also remains concerned with the 
Bureau's legal ability to deny development if a site specific analysis indicates unacceptable 
environmental consequences will occur. Please provide us with the opportunity to discuss 
these concerns with you in the near future. 

THREATENED AND ENDANGERED SPECIES, GENERAL 

The Draft Statement provides few details on threatened and endangered (T/E) species. A more 
in depth discussion of the species' occurrence in the planning area and the project's potential 
impacts to them is needed in the Draft Statement. Since the Assessment provides more details, 
we believe it would be helpful to attach the Assessment to the Final Environmental Impact 
Statement as an appendix. This would facilitate full disclosure of project impacts. 

The discussion of listed species' presence in the planning area (page 150 of the Draft 
Statement, as well as throughout the Biological Assessment) is quite limited and somewhat 
unclear, particularly with respect to grizzly bears and wolves, making it difficult to determine 
what impacts are a real possibility, Neither document provides detailed descriptions or maps 
of listed species' distributions or sightings. While we acknowledge that it may not be prudent 
to provide maps of a sensitive nature (such as bald eagle nest sites), it ii unfortunate that 
detailed locational ^formation is presented only for game animals. Please provide the Service 
with more information on the extent, nature, and results of surveys for T/E species. 

More details should be provided to explain why each alternative does not effect T/E species. 
Based on your December 14, 1994, memo accompanying the Assessment, the Service 
understands the Bureau of Land Management (Bureau) has determined the preferred alternative 
will have no effect on any listed species. This determination is not clearly made in the Draft 
Statement. Instead, the Draft Statement indicates there will be "no significant effect." To 
ensure compliance with section 7 of the Act, the statement should be worded to indicate that 
alternatives will have "no effect" or are "not likely to adversely affect" T/E species. While the 
Assessment addresses only the preferred alternative, the Draft Statement provides a very brief 
summary of the environmental consequences to threatened and endangered wildlife species for 
each alternative, but gives no explanation of how these consequences were derived. The 
Service questions how each of the varied alternatives has identical environmental 
consequences for threatened and endangered wildlife species, namely no significant effect. 



102.3 



BALD EAGLE 

1 commend you for your commitment to protect bald eagle roosting and perching habitat by 
allowing no cutting of desert cottonwoods and protecting the Big Hom and Greybull river 
corridors from development on public land tracts. I am uncertain whether only desert 
cottonwoods are used as roosts and perches in the area. If other structures (such as other tree 
species or utility poles) serve as roosts and perches, please explain how they will be protected. 
While the Service concurs with your intention to protect the public lands along the rivers from 
development, I would appreciate more details on how this will be done. Also, please provide 
more information on potential impacts that may result from oil and gas development, 
recreation, grazing, and other land uses along the river, as well as measures to protect the 
eagles from adverse impacts associated with these activities. For example, grazing has the 
potential to impact eagles if cattle graze on cottonwood regeneration areas, thus limiting future 
roost/nest sites when older, decadent trees are lost. Furthermore, the Draft Statement 
indicates emphasis will be placed on acquisition of access to public lands on the Bighorn and 
Greybull rivers to enhance recreational opportunities and wildlife management. Enhancement 
of recreational opportunitieji may not be compatible with protection of eagle roosts and 
perches. 

PEREGRINE FALCON 

While we concur that only marginal, and probably currently unoccupied, habitat for peregTine 
falcons is found within the planning area, the Service is unsure how long the habitat will 
remain unoccupied. Please provide details on any surveys thai will be conducted in the future 
to determine peregrine occupancy. The Service also concurs that designation of upper Owl 
Creek as an Area of Critical Environmental Concern (ACHC) will help protect potential habitat 
in that vicinity. We remain uncertain, though, of the amount of protection that will be 
provided in the South Fork of Owl Creek Canyon. Please provide us with more details. 

BLACK-FOOTED FERRET 

The Service recognizes that ascertaining whether ferrets are present in prairie dog colonies 
prior to surface disturbances will prevent direct adverse impacts to black-footed ferrets, but we 
question how this will address the long-term recovery of ferrets if no protection is provided for 
potential habitat. If large prairie dog complexes are found within the planning area, 
consideration should be given to maintaining these prairie dog complexes, not only for future 
use by ferrets, but also to protect the biodiversity found within this rich habitat. Please 
provide the Service with details on efforts to date, as well as future plans, to map prairie dog 
complexes in the Grass Creek Resource Area and general information on significant complexes 
identified in the area (including location, size, and proximity to other complexes). 



325 



102.4 



CRAY WOLF 

Information on the possibility of wolf occurrence in the planning area is somewhat vague. 
Please provide more information on the sightings and other indications of wolf presence in the 
planning area, including location, date, and credibility of the reports. While wolves in the 
vicinity certainly might be helped if their prey base is adequately protected, protection of 
wintering big game populations would not fully protect wolves. Has any kind of contingency 
plan been developed in case wolves eventually inhabit the planning area? 

GRIZZLY BEAR 

The discussion of grizzly bear presence in the planning area is somewhat unclear in both the 
Draft Statement and the Assessment. Does the information include reports from 1994? It is 
our understanding that a grizzly bear was found feeding on a dead cow at the head of 
Gooseberry Creek, as well as two confirmed incidents and several sightings in the Grass Creek, 
vicinity. Please provide more detailed information on grizzly bear sightings in or near the 
planning area. 

The Assessment seems to rely heavily on the Management Situation (MS) 5 designation and 
associated Interagency Grizzly Bear Committee Guidelines to defend the 'no significant 
effect" determination given in the Final Statement. The MS 5 designation provides only 
guidance and cannot be used to verify that habitat is unoccupied, determine that federal 
activities will not affect the species, or conclude thai grizzly bears need not be considered 
when making management decisions (particularly under section 7 (a)(2) of the Act). Nor does 
the MS 5 designation negate the Bureau's responsibilities to carry out programs to conserve 
endangered and threatened species as outlined in section 7 (a)(1) of the Act and in the Bureau's 
6S40 manual. 

The Assessment needs to be expanded to include discussion of Increased access, recreation, oil 
and gas, range management (particularly potential for livestock depredations), and potential 
impacts to the grizzly bear resulting from these activities. Consideration of impacts to grizzly 
bears occurring outside the planning area should also be discussed, as activities within the 
planning area (such as improved access to National Forest lands and increased recreation on 
those lands) may impact bears outside the planning area. 

The fourth paragraph on page 21 of the Assessment should be amended to indicate that 
insufficient regulation of bear attracunts in camping areas may cause problems for grizzly 
bears. Discussing problems caused by bears, as in the current wording, is inaccurate and 
judgmental. 

Based on information provided in your June 2, 1994, Upper Owl Creek Access Easement 
Biological Assessment, it was the Service's understanding that the Bureau intended to 
implement use restrictions to reduce/eliminate attxactants as well as a seasonal closure of that 



102.5 



area- Are those restrictions currently in place? This Assessment for the Resource 
Management Plan indicates that these types of restrictions are merely being considered for 
future use. 

Please provide more information on measures to reduce impacts to grizzly bears, including 
details of anticipated public education programs, sanitation regulations (including how the 
determination will be made CD implement such regulations), and other mitigation designed to 
minimize impacts from habitat alteration. 

CANDIDATE SPECIES 

The discussion of candidate species occurring in the project area (page 150 of the Draft 
Statement) is incomplete. The Draft Statement should address the occurrence of and potential 
impacts to the following species, based on information provided in Federal Register volume 
59, number 219, November 15, 1994. 



S p tT' ffS CfltfiflOQE, 

Mammals 

Spotted bat 2 

Euderma maculatum 
Townsend's big-eared bat 2 

Plecotus townsendii paltescens 



Small- footed bai 

Myolis ciliolabrum 
Long-eared bat 

Myotis cvotis 

Long-legged bat 

Myotis volans 
Yuma bat 

Myotis yumanensis 
Allen's 13-lined ground squirrel 

Spermophilus tridecemlincatus 
aUem 
North American wolverine 

Culo gulo luscus 
North American lynx 

Felis lynx canadensis 



Expected Qtxsxnxat 

Big Horn County 

Deciduous forests, dry coniferous 
forests, basin-prairie and 
mountain- foothills shrublands, 
desert grasslands 

Non-mountainous area statewide 

Coniferous forests, riparian, 
prairie shrublands, and sagebrush 
grasslands 

Widely distributed statewide 

Prairie/ shrublands of northcentxal 

Wyoming 
Western slope Bighorn Mts. 

Sc upper Green River. 

Mountains statewide 
Mountains statewide 







102.6 


Rirrf* 




6 


Trumpeter swan 


2 


Northwestern Wyoming 


Cygnus buccinator 






White-faced ibis 


2 


Wetlands statewide 


Pusgadis chihi 






Harlequin duck 


2 


Rivers in northwest Wyoming 


Histrionicus histrionicus 






Ferruginous hawk 


2 


Grasslands statewide 


Buteo regalis 






Northern Goshawk 


2 


Forests statewide 


Accipiter gentitis 






Western burrowing owl 


2 


Prairie, grasslands, and 


Aihent cunicularia 




agricultural lands 


Mountain plover 


1 


Grasslands statewide 


Charadrius montams 






Western snowy plover 


3C 


Shorelines of aquatic areas 


Charadrius alaondrinus 






Long-billed curlew 


3C 


Grasslands/wetlands 


Numerous americanus 






Black tern 


2 


Wetlands statewide 


Chlidomas nigcr 






Loggerhead shrike 


2 


Wood lands/ shrublands 


Lanius ludovkianus 






Baud's sparrow 


2 


Shortgxass prairie 


Ammodramus bairdii 






Amphihi2nfi 






Western boreal toad 


2 


Medicine Bow Mts. , western Mts. 


Bufo boreas boreas 






Spotted frog 


2 


Northwest Wyoming; Yellowstone 


Rana pretiosa 




National Park 


Reptiles 






Eastern short-horned lizard 


2 


Statewide in non-mountainous 


Phrynosoma douglassii 




areas 


brevirostra 






Ehh 






Sturgeon chub 


1 


Powder & Bighorn rivers 


Macrhybopsis gelida 






Flathead chub 


2 


Platte, Cheyenne, Belle Fourche, 


Platygobio gracilis 




Little Missouri, Powder, Tongue, 
and Bighorn rivers 



102.7 



Western silvery minnow 

Hybognathus argyriiis 

Plains minnow 

Hybognathus placitus 



Bighorn and Powder rivers 

Platte, Cheyenne, Belle Fourche, 
Powder, and Bighorn rivers 



•1 = Federal listing appears appropriate and is anticipated. 2 = Current data insufficient to 
support listing. 3C = More widespread or abundant than previously believed, or no 
immediate threats identified. 

Many Federal agencies have policies to protect candidate species from further declines. It is 
our understanding that guidance provided in the Bureau's 6840 manual directs Bureau 
personnel to provide protection adequate to prevent the eventual listing of candidate plants and 
animals. Neither the Draft Statement nor the Assessment is clear about how this is being 
accomplished. 

After careful review of the Statement and the Assessment, the Service does not anticipate 
problems with providing our concurrence upon receipt of the information outlined above and 
discussions to address our concerns. My staff looks forward to working with your staff. If 
you have any questions regarding our review of the documents, please contact Mary Jennings 
of my staff at the letterhead address or phone (307) 772-2374. 



/'7 
Charles P. Davis 



Director, WGFD, Cheyenne, WY 
Nongame Coordinator, WGFD, Lander, WY 
Kevin Hurley, WGFD, Meeteetsee, WY 



326 



XXXXXXXXXXX 
XXXXXXXXXXXXXXXXXXXXXXXX 

March 21, 1995 

Bob Ross, Team Leader 
Bureau of Land Management 
P.O.Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross: 

1 would like you to make the following changes in the management plan. 

The Absaroka Foothills, Badlands, Badlands, and Red Canyon Creek Special 
Recreation Managment Areas should be protected from oil development. 

The Badlands SRMA should also be designated an ACEC because of its scenic and 
extremely fragile soils. 

Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish these goals in the next five years. 

Sincerely yours, 

/s/ Theresa Hastings 



RECEIVED 



MAR 2 4 1995 



104 



nub Rosa 

Team Leader 

Bureau of ! .and Managment 

P.O.Box 119 

Worland. Wyoming 81401 

Dear Mr. Ross. 

1 fear that the draft managment plan for the Grass Creek Resource Area will 
peiTiiil virtually uncontrolled oil ami gas development in the southwestern quarter of the 
Bighorn Basin. This is one of the most beautiful areas of Wyoming, where one tan see 
the sharp contrast and beauty of Wyoming landscape from arid deserts to lush mountain 
forests. Such areas of great beauty should not be subjected to the oil and gas development 
allowed for the draft managment plan. 

1 urge that the draft managment plan be revised In 4 key ways. The first being that 
the Absaroka Foothills. Badlands. Bighorn River and Red Canyon Creek SRMA be 
protected from oil development. We should not mar the landscape of such a beautiful area 
by allowing for oil development. Secondly. I fct;\ that more definite goals addressing the 
problems of overgrazing in the resource area should be made, as well as a timeline to 
accomplish these goals in die next five years. 

Some more areas that need greater protection are all the areas included in the 
Conservationists' Alternative to the BLM's Wilderness Proposal including lands outside 
the Wilderness Study Areas. The Badlands SRMA should also be redesignated an ACEC 
because of its spectacular and extremely fragile soils. 

Thank you. 



Sincerely, 

abtov one Hen' 



(fMJS&r^ 



WR2AI995 



March 20, 1905 



Bob Ross 

Team Leader 

Bureau of Land Management 

P.O. Box 119 

Worland, WY B2401 



Dear Mr. Ross: 



I'm writing to comment on the BLM draft management plan for 
the Grass Creek Resource Area in the Bighorn Basin. I urge you to 
make the following changes in the management plan: 

1) Protect the Absaroka Foothills, Badlands, Bighorn River, and 
Red canyon Creek SRMAs from oil development. 

2) Designate the Badlands SRMA an ACEC because of its spectacular 
scenic and very fragile soils. 

3) Protect all areas included in the Conservationists 1 Alternative 
to the BLM's Wilderness Proposal including lands outside Wilderness 
Study Areas. 

4) Set up more definite goals to address the problems of 
overgrazing in the resource area, and establish a timeline for 
accomplishing those goals over the next five years. 

Thanks very much for considering these suggestions, and for 
working to preserve the beauty of the Bighorn Basin. 



Yours sincerely, 
Jennifer Howard 



«c 



MW211995 



106 



BUREAU OF UKSWFWaEMEt'! 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box lis 
Worland, WY 82401 



March 20,1995 



Mr. Ross: 

I am writing due to my concern over BLM's proposed plan for 
Grass creek. This is one of the most beautiful areas of 
Wyoming and I would hate to see it destroyed by laisse faire 
management practice* . Such areas do not prosper from oil and 
gas development. 

I believe that the Absaroka Foothills, Badlands, Big Horn 
River and Rod Canyon Creek srma should be protected from oil 
development. 

I believe the Badlands SRMA should also be designated an ACEC 
due to its beauty and fragile soils. 

i believe that the elm should protect all areas included in the 
Conssrvationits' Alternative to the blm's Wilderness Proposal. 

I have enjoyed my visits to the area in question and my heart 
would be broken if it were irrevocably damaged by short-sighted 
development for a non-renewable resource. It is time that 
America stopped plundering the remaininq beauty of our country 
and look for alternative long term solutions to our energy 




for your consideration. 



327 







William L. Simerly 
Uri S. Simerty 








RECEIVED 






MAR2 A 1995 


1 

; 20 March 1995 


BUS 


EAU OF LAriD l-A^OEIn 


HT • 



WF 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O.Box 119 
Worland, Wyoming 8240] 



The Grass Creek Resource Area is in one of the most beautiful parts of Wyoming. We are 
concerned that BLTvTs new draft management plan for the area will not adequately protect 
it from the destructive effects of oil and gas development We ask that the following 
changes be made to the plan: 

- The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 

Recreational Areas should be protected from oil and gas development. 

- The Badlands SRMA should also be designated an Area of Critical Environmental 

Concern because of its spectaeular scenery and fragile soils. 

- Protect all areas included in the Conservation i sis' Alternative to the BLM's Wilderness 

Proposal including lands outside Wilderness Study Areas. 

- Provide more definite goals to address the problems of overgrazing in the resource area, 

and provide a timeline to accomplish those goals in the next five years. 



Thank you for your time. 



Sincerely, 



ill Simerly - "-- J 



Bill Simerly 



Lori Simerly \«_/ 



% 



xxxxxxxxxxxxxxx 

XXXAXXXXXXXXXXXXXXXXXX 



Bob Ross, Team Leader 

BLM 

P.O. Box 119 

Worland, Wyoming, 82401 

Dear Mr Ross 

Wyoming's wilderness lands must be protected from the adverse effects of massive oil 
and gas development. 

I urge you to change your management plan for the Grass Creek Resource Area. The 
Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special Recreation 
Managment Areas must be protected from oil development! 

None of the alternatives consider protection of Wilderness Areas. Your management 
plan allows for all of the Grass Creek resource area to be leased for oil and gas 
development. I urge you to protect all the areas included in the Conservationists' Alternation 
to the BLM's Wilderness Proposal. The Badlands SRMA should be designated an ACEC. 
The management plan must also address problems of overgrazing in the area. The Bureau of 
Land Management must protect the American land! 



/s/ Peter Zadis 



Sincerely Yours 
Peter Zadis 



IVatherinc Johnsor 



MAR24BG5 



mw 




March 16, 199.5 



Mr. Bob Ross 

Bureau of 1 -and Management 

P.O. Box 1 19 

Worland. Wyoming 82401 



Dear Mr. Ross, 

I am writing to you ul the request of my local Sierra Club Chapter to ask for the following changes 
in the management plan. 

1) The Absaroka Foothills. Badlands. Bighorn River, and Red Canyon Crck Special 

Recreation Management Areas (SRMA) should be protected from oil development. 

2) The Badlands SRMA should also be designated an ACEC because of its spectacular 
scenic and extremefy fragile soils. 

3) Prolccl all areas included in the Conservationists' Alternative to the Bl -M's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

4) IVovide more definite goals to address the problems of overgrazing in trie resource 
area, and provide a timeline to accomplish those goals in the next five years. 

Thank you for your time and attention to this very important and complicated issue in Land 
Management 



Sincerely yours. 



& 



,Lf+ 



K;iiherine Johnsun 




110 



<»ing til j,Uou ■.-.,-,;: 
iO'.ir.:* Area c < ;,..» 



3©Ar Mr. Hoskj 

In* RursAu Dl Lsr.d KaA.gemnl Ij rtar. 
of t>.-s r.sourc* arfta in t.'.u ? .rii(. Cr«*3t =6 
blghOVf. -3a:'v, ta fc^ Ita^t.:! i- t ,..; . ,„-- ,,^,- 
proposa] L K nora» ta« -i.ti j; n+*A .",,'"-, 
■ r **&- Al.a* =»a* iliuuia be adares-.d'are: 
-n* Assarosa Foothills, Badlands a!«t.o:,. Bjv« r and at, 1 
•-.nynn ..r.,n Speol.: S.crs.t.lon Ksna a .nant i™,, (RSMAs 

--h.3s.lUnd. .-.MA bu such eKW.ns!,, fr. e i I, soils, that 

-All area* -.tot. „-, inoludss l„ the Co«.r».tt«U«ta" 
Alt.rnjMv. Lu rh. BLIP . »Ud.rn.«, Propoml should t, 
-rr.t.^.t.a. i, „-,[„,;, „ s la , ldH ou ..,, !e »[id.rn**s Study Al «s 
uvergraa.n^ In the west i„ a niajiw amble-a, Baagelande a 

;;.;„?•-•' r , lhlt " 1U ■-'■ ; '■" «"••■ »»>"< soiuti™. 

ail,--*"-, "■'''" " !,: »«»«» •'<= "■»■ te;i = lt e ,„,,!. - 

ajdr.as it,., j,, _.„,,„ „i..ii„ tj> , raeourc. i..j saouid be 

f";'^: : "" h " ,;n " ,,! '"' '= «««»K"1> <■•«•» «tM.\5 „.„ 

' - ' : ' * * p:*f* i>» ! .ii"«i iiy ^ ; j atiil fai oowiiJtnl#a to txels't 
ev.,ry a*iM, .,,., tor develops,,,?. ! fail Uat mm ,,™ 

They deserve [fDUi'lo,, , s *.„»; „ e E ,,,..„, w , t> ^."ii™ 1 
c>2iitit)t.4d a.^jr. t.rn-^i-tB- n-ri . ™. ( „ . JI;V * 

":'- .',:!-'L ■ .J'.;'" " " s, ' reL, IJ ' q,so r * s » -> 



tf^t^xsTt.^Zzr*^ 



328 



mum 



m 



HilF.aU CF LAKD W.S*8Etf JN! 



Bob Ross 

Team Leader 

Bureau of I -and Management 

P.O. Box 119 

Worland, Wyoming 82401 



Dear Mr. Ross. 

1 am presently taking this time to write you to inform you as to my high 
level of concern as a citizen «f lins-country, and as a fellow human being who understands 
that you posess a great deal of responsibility as to deciding the future of a peerless 
resource. I am shocked to have heard that all of the options on the table for the management 
of Grass Creek Resource Area impose a laizze-faire system of oil and gas development on 
100% of the area. As a biology major, 1 am aware of how little even the experts know 
about the full extent of any impact our activities have on the dynamics of an ecological 
system, and I hope that we can limit the impact of the oil lease in the Bighorn Basin if we 
consider some of the following points. \ will tell you specifically what 1 have in mind as 
the responisiole option to ensure the principles of multiple-use are considered from as 
objective a standpoint as is possible 

I believe that the three designated ACEC sites need to have more stringent 
enforcement and protection measures. The Absaroka foothills. Badlands, Bighorn river, 
and Red Canyon Creek Special Recreation Management areas should definitely be protected 
from any level of oil development. Because of its extremely scenic landscape, and also its 
particularly fragile soils, the Badlands SRMA should be designated an ACEC. I also 
implore you to protect all of the areas included in the Conservarionists' Alternative to the 
BLM's Wilderness Proposal, including areas outside the Wilderness Study Areas. Finally, 
please consider providing more definite goals to address tie problems of overgrazing in the 
resource area, and please provide a timeline to accomplish these goals in the next 5 years. 

Thank You. 



With utmost sincerity, 

Jeremy Phillip Kamil 




¥.A? 



112 



GRASS 



Grass Roots Alliance For State Sovereignty 
Box 263 Grey-bull, WY 82426-2063 



[Same as Letter #1] 



Additional comments: 

YOU SHOULD READ THE CONSTITUTION OF THE UNITED STATES &. OF WYOMING SOME 
TIME. 



Name: R. E. Riddle 

Mailing address: xxxxxxxxxxxxxxxxxxxx 

City, State & ZIP: xxxxxxxxxxxxxxxxxx 

Signed: N R. E. Riddle Date 





RECEIVED 






WR27B95 


NI 


Bu 


EAJOrUWC S-V.Y^.::., 



11113 



Rich P. Sheff e rs on 
March 22, 1995 



Bob Roas, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming B2401 



Dear Mr. Ross, 



I am very concerned by the draft management plan your agency 
has released for the Grass Creek Resource Area. Protection and 
conservation, it seems, are barely even mentioned. Handing over 
this resource area for oil and gas development would be a big 
mistake for the BLM. Grass Creek is undoubtedly one of the most 
marvelous parts of Wyoming. 

I ask chat you modify the management plan so that : the 
Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas become protected from oil and 
gas development; the Badlands SRMA becomes designated an Area of 
Critical Environmental Concern (due in part to its extremely 
fragile soils); all areas included in the Conservationists' 
Alternative to the BLM wilderness Proposal become protected 
(including lands outside Wilderness Study Areas) ; and that more 
definite goals and timelines to address the problem of overgrazing 
in "he resource area become instituted. 

Thank you for your time. 



Sine i 



Bly, 



Rich P. Shefferson 



114 



Dear Mr. Ross, 

As someone who enjoys the wide open spaces of the American West, I request that you do 
all in your power to protect the Wyoming SRMAs from development, strictly enforcing 
ACEC against overgrazing and oil/gas exploitation. Thank you for helping to save the 
natural beauty of the Badlands, the Absaroka Mountains, Red Canyon, and the Bighorn 
River. 

/s/ John Maybury 

XXXXXXXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXX 



329 




m 



March 2L, 1995 



Bod ho^5. Teem leader 

Bur e»u o-f Land Management 

P.O. Box 119 

Hur land, WV 82401 

Mr . PtOMt 

I would like to commant or. some: proposals in the draft 
management plan far the bra-is Creek Resource. Area which I believe 
would be harmful tu this wxtrenmly beeuti+ul and sensitive area. 

The plan allows -fur 100X of the resource area to be cipsn to 
leatrng ior oil and gas exploration. T(,i^ t « « wasteful and 
riflm^ging policy, sinre areas once tuoded and drilled can never 
be restored to their present condition and may be gone forevpr . 

While bha plan designates three special management areas for 
sreas ot critiml environmental concern, criter i a'a-f management 
arc more lax than would be necessary to actually protect these 
areas trcm degradation uncirsr thw rest of the plan. 

1 believe that the flbsarot.-a Foothills, Badlands, Bighorn 
River, *nd Red Canyon Creek Special Recreation Management Areas 
in particular should be completely and permanently protected tram 
nil and gas development. These SCWnic areas would be irreparably 
damaged i -f drilling and road building were allowed thers. 

The Badlands recreation area should be designated an area of 
critics! «nvi runmental concern because i to scenic beauty i* BQ 
-frag lie and vulnerable to erosion. 

The conservationists alternative lists, important areas which 
should be added to the list q-f protected &!**•*. 

Dvfirgrazlng pn»=s a threat to th» fragile soils and 
senwti/a flora or theise areas and should De specif icell y 
addressed in the management plan. 

I hope that these continents will be seriously considered in 
amending the plan before it goes into effect. Remember, 1 andt, 
oni_e degraded m*y be gone -forever. 



A\ -. (] . sTia, Cl^ 



Mary Ellen Clint. 




116 



XXXXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXX 

March 23, 1995 

Mr. Bob Ross, Team leader 
Bureau of Land Management 
P.O.Box 119 
Worland, Wyoming 82401 

Dear Mi. Ross: 

The following changes are needed in the management plan for the Grass Creek 
Resource Area; 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas (SRMA) should he protected from oil development. 

The Badlands SRMA should also be designated an ACEC because of its spectacular 
scenic and extremely fragile soils. 

Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next five years. 

Sincerely yours, 

111 Theresa A. Hastings 



117 



[LAST NAME ILLEGIBLE] 

I'm writing to request that you consider a Conservation Alternative for the Grass Creek 
Resource area. You should prohibit sensitive areas from oil & gas leasing, and limit ORVs 
to existing roads and trails - not in roadless areas and wilderness Study areas. There's 
plenty of places for them to ride without going into the wildest, most sensitive areas! 
Thanks, f&f CR [Euald], xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 




118 



— j cchlra i99s 

- Mr ,._ fy >b Ross, Team Leafier 
Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross: 

This letusr la in regards to the draft management plan (or the Grass 
Creek Resource Area of the Bighorn Basin. We object to the allowance 
ot 100* of the resource area to be leased for oil and gas development. 

We urge you to add the following changes to the management plan: 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas (SRMA) should be protected from 
oil development. 

The Badlands SRMA should be designated an Area of Critical 
Environmental Concern (ACEC) because of its spectacular scenic and 
extremely fragile soils. 

Protect all areas included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal including lands outside the Wilderness Study 
Areas. * 

Provide more definite goals to address the problems of overgrazing in 
the resource area, and provide a timeline to accomplish those goals in 
the next five years. 

Sincerely, 

■ ■ ■ •'--.don Bluestein 



330 



MK27S95 



(U«JUJ OF UhD KAfiAifaEHl 



March 23, 1995 

Bob Ross, Team Leader 
Bureau of Land Management 
P. 0, Box 119 
Worland, Wyoming 82401 

Dear Mr Ross; 

The Grass Creek Resource Area Is one of the moat 
beautiful areas of the United states. It would be a real 
traqedy to nee it decimated by oil and gas exploration, 
urge you to consider the toll owing changes in the 
management plan: 

1) The Absaroka Foothills, Badlands, Bighorn River, and 
Red canyon Creek Special Recreation Management Areas 
(SRMA) should be protected trom oil development. 

2) The Badlands srma should also be designated an ACEC 
because of It's spectacular scenic and extremely fragile 
soi Is . 

3) Protect all areas Included in the Conservationists' 
Alternative to the BLM's wilderness Proposal including 
lands outside Wilderness Study Areas. 



Thank you for your consideration. 



Robert E Fullerton 



120 



Olga M. Rosche' 

XXXXXXXXXXXXXXXXX XX 

xxxxxxxxxxxxxxxxxxxxx 
March 23, 1995 

Mr. Boss Ross, Team Leader 
Bureau of Land Management 
P. O. Box 119 
Worland, Wyo. 82401 

Dear Mr. Ross, 

I am o pposed to uncontrolled oil and gas development in the Grass Creek Resource 
Area (southwest comer of the Bighorn Basin). 

I suggest these changes: 

• These parts should be protected from oil development, --Absaroka Foothills. Badlands. 
Bighorn River, Red Canyon Creek Special Management Areas. 

• The Badlands SRMA should also be designated an Area of Critical Environmental 
Concern because of its spectacular scenery and very fragile soils. 

• Protect all areas included in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside Study Area. 

• Provide more definite goals to change the problem of overgrazing & provide a timeline 
to setup goals for the next five years. 

Yours truly, 
/s/ Olga Rosche' 



121 



xxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxxx 

March 23, 1995 

Mr. Robert Ross 

Bureau of Land Management 

P.O. Box 119 

Worland, Wyoming 82401 

Dear Mr. Ross: 

It is a real shame the way some of the most gorgeous parts of our country go the way 
of oil development. 

Now, I read the absarolca Foothills, Badlands, Bighorn River, Red Canyon Creek 
Special Recreation Management areas are in the draft plan of the Bureau of Land 
management for oil and gas development. 

I strongly ask these spectacular scenic areas be spared. 

Sincerely yours, 
Isl Lillian A. Snider 



122 



March 23 '95 



Bob Ross, Team Leader 
Bureau of Land Management 
P.OBox 119 
Worland. WY. 82401 

Dear Mr. Ross. 

Re the draft management plan for the Grass Creek Resource Area, I urge the 
following changes: 

1. The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas should aj] be protected from oil development. 

2. The Badlands SRMA should also be designated an ACEC because of its 
spectacular scenic and extremely fragile soils 

3. Protect all areas included in the Conservationists Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

4. Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timetable to accomplish those goals in the next five years 

I si Jack Robbins 

xxxxxxxxxxxx XXX xxxxxxxxxxxxxxxxxx 



331 



WR27B96 i 



123 



HJIEAU DF LAND ESI 



March 23, 1095 

Mr. Bob Ross, Team Leader 
Bureau of land Management 
P.O.Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross: 

I am writing about the draft management plan for the Grass Creek 
Resource Area. I am requesting the following changes in the plan: 

- The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas should be protected 

from oil development. 

- The Badlands SRMA should also be designated an ACHC because of 
its spectacular scenic and extremely fragil soils. 

- Protect all areas Included in the conservationists' Alternative to 
the BLM's Wilderness Proposal including lands outside Wilderness 
Study Areas. 

- Provide more definite goals to address the problems of overgrazing 
in the resource area, and provide a timeline to accomplish those goals 
in the next five years. 

Thank you for your attention. 

Sincerely yours. 



/w./*^ f basdh*-^ Urw,. 



Barbara &. Brian Comnes 



124 



To: Bob Ross, Team Leader 3/21/95 

BLM 
POB 119 
Worland Wyoming. 82401 

From: Victor Parra 

xxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxx 

Re: BLM Bighorn Basin Plan 

I would like to see the Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek 
Special Recreation Management Areas protected from oil development.. The last thing we 
need in these kinds of Areas is oil- oil companies! Also, the Badlands SRMA should be 
designated an ACEC because of it's spectactular beauty. In addition, I ask that you protect 
all areas included in the Conservationists' Alternative to the BLM's Wilderness Proposal 
including lands outside Wilderness Study Areas. Lastly, regarding over-grazing in the 
resource area, pres please provide specific goals & timeline for accomplishment. Thank-you 

/s/ Victor Parra 
P.S. If you want to leam more about how to mess up a place by over-developing it, come to 
L.A.! 



125 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
POBox 119 
Worland, Wyoming 82401 

My dear Mr. Ross: 

In the name of my children and grand-children and your children and grandchildres 1 
urgently request the following changes in BLM's Bighorn Basin Plan: 

1. The Absaroka Foothills, Badlands, Bighom River &. Red Canyon Creek 
Special Recreation Management Areas protected from oil development. 

2. The Badlands SMMA should also be designated an ACEC because of its 
spectacular scenic and extremely fragile soils . 

3. Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

4. Provide more definite goals to address the problems of overgrazing in the 
resource area, and provide a timeline to accomplish those goals in the next five 
years. 

Help save the wonders of our beautiful country for the many. 

Yours sincerely, 
/s/ Deborah Slosser 

xxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxxx 



126 



xxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxxx 
xxxxx 
March 22, 1995 



Dear Mr. Ross: 



1 understand that the BLM recently released a draft management plan for the Grass 
creek Resource Area and I would like to register with you some concerns that arise from a 
review of the plan. 

Please consider designation of the Badlands Special Recreation Management Area as 
an Area of Critical Environmental Concern. The fragile nature of the soils and topography 
of this area certainly warrant the greater protection that would come with designation as an 
ACEC. 

Please consider closing your ACEC's and SRMA's to oil and gas leasing. From past 
experience on BLM lands, I have seen the negative impacts of oil and gas leases on the 
environmental. I am surprised that your draft suggests that oil and gas leasing would be 
compatible with wildlife, scenery, and environmental concerns and I urge you to close all of 
your SRMAs and ACEC's to oil and gas leasing. 

Also I was concerned that the Wilderness Study Areas would not be afforded greater 
protection and I urge you to do all in your power to ensure that these key WSA's and the 
adjoining lands be closed to non-compatible uses like oil and gas leasing. 

Thanks for listening 

/s/ Paul J Parley 



332 



127 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P Box 1 19 
Worland, WY - 82401 

Dear Sir: This letter is in reference to the development of the Grass Creek Resource area in 
the Big Horn Basin. 

I am very much against the uncontrolled (and controlled, also) development of Oil 
and Gas in this very beautiful part of the state. I have been to Wyoming and it is one of our 
most beautiful states! It is a shame to duller all of that wild, natural beauty with oil rigs, 
and such. 

I request the following changes in the management plan: 

1. Absaroka Foothills, Badlands, Bighorn River &. Red Canyon Creek Special 
Recreation Management areas (SRMA) should be protected from oil & gas development. 

2. Protect all areas included in the conservationists' alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

3. Badlands SRMA should also be designated an ACKC because of spectacular 
beauty and extremely fragile soils. 

4. Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline of five years to accomplish those goals. 

My son is planning on a trip to Wyoming, and 1 want him to see the same natural 
beauty that I was privileged to see, not the ugly blight of oil and gas exploration. 

You lucky people there may take your beautiful state for granted, but to us easterners, 
who do not have much spectacular visits as Wyoming, do appreciate the glory of God's gift 
to you all! 



Thank you and Most sincerely, 



MrsKathie S. Ritchey 
xxxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxx 
xxxxx 



128 



GRASS 



Grass Roots Alliance For State Sovereignty 
Box 263 Greybull, WY 82426-2063 



[Same as Letter #1] 



Additional comments: 

I would like to know why the private lands along the Big Horn and Grey Bull river 
drainages are included in the Grass Creek Resource Area? 

Name: James D Miller 

Mailing address: xxxxxxxxxxxxxxxxxxxx 

City, State & ZIP: xxxxxxxxxxxxxxxxxx 



Signed: /s/ James D Miller 



Date: 3/25/94 



WW27I9S6 






129 



Mr Bob Ross 

Team Leader 

Bureau of Land Management 

P.O. Box 119 

Worland, Wyoming 82401 



r Mr. Ross, 



Re: BLMS Big Horn Basin Management Plan for the 
Grass Creek Resource Area 



I love the State of Wyoming, particularly the Big Horn Basin. I am a native of the Big 1 lorn 

Basin, having lived in Lovell, Burlington. Grass Creek, and Thermopolis. I graduated from 

Lovdl High School. My grandfather George Allphin, came to the basin before the turn of the 

century and hundreds of his descendants live throughout the State. My wife Gail was born in 

Lovcl! and her grandparents are also early settlers 

My father and Gail's father both worked for Marathon Oil Company We are very familiar with 

the history of oil and gas development in the basin and it's contribution to the economy of the 

region, 

1 am a petroleum scientist with a Ph. D. degree from the University of Colorado. Gail is a 

botanist and one of our daughters Loreen is a botanist at the University of Utah. I have been 

employed by Marathon Oil and Chevron Oil for much of my career 

As a family of scientists, we are acutely aware of the need to develop natural resources, such as 

gas and oil. We are also aware of the critical need to preserve the precious fragile land that is a 

gift to us from the Creator that has no way to protect itself In our lifetime we have seen many 

treasures destroyed, never to recover or be seen again. We have seen fields of lupines, in colors 

of blue, pink and white which have totally disappeared from areas of the Absaroka foothills 

because of intensive overgtazing by sheep and cattle We have seen total streams diverted from 

the Big Horn mountain foothills leaving miles of empty steam beds and rare flora and fauna 

disappear from the region. 

1 am writing this letter to comment on the recently released draft of the Management plan for the 

Grass Creek Resource Area encompassing the southwest quarter of the Big Horn basin. I 

sincerely hope changes will be made to the plan, because much of the land is so fragile and 

without significant restrictions irreparable damage will occur. Here arc my recommendations 

1) The plan needs to provide much more definite goals to address the issue of over 
grazing and to put together a precise time line and strategy to accomplish them 

2) Additional areas must be added to the BLM's Wilderness proposal The so 
called Conservationists Alternative outline these areas 

3) Based on a careful risk vei.sus reward studies, I feel that Red Canyon 

Creek special recreation management area(SRMA) should be protected from 
further oil development and also the Big Horn River area 
4) The Absaroka foothills and the Badlands SRMA must also be protected from 



129.2 



development for gas and oil. 
5) The Badlands SMRA should also be designated as an additional Area of 
Critical Environmental Concern (ACEC) because of extremely fragile soils 
and spectacular scenic value. 

Please consider our request. In this world of global issues this little spot on the globe is 
important. How can we expect the natives of the Amazon region to say no to special interests 
and save the rain forests, if we don't have the courage to say no to our special interests here in 
the U.S. Gail and I and Loreen, join our voices together in hopes we will be heard. We say to 
you; 

Please protect and nurture this land of ours, 

Not owned by one, but owned by all, 

That generations yet unborn, will praise. 
Your vision, your wisdom and your courage! 



Sincerely yours, 



333 



RECEIVED 




n§ 



March 12, 1995 

Mr. Bob Ross 

Team Leader 

Bureau of Land Management 

P.O. Box 119 

Worland, WY 82401 

Dear Mr. Ross, 

I bet you don't get many letters from Chicago about the Grass Creek Resource 
Area, but since I left Wyoming two years ago I try to stay on top of what's going on, and 
1 hope to be able to move back once I finish school. I had the chance to work with some 
BLM folks over the Cumberland allotment a few summers ago, and I know you all are 
trying to do the best job you can. 

1 am concerned about the management plan for the Crass Creek Resource Area. I 
think that too many concessions are made to oil and gas development, and that the 
management of the ACECs is not tough enough. 

A better plan would 

" protect the Absaroka Foothills, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas from oil and gas development. 

• designate the Badlands SRMA as an ACEC because of its fragile soils and the 
excellent scenery. The belt of badlands in this area is as nice as any I've seen, and 
it shouldn't be trashed. 

• protect the areas listed in the Conservationists' Alternative to the BLM's 
Wilderness Study Areas. 

I also think more needs to be done about overgrazing In the resource area. I 
worked on a ranch before I came back east to go to school, and I am no enemy of 
ranchers, but in such dry areas too many cattle Will trash the land, especially the 
riparian zones. Reducing grazing limits from the paper limits to the number of AUMs 
now grazed may anger the ranchers, but it doesn't really do anything to protect the 
land. The resouce area needs real reductions in grazing, and more aggressive 
management to protect the most sensitive areas. 

Thank you for your efforts to protect the Bighorn Basin. 

Sincerely, 

-2.<~G H-Q-Q. 



KW28B95 



BUBEAO OF UNO BANAGEMIHT 



1311 



March 24, 199S 



Bob Ross, Team Leader 
Bureau of L,and Management. 
P.O. Box 119 
Worland, Wyoming 82401 



Dear Mr. Kogg; 



I am writing to state my concerns about your recently released 
draft management plan for -he Grass creek Resource Area; if 
implemented it will permit virtually uncontrolled oil and gas 
development m this very beautiful part of your atata. 

I would like to make the following recommendations; specifically: 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas should ALL be protected 
from oil develo 



The Badlands SRMA should also be designated an ACEC because of its 
spectacular scenic and extremely fragile soils; 

That all areas included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal be protected, including lands outside the 
Wilderness Study Areas, and; 

More definite goals to address the problems of overgrazing in the 
resource area be provided, along with a Limeline to accomplish 
those goals ir. the next five years. 

I hope you will take the time to consider each of these 
recommendations. 1 appreciate you taking the time to read this. 



Sincerely, 



T&fe, &&A 



Mike Echols 



132 



GRASS 



Grass Roots Alliance 
Box 263 Greybull, WY 82426-2063 

[Same as Letter ff\] 



For State Sovereignty 



Additional comments: 

It is now time to back off. take a deep breath, think a little, read the 
constitution of our country & state. Then use some common sence. 

Name: /s/ Robert Redland ROBERT ReDLAND 

Mailing address: xxxxxxx 

City.State & ZIP: xxxxxxxxxxxxxxxxxxxxx 

Signed: ft? Robert Redland Date: 3-24-95 



RECEIVED 



mZ8Q35 



BUREAU OF UKD MANMEMEKT 



133 



February 2, 1995 



Bob Ross, Team Leader 

P.O. Box 119 

Worland, Wyoming 1)2401-0119 



Dear Mr 



Ros 



Thank you for providing us with a copy of the Grass Creek 
Resource Area Resource Management Plan/Draft Environmental Impact 
Statement. . It is a rare to find a government document so 
superbly edited, and easy to understand. Each member of the team 
obviously put a good deal of thought into their sections, and we 
very much appreciate their hard work, We have comments on only 
four sections : 

1- CULTURAL AND PALEONTOLOGICAT, RESOURCES 

1. Page 107 . Please mention in the Paleontology section that 
the Willwood Formation in the 3ig Horn Basin is home to Lhe 
oldest primates in the world. Cantius and Notharctus are 
unique to our area. For the sake of the public, they should 
be noted in the document. 

a. An -interpretive pull-out and sign on the highway, or 
along Goosaberry Creek Road at the edge of the 
willwood Formation would be a small cost and provide 
extremely important scientific information to the 
public. Please consider this. 

2. Please see III, 2, below. 

II. BILDLIFE 

1. Paces 14:.}, 147 and Map 31. The Red Canyon Allotment 

Management Plan cpecities that the allotmcnL contains raptor 
nesting areas, and crucial winter habitat for mule deer and 
antelope. None of these are mentioned in the Wildlife 
sections or on the relevant maps. Have these areas been 
reclassified? It co, we believe it was done in error. 
During the very hard winter of 1992-93 two to three feet of 
snow lay in the flats on Red Canyon Ranch from November- 
through the end of March. Over one hundred antelope relied 
on the crucial winter range in T42 R95, sections 5 and G; 
T43 R95 sections 31 and 32,- and T43 R9S section 36. 

That same winter we noted that at least fifty mule deer 
used the crucial winter range in Red Canyon and the 
surrounding highlands where the wind blew the snow clear. 
This range includes portions of T42 R.95 sections 4, 8, 17, 



334 



133.2 



GEAR- -RHP COMMKH-;! 



18, 19. ^C; and T42 R96 sections 13, 14, 23, 24. Becauae of 
the multitude of side-canyons and draws in Red Canyon, the 
actual number of deer using Lhat crucial winter range may 
have been two to three times as high as we noted- 
Each year several pairs of golden eagles, redtailed hawks, 
great horned owls, prairie falcons and other raptors hrbL in 
Red Canyon, We have counted fourteen nests in the vicinity 
around Nostrum Spring. Four of those nests have been used 
by the same pairs of raptors for the last three consecutive 
years. Please mention thia extensive nesting area in the 
document? 



III. RECREATION 



192, and Maps 1£ and 2JU 



lease clarify the basis tor the 1,226 vis 
isted on page 192? 



.tor use days 



xr. 1990 when the utilization is claimed we do not believe 
that the Wind River Reservation, Mr. Jones, or Mr. Weese 
authorized such trespass. If people did net cross any of 
these property owners' holdings, how did they get into Red 
-any on? 

Please note that in the three years that we have owned Red 
Canyon Ranch we have seen no one using Red Car.yon for 
recreational purposes, which makes it hard for us to believe 
Che heavy use implied by the listed 1,226 visitor use days. 
Where does this figure come from? 

Upper Red Canyon contains an unrecorded archeological 
district which is potentially eligible for the National 
Register of Historic Places. The district consists of 
dozens of rockshelter Hitea, lithic scatters demons L rating 
lona distance trade, historic inscriptions, one stage 
station, two stage/freight roads, prehistoric and historic 
burials, campsites dating from the Paleo Indian period 
straight through to the proto-historic (one of which 
contains ceramics! , and at least two historic homestead 
sites . 

This district is so extensive and so rare we do not believe 
there is any way to mitigate the impacts which recreational 
usage will cause. Because of the very abundance of 
archeology, vandalism wjll occur, no matter how much 
public education is done. These sites, particularly the 
rockshelter sites, are very fragile and have the potential 
to significantly increase our knowledge cf past lifeways on 
local, state and national levels. 



133.3 



CEAR--RM? COMMENTS 



3, In addition, Red Canyon, as noted above, is crucial winter 
range for mule deer, and is extensively used by raptors as a 
nesting area. The high number of proposed "visitor use 
days" listed on page 193 is certain to adversely impact the 
wildlife, even if usage is seasonally limited. 

4. Map 28 lists Red Canyon and the surrounding area ae 
"Semiprimitive Motorized." However, there are BLM eigne 
posted along the south side of the canyon which state that 
motorized vehicles are prohibited. As a result of these 
signs, all grazing allotment work done ;i n Red Canyon Ranch's 
Slope Pasture has been conducted on horseback, Has the 
designation for that area changed? Let us clarify that 
while ranch work on horseback is obviously more labor 
intensive, we recommend that that area remain "non- 
motorized." For the reasons noted in i, 2, and 3 above. 

In conclusion, the proposed trailheads, trails and primitive 
recreational usage of Red Canyon will adversely impact 
raptor nesting areas, crucial winter range for mule deer, 
and cultural resources. How do you plan to mitigate these 
impacts? 

IV. GRAZING 

1. Since Mr. Vessels says that the "Preferred Alternative" 
describes existing management, are we to assume that it has 
always been the Resource Area's intention to achieve "a ib% 
reduction in total authorized grazing," as specified or. page 
177? Or is this figure in error? If so, please restate the 
Resource Area's intention. 

2. After attending two public meetings concerning this RMP we 
know that the Resource Area did not intend Table 3-3 in 
Appendix 3 to be used as a management tool- -but surely you 
realize by now that it c an, and wi 1 I be. 



situation where enemies of grazing 
say, "The BLM's own statistics 



It is easy to envision 
will take this table a: 

demonstrate that allotment 00572 is being utilized at 140% 
capacity. Obviously the AUMs on this allotment must be 
reduced by 40%." Those groups will not care that 00572 is 
an "M" class allotment which is in excellent condition. 
They will care only that the statistics "prove* the area is 
being overgrazed. 

Table 3-5 clearly implies management objectives — whether 
intended or not. Please eliminate this entire table from 
the final document. It is misleading and potentially 
devastating to Wyoming' a livestock industry. 

Not only that, if such cute were forced through lawsuits 
brought by environmental groups, it would undermine proper 



133.4 



CEAR--RM? COMMENTS 



utilization of the publi 
ootions. 



ange by reducing BLM's management 



3. In the event that you opt not to delete this table, please 
answer the following questions: 

a. What is the source of tha figures in the "Suitable AUMs" 
category? And please do hot just site another document. 
Clarify the scientific criteria upon which these numbers are 
based. How were they arrived at? You have admitted 

that these criteria come from a 1982 study, which means they 
do not reflect improvements made, or changes in grazing 
practices implemented by landowners over the past thirteen 
years. Please justify how these out-of-date "suitability" 
criteria can be' applied to today's allotment conditions? 

b. Please quantify the economic loss {the dollar amount) 
which each county will suffer as a result of this decision? 

We would appreciate it if you could specifically address the. 
following issues in your economic evaluation. 

(1) A 34% redaction in AUMs will reduce the value of 

property within Hot Springs and Washakie counties 
by a corresponding amount , which means a 
drastically lower tax base to fund schools, fire, 
sheriff , and other tax -based institutions. 
Please quantify the anticipated losses for each 
tax-based element of the affected communities? 

(2) As well, the impact to local businesses caused 
by a more than one-third drop in ranching income 
will have repercussions in every sector. Please 
quantify the losses for each sector, such as 
service industries which include restaurants and 
motels, manufacturing, tourism, etc. 

(3) Please address the socio cultural impacts, 
particularly demographic dislocation. How many 
ranching and other small business operations may 
be anticipated to fail and require the previous 
owners to relocate to ether communities to find 
work? 

Based upon the proposed failure rates of small 
businesses, please give a general description of 
the cultural changes which might be expected in 
those communities? If lands are no longer viable 
as ranching operations, should communiti.es in Hot 
Springs and Washakie counties expect those lands 
to be purchased by outside interests? lie 
subdivided? Be left unutilized because of 
economic inv lability? 



133.5 



GEAR- -RMP COMMENTS 



should those communities expect bank failures? 

4. Please delineate, by range site, what constitutes "good" 
condition? We believe it is important to clarify this in 
the Draft EIS, so that misunderstandings regarding 
"suitability" might be avoided. 

5. You suggest on P. 190 that 8,910 AUMs will be added to 
grazing allotments in the Resource Area as a result of good 
management. We believe the criteria used Lo determine how 
these AUMs will be awarded should be stated in the document, 
so that lessees know the "rules" and can document that they 
have mat BLM'S goals and merit these additional AUMs. 

Once again, we appreciate having the opportunity to comment on 
this document. If we can be of further assistance, or clarify 
any of our questions, please let. ua know. Thank you for taking 
the time to address our concerns. 



W. Michael Gear am 
Red Canyon Ranch 



Kathleen O'Neal Gear 



Governor Jim Gcringer 

Senator Allan Simpson 

Congresswoman Barbara Cubin 

Senator Craig Thomas 

Dick Loper, Wyoming Stock Board 



335 



Stephen Joel Coons 



MWZ9HB 



March 26, 1995 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 

Worland, Wyoming 82<l0t 

Dear Mr Ross; 

I am truly concerned about the Bureau of Land Management's draft management plan for the 
Grass Creek Resource Area. Although I have never visited that part of Wyoming, 1 plan to some 
day and do not want to see that the beauty of the land has been compromised or destroyed by oil 
an d gas development. Therefore, I am requesting [hat the BLM reconsider the plan and 
incorporate much more stringent protection of the area. Specifically, I am asking for the 
following changes in the management plan: 

■ Protect the Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek SpcciaJ 
Recreation Management Areas from oil development. 

■ Also designate the Badlands SRMA an Area of Critical Environmental Concern. 

" Protect all areas included in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside the Wilderness Study Areas. 

■ Provide more definite goals to address the overgrazing problems in the resource area. 

I am a resident of Arizona, another state that has spectacularly beautiful natural resources ranging 
from arid deserts to lush mountain forests. The preservation of this type of national treasure is a 
much more valuable investment than the short-term gain produced by oil and gas development or 
cattle grazing. Please take steps to change the current direction of the management plan for the 
Grass Creek Resource Area 

Sincerely, 



134 



135 



Kathleen M. Conner 

KXXXXXXXXXXXXXXX 

XXXXXXXXXXXXX 

March 27, 1995 

Mr. Bob Ross 

Team I^eadcr 

Bureau of Land Management 

P. O. Box 119 

Worland, Wyoming 82401 

Dear Mr. Ross: 

I am writing to you as a concerned citizen who very much loves the natural world and 
all its wildlife. I am deeply concerned about the destruction of our environmental that is 
taking place everywhere at an alarming rale in favor of economic exploitation.. Therefore, I 
am asking you to please take an active role in safeguarding our fragile ecosystem. I request 
that the following changes in your management plan be implemented: 

1) The Absaroka Foothills. Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas (SRMA) should be protected from oil development. 

2) The Badlands SRMA should also be designated an Area of Critical Environmental 
Concern because of its spectacular scenic and extremely fragile soils, 

Lpe 2J 

3) Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

4) Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next five years. 

Thank you for supporting these goals. 

Sincerely, 

til Kathleen M. Conner 
Sierra Club Member 



DECEIVED 



mz^rn 



BUMAU OF UKD E.VUtfiEHEM 



136 



Kirch 26, 1995 



Mr. 3ob Rcas, Tonm Lendor 
Buro&u of b»"d Jfcr.ugfl-^r.-t 
P. 0. 3ok It? 
Worl^d, tfyomir.g, fi24ot 

Door Mr. Flo obi 

Co n Q»rni n g tho Bunin of Ia.nd lfan«.ponont ' 3 Bighorn Basin ?ls.a in Wyoming, j 
respectfully auk that the following aha"g«a bo Bad* 1" m 

Tho J»b«arota Foothills Badlands, Bighorn Hvm, o n d Red Canyon Cr*»k Special 
aocrention Areas (SRKn) should bo, pretectal from oil dov«lopm*nt. 

The Bodlnfdo SRMA should also bo designated o" /iron of Critical Environmental 
Co"cort (AOIC) baoouse of Its apoctncular iconic a"d axtromoly fragilo oollo. 

Protoot all areas included in the C&naorTntioniBtr' AlW»ativ* to tho 
BUC'a Wildarnano Proposal, including lands outdid* HUd*r"osB Study Areas. 

Provida mora definits goula tc- address tha problem* of 0VBrgra«i"g i» tho 
roDOnroa area, B r c provide a tloeli n s to accomplish those goals i n tho n oxt' fivo 



Tha "It you for your atte n tlo n . 



Kflfipj. pq.flk 



137 



Bob Ross, Team Leader 

P.O. Box 119 

Worland, Wyo. 82401-0119 

In reference to the proposed Resource Management Plan (imp) for the Grass Creek 
Resource Area. I'm sending this letter to you and hope that you will forward to your local 
BLM office. 

I have reviewed the alternatives and if I had to pick one that would do the less 
amount of damage to the citizens of Wyo. it would be alternative B. Although this would 
have a negative impact on timber sale and grazing it would the lesseT impact on oil and gas 
industry and this would protect the states tax base that is received from Oil & gas. Has the 
BLM completed a study to find out what financial impact this will have on the state? 

Why is there a need to restrict grazing, oil and gas, timber sales, and recreational 
use? What studies have been completed and complied to justify your restrictions. Why are 
you restriction all public land users instead of dealing with the apparent cases on an 
individual bases. The customs, culture and the livelihood of the citizens of the state of 
Wyoming need to be protected and this is not in support of that, ¥e The BLM's lack of 
understanding of the complex inter-nat of local communities is sad. It take all of the citizens 
in recreation, oil and gas, timbering and grazing to make small 

fPg2] 

Communities thrive. Why doesn't the BLM ask for help from the communities when 

preparing such alternatives, that would enhance the community rather the destroy or degrade 

it? 

My pcrsonel belief is you need to go back to the drawing board. Ask for help from 
the local-come up with a plan that would be beneficial to the community and multiple 
poublic and users! 

/s/ Debbie Meeks 
V.P. Upper Green River Valley 
Charter Membership of the 
People For the West. 
Sublette County Citizens 
Box 763 
Big Pincy, Wyo 
83113 

Please send additional information that the PFW of Big Piney could help with! 



336 



RECEIVED 

MK29B95 



24-Mar-1995 



WM 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worlaud,WY 82401 

Dear Mr. Ross; 

I am writing you regarding the planned allocation of 1 00% of the Grass Creek 
Resource area to oil and gas development. I would urge yon to consider 
other alternatives, specifically: 

• The following unique and special areas should be protected from oil and 
gas development: Absaroka Foothills, Badlands, Bighorn River, and Red 
Canyon Creek Special Recreation Management Area. 

• The designation of "Areas of Critical Environmental Concern" should be 
given to the Badlands Special Recreation Management Area. This is due 
to the special value of scenery, extremely fragile soil types, and the special 

nature of this area. 

• Clear and well-defined goals are needed to address the problem of 
overgrazing in the entire resource area. In addition, a budget and time 
frame need to be associated 10 achieve the resolution of this problem. 

• All lands included in the Conservationists ' Alternative to the BLM's 
Wilderness Proposal need to be protected. This includes lands outside of 
the Wilderness Study Area. 

I hope that you value and incorporate these strong recommendations. 

Sincerely, 



139 



GRASS 



Grass Roots Alii. 
Box 263 Greybull, WY 82426-2063 



[Same as Letter #1] 



nee For State Sovereignty 



Additional comments: 

It is a sad commentary that people like myself must fight against the people who are 

supposed to be representing us in land management. I am not in favor of our public lands 

being run by ranchers or industry, but I certainly oppose the opprcsivc nature that the BLM 

has shown toward everyone who lives in the west, wake-up ad gel real, or you will be 

replaced. 

Name: David O. Bayert 
Mailing addaress; xxxxxxxxx 
City.State, ZIP: xxxxxxxxxxxxxxxxx 

Signed: /s/David O. Bayert Date: 3-27-95 



gg4gg 



114© 



&> 263, Q-ahtt. 1VIJ 62426-0263 



January 17, 1995 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Woriand,WY 82401-0119 



S m'1 

(307J?(>3-22i* 



Re: Grass Creek Resource Area Draft Land Use Plan 



Mr. Bob Ross. 



The purpose ofthis letter is to oppose mart resrrictkitis on Wyoming's public binds. Your 
document is filled with restrictions thai your agency is not authorised lu impose. We speak 
»ith the authority of the ("otutttution of Utc United Slates of America and thai or the greal state 
of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, ihe control and usage of 
our land belong to our slale us welL Prudent management of our resources, is sound business 
practice, and our businesses operate with that in mind now. We have managed the affairs of our 
state quite well . . . if you do not agree with (his, took At the eastern states. 

This plan does run consider the needs of the citizens or businesses of Wyoming, ycT you 
would impose this an us hs if we did not value our public lands- Any restrictions deemed 
necessary should come from the slate of Wyoming. 

We oppose this document in lis entirety. 

Additional comments; 



Maflaig addnas: _ f £oj ( 



1 kT 



cav, SUU & ZIP: Xai;„ M ftfte 



J^uJLl. JLumzi 



.ifaAf 



141 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box U9 
Worland, Wy. 82401 

Dear Mr. Ross, 

In the past, there have been time when I have been encouraged by the stand that the 
BLM has taken in managing land use, but the draft management plan for the Grass Creek 
Resource Area is certainly not one of them. Please don't implement this plan. 

Protect the Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek 
SRMA from oil development and designate the Badlands SRMA as ACBC. This whole area 
is so unbelievably beautiful and you should know from past experience what happens to the 
land from the oil, timber and ranch industries. Total devastation! 

Please take time to really see what those proposals might lead to and plan for our 
future generations. I am 72 years old and during my lifetime I've seen greedy people do 
irrevocable damage to this planet. It's not to late to save what is left. I want this for my 
grandchildren and my great grandchildren and for every one elses. Thank you! 

Sincerely, 

hi Sara H. Haubert 
xxxxxxxxxxxx 

X XXXXX XXXXXXXXX X 

3/27/95 



337 




Ml 



QiennisJ. andtSarfara Lynn mmSa 



March 21 , 1995 



Mr. Bob Roes, Team trader 
Bureau of Land ManagtMiettt 
world District 
P. 0. Box 119 
Norland, Wyoming 



Dear Mr. Koes; 



(irons Creek Art 
Com menu 



We have received and reviewed the proposed Crass Creek 
Resource Area, Resource Management flan, Draft Hnvironmental Impact Statement , 

We were raised in the general area and wo have had a permit 
for grazing on the Fifteen Mile Allotment since 198!=. The 
permit has been held by Lynn's family, however, since 1935, 
first in the name of J. M. Andrews [Lynn's Grandfather) and 
in 1952 an allotment wan issued to M Diamond Sheep Conroany 
(Floyd and Ruth Kleinschmidt, Lynn' s parents). These 
allotments were contained and attached to the Ten Mile farms 
in the Ruth Kleins chmidt Trust and then purchased by us in 
1985. We are familiar with the erratic weather; the 
generally arid conditions that exist; and the requirement 
for good rar.ge management to maintain or improve the range 
conditions in the area, we are also iamiliar wich the value 
of the archeology, wildlife, and mineral resources. 

The area haa ueen multiple use- Surrounding 
communities have derived benefits trom livestock' production, 
minera's development, wildlife benefits, limited timbering 
activities, and limited recreational use. "The orinciples 
Of ecosystem management, used in BLM's day-to-day management 
Of r.he public lar.ds and resource, include the recognition 
that people and their social and economic needs are an 
integral part of ecological systems." The area is unique 
and has maintained its ur.iqi;eriena over t.he many years cvon 
to the extent to suggest some areas need to be "preserved" 
for future generations. To make extensive changes in the 
current use of the lands will change Che uniqueness of the 
area. However, some aspects of the management, need to be 
addressed due to the continual change in use observed in the 



<HAQE WD. 2 

area. Sensitive lands and resources need protection to 
retain Che unique resources and biological diversity. 

1) Cultural, Paleontological & Natural HiBtory Resources: 

These resources need protection for future study and 
observation, however the proposal to expand the 
opportunities tor scientific and educational uses will 
actually provide less protection than afforded in the 
past by making these areas more accessible 10 more 
people. 

2) land use or resource: Those lands that can be used for 
agricultural purposes (farming) should be sold and put 
into production. These are minor acres, adjacent tc 
private lands with far less value as "BLM administered 
lands" . 

3) Livestock grazing management: From the numbers given 
in the draft EIS, the livestock industry has been 
responsible in keeping the grazing numbers to meet the 
forage production with less AMU's in periods of lower 
production and more AMD's used in years of more 
moisture and more forage production. Areas of concern, 
including areas of high erosicr or excessive use, will 
require protection by fencing tc exclude the livestock, 
however the cost to build and maintain these structures 
was not addressed and Z assume it will.be the 
responsibility of the permittee. Decreasing livestock 
numbers to provide forage for wild horses is not an 
answer; the numbers of wild horses on the range need 
to be addressed by keeping herd sizes at the current 
levels. Expanding the herd area will also effect other 
resource uses and will have additional stipulations for 
grazing and mineral extraction imposed. The timing of 
grazing use and the numbers of AMU's will require some 
adjustments by all permittees. Modification of permits 
for sheep or cattle use and adjustments in AUK numbers 
must be applied to all permittees with adjustments 
substantiated with scientific evidence from studies 
conducted in the resource area. 

3) Treatable Minerals: The mineral resources have been of 
significant value to the area and Wyoming by supplying 
revenue through tuxes and royalty and providing jobs 
and supporting the local economy. Protection of other 
resources can be achieved by the use of directional 
drilling in areas of no or limited surface occupancy. 
Development of the mineral resources and especially the 
natural qas resources is necessary to sustain the 
economy of the area. 



142.2 



gWLIS CWFEKJiamA COMMENTS 
<tngii$to.3 



142.3 



4) Recreational Management: Extensive development of 

potential recreational sites is proposed, however the 
present use of the sites was not defined and the 
potential benefit of development was not projected. 
The question of who is to pay for the development and 
maintenance of the proposed sites was not addressed. 
The cost/benefit of the proposed developments were not 
addressed. 

The Preferred Alternative is a movement from the 
current use of the area to more recreational, however the 
increased use by recreatianists is questionable. The 
significant costs to be incurred in the preparation of the 
area for more recreational use is not adequately supported. 
Timbering, grazing and mineral extraction all pay for their 
use of the lands and provide a significant benefit to the 
local communities. The limited use and excessive cost to 
increase recreational use above that now observed in the 
area is not justifiable and will have very limited benefit 
to the surrounding communities. 

Protection of the resources in the Grass Creek Resource 
Area is of great importance to everyone. Prevention of 
excessive erosion will provide the ranching community future 
use of the lands by prudent application of acceptable 
measures today. Mineral development can be accomplished 
without detrimental harm caused to the areas by prudent 
application of technology as required in the ffSPA process*. 
Recreation has been an important resource in the area and 
has been enjoyed with the current activities using the other 
resources, however the minimal increase in recreational use 
and no increase in funding provided by the recreationists , 
docs not justify the additional expenditure for this 
activity. Attempting to expand the recreational resource at 
the expense of the other resources is not justified. 

Alternative "B" proposed in the Draft EIS seems to most 
nearly address these concerns we have outlined above. This 
proposal will provide for the protection of sensitive areas, 
yer. allow development and use of the other resources. 
Recreation as currently used in the areas will, continue and 
will have additional development. Future development of the 
recreational aspects can be made if and when the demand 
occurs. Grazing would bo allowed to continue with a 
reduction in the AMU's and adjustments in times of grazing 
and protection of sensitive areas to enhance the forage 
production The changes propose by Alternative "B" would 
have the leaat impact on the customs and culture of the area 



WlffE .WD. 4 



142.4 



yet achieve the necessary modifications for protection of 
all resources and allow the continuation of the multiple use 
of the area. 



Dennis •'and Lynn Br^rbec 




338 





RECEIVED 




m 3 1995 

1 


BUREAU OF LAND RMA6£Uil><: 



143 



Dear Mr Bob Ross, 



I believe thai the Draft Management Plan for the Grass Creek Resource Area needs 
revising badly. Please incorporate Hie following changes into the draft plan: 

• The Absaroka Foothills. Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas (SRMA) must be protected from gas and oil 
development. 

• The Badlands SRMA should also be designated as an ACEA because of its 
spectacular scenery and fragile soils. 

• Protect all ares included in the Conservationist's Alternative to the Bl.M's 
Wilderness Proposal, including lands outside of Wilderness Study Areas. 

» Provide more definite goals to address the problems of overgrazing in the rcsonrce 

area, and provide a time line lo accomplish the goals in the next five years. 



I believe thai with these changes, you will have a good plan for the Giass Creek Resource 
Area- 



Cordial ly, 
Robert Markcloff 



144 



Dear Mr. Ross, 

i comment as follows, on the draft management plan for ihc Grass Creek Resource 
area: 

1) 100% of the areas should NOT be leased for oil & gas development. 

2) The Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek SRMAs' should 
be protected from oil development. 

3) The Badlands SRMA should also be designated an Area of Critical Envir. Concern 
because of its spectacular beauty & extremely fragile soils. 

4) Protect all areas included in the Conservationists' alternative to the BLM's wilderness 
proposal including lands outside the Wilderness Study Areas. 

5) Provide more definite goals to address overgrazing in the resource area £ a timeline to 
accomplish these goals in the next 5 years. Thank you, 

/s/ Eleanor MacLellan 



xxxxxxxxxxxxxxxxxxxxx 



RECEIVED 



Mr. Bob Ross 

BLM Team reader 

Box 119 

Wocland, Wyoming 82 41 01 



Dear 



Ross 



I am writing to ask. you consideration for the following with 
regard to the Grass creek RJcsourceAre Management Plan; 

1. Withdraw the Absaroka Foothills, Badlands Red canyon Creek 
and Bighorn sprecial Recreation Management Areas, and the 
proposed Meeteetse Draw, Upper Owl Creek and Fifteenmile ACECs 
from all oil and gas leasinq due to the sensitive nature ot 
these areas and the Inadequacy of proposed stupul ations; 

2. Improve range condition to encourage ecosystem health and 
biodiversity by incorporating time limitations; 

3. Limit off-road vehicle use to existing roads and trails 
as proposed, prohibit their use in roadless areas, ACECs and 
WSAs. Strictly enforce these limits. 

Damage done to this area is not easily undone, and would be 
decades, if not centuries, in the undoing. I urge you not to 
cave . in to,, temrjpxaj^^i^4cal sentiments, but to take the long 
picture with, t Hou^ht^for future generations and to the health 
of the entire ecosystem. » 




RECEIVED 



MAR 3 1995 



I juseaiIOF LMBKANJtfEHENI 



146 



ot Land Managei 



Dear Sirs, 

T have recently been told Ot your plans to lease an 
area named Bighorn Basin Cor oil and gas development. I 
have deep reservations about the removal of thin, our land. 
A single bleach spot on your dress is cause for dismissal, 
discard, perhaps it will be bought secondhand. 

I would ask the plan be looked at again with changes 
SUCh as designating the Badlands Special Recreation 
Management Areas with ACEC status, providing protection for 
the Absaroka Foothills, Bighorn River, and Red Canyon Creek 
SRMA' a from oil and other development. Reread the 
Conservationists ' Alternative to BLM's Wilderness Proposal 
and protect these lands as well as lands outside Wilderness 
Study Areas. Finally, set detinite goals to address 
overgrazing problems in resource areas in the next tew 
years. 

Please, leta get this done cleanly and have it last tor 
some time regardless of decision. Please, don't cave in 
because of big money, I have never been to these areas but 
hope to enjoy them all in time. Poor men can still walk and 
buy bullets, parking garages make people dizzy, and the 
earth has enough pavement in the air, don't you agree? 




339 



147 



Bob Ross, Team Leader, 
Bureau of Land Management, 
Worland, Wyoming 



Dear Sir: 



xxxxxxxxxxxxxxxx 

XXXXXXXJCXXXXX 

xxxxx 



March 27, 1995 



Concerning the Grass Creek Resource Area of the Bighorn Basin, please 
consider the following changes in the management plan. These changes have already been 
studied by other; I also feel that these changes are essential to keep on of the most beautiful 
location of Wyoming from severe damage. 

1. Protection from oil development is needed in the Absaroka Foothills, Badlands, 
Bighorn River &. Red Canyon Creek Special Recreation Management Areas. 

2. The fragile soils and outstanding scenic qualities of the Badlands SRMA should 
also be designated an ACEC. 

3. All areas included in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Areas need protection. 

4. More definite goals to be accomplished in the next five years are needed to 
address the problems of overgrazing in the resource area. 

Wyoming has long been my favorite State in the Rock Mountain West. Its' scenery 
(along with Glacier National Park in Montana) is (he very finest scenery to be found 
anywhere. 

Sincerely, 

/s/ Walter Rivers 



MAR 30 1995 



148 



BUREAU OF lAHD L-J.r,AGE!«ENT ! 



20Marcc 1995 



?^3-;5?.T>am Leader 

Bureau o: Land Management 

TTyt'tttttd. WT 5*401 



In response to "our recently released draft management plan for the 
;jr ass Creek Resource Area, l ask you to mate tie following changes 

• The Absorofca Foounib, Badlands, Bigrwrn River, and Red Canyon Cieek 
>;><■<!*: Recreate Management Areas should t» protected from oil 
aevelopment 

• The Badlands SRMA should also be designated an Area of Critical 
Environmental Concern because of its spectacular scenery and extremely 
fragile sotfs 

« Protect ail areas included in me Con ser va Lion ists Alternative to the BUf's 
Wilderness Proposal including Lands outside the WSA's 

• ?::>'n-j? more definite goals to address the problems of overgrazing m the 

resource area and provide a timeline to accomplish those goalc in the next 




147 



Bob Ross, Team l>eadcr, 
Bureau of Land Management, 
Worland, Wyoming 



Dear Sir: 



XXXXXXXXXXXXXXXX 
XXXXXXXXXXXXX 

XXXXX 



March 27, 1995 



Concerning the Grass Creek Resource Area of the Bighorn Basin, please 
consider the following changes in the management plan. These changes have already been 
studied by other; 1 also feel that these changes are essential to keep on of the most beautiful 
location of Wyoming from severe damage. 

1. Protection from oil development is needed in the Absaroka Foothills, Badlands, 
Bighorn River & Red Canyon Creek Special Recreation Management Areas. 

2. The fragile soils and outstanding scenic qualities of the Badlands SRMA should 
also be designated an ACEC. 

3. All areas included in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Areas need protection. 

4. More definite goals to be accomplished in the next five years are needed to 
address the problems of overgrazing in the resource area. 

Wyoming has long been my favorite State in the Rock Mountain West, Its' scenery 
(along with Glacier National Park in Montana) is the very finest scenery to be found 
anywhere. 

Sincerely, 

Is/ Walter Rivers 



RECEIVED 



MAR 3D 1995 



148 



BUREAU OF UND WIAGiSEN! 



26 March iyys 



Sob Ross, Team Leade: 
Bureau of Land Management 

Wwrland. WT 5240! 

Mr ftoi£, 

In response to your recently released draft management plan for the 
Grass Creek Resource ftrea, I ask you to max- the following changes 

• t;i* Afcsorofca Poothffls, Badlands, Bighorn River, and Red Canyon CreeK 
special Recreation Management Areas should be protected from oil 
development 

• The Badlands SRMA should also &e designated an Area oi Critical 
Environmental Concern because of its spectacular scenery and extremely 
fragile soils. 

• Pretectal areas included in the Conservationists' Alternative to the &lm« 
Wilderness Proposal including lands outside the wsa's 

• Provide more definite goals to address the problems oi overgrazing in the 
resource area and provide a timeline to accomplish those goals in the next 



Vyf 



340 



149 



Dear Mr. Ross 

Please don't tleslroy are wildlantls! I am specifically writing about permitting the oil and 
gas development in the Grass Creek Resource Area. The area is historical and scenic land, 
which includes the Ahsaroka Mountains and part of the badlands, also, many animal need 
that area first to survive. Saving our wildlands is so beneficial to all living things including 
us. A first glance at these areas may not seem like much to some people, but if we look 
closer we can learn more about ourselves. Area like the Grass Creek area took millions of 
years to develop into what they are today. Besides, I have been wanting to see the badlands, 
and definitely people in the next generations would love to seem them also. 

Therefore, before you destroy all of the land for a temporary profit, please take another 
look at it. Because once you developed all over it and sucked up all the oil, you cannot 
make the land back to the way it was. 

Sincerely, 

I si Julie Serocki 

X XXXX XXXXXXXX XJCXX 
XXXXXXXXXXXKXXXXXXXX 



March 27, 1995 



RECEIVED 



m 3 1995 



150 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
norland, MY 82401 

Mr. Robs: 

I am writing regarding the BLM draft management plan for the Grass 
creek Resource Area. Because of concerns about oil and gas 
development leasing, I suggest the following changes: 

The Absaroka Foothills, Badlands, Bighorn River and Red Canyon 
creek Special Recreation Areas should be protected from oil 
development. The Badlands SRMA should also be designated an Area 
□f Critical Environmental Concern because of its spectacular 
scenery and extrBmely fragile soils. 

All the areas included in the Conservationists' Alternative to the 
BLM wilderness proposal should be protected, including the lands 
outside Wildernss Study Areas. 

The management plan should provide more definite goals to address 
the problems of overgrazing in the resource area. The plan should 
also provide a timeline to accomplish these goals within the next 
five years. 

Thank you. 

Sincerely, 



~W(tAfr &&*^(f~ 




03/26/95 

Richard W- Hoffman 



RECEIVED 






AHl'v 



Bob Rosa-, -Team Leader 
Bureau of. Xand Management' 
■.0. Box 419, 






P.O. BWOliiV -i. ■-,-,.; tin ^ ,: ,l«lB£> 



I sua writing you ; be<}auae I believe that the Bureau :a£ Land 
Management'^ Bighorn Basin tlan wn'ieh "calls for -massive oil and gas 
development must 1 be changed. ■* 

I have.<traveled by''*-utomobile throughout '-,- this beautiful; and . , 
fragile .ar^-.i(KW.t&<4 'in.<j^aing. In 19Blj -I" drove .a rental ■ (Jar ovjer 
the easterners lopes.- qX tip** Abaaroka .Mountains and dawn., into' central 
Wyoming. 'Then I retr-ae'wd .my rbufc? . pver the "eoinie 'road on. my return 
drive to ^to*r±etajS^ " rtyoa ing'. -. The. western alopee jb£ the Absaroka 
Mountains'are. Yery arid- s and "this ayea includes- finproe'Bive badlands 
and very sfCenlc spectacular rock forniati<tae. The eKfrfeern slopes of 
the same HJcWntain range- -provide a sharp eotatraat with, ;t$ieir .lush, 
green foreete and abrcndart mountain streams" and. waterfalls'. . 

I alen took a btfa. rlda through the- m^^ii^i^iirm^paai^^t* . 
traveling * from Great Sg&A^Mjpntana tq^Oa^S^I^SiM^,!^^^*^^ ' 



the Sioux defeated General George Armstrong , Custer on Juab. 25, 18?6. 
The areaeaivng .the Big Horn and iiittle Big .Horn Rivers are grasslands 
that are pej»'iodI*ally f lodded by the rivers running th^flugh them. 
The area along thtKBlg Horn River is delicate ecologically and the 
water quality in t-he.se riparian areas must be protected.". V 

The JffiSa'r'Qka, 'foothills,. Badlands-, Big Horn RiyeSV'land &ed Canyon 
Creek Spsa^l.B.ecriM^iion Management Area tF must be protected from oil 
and gas -development. ' ^ e Abstfi'oic*- Badlands Spec ial-Becreat ion 
Kar.aKeme»t;-Areai^H : ould-b»yde>iitiat*d as an- Area of .qacltioal ' " -. - 
£nv-iroimeaiai\Cpftee^,beea-u3S'- pf 2-ts scenic and ver 1 ?; fragile soils. 
T"ie soil^-.-in this -art^ iar^a Aie. very exposed and are, £ujD$*b-t . to wind 
erosion. .-. ■!*&', an ".aiicL, desert', environment such as :.tH^3,. Balis' .are ..arach 
more frag±l*i-,and tend to .migrate much more f requehtlj'.-atid .fir'e, heavily 
impacted by'nuaan disturbance. :,. 'V 



tt) 



151.2 



I urge yem to prbtect all. areas included in the 'Cbiajae-rvationists ' 
Alternative' to the Bureau- of Land-'iManagement ' 9- Wilderness "Praposal 
including Uands outside Wildefn'^'-Sttdy Areas. The Bureau -off Land 
Management must set very specific goals to address' the problems caused- 
by overgraaing ±a .the resource 'area and provide^ a definite time-table 
to achieve these goals wlthip CVfe^Et^xft /lye years'., 
J -(.-, k'S *'"■■-■ . V ,V* 

Tbankyou f or- yonr .a^tenti^n tp . my fc-rflinftn tla and observations. " 



:*;, Richard W. Hoffman 



341 



RECEIVED 



WR3I B95 



152 



Bnb Ross 

Team Leader 

Burcaj of [.and Management 

P.O. Box 119 

Worland. Wyoming S2401 

Dear Mr. Ross, 

Following my learning of BLM's Bighorn Basin Plan, as an ordinary 
cili7.cn, I am writing 10 you to ask you fo_r the following chan g es in 
the management plan: 

(1) The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas (SRMA) should be 
p,rpjtecj;.c,d from oil development. 

(2) The Badlands SRMA should also be designated an ACEC because 
of its spectacular scenic and extremely fragil soils. 

(3) Protect all areas included in the Conservationists' Alternative to 
the BLM's Wilderness Proposal including lands outside Wilderness 
Study Areas. 

(4) Provide more definite goals to address the problems of 
overgrazing in the resouce area, and provide a timeline to 
accomplish those goals in the next five years, 

If BLM's current plan was implemented it would permit virtually 
uncontrolled oil and gas development in the natural gem of the 
Bighorn Basin, one of the most beautiful pans of Wyoming! Please 
don't let that happen, countless generations of humans after us are 
entitled to enjoy this beautiful parts of Wyoming untouched by 
human development as it stands now! 



Thank you for caring. 



X 



\ 

6 




153 



: T1'3 " 



Bob Rosi 

Team Leader 

Bureau of Land M»8»|enieol 

P.O. Box My 

Worland, Wyoming 8240I 

Dear Mr. Robs, 

Following my learning of BLM's Bighorn Basin Plan, as an ordinary 
citizen. I am writing to you to ask you £p_r the following chug gES in 
the management plan: 

(1) The Absaroka Foothills. Badlands. Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

(2) The Badlands SRMA should also be designated an ACEC because 
of its spectacular scenic and extremely fragil soils. 

(3) Protect all areas included in the Conservationists' Alternative lo 
the BLM's Wilderness Proposal including lands outside Wilderness 
Study Areas. 

(4) Provide more definite goals to address [he problems of 
overgrazing in the resouce area, and provide a timeline to 
accomplish those goals in the next five years. 

If BLM's current plan was implemented it would permit virtually 
uncontrolled oil and gas development in the natural gem of the 
Bighorn Basin, one of the most beautiful parts of Wyoming! Please 
don't let that happen, coumlcss generations of humans after us are 
entitled to enjoy this beautiful parts of Wyoming untouched by 
human development as it stands now! 



Thank you for caring. 



##» 



7 



154 



Mar. 26, 1995 



Dear Mr. Ross, 



I am writing to express my concern of your managment plan of the Grass Creek 
Resource Area. I understand that your plan would allow complete oil and gas leasing inthe 
resource are. I used to live in Rock Springs and currently work as an engineer for a major 
oil company. 

I believe that you must iftekide exclude significant areas from an proposed leasing. In 
particular, Absaroka Foothills, Badlands, Bighorn River, and& Red Canyon Creek Special 
Rec. Mgmt Area should be protected from development. Badlands should be designated an 
ACEC to give the needed special protection! 1 support the Conservationists' Alternative to 
the BLM's Wilderness Proposal and want all the lad in the Alternative Proposal protected. 

As a member of the oil industry, I understand the need to develop our oil and gas 
reserves. I also understand the greater need to protect our unique and precious lands!!! 

Yours truly, 

/s/ G Lafrarnboise 



155 



3-27-95 

Dear Mr. Ross: 

Re: Grass Creek Management Area 
How can uncontrolled oil & gas developments be Permitted in the Big Horn Basin area? 
SRMA areas should be protected from oil development. The Badlands SRMA should be 
considered for Special concern because of scenic views and fragile soil, overgrazing should 
be addressed with a rime-line. Protect all areas inside & outside the Conservationists' 
Alternative to BLM's Wilderness Proposal. 

Please change the current Plan to cover the above suggesions. Thank you. 
Sincerely, /sJ Catherine K. Mueller 



342 



RECEIVED 



H 



HOFLAMDVJUMiMfV 



Wendy Derain 



Bob Ross, Team Leader 
Bureau of land Management 
P.O. Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross: 

As a concerned citizen, 1 am writing this letter in regards to the Bureau of Land 
Management's recently released management plan for the Grass Creek Resource Area 
(southwestern quarter of the Bighorn Basin) in Wyoming. 

I believe the Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas should he protected from oil development. 

Also, the Badlands Special Recreation Management Area should be designated an Area of 
Critical Environmental COOCKD because of its very fragile soils. 

I also urge that all areas included in the Conservationists' Alternative to the Bureau of Land 
Management's Wilderness Proposal, including lands outside Wilderness Study Areas, be 

protected. 

It is necessary that more definite goals addressing the problems of overgrazing in the 
resource area be provided, including a timeline to accomplish these goals within the next 
five years. 

I sincerely hope these changes in this management plan will be seriously considered in order 
to preserve this exceptionally beautiful area. 

Very sincerely, 



Wendy Derain 



i. 



157 



March 27. 1995 

Bob Ross, Team Leader 
B.L.M. 

Dear Mr. Ross: 

I am very concerned about the massive gas and oil development being planned for the 
Grass Creek Resource Area. Having travelled through the Absaroka Mountains I am aware 
of the beauty of this region. 

I would like to see the following changes in the plan: 

- The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Recreation Management Areas should be protected from gas & oil development. 

- The Badlands SRMA should also be designated an ACEC because of its fragile 
soils and spectacular scenery. 

- Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study areas. 

- Provide more definite goals to address the problems of overgrazing in the resource 
area, and provide a timeline to accomplish those goals in the next five years. 

Sincerely, 

fit Phil Broussard 
xxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxxxx 




mB 



March 22, 1995 



Bob Ross. Team Leader 
Bureau of Land Management 
P Box 119 
Worland, Wyoming 82401 

Dear Mr Ross: 

I am writing to urge you to make the following changes in the management plan for 
the Grass Creek Resource Area which comprises the southwestern quarter ot the 
Bighorn Basin. 

1 The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek 
Special Recreation Management Areas (SRMA) should be protected from oil 
development 

2 The Badlands SRMA should also be designated an ACEC because of its 
spectacular scenic and extremely fragile soils. 

3. Protect all areas included in tne Conservationists' Alternative to Ihe BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

4 Provide more definite goals to address the problems of overgrazing in the 

resource area, and provide a timeline to accomplish those goals in the next five 
years. 



Q$£^fk^.^^Jt-iLAl^c/^ - 



m 5i 



TOUI Of LAND MMKIEN! 



GRAVES & ASSOCIATES, LIMITED 



159 



3o7-P96-79a8 PAX ."i07-fl^6-Bfiti8 
Apri I 3, J 99 5 



Barrel! Barnes, Dist. Mcr. 
Hureau ot Land Management 
worland District Qffic* 
P.O. Pox 119 
Worland, Wyoming 82401-0119 



RE: Crass Creek Res- 
Dear Mr. fiarnes: 



jrce Artja Draft. 



I generally agree with the plan use alternative chosen 
by your office, and believe L.hai sufficient protection to the 
environment is given. One study area, however, does deserve 
more attention. 

With few exceptions, emphasis should be directed toward 
mineral development within the area. This, however, can not 
be done until cursory geologic examinations are completed. 
As usual, the B.1..M. spends little tSme on geological eval 
uationa, especially thar which pertains to the so-called hard 
minerals. t am aware of numerous unmentioned mineral con- 
centrations in the Crass Creek area which have development 
potential. Said development need not effect the environment 
in any way. As a matter of tact, through use of modern re- 
clamation methods, improvements would be imminent. Laws are 
presently in place for that result. 

Only passive mention is given (see "GRASS CREEK RESOURCE 
AREA RESOURCE MANAGEMENT PLAN DRAFT ENVIRONMENTAL IMPACT STATE- 
MENT", September, 199-11 to the titan ium-zircon deposits located 
near Lhe town oi Grass Crcuk. This consists of large h iqh grade 
deposits of material which is imported into the United States, 
dramatically effecting the balance ot payments. The deposit 
io presently known to be economically viable, find will be 
produced in the near future. Because this will provide irietny 
jobs in the area, it is reconracr.dud that special Attention be 
given which allows che pursuit of mineral exploitation activ- 
ities. 

Regardless to what the tavirOtUMttttti activists may say, 
Wyoming's future nnimimi i |£l I'll the development of public la 



WG/bg 
f.les 




343 




160 



March 31, 1995 



Darrel Barnes 

District Manager 

Bureau of Land Managemen 

Worland District office 

P.O. Bolt 110 

Worland, WY 32401-0119 



Dear Mr. Barnes: 

we attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft EIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects li)se cutting 
back on the grazing permits, expanding the wild horse range, which 
i s not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming, We think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses. If they are meant to be there, Lhey will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses. 

Sincerely, -sfcw I"U«**-^V 




Dar 



2l 



District Manager 

Bureau of Land Management 

Worland District Office 

P.O. Box 119 

Worland, WY 82101-0119 



Dear Mr 



We attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft SIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming. Ke think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses, if they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses. 
Sincerely, 






RECEIVED 



APR 31! 



162 



SUtfMj OF UiiD EARASEHEin j 



March 31, 1995 



Darrel Barnes 

District Manager 

Bureau of Land Managemen 

Worland District office 

v.q. Box 119 

Worland, WY 62401-0119 



Dear Mr. Barnes: 

We attended a meeting March 30 in Lovell, Wyoming. The Crass Creek 
draft EIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wi Id horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that, 
if the wolves were to move in to the Grass Creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming. We think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses. If they are meant to be there, they will take care of 
themselves with all the Came and Fish laws and protection they 
already have for endangered 3pecies and wild horses. 
Sincere! 



ftPR 31! 



ai.!KtAU QF L/l-iD CASftStMEWT 



March 31, 1995 



Darrel Barnes 

District Manager 

Bureau of Land Management 

Worland District Office 

P.O. Box 119 

Worland, WY 82401-0119 



Dear 



Mr 



Grass Creek 
ere totally 



We attended a meeting March 30 in Lovell, Wyoming 
draft EIS public hearing was on the agenda, 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass Creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
hnnef it nf the people of Wyoming, we think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses. If they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses. 

sincerely. 



%c% bJiM* 



XMrttL 






344 



RECEIVED 



APR 3! 



iURtAU OF IAS0 W.KAGLMErP 



1@4 



APR 31! 



auRiAuof iA!»0>v.'-:B;!rr.,f''i 



165 



March 31, 1995 



Darrel Barnes 

District Manager 

Bureau of Land Management 

Worland District Office 

P.O. Box 119 

Worland, WY 82-101-0119 



Darrel Barnes 

District Manager 

Bureau of Land Management 

worland District office 

P.O. Box 119 

Worland, WY 82401-0119 



Dear Mr. Barnes: 

We attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft EIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there ore not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, raining and cattle industries alive and well for the 
benefit of the people of Wyoming. We think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildl ife and wild 
horses. If they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 



Dear Mr. 



Rn 



already have for endangered spc 




nd wild horses. 



we attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft RTS public hearing was on the agenda. Wg were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass Creek planning area, all 
other interests in the area would bs out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming. We think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses. If they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses. 
Sincerely, 



RECEIVED 



APR 31995 



lis 



RECEIVED 



167 



! BUfiEAU OF LAKO KAHA«£MENT 



1 BUB£AU OF UNO CARA8£«E"1 



March 31, 



March 31, 1995 



Darrel Barnes 

District Manager 

Bureau of Land Management 

Worland District Office 

P.O. Box 119 

Worland, Wy 82401-0119 



Darrel Barnes 

District Manager 

Bureau of Land Kanagamer. 

Worland District office 

P.O. Box 119 

Worland, wv siMci-oiiq 



Dear Mr. Barnes: 

We attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft EIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years. They also 
discussed cutting back on mining and oil, Which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass Creek planning area, all 
other interests in the area would be out. We strongly feel that we 
don't need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming. We think the ELM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wl Id 
horses. If they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses. 

Sincerely, 



Dear :■ 



Bar 



We attended a meeting March 30 in Lovell, Wyoming. The Grass Creek 
draft EIS public hearing was on the agenda. We were totally 
surprised at what we heard; they brought up subjects like cutting 
back on the grazing permits, expanding the wild horse range, which 
is not needed, since the horses there are not wild horses but 
horses that have escaped from ranches over the years . They also 
discussed cutting back on mining and oil, which takes away money 
from the schools in Big Horn County. Also, in the proposed land-use 
plan, there are two different places where provisions are made that 
if the wolves were to move in to the Grass Creek planning area, all 
other interests in the area would be out. We strongly fee] that we 
don' t need any more wild horse ranges and that we do need to keep 
our oil, gas, mining and cattle industries alive and well for the 
benefit of the people of Wyoming. We think the BLM should drop this 
whole plan and start taking care of what is important to this part 
of Wyoming, and quit worrying about wolves, wildlife and wild 
horses. If they are meant to be there, they will take care of 
themselves with all the Game and Fish laws and protection they 
already have for endangered species and wild horses- 



aly. 



r ,y/^ 



IQK, 



345 



o» s : 



RECEIVED 



APR 3B95 



use 



BUREAU OF UXD EAHAGEMENI 

i<r-V r& 'W"J''"- W ^* I "'C j 



AliccTscng 



Team Leader 

Bureau of Lain! Management 

P.O. Box 119 

Worland, Wyoming 82401 

Dear Mr. Ross, 

Following my learning of BLM's Bighorn Basin Plan, as an ordinary 
citizen, I am writing to you to ask you £o_r the following chang es in 
the management plan: 

(1) The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

(2) The Badlands SRMA should also be designated an ACEC because 
of its spectacular scenic and extremely fragil soils. 

(3) E xotect all areas included in the Conservationists' Alternative to 
the BLM's Wilderness Proposal including lands outside Wilderness 
Study Areas. 

(4) Provid e more definite goals to address the problems of 
overgrazing in the resoute area, and fcro_vide a timeline to 
accomplish those goals in the next five years. 

If BLM's current plan was implemented it would permit virtually 
uncontrolled oil and gas development in the natural gem of the 
Bighorn Basin, one of the most beautiful parts of Wyoming! Please 
don't let that happen, countless generations of humans after us are 
entitled to enjoy this beautiful parts of Wyoming untouched by 
human development as it stands now! 

Thank you for caring. 



h 



1 



XXXXXXXXXXXXXXXXXX 
XXXXXXXXXXXXXXXXXX 

March 28, 1995 

Mr. Bob Ross, Team Leader 
Bureau of I .and Mgmi. 
P.O. Box 119 
Worland, WY 82401 

Dear Mr. Ross: 

Please make the following changes in the management plan for the Grass Creek 
Resource Area. 

Protect this area fr om oil development which would be unconatrolied and threaten this 
beautiful part of Wyoming. 

The extremely fragile soils warrant an ACgQ .jn the Badlands SRMA. 

More definite goals should be provided to address the problems of overgrazin g in the 
resource area — a timeline for the next 5 years and what should be accomplished shoulkd 
also be provided. 

Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal. 

Thank you, 

hi Lynda Fanning 



APR 3 1! 



170 



March 31,1995 

Dear Mr . Ross, 

I am extremely disturbed to learn of recent proposals to further develop 
lands in the Grass Creek Resource Area. 

What upsets me most is that the increase of oil and gas leasing will 
likely destroy what is one of Wyoming's last refuges for quality type desert 
mule deer hunting, not to mention the hunting for sage grouse, chukar and 
Hungarian partridge the area provides. 

Years ago I could find quality deer hunting in the Flat Top and Powder 
Rim areas west of Baggs. In the past decade the gas leasing and associated 
roads have cut up the country to the extent that there simply is no place a 
deer can go to live long enough to be a trophy. 

Because of the developments, I abandoned the Baggs area and discovered 
the areas around Tatznan and Sheep mountains. Now 1 hear you're planning on 
doing a number to that country as has been done around Baggs. 

Somewhere, somehow, we have to make a stand and say enough is enough. 
When we lose the wild places we also lose a part of what wakes Wyoming 
special. T feel your proposal to allow oil and gas leasing on all public 
lands is irresponsible and violates your multiple use concept. Sure, 
hunting will still be allowed, but if history is any indicator it will only 
be a shadow of its former self. 

Your proposals to support wildlife populations -co the "extent possible," 
or "where appropriate," is hollow and without any resolve on your part to do 
what's right for the sportsmen of this state. 

The only proposal you have that makes any sense at all is Alternative C 
as it allows at least some concrete protection for big game and wildlife 
habitats. Everything else you've come up with violates the public trust 
regardless of what our esteemed legislature or congressional delegation would 
have you believe. 



^^C^Z^C^- 




171 



3/29/95 

Hi! A few suggestions 

1) Protect The Absaroka Foothills, Badlands, Bighorn River & & Red Canyon Creek SRMA 
from oil development. 

2) The Badlands are great as is - designate an ACEC - to keep ihem that way! 

3) Protect all areas included in the "Conservationist" Alternative including lands outside of 
Wilderness Study Areas 

Thanks /s/ Penny Hanna 

xxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxx 



346 




172 



March 30. 1 995 



Bon Pnss, Team Loader 
Bureau of Land Management 
P.O. Box 119 
Worland, Wyoming B240 l 



□ear Mr . Rosa, 



! am writing to ask; you to consider some changes to the 
Bighorn Basin Grass Creek Resource Area management plan. 

Please provide for the protection of the Absaroka Foothills, 
Badlands, 31ghorn River, ana Red Canyon Creek SRMA from oil 
development. Also, consider protecting all areas included 
in the Conservationists'' Alternative to the BLH'a Wilderness 
Proposal including lands outside Wilderness Study Areas. 
Particularly, the Badlands Special Recreation Management. 
Area needs to be designated an ACEC because of Its fragile 
soils and its extraordinary scenic value. 

Also, please provide more definite goals to aaoress the 
prooiems of overgrazing in the resource area, and provide a 
timeline Lo accomplish those goals in the next five years. 

Tr.anK you for your time and consideration. 



^^Cjr 



RECEIVED 



BUREAU OF LAND EASAGtHENT 



Christopher P. Valle-Riestra 




March 30, 1993 



Bob Hosa, team Loader 
Bureau of Land Management 
P.O. Box 119 
Worland. Wyoming 82-101 

Re: Grass Creek Resource Area draft management plan 

Dear Mr. Ross: 

Thank you far the opportunity to comment on the draft management plan 
Tor the Crass Creek Resource Area. 

Probably the most potentially damaging shortcoming of tho draft plan Ls the 
omission ffVftn lo consider making li?ss than all or lhe resource area available for 
oil and gas leasing. At a minimum, the following areas should he withdrawn from 
leaslnft: 

The designated Areas of Critical linvironraental Concern. 

O The Absarnkn Foothills. Badlands. Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas. 

While I appreciate the proposed designation of three ACKCs. please also so 
designate Lhe Badlands SRMA. 

All areas in the Conservationists' Alternative to the agency's wilderness 
proposal (including lands outside wilderness study areas) should be managed to 
preserve their primitive and natural values intact. 

More specific goals against which actuai conditions can be measured should 
lie given to address overgrazing problems. Definite plans should he laid out fur 
accomplishing these goals over a period of not more than five years. 

Very truly yours. 



Chris Valle-Riestra 



RECEIVED 



APR 3(995 



BtlRLAU OF LAND KA.tAGEKENT 



V.i. Rob Ross 

Team Leader 

Bureau of Land Management 

P.O. Box 119 

Worland, Wyoming 62401 



:]ear Mr. 



Ros 



ing changes In the draft management plan 



1 urge the folio 
for the Grass Creek Reeouro 

•The Absaroka Foothills, Badlands, Bighorn 'River, and Red 
Canyon Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

"The Badlands Special recreation Management Areas should 
alao be designated an Area of Critical Environment Concern (ACEC) 
because of its spectacular 8Cenic/ariEl u eJEtreiBely fragile Boils- 

•Protect all areas included in the Conservationists ' 
Alternative to the Bureau of Land Management's Wilderness proposal, 
including lands outside Wilderness 5tudy Areas. 

•provide more definite goals to address the problems of 
overgrazing in the resource area, and provide a timeline to accomplish 
those goals in the next five years . 

As you knov, the erase Creek Resource Area is located in 
one of the most beautiful parts of Wyoming- The area includes the 
eastern slopes of the Absaroka Mountains, and some of the most extensive 
and Impressive badlands in Wyoming, as well as awe-inspiring rock art. 
In the resource area, one can view the Stark contrasts of Wyoming from 
the arid deserts to luBh mountain forests- 

If the current plan is implemented, It will permit virtually 
uncontrolled oil and gas development in this beautiful part of the 
state of Wyoming, especially since none of the alternatives consider 
leasing less than 100% of the resource area for oil and gas development, 
inevitably leading to the destruction of the awe-inspiring rock art, 
and the beautiful lush mountain forests, rivers and creeks of th* 
Grass Creek Resource Area. 

I respectfully request that you inform me as to what Steps 
you intend to take in this matter in order that I may inform the 
Northern Plains regional office of the Sierra Club in Sheridan, Wyoming, 
and its Washington, D-C- office. 



RECEIVED 



APR 3(995 



175 



March 29, 1 995 



Bob Ross. Team Leader 
Bureau of Land Managcm 
P.O. Box 119 

Worland, WY 82401 



Dear Mr. Ross; 



1 am writing in regard io lhe draft management plan for the Grass Creek Resource Area. The 
draft plan places too much emphasis on oil and gas development, and fails to adequately provide 
for the conservation of the natural resources of this area. I encourage you lo amend this plan to 
include the following provisions: 

the protection of lhe Absaroka Footlands. Badlands. Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas from oil and gas development 

the designation of the Badlands Special Recreation Management Area as an Area of 
Critical Hnvironmenlal Concern 

the protection of all areas included in the Conservationists' Alternative lo lhe BLM's 
Wilderness Proposal, including areas outside of Wilderness Study Areas 

the provision of more definite goals to address the problems of overgrazing in the resouic: 
area and a timeline for accomplishing these goals 

We must proieel areas of natural beauty from uncontrolled development. 1 encourage you to 
amend Lhe drafl niatiugement plan for the Grass Creek Resource Area to place more emphasis on 
conservation needs, and to reduce lhe impact of oil and gas development, I hope thai you will 
include the provisions lhat I listed above in the final draft of the management plan. 

Thank you for considering these matters 



amuaeiy, 



347 



176 



For State Sovcrei 



n t y 



GRASS 

Grass Roots Alliance 
Box 263 Greybull, WY 82426-2063 

[Same as Letter #1] 



Additional comments: 

I oppose the Grass Creek land use plan since it does not address the views of local 
and state citizens. We do not need outsid extreme environmental groups to tell us how to 
manage the lands. 

Name: Don Clucas 

Mailing address: xxxxxxxxxxxxx 

City, State & Zip: xxxxxxxxxxxxxxxxxx 

Signed: /s/ Don Clucas Date: 3-31-95 



177 



Dear Mr. Ross, 

I am gravely concerned and discontented with the draft management plant for the 
Grass Creek Resource Area. Opening the entire area for oil and gas devclomeru is not 
acceptable. In addition you have not provided definite goals to address overgrazing nor a 
reasonable timeline to accomplish those goals. 

The management in the Areas of Critical Environmental Concern is not sufficiently 
stringent. The Badlands ought to also get the ACEC designation. 

Please consider the Conservationists' Alternative to the BLM's Wilderness Proposal. 

Big corporations have had their way with BLm for far to long and at great financial 
and environmental cost. Please help stop this madness. 

Sincerely, 

l$J Mary (Catherine Ray 
xxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXXX 




178 



Dear Mr. Bob Ross 

1 have followed the events regarding the BLM's Bighorn Basin Plan. 
While I am not a resident of the region 1 visited the area of Grass Creek 
Resource area. This area is of out standing scenic beauty and needs to 
managed as an asset to the BLM and the nation as a hold.. 1 travel from 
Yellowstone to Cody to visit the museum there and the Bighorn region is 
to natural for 100% energy development. 

Allowing a 1 00% development non comprised leasing for oil is excessive 
in managing position for the entire tract of land. 1 believe that you need to 
consider the highly scenic corridors of the Big Horn River, The Absaroka 
foothills,Red Canyon Creek for special easement consideration and exclude 
these area from resource development. 

I know that Wilderness is a bad word in the BLM rank and file service 
employee, Bui the Badlands have a very fragile soil composition and 
Wilderness can be a cost saving method of dealing a potential erosion 
and costly long term management issues . Hell save it , button it up stick it 
in a land bank and develop that will give you return on your investment. 

Sincerely r ~y ,- 

Rich Cimino \^HTd-(^lA_ .. 



risrch 22, I97S 



APR 3J9S6 



179 



Hub Ross;, l>am l_F»adi;r 
F'urpau Erf Land flftrnnaoment 

F , . Sn>: 1 I " 

Worl and, Wyoming 32401 

Dear Mr. ftefsss 

As * citu*n concerned with ronssr vati on and a;; a 
member o-f thr Biorra Club, I'm conrprned about thw dratt 
mandqempnt pi *n for the Grass Cr eel.- teiourcR ttrea in the 
Bighorn Basin. i believe that uncontrolled oil and cjas 
development m this area i * unwi se at tiest. 



the *ol lowi ng 



I respectfully request that you conoid 
changes* 

The Absarok* Foothi 1 1 s , Badlands, Biqhorn River, and 
Rtid Canyon Creek Special F»er«itien Manacioment ftreas should 
be, protected -from oil development. 

The badlands Sftflft should also be designated an ftCfiC 
b«eauae o-f its, spectacular sce~,ir and extremely fr»ail« 
sails. 

Protect rfl I area* i nrluded : r th» Conser vaL 1 om Ets" 
Alternative ro the BLM's Wilderness H opout including lands 
outside WlTtlerr.ess Study Areas". — ~" 

Provide more definite goals. x.o address the problems c4 
o^erqrs7inr| in the resource area, and provldo a timeline to 
accomplish those qnai s in the ne>: t; -fi.vD years. 




iti onm 



J cert* yet 



348 



RECEIVED 



APR 3BS6 



180 



Bob Boss, Team Leader 
Bureau ot Land Management 
P.O. Box 1 1 3 
Worlanfl, Wy B2401 



Dear Mr. Kosa, 



T'm wrttin9 you today regarding the draft management plan for the 
Grass Creek Resource Area. From what I understand of th« current 
draft, it will allow oil and gas development over too much of the 
orea, including atmsitive habitats and recreation areas. Therefore, 
X am asking that the following changes be made in the plan: 

-keep oil development out of the ftbsaroka Foothills, Badlands, Big- 
horn River and Red canyon Creek Special Recreation Manaqcmcnt Areas 

designate the Badlands SRMA an ACEC because of its spectacular seen 

ery 

protect all areas included in the Conservationists' Alternative to 

the BLM's Wilderness Proposal tncl. lands outsinc WSAs 

-more sharply define goals to correct overgrazing and establish a 
timeline to accomplish these goals within five years. 

Thank yon for your time and attention. 



Noel Mc-Junlcin 



March 31, 1995 



RECEIVED 



APR 31995 



BUREAU Of LAKD '.;.■ ■ 



181 



Bob Ross 

BLM Team Leader 

P.O.Box 119 

Worland, WY 82401-01 19 

Mr. Ross. 

Regarding your request for comments and the Grass Creek Management Plan, I would like 
to submit the following comments. My comments deal with one theme ... I support 
environmental protection and the conservation of natural resources in the resource area. 

1 grew up in Cody. 1 have spent many days in the Grass Creek Resource Area, whether it 
was hiking, hunting orjust exploring, tn the past few years, I have spent time in the area. It 
is still relatively unspoiled and undisturbed, Wildlife, is abundant. 

I am disturbed by your agency's plan to allow oil and gas leasing and development on 
public lands. The Gooseberry Badlands, the East Ridge -Fifteen Creek, Tarman Mountain 
and other areas should be left a 1 ? they arc. 

If oil and gas leasing and development is allowed in these pristine areas, you will abuse 
your multiple use mandate. Multiple use also includes non -extractive uses like protecting 
and managing wildlife habitat, maintaining healthy and functioning fisheries, prelecting 
water quality and watersheds, providing opportunities for education and .scientific research, 
recreation, and aesthetic values, and preserving important historic and cultural resources. 

Recreation without roads is important, too, and must be maintained. We have enough 
roads in this part of ihc stale. There are plenty of areas in Wyoming that are wide open to 
motorized recreation activities. Let's provide lor activities like backcounlry hunting, fishing, 
hiking, camping, wildlife watching, sightseeing, nature study and opportunities for quiet 
time in the outdoors, 

Improving riparian habitat areas and rangeland is also a mandate that you face. Riparian 
habitat is very important in our arid state, and especially in the Grass Creek area. Rangeland 
in this area is degraded and unhealthy, and 1 can't see increased oil and gas leasing and 
development helping that situation. A more aggressive use of coordinated range 
management techniques, used in conjucrion with time-controlled grazing practices, would 
greatly improve conditions in the Grass Creek Resource Area. Our stale's Department of 
Agriculture trumpets the success of its coordinated range management program, Take note. 
BLM, 

I support Fiftecnmilc Creek, Meoteeise IJraw and Upper Owl Creek ACECs. These areas, 
however, must be off limits to Oil and gas leasing and mineral development. Protect the 
Fifteenmile Creek watershed area. Also, do not allow oil and gas leasing and mineral 
development in the South Fork of Owl Creek. 

The BLM should place a much greater emphasis on managing fish and wildlife habitat. 
Using phrases like "to the extent possible" and "where appropriate" when you address 
wildlife is scary, at best. When oil and gas leasing and development takes place, wildlife 
ultimately loses. Roads arc built and never closed. Forage is destroyed. Riparian zones are 
abused. Look at what is happening in southwest Wyoming. Do we want that in the Grass 



181.2 



Creek Resource Area? No! Concerning wildlife, anything less than supporting Alternative 
C is wrong. BLM must meet Wyoming Game and Fish Department wildlife objectives 
and "allow (b) the expansion of wildlife and fish into high potential habitats." Alternative C 
provides adequate protection for all big game winter range. 

Protect - don't destroy - one of the last remaining areas of its kind in Wyoming. 
Someday. 1 would like to take my son to a quality area to hike, fish and hunt. If this plan is 
approved, the area I remember from my youth will be gone. Is thar progress? 1 ttiiuk not. 




APR 4085 



182 



BUREAU OF LAW) BAKMENEIH , 



March 29. 1995 



Bob Ross. Team Leader 
BLM 

PO Box 119 

Worland, Wyoming 32401 

Dear Mr, Ross; 

Please protect the Absaroka Foothills, the Badlands, the Bighorn River, and trie Red Canyon Creek 
Special Recreation Management areas from ALL oil and Gas Development. [ live in Alaska and have 
witnessed what greed and ill advised '"management" of the land will do I am not agamsi jobs but] really 
would like my children id have some places left lhal aren't covered with grease and asphalt and mudslides 
and slash and everything else people do :o the land 

Thank you 



CharloneTannci 



349 



B E C E I VED 



m 4835 



Bob Ross 

Team Leader 

P.O. Box 119 

Worland, WY 32401-0119 

Dear Bab, 

As I've talked to you many time about the Crass Creek Re- 
source Management Plan you already have most of my comments, oral 
and written- I just want to be on record as having participated 
in the review process . I'm still reviewi ny the economic impact 
material that you sent me. Thanks for your help in providing 
requested materials . 



95 

•im: 



PAGE 36 2nd paragraph 



Change 



The current amounts, kinds, and seasons 
of livestock grazing use would continue 
to be authorized 



The 1994 amounts, kinds 
specific year 



ild horse management going to 



HAP 20 Why is the area used for 
be increased? 

HAP 24 Is the BLM going to get public access to the shaded 
areas? 

PAGE 179 SOCIOECONOMICS GENERAL How does all lands in planning 
area increase in impact to local area and BLM administered lands 
decrease? What is the BT.M doing to cause this decrease? 

PAGE 180 SOCIOECONOMICS LIVESTOCK GRAZING If things are going to 
remain the same ( see page 36) how come we lose 3 million dol- 
lars. What is the cause of this projected decline in our area 
and BTW grazing in our area? 

PAGE 181 SOCIOECONOMICS RECREATION What is going to increase the 
value of recreation on BLM land by 3 millipn and the local area 
by 13 million dollars? Is there a program out there? How many 
tourists dqes this equate to? where are they coming from and 
where are they going to stay? 

PAGE 183 WILD HORSES I don't see anything Ln the current man- 
agement plan that indicates the need;" for 160,000 acres to expand 
the range. 'Since the preferred alternative reflects the current 
management X!$"qy$$ more confused abgpt expanding the range. 



'■ fJ^ s 

Ponald L. McCracken, Jr. 



184 



Robert F. Creech, Jr 
xxxxxxxxxxx 

Bob Ross, Team Leader xxxxxxxxxxxxxxxxxxxxxxxx 

Bureau of Land ManagemeniL xxxxxxxxxxxxxx 

P. O. Box 119 

Worland, Wyoming 82401 

Mr. Ross; 

This comment is in regard to BLM's draft management plan for Grass Creek 
Resource Area. If this plan is implement there will be uncrolled oil and gas development. 
What a shame -- this is certainly one of the most beautiful parts of Wyoming. 

I would asked that the [ ] following changes be made in the management plan: 

The Badlands SRMA should be designated an ACEC because of its spectacular scenic 

and extremely [ ] fragile soils. 

Protect all areas included in the Conservationists' Alternative to the BLM Wilderness 

Proposal including lands outside Wilderness Study Areas, 

Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek Special Rec- 

(1.) 

reation Management Areas (SRMA) should be protected from oil de v clpm 

development. 

Provide more definite more definite goals to address the problems of overgrazing in 

the resource area, and provide a timeline to accomplish those goals in the next five 

years. 

Please consider, thank you. 

Respectfully, 

/s/ Robert F. Creech 



U 



2.1 



3./ 



APR 41995 



BUREAU OF UN D 1MUMWH1 



185 



March lb, 1995 



Rob Ross. Team Leader 
Bureau of Land Management 
P.O. Don 119 
Worland, Wyoming 8240! 



Dear Mr. Ross, 



We are writing in regards to the BI.M's management plan for the Grass Creek 
Resource Area. If ihc current plan is implemented it will permit virtually uncontrolled oil 
and gas development in this beautiful pari of" the Stale. 

We would like to you to know that we feel the fallowing changes are imperative 
in the management plan: 

* The Ahsaroka Foothills. Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas (SRMA) should be protected from oil 
development. 

* The Badlands SRMA should also be designated ar. ACEC because of its 
spectacular scenic beauty and extremely fragile soils. 

* The plan should protect all areas included in the Conservationists" Allumativu 
to the BLM Wilderness Proposal including lands outside "Wilderness Study Areas. 

* ll should provide more definite goals lo address the problems of overgrazing in 
the resource area, and provide a timeline (o accomplish those guals in the next five years. 

We feel very strongly that this area needs to be protected. There is so little left. 
Humans" stewardship nf the earth has been poor. Please know dial we want this 
management plan changed. Thank you for taking nolc of our concerns. We hope you 
will work to change this. 

Sincerely, 

Terri I,. Gerher (j 
David K. Blough 



186 



Jack Highfill 
xxxxxxxxxx 
xxxxxxxxxxxxxxx 
xxxxx 

Bob Ross, Team Leader 
Bureau of Land Management 
P. O. Box 119 

Worland, WY. 82401 

Re: Management Plan for Grass Creek Resource Area 

Dear Sir: 

As a Sierra Club member, 1 have been advised that your draft management plan for 
this area is woefully inadequate. I'm sure this comes as no surprize to you as whatever 
you propose is probably woefully inadequate. I have never been to this area of 
Wyoming so am not the least bit qualified to comment on your management plan. 

As 1 understand it this is quite a large area encompassing a wide variety of terain 
including some considered for designation as wilderness, with this in mind, it would 
seem that at least parts of this area would be inappropriate for oil and gas or other 
development. 

(over) 
[page 2] 

I have no way of knowing if you and your team actually have any say concerning the 
stewardship of this area or if your responsibilities consist of merely turning out a 
management according to prescribed guidlines with a pre-dcicrmined outcome. If the 
latter is the case, then this letter and postage are a waste of time and money. 

Hoping against hope that you and your team area group of qualified individuals who 
are intimately familiar with the area and not beholden to special insteres, 1 trust you will 
recognize the value of lightly or un-developed areas and recomend the appropirate level 
of future development - None. 

We have very few areas left to develope and should guard them colsely. 

I am not against all utilization or development. I think timber harvesting is fine for 
the entire Black Hills, needs to be much more selective in the Big Horns. Strip mining 
is inappropriate in either but is fine in the Powder River BAsin as is oil and gas 
development. 

I hope I have made al least one point in all of this and if so that you will consider it 
when you submit your final management plan. 



Sincerely 

/s/ Jack Highfill 



I hope to visit this area this summer. 



350 



m &®& 



BOIEAliOf LAMDBJtNASEiENT 



m? 



Mr. Bob Ross 
Team Leader 
BUM 
Box 119 

Worland, Wyoming 
82401 

Mr. Ross, 



I think the BLM should look at the management plan for the Grass Creek Resource 
Area again, I know that the managers in your agency can produce a better document 
with better alternatives for protection of the Absaroka Foothills. Badlands, Bighorn 
River and Red Canyon Creek SRMA's. These areas should Clearly be protected from 
oil and gas development It you would like to see the negative impacts of oi! and gas 
development, you should get somB of your friends from the BLM to take you on a tour 
of the area between Baggs and Rawlins. The uncontrolled road building and poor site 
reclamation has permanently destroyed much of this part of the red desert. Badlands 
areas with their soil conditions are particular vulnerable to this kind of exploration and 
poor management. 

Many of these areas should bB protected and would be protected if you would work for 
the Conservationist's Alternative to your agencie's Wilderness proposal. Until you are 
able to address this alternative in a more sensible manner, your agency should set 
these areas aside. 

Lastly, your management plan should address clearly the problems of overgrazing in 
these areas and set definite goats and time tables to alleviate these problems. 

Thanks. I realize your agency is working hard, but I would like to see you do a little 
better before the final plan is put out. 




RECEIVED 



APR ABSfJ. 



mitJi OF WHO HMAttlOfT 




Sierra Club 

Harvey Broome Group 

105 Evans Lane 
Uak Ridge. Tennessee 37830 
Marcn 21, 1995 

Bob Ross, Team Leader 
Bureau o£ Land Management 
P. □. Box 11** 
Worland. Wyoming 8^401 

SUBJECT: OIL DEVELOPMENT IN BIGHORN BASIN 

Dear Mr. Roaa: 

The Harvev Broome Gruup (HBG) of the Sierra Club currently numbers in excess 
a thousand individuals who reside in east Tennessee. In writing to you I am 
speaking tor the HBG. concerning the current olan which would Dermit virtually 
uncontrolled oil and gaa development in the Grass Creek Resource area. 

Many of our jroup Have hiked extensively in Wind Rivers and the Bighorns, and 
we are well acquainted with the natural beauty of your State. We are alao aware 
ot the need to protect manv of the lovely and fragile areas from uncontrolled 
development. We are accordingly asWrg that a number of important changes oe 
made In the BLM draft management plan, vi*,: 

1. Restrict the Absaroka Foothills. Badlands, Bighorn River, and Red Canvan 
Creek Recreation Areas from development. 



3. Areas listed in the "Conservationists' Alternative to BLM'3 Wilderness 
P'oposal" Should be accorded a high degree Of protection. Please extend this 
protection status to recommended lands outside the Wilderness Study Areas. 

■t. Overgrazing is a proolttm everywhere in the West. Please give this problem th 
attention it deserves In the Resource Area. 



188 



5. We understand that none of BLM 

percent of the Resource Area tor o 

proposals so as to 

retain some degree of control of proposed developmei 



ilternativea consider leasing less than 1 00 
nd gas development. Please mocl£y these 



Thank Vou for this opportunity 



exprs: 



i our concerns. 



Ken Warren, Secretary, 



£i vt'onmtnia! Quality, Wilderness Preservation 



189 



nutinp.w h Hdtden 



RECEIVED 



APR 4B95 



BUREAU OF UHD UNA6EHENT 



Bet Pcss, T ?em Leadsr 
Ryroivi of L ana heragemem 
p Sax M 9 
weriana Wyoming 52'iOl 



'. am cnnceT.eC fi&out the Surest; of Lsnd Management's recently released 
■Iran menegpment plan for the Grass Creek Resource Area of the 
ttignnrn Sastn I «m vujnniuqiij nnnflppd to the plan'? allowance for 
virtually uiiGornroiied m\ anu yes development in mis neautiful region 

Specifically, ! urge you to make the following changes; 

The ads&toks Foothills, Badlands, Bighorn River, and Red Canyon 
Creek Special Recreation Management Areas (SRMA) should be 
protected from oil development. 

Trie Badlanos SRfiA should also be designated an Area of Critical 
Environmental Concern because of its spectacular scenery and 
extremely fragile soils. 

Protect all areas inductee In the Conservationists' Alternative to 
the SLH's Wilderness Proposal including lands outside Wilderness 



Provide tw'b lisi'inite goals to address the problems of overgrazing 
in the I'esouiCe area, and provide a timeline to accomplish those 
qouis in the ne^;t five years. 



rk ucu for your attention to tmc. 




190 



Dear Sir, 

Through the Sierra Club, I recently learned of the Bureau of Land Management's plan for 
the Grass Creek Resource Area in the southwestern quarter of the Bighorn basin. 

What I learned disgusted me. The Grass Creek Resource Area is one of the 'most 
beautiful areas' of Wyoming, wherein lies the eastern slope of the Absaroka Mountains, 
impressive badlands, and 'awe-inspiring' rock art. 

Your proposal allows for 100% of this gorgeous, priceless area to be leased for oil and 
gas development. And the 3 Areas of Critical Environmental Concern (ACEC) are severely 
mismanaged and do almost nothing to protect these beautiful lands, 

I insist that the Absaroka foothills, Badlands, Bighorn River, and& Red Canyon Creek 
Special Recreation Management Areas SRMA be protected from oil development, and that 
the Badlands SRMA should also be designated an ACEC because of its spectacular scenic 
and extremely fragile soils. 

I call upon you to protect all areas included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal, including lands outside Wilderness Study Areas, and to provide 
more definite goals to address the problems of overgrazing in the resource area with a 
timeline requiring you to accomplish these goals in the next 5 years. 

Thank you. Sincerely, /s/ Jerry Cassel 



351 



Mary Ann Holden 



3/28/95 



W% 




Bob Ross, Team Leader 

Bureau of Land Management I B <JKAU0f LWOIAJ ■■"■■! 

P.O.Box 119 

Worland, Wyoming 82401 



Dear Mr. Ross: 

i am concerned about the Bureau of Land Management's recently released draft 
management plan for the Grass Creek Resource Area of the Bighorn 
Basin, j am vigorously opposed to the plan's allowance for virtually uncontrolled 
oil and gas development in this beautiful region. 

Specifically, I urge you to make trie following changes: 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas (SftMA) should be protected from 
oil development. 

The Badlands SRMA should also be designated an Area of Critical 
Environmental Concern because of its spectacular scenery and extremely 
fragile soils. 

Protect all areas Included In the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

Provide more definite goals to address the problems of overgrazing in the 
resource area, and provide a timeline to accomplish those goals in the 
next five years. 

Thank you for your attention to this. 

Sincerely, 




192 



[LETTERHEAD] 

"BLM's Bighorn Basin Plan 
Caixh for Massive Oh. and Gas Development 

The Bureau of Land Management has recently released it draft management plen for the Grass Creek Resource 
Area which comprises the southwestern quarter of the Bighorn Basin. If the currant plan is implemented it will 
pertnil virtually uncontrolled oil and gux development in this beautiful part of the state. Your help is needed. It 
is only with your comments that this plan will be changed. 

The Natural Gen of the Bighorn Basin 

The Craw Creek Resource Area Is located in one of the most beautiful parts of Wyoming. The area include the 
eastern elopes of the Abwroka Mountains, and some of the most extensive and impressive badlands in 
Wyoming, as well as awe-inBptrintf rock art. In the resource area, ooe can view die stark contrasts of Wyoming 
from the arid deserts to lush mountain forests. 

The Problem 

In its management plan for Grass Creek, the Bureau of Land Management is proposing a laizze faire system of 
management which allows for JO0K of the resource area to bo leased for oil and gas development, in fact, 
none of the alternatives consider leasing less than 100% of the resource area for oil and gas development. 

Special area management in also a big problem. Although the plan designated three Areas of Critical 
Environmental Concern {ACEQ, the management in these areas is not sufficiently stringent to betiec protect the 

Bob Ross 

Bureau of Land Management 3/28/95 

Worland, WY 

Bob; 

Many things "flash" across my desk in the course of a busy day, many of which arc 
hard for me to believe are true at 

[page 2] 

face value. Such is the enclosed which I have just received from the Sierra club. However, 

if this notification has gnv, truth to it, then I, as a citizen, must register my complaints and 

feelings. 

Based upon the proven catastrophic history of big business, especially the petroleum 
industry, we, as a country should go out of our way to protect these areas and not allow 
further development/exploration - the Bighorn basin area (I know well - I had led 
backpacking trips there) is too fragile and spectacular an ecosystem to even t hink of 
developin. The area should, be classified as an ACEC area if not a wilderness area. 

I am not a fanatic conservationalist- but rather a concerned citizen and a family 
physician, one concerned not only with the health of my patients but the health and viability 
of gjjr entire environment - because this impacts us all! Thank you 

/s/ Robert Fritz MD 
R. Fritz CO#3l88l 



WEC1IV6D 



tf* 4«5 



193 



■IWUOFUUIDBjUMSCM t> 



28 March, 1 995 



8ob Ross, team Leader 
Bureau of Land Management 
P0B0X I 1 9 

wetland, WV52401 

Deer Mr. Ross: 

I em writing to urge certain changes in QLM's Bighorn Basin Plan. 

Oil and gas development must be restricted in the Gross Creek Resource Arse. The 
environment here is too special to warrant the threat of such development. 

Tne Sadlenas SRMA must be designated on ACEC. The fragile nature of the soils 
demands protection because of this area's unique beauty. 

The problems of overgrowing must be addressed with specific goals provided for 
the next five years. 

If we lose our special areas through greed and overdevelopment. even the economy 
of trie nation will suffer. We are witnessing this in the east with our fishing 
industry decimated fry lack of protector. ?nd cars, causing now untold suffering to 
those who over-exploited the natural resources 

I urge you to consider these changes 

Sincerely 



Judith B DeMarrais 



194 



March 29, 1995 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P O Box 1 19 
Worland, WY 82401 

Dear Mr. Ross: 



I write to you with concern about the management plan for the Grass Creek Resource Area 
of the Bighorn Basin. 

• The Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek SRMA 
must be protected from oil development. 

• The Badlands SRMA should be designated an ACEC due to the fragile ecosystem. 

• Protect all areas outside Wilderness Study Areas, 

• Address overgrazing problems 

• Set a timeline for establishing above goals. 

Big business & development should not be able to destroy our few remaining ecosystems. 
Please respond as soon as you can. Thank you for all yout conservation. 

Sincerely, 

IsJ (Cathy Baugh 

XXXXXXXXXXXXXXXXXXXX 

XXXXXXXXXXXXXXXXXXXX 



352 



1S5 



March 29, 1995 

Bob Ross, Team Leader 
Bureau of Land Management 
POBox 119 
Worland, Wyoming 82401 

Dear Sir: 

My wife Euka and I are writing about your draft management plan for the Grass Creek 
Resource Area. We are not at all happy with you plans to not protect their land in any way. 

We ask for the following changes: 

1) The Absaroka Foothills, Uadiands, Bighorn River and Red Canyon Creek Special 
Recreation Management Areas should be protected from oil development. 

2) The Badlands SRMA should also be designated an ACEC because of its spectacular 
scenic and extremely fragile soils. 

3) Protect all areas included in the Conservationists* Alternative to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Areas. 

4) Provide more definite goals to address die problems of overgraj.ing in the resource area, 
and provide a timeline 

(Over please) 
[page 2] 
to accomplish those goals in the next five years. 

Having worked in the oil fields as a roustabout and well puller I know very well the 
destruction that oil drilling will do to these areas. Please implement the about five points. 

Sincerely, 

hi Tom Denison 

xxxxxxxxxxxxxxxxxx 

xxxxxxxxxxxxxxxxxx 



196 



GRASS 

Grass Roots Alliance For State Sovereignty 
Box 263 Groybull, WY 82426-2063 

[Same as Letter #1] 



Additional Comments: 

The people that compiled this document knows nothing of conservation. This 
is not their land, it is not federal land. It is the people of Wyomings land 

Name: David A Bouma 
Mailing address: xxxxxxxxxx 
City, State & Zip: xxxxxxxxxx 

Signed: 1st David A. Bouma Date: 4/3/95 



RECEIVED 



APR 5B96 



BUREAU OF LAftO BASHED 



W7 



March 31, 1995 



Bureau of Land Management 
Boh Rons, Team Leader 
P.O. Sox 119 
Worland, Wy S2407 D]]9 



Dear Mr. Ross; 



] am writing to voice my concern about the Alternatives 1 isted in the Grass Creek 
draft LIS. It appears to me that the BLM has MOT to the conclusion that there 
is little or no potential for further natural resource development in the Grass 
Creek area. Therefore, you believe that your proposed additional restrictions 
on leasing and surface occupation will not have a significant economic impact 
on the local economy or state revenues. 



As could be expected this u 
Tie BLM may not be able t 
' sight 



lateral and short : 

into the " 
; to your position. 



|hled conclusion is dead wrong, 
but a look at history should 
iloptnent of natural resources 



provide sufficient insight as to your position. Development of natural resources 
in the Grass Creek RMP has had a significant positive impact on Wyoming state 
revenues, the local economy and the quality of life for Wyoming residents for 
over 100 years. How can the BLM assume that this will not be the case for the 
next 100 years? The proposed restrictions under preferred Alternative A will do 
nothing but ensure that 1t won't! 

Oil and gas leasing and production, as well as, grazing have provided nothing but 
a positive benefit to the Region. Therefore I think that it is an obligation of 
the BLM to ensure that it has the potential to continue to do so well into the 
future. In respect, to oil and gas leasing, new technologies are continually 
Deing developed which provide for new discoveries and enhanced recoveries from 
existing fields. Please don't be short sighted; one small discovery can add 
millions of dollars to local, state and federal revenues, and provide a very 
solid base for economic development. 



Based on the above comments, I recommend that the proposed EIS be 
Alternative B being the preferred alternative. 



redrafted « 





198 



X WIJ BS4SS 0263 



January I?. J?*5 



Mr. Bob Ross 

BLM RMP Team Leader 

Box 119 

Worland, WYS24O1-0119 



fte: Grass Creek Resource Area Draft L*nd Use Plan 



Mr. Bob Ross, 

Thepujposeoffhisfeflerbloopposeraorcrestrictionsan Wyoming's public lands. Your 
dooimenl is filled with restrictions that your agency is not authorized to impose. We speak 
with the authority of the Canstilutiun of [he United States of America and (hat of the great state 
of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land bckmg to our state as well Prudent management of our resources, is sound business 
practice, and our businesses operate with that in mind DOW. We have managed the affairs of our 
state quite well . . . if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, yet you 
would impose this on us as if we did not value our public lands. Any restriction* deemed 
necessary should come from the state of Wyoming. 



We appose this document in its entirety. 



Additional comments: 



1W: &Aa^ - YWX^ y c-^ih.L 
Mailing address; | (\ . 



City, Slate &ZIP: 
Signed: 



| V\n^ jgJLLi. 



■La D«Usi 



. &-%<~= -<\< 



353 



'l!9@ 



April 3, 1995 

Dear Mt. Ross, 

I am writing la regards to the Grass Creek Resource Area, a place where 1 spend quite 
a bit of time hiking & fishing & hunting. I would like to ask that you include in your 
management plan some effective ways to keep this special place rich in wildlife. I have fears 
that more mining & oil drilling will have affects on the area that will make it less rich. 

I have already noticed the effects of ATV traffic on certain areas & less wildlife in 
other areas. We need to keep some viable habitat for the fish & animals of the area. 

One way would be to make South Fork of the Owl Creek a Wild & Scenic River. Also 
maybe some way to protect the Fifteen Creek Badlands & the Greybull River. 

Please consider in your plan ways for multiple use, but also ways to keep this area wild 
& provide a home for the many wild creatures that live in Wyoming. 

Thank you for your time. 

Sincerely, 

Is/ Lisa Jaeger 




200 



Mr. D<Lrrell Barnes 
Di.Btri.ct Manager 
Bureau of Land Management 
Borland District Office 
P. 0. Box US 
Worland, Wyoming 82401 

RE: Grass Creek Hu source Area 

Dear Mr. Barnes: 

I am a county commissioner from Park County Wycraing, but this tostinony in 
iron ay perupective, not neceasarily that Of all Park County CorunieBionaz-s. 

Thank you, for giving me the opportunity to utate my viawa. 

I would £irat like to state my concerns over cuBtom and culture of thia ar~». 
fiCter the civil war in the ia60'e the United States had people who were 
encouraged to move into the desert areas of the western ntetea to develop the 
land. Thee© wors mine™, loggers, and ranchers who wore rugged individuals 
who brought a custom and culture to theBe western areas with the use of their 
imagination and the unregulated use of the area that no one else wanted. 
There ore museums and artiste who vividly depict the custom and culture of 
these people, which was created ae port of the developing of theae vast open 
ranges. I Bincerely hope ve do not lose our way of life from the regulations 
we are bringing to the land in thone areas. 

As a county commissioner trying to meet operating needs, I have concern over 
how we are to be reimbursed by the impactH that are written into the plan. 
The beBt data available tells us that each AUM directly addH to the economy of 
the area and we have estimates on r.he number Of AUM 'a from domestic animals. 
He also estimate returne from mineral and timber income. An AUM is worth 
about $32.43 directly to the economy of the area and an additional $44.68 
indirectly, making a total of $77.11 per AUM of domestic liveatock. How does 
trie area get reimbursed for the mule deer which 1b, according to University of 
Wyoming data, .15 AUH, from the elk which is .7 AUM, from the moose which is 
1.2 AUM, the antelope which ia .12 hum, white tail deer which iB .1 AUM, and 
the wild horse which is 1.5 AUH. How do you raimbuxfle local economies for 
recreation use and other free occeBe ubob? 

Thank you, for your consideration of theee concerns. 



Sincerely yours 




?;©1 



John R. Swanson 
xxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXJCXX 



April 2, 1995 

Bureau of Land Management 

FOB 119 

Worland, Wyoming 82401 

Dear Sirs; 

Please accept my following comments concerning the Draft Resource Management Plan& 

Environm ental Impact Statement. Grass Creek Resource Area. Wyoming. 

The Grass Creek Resource area contains outstanding scenic, wildlife, and wilderness 

attributes of certain National significance. 

As this area features unique, varied, and fragile resources that must be preserved. 

1, then, wish to advise that 1 oppose oil and gas development in this region, as development 

will destroy soil, water, vegetation, and wildlife assets. And urge that each of the following 

areas, with acres, be designated as wilderness : 

Owl Creek 10,500, Bobcat Draw Badlands 35,000, 

Sheep Mountain 33,000, and. Red Butte 27,000. 

With each of the following streams designated as a National Wild and Scenic River: 

Bobcat Draw, Fifteen Mile Creek (complex), Grass Creek (complex), anal Owl Creek 

(complex). 

To select as Preserves the following areas, with acres: 

Fifteen mile Creek Watershed 285,000, Upper Owl Creek Area 19,300, and Mceteetse Draw 

Rock Art area 9,000. 

To preserve the habitats of the Black-Footed Ferret, Bald Eagle, Grizzly Bear, Northern 

Rock Mountain Gray Wolf, Peregrine Falcon, Wolverine, Lynx, Goshawk, Trumpeter Swan, 

and Spotted Bat. 

To select the following as Sanctuary Areas: 

Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek. 

To eliminate grazing so as to save soil and vegetation. 

To dedicate this Grass Creek Resource area as a National Preserve and Wilderness With the 

Wilderness to include 631 

and Ny development activities. 

To promote biological diversity, ecosystems conservation, Wilderness Preservation, Stream 

Preservation, ajrjd. Wildlife, Fish, and plant species preservation. 

So as to fully benefit man, and all Life! 

Sincerely, 

/s/ John R. Swanson. 



RECEIVED 



APR G! 



202 



■'.l: i) : I.-.; 



J Bfenda Poston Scnaeffer and,'or Da-yjd Schaeffer 



31 March. 1995 

Hob Ross, TearnLeader 
Bureau of I and Management 
P.O.Box 119 
Worland, wyo. 82401 

Greetings Rob, 

I am writing as One Greatly Concerned 
Human/Spiritual Being living on a Planet which has been 
and Is being mistreated - in gross depletion of flora and 
fauna. 

In particular I would like to greatly uphold the 
fol lowing- 

1 -that, the Badlands Special Recreation 
Management Area (SRMA) be designated an ACFC In resnect 
of its spectacular beauty and tragile soils, 

2- that the Absaroka Foothills, Badlands, Bighorn 
River, and Red Canyon Creek SRMA be protected from 
ANY/oil development; 

3- that all areas included in the 
Conservationists' Alternative to the BLM's Wilderness 
Proposal including land outside Wilderness Study Areas be 
PROTECTED' 

and A- that more definite goals to address the 
PROBI EM OF OVERGRAZING in the resource area, and a 
timeline to accomplish those goals In the next 4 years he 
PR0V1DFD. 

I urge you with rational/emotive fervor and dedication 
to the protection of all wilderness and other areas or 
thlsPlanet./i 



354 



RECEIVED 



APR 65S6 



3UREAU OF 1AN0 tfAHMEKENT 



.il derisii 



GERALD R. BROOKMAN 



April ?., 1995 



2@3 






l would like to urge that the Absar 
er, and Red Canyon Creek Special Rccr 
'tested from all rievel opment , or mrlier 
;hcir present condition by leading to 
vegetation and wildlife habitat In any way. 

I would like to urge that the Badl, 
ia Of Critical Environmental Concern 1 
extremely fragile coils. 

I urge the complete protection £rw» any 
loded in the Conaeruatlonintg' AltcrauLiv. 
al, including those lands Included in it ' 
derness Study Areas. 



geatnt plan for the Criluti Creek 
ts be c.onnldered as il they had 
c hearing and used to help wake 

Poo thills, Badl.inda, Bighorn 
Ion Management Arean .iliould be 
tiviEy ttiaL would be detriTnent.il 



SRMA should be designated ■ 
Be of -iC'a magnificent Hcai 



-Iiicl 



T : 



irongly urge char, your agency make a comprehei 
; uore deftnace goaln to address, the prnblenv 
sek Resource Area, and provide a timeline to , 
is practicable. In no cose oxtcedins five yea 

Sincerely, 



nlve study o£, and 
of overgrazing lii thi 
icompliab those Koala 



APR ens 



2m 



m M OF LAKO KAMAOEMENl | 



Robert Ross 
Bureau of Land Mans 
PoaL Off ice Box 119 
Worland, WY 82401 



I understand that the plan allows for 100% Leasing of thi 
area for oil and gas drilling. This concerns me very much. This 

iirc-u. It should not bo completely opened to oil and gas 
development and should be subject to Stricter management of 
environmentally significant areas. 

In particular, I urge the following: 

1. The Badlands Special Recreation Management Area is 
scenically spectacular, and ] understand it has extremely fragile 
soil; therefore, it should be designated ua an "Area of Critical 
Environmental Concern" (ACEC); 

2. Oil and gas drilling activities should not be 
permitted in the Special Recreation Management Areas: Badlands 
(redesignated as an ACEC), Absaroka foothills, Red Canyon Creek, 
and Bighorn River; 

3- All areas included in the so-called 
"conservationist' 3 alternative" to the BLM wilderness proposal 
should be protected; and 

•1 . Better control of grazing in the entire resource 
area should bo implemented in the near Future i, ti order to deal 
with Ihe existing problems of overgrazing. 

Thank you very much for giving my comments your serious 
consideration. 






Hon. Dianne Feinst.ein, United States Senate 

Hon. Barbara Boxer, United States Senate 

Hon. George Miller, M.S. House of Hepresentat 1 



205 



To Mr. Bob Ross: 

Please include the following changes in the management plan for the Grass Creek 
Resource Area. The Absaroka Foothills, Badlands, Bighorn River and Red Canyon Creek 
Special Recreation Management Areas should be protected from oil development. The 
Badlands SRMA should also be designated an ACEC because of its fragile soils and 
spectacular scenery. Please protect all of the areas included in the Conservationists' 
Alternative CO the BLM's Wilderness Proposal including lands outside the Wilderness Study 
Areas. More definate goals need to be provided to address the problems of overgrazing int 
he resource area, and a timeline should be set up in order to accomplish these goals. 

Corporate short term profits shouldn't be the main consideration in determining how our 
resources are managed. These resources belong to all of us, not only to the corporations. 

Sincerely 
/s! Doug Goodall 



RECEIVED 




206 



*&&&$€:■ <5w t &&G& &'t>/?is?b/^sbst 



13071 777-7W7 CHEYENNE, WYOMING 82QCJ 

FAX 1307) 777-5700 
TTY i3071 777.7 «7 



A LCX J. EUOPULOS 

em* couwa -v« 
comssjoH srowTAur 

STEPHEN G. OXL£Y 
AOrt**TH>TO» 



MEMO RA NDUM 



MS JULIE HAMILTON 
POLICY ANALYST 
GOVERNOR'S OFFICE 

JON F. JACQUOT 
ENGINEERING SUPERVISOR 
PUBLIC SERVICE COMMISSION 

MARCH 24, 1995 

BUREAU OF LAND MANAGEMENT GRASS CREEK 
RESOURCE AREA MANAGEMENT PLAN, STATE 
IDENTIFIER NO. 90-081 (aj 



Please forgive the lateness of this response to your request to comment on 
the referenced matter. The Commission requests that no unreasonable restrictions 
be placed on the provision of utility service or on the construction of utility and 
pipeline facilities as a result of the implementation of the proposed plan. 

'["he Commission would prefer that the Bureau of Land Management avoid 
mandatory undergrounding of electrical utility facilities as a management 
objective. The cost of constructing, operating and maintaining underground lines 
is generally higher than the cost of comparable overhead facilities and the 
reliability is not as good. The Commission's general policy is that those who cause 
the higher costs of undergrounding electrical lines should pay the difference. If 
the additional costs are not borne by those who cause them, the ratepayers of the 
affected utility would be unfairly discriminated against when burdened with 
paying the additional costs. 

The Commission requests that, when mineral leasing is being done, the 
costs of relocating any utility and pipeline facilities to accommodate mineral 
production be borne by the lessee, if these costs are not borne by the lessee, those 
costs would fall unfairly on the ratepayers of the affected utility or pipeline. 



355 



206.2 



The Commission requests that, in cases involving oil and gas leasing, the 
Bureau of Land Management not restrict the construction of utility and pipeline 
facilities necessary for the exploration and production of oil and gas. 

The Commission requests that, when the Bureau of Land Management sells 
or exchanges lands, the rights of the utilities and pipeline operators holding right- 
of-way easements from the private landowner and right-of-way grants from the 
Bureau of Land Management be protected. The Commission suggests that the 
private land owners acquiring Bureau of Land Management lands give new right- 
of-way easements to the utilities and pipeline operators for their existing facilities, 
and that, when the Bureau of Land Management acquires private lands, it issue 
new right-of-way grants to the utilities and pipeline operators for their existing 
facilities. 

Where construction is undertaken, the Bureau of Land Management or 
those managing the construction should contact and coordinate with the utilities 
and pipeline operators serving and otherwise present in the area to prevent 
contact with and damage to utility and pipeline facilities. If it becomes necessary 
for utility or pipeline facilities to be modified or relocated, the cost of modifying or 
relocating any utility and pipeline facilities to accommodate construction, should 
be borne by the Bureau of Land Management or those benefiting from the 
construction. If not, those costs would fall unfairly on the ratepayers of the 
affected utility or pipeline. 

The Bureau of Land Management should make provisions requiring those 
with timber operations to contact and coordinate with the utilities and pipeline 
operators serving or otherwise present in the area to prevent contact with and 
damage to utility and pipeline facilities. This should also apply to those clearing 
future right-of-ways. Consideration should also be given to the establishment of 
utility corridors through timbered areas, with maintenance of cleared areas for 
construction. 




HAKIE COUNTY COMMISSIONERS 

Courthouse 

PO Box 260 
WORLAND. WYOMING S2401 



Pnonfi(307| 547-6491 
Fa j Phons (307) 347.9386 



Cetifrty CoiMri.Btii 



rS COflfflPit? 



nd U*> 



Cunty Hoiiili(is6i0iers *Ou!d like tc thank the lo 

r.*t ^■B.-DHnt' of f lee.for twtendl.njj tH<-.*eij|i Brant p 
his (jiioj Ic.l'^ar.irtq. QiV.thff Draft CIS arid c^spos 
as reqyOTtfttt::by-.. th« four count res', li^yo^ ved . 






Dur comments, ™ill U* g»ty»ra) tr naturjs th#t mw : «V.U :! hav» entereo 
into the record tod*y.;.- .Mo^e ■ -W ■daBth'c'i^cpr n; taint '. *ylng 
specific BBcf.oftti-.cf :J^"p_l*p r jili-|-iVDe euWj t ted' at ■ a iater data. 
The May 7th flead ; i^e for.. Comments' ,it( artjy 9nc_^$b I'.jstm^ to study 
on* section oi tr-c p \it^-: The.-. Bureau r.' L*n<S.'*iart«gemeiit h 3s takei 
Tour years to preja're M.KF*. rjotUir^-.t aw v.e >sc<(\y«i ;jr fjrnt 
draft in January a fc jl *?tje,| '■ .f^v,r : 'ior'.th^ : « Jftsrd\y Br.eugh time to 
address all tft* isaii'ea.firopl*^ fy-V ■ • ■ V " «V'".: ■ : ,.:^ 

The law through \£fo..*rd\i£w>X-&: 

In the ola-'.hyr.Q p roces^cVi' "" 

at the planning **&&•?*' 

M,inaggment, that an i nvl ta.t lor. tft 

Suresii of Lanu Manajenswt , i & trie ' 

through a' planning process ai'.^iSnvilrea ey 1 -iw . 

Our local .economy arie 'eouctlon c' ,. ew tj< base is at a -ick and 
could cause extreme^ *ar Stfn i ? » C r- ow local citiiens that are left 
fto pay the tan tull'f-oi- 't^9.?e-vir'K,' That ta« oUr.e car oe 
identified Jnier Umitirc ot.l a-ic yas exp lo-a t : an, dnij". 
production. Tmijer;^ iw'ia Viatic irdustry that will bt? 
affer.t.ed. LiTiteo access bv : r»=reat lomsts and hunte-s wi lJ,jl#laQ 
affect our t3« base, -":■ 

A major problem :the :cun:y hil^itB th* -educt; o« of flj^f.-iy P5K 
when there has ^a ! -eady oaen -ar : i*ippf-ox • mate MX -eductisn in ;fch* 
last. 20 years ..j" tfia^Buc i n§ AUM ' p.-Jk^o doub.1 in'g the rfOd icirse tiera 
range is [to u9* r idicul sus ana, -.Cef-ta^nly doe* no-t support air 1 l. 
Btunomis berie'i: 'or our county*. ' Contfexris w c> -ave rarnct be '" "* 
rosea rcned by the May 7th deadline and could take jp ta rwo 

CHIEF WASHAKIE 



207.2 



Si* years ago the 5tate of Wyoming, in cooperation w jth the 
county governments, developed a local Big Horn Basm Master Water 
Plan. That plan identifies 50,000 acre feet of water still to be 
used for irrigation purposes on newly developed land in the Big 
Horn Basin. Fifty thousand acre feet could he doubled under the 
IntpriDi ' a Departments new conservation plan. The Big Horn 
master water plan identifies approximately 60,000 acres of 
federally cunt r ol 1 ed land can be put under irrigation viryen the 
nut ket can afford the development. The feasibility of 
beveluping such lands is getting closer. The lands identified in 
the master plan are located from Thermopolis to Powell and are 
within the buundarjes Df the Grass LIreek Resource arpa. If we 
can put 50"/, of the identified lanes into production it would De a 
15 million dollar economic boost to the tour counties here in the 
Big Horn Basin. I'm talking direct dollars annually. The 30,000 
arres proposed to be developed are a very small percentage 
compared to the ^00,000 acres this plan W«n*» to set aside for a 
cri t Lea 1 environmental concern. 

No where in the proposed Brass Creek Resource Plan is there 
reference to any of these lands to Be developed for agriculture. 
These need to be identified and recognized in the plan and if 
they are not it would be a great economic loss to this county ' s 



aary should be ewp 

ed In the document 

to faoi 1 itate ana 

publications and 



to include definitions of all 
index must be added to the 
The reference should cjte 
rs for all decision* made in th 



nt for which there is disagreement or controversy m the 
yntific and business community. Lack of a complete glossary, 
index and a complete reference section has made it difficult, 
not impossible io analyse the Crass Creek Resource Management 



lace 


o 


t 


hi? 


manaqemtL 


nt p 


ar> 


per hapE 


a 


coo 


rd 




d reso 


gems 


nt 


pl 


an 


.ould 


be 


deve 


lop 


















losi 




we 


Ad 


coun 




ommi 


SSI 


STW 


^ ar 


■ cone 


Br 


ned a 







ons. 




jit 


ure 


and 




fcrCO 


nom 


ic 


:ase 


be 


ng 


er 


nried 







Sineerel 



William Glanz, Cfc« 
Uashakio County Co 



Harold Cofe'r'Membe 



208 



4/5/95 

Mr. Ross, BLM 

I'd like to submit this as commentary on the Grass Creek Mgml Plan , 

L. First I am in favor of taking the Ippg view and preserving what's been left here 
intact rather than opening it up to all ends of short term uses which invarably accrue to the 
benefit of a few. 

L. The idea of multiple use is in fact not served when it allows a particula r user to 
extract for his sole use- or establish ruts & roads for a certain groups use or cut timber for 
the benefit of a few companies, 
[page 2j 

It The long term values of non-use, non extraction should be realistically included. 
There's more long range value in preserving what's left than in using it up &. screwing it up 
the way most of the other states have done. 

4,, The Wilderness Study Areas should be kept primitive and unroaded. Once the level 
of protection slips, we can't go backward toward "pristineness" if it is sacrificed. The 
WSAs should be off-limits to extractive industries. They're too valuable as they aie^ 

5_i Management should favor protection of riparian areas (absolutely vital), scenic 
values, and. wildlife. Esp. habitat zones for grizzly bears, elk, moose, bighorn, 
[page 3] 

pronghoms, and the myriad non-game mammals, birds, etc. These things are worth more 
than any severance taxes on oil & gas and such. 

Again, we need to that the long range, conservation view. Not the short range, selfish, 
what's-it-worth now approach. 

It In the near future it will become even more obvious that the heroes in BLM are the 
ones that stand for less use & abuse of the resource and for more careful stewardship. 

The beautiful, serene, awesome spaces of the Grass Creek Area and the critters that iive 
there naturally deserve the maximum level of protection. 

[illegible] 

/S/ Gene Ball 
xxxxxxxx xxxxxxxxxxxxxxxxxxx 



356 




209 



January 17, 1995 



Mr, Bob Rosa 

BLM RMP Team Leader 

Box 119 

Worlood, WY 82401-01 19 



Re: Grass Creek Resource Area Draft Land Use Plan 

Mr. Bob Ross, 

The purpose of this kller is lo appose more reslrktions on Wyoming's public lands. Your 
document is filled with restrictions (Jit! your agency is not authorized to impose. Wc speak 
Wull the authority oflte ConstiluUun nf [he United Slates of America and that or the great ittale 
of Wyoming. 

The resources m Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belong to our state us welt Prudent management of our resources, is sound business 
practice, and our businesses operate with that mound now. Wc have managed the affaim of our 
state quite well ... if you do not agree with this, look at the eastern states. 

This plan does not consider the needs of the citizens or businesses of Wyoming, ye i you 
would impose this on us as if we did not value our public lands. Any restrictions deemed 
necessary should come from the state of Wyoming. 

We oppose this document in Its entirety. 

Additional comments: 





■m 



April 3, 1995 

Bob Ross, Team Leader 
Bureau of Lard Management 
P.O. Box 119 
Worland, Wyoming 82401 

SUBJECT: Comments on Draft Management Plan of the Grass Creek Resource Area 
(Bighorn Basin) 



As a visitor to Bighorn Basin, a mother, and an environmentalist, I have major concerns 
about the draft Management Plan. It needs to be changed in the following ways' 

The Absoraka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Area (SRMA) should be protected from oil development. 

The Badlands SRMA should also be designated as an Area of Critical Concern 
(ACEC) because of its spectacular scenic and extremely fragile soils. 

Protect all areas included in the Conservationist's' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas 

Provide more definite goals to address the problems of overgrazing in the 
resource area, and provide a time line to accomplish those goals in the next five 
years. 



Thank you for this opportunity to comment. Now change the plan! Create alternatives 
with less than 100% of the land leased for exploitation! 



(L if 

Kristina Younger 



RECEIVED 




2M 



BURUUOFianaiu!U«EUeNT 



_ob hetiK, n oii:;. Leader 
Bureau of :<at)d : i atafl^«a*«.l3 
P. I,, 5QZ liS 
foriUBd, -.'yojulaii C2401 
TiQ&t i r. ;io.Bt, 

z 'cm iistrei'Bffd vo ieana thut the dr.ift nana^ 
pJ.AA for the GasMSfl ".'reek '(csource ^re- will aiiew 
at ths resource areK za bs leased for oi". and $dz 
uevs'o?fli8n'i;» etitJ waula Liite to ■safest tihut aov.e s 
^lould be protected from this. 

'Jiie .ibsGrckc !--'ooti:i J J.s , 
tuiJ p.ed '^nyon '.'reel! " , :.gcla'i 
»rw.£ should be no vrcije'c-ed. ;.iio tii- ":',£^i.-j ndd :;,;:..; 
ciiould be aa ,\ren ci' flrltioti] wvisomiictrtai .'oncar/j 

(:; ■'.:■'; tje-eaaaa of ox-irentijiy frK&iie soij.? an:! racUy 
iy,?cct0Mifii7 trenerv. T r^-o believe that Bll e.rer.e 
iuciuaeti la the reader vs. tioni.-ta 1 ..Iterratr.': to 'ti'ie 
Bi::'i '.'IMarneK- froj>orRl iaclailes l&uck out. ids 

'ilelsrotrsi, "tudy ^reae elioii^i be protected freia oiJ 

1 1 wculi'l f.ist.' E'jqci wIj^ t;cj i?T07lfle i:.cre ie£inS"Ss 
jOi-la tg B'iireur the pwljieiafe oC overgrftsiajs in tiie 
resource rrcr , inclu-.l i.n;; & ircjrieiuv.e or definite tlffif* 
bo Rocompiiari tii-e-a s ja-a.le in ihc next fiv-e vgem:. 

.■■.iii'nou^b j hiive never visited '-'VtMuiai, 1 iiwva re«d 
su-clj tbout its jp^c it. i. b*feyties:, '* book by John :;al'b&*> 
b.in.^ cue oX 'the most itttereEtiti.-i. I have been in o*lWp 
nrsi :; oi' the n&t*t where the t.*!a.$ii£ictmt scsnerj uaa 
gal "S3 Bverwhelihln^. 'i'hase experiences &L¥B ie<] ae So 
■ru^rcrt the eaageatlor^ I have rnuiu i:: thia leLUr. 

"incorely , _^ 



AW 71986 



JUKAU Of IAND MNMEM 



Monday, April 3, 1995 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P. O. Box 119 
Worland, Wyoming 82401 

Dear Mr. Ross 

If the droll management plan for the Grass Creek Resource Area of the Bighorn 
Basin is implemented as it is now drafted il will allow uncontrolled oil and gas 
development in one of the mosl beautiful parls of your slate. In this plan the entire 
area is lo be leased for oil and gas development, with none of the alternatives 
considering less than 100% of the area for development. Three Areas of Critical 
Environmental Concern are designated in the plan, but the management of these 
areas is not sufficient lo protect the area. The plan should be changed so that the 
Absaroka Foothills, Badlands, Bighorn River, and Rod Canyon Creek Special 
Recreation Mangemenl Areas are protected from oil and gas developmenl and the 
Badlands Special Recreation Management Area should also be designated an Area 
of Critical Environmental Concern because of ils scenic and very fragile soils. The 
plan should protect all areas included in the Conservationists' Alternative to the 
BLM's Wilderness Proposal including lands outside Wilderness Study Areas. Goals 
should be provided lo address ihe problems of overgrazing in Ihe resource area 
and a timeline should be provided for accomplishment of Ihese goals within the next 
five yeors. 




357 



213 



Ms. Ruth A. Mains 
xxxxxxxxxxx 
xxxxxxxxxxxxx 
xxxxxxxxxxxxx 

Dear Bob- I am writing about your Bighorn Basin Plan. 

I would like to see the following changes. 1. The Absaroka Foothills, Badlands, Bighorn 
River, and Red Canyon Creek Special Recreation Management Areas should be protected 
from oil development. 2. The Badlands SRMA should also be designated an ACEC because 
of Its spectacular scenic and extremely fragile soils. 3. Protect all areas included in the 
Conservationists Alternative to the BLM's Wilderness Proposal including lands outside 
Wilderness Study Areas. 4. Provide more definite goals to address the problems of 
overgrazing in the resource area, and provide a timeline to accomplish those goals in the next 
five years. 

Sincerely 

Isl Ruth A. Mains 



RECEIVED 



APR 7(995 



114 



BUREAU OF LAhDSMAfiEMC^ 



BLM 

P.O. box 1 19 

Worland, Wyoming 82401 



Dear Mr. Ross, 



As ycu are aware the Grass Creek Resource Area Is one of the meet 
beautiful parts of Wyoming that contains the eastern slopes of the Absarctea 
Mt. and extensive ott and gas development. This, I fed Is a big mistake. I ask 
that the plan be altered to Include the following: 

a. TheAbearoka Foothills. Badlands, Bighorn River and Red Canyon 

SRMA be protected from oil development. 

b. The badlands SRMA be designated an ACFC because of outstanding 

beauty and fragile sell. 

c. Protect areas included tn the Conservation a! Alternative to the BLM 
Wilderness Proposal Including lands outside Wilderness Study Area. 

I encourage ycu to include the above in the management plan. Thank 
you for your time and consideration In this matter. 



Sincerely, 



Richard Davlfi 



RECEIVED 



m idi 



'UUOFUKDMBMEnClfT 



m& 



Bob Ross 

BLM Team Leader 

P O Box i 1 9 

Worland. WY 82401 -0119 

tt*W> s 

I've just gotten wind of whir's In the BLM draft man age mem plan for the Grass Creelc Resource 
Area. Considering dial only a small percentage of the territory is even considered as wilderness 
study, don't you think, in the name of multiple use, yon could leave it as WSA instead of 
dedicating il *U to Oat use - oil and gas? Even if Congress rejects them as designated wilderness, 
they are stiJl so special thai they should be protected. (I'm talking about Owl Creek, Slieep 
Mountain. Red Butte and the Bobcat Draw area), 

If ! understand the plan correctly, every inch of the Grass Creek area, including areas of critical 
environmental concern, sensitive wildlife habitat and undeveloped recreation land is to be 
opened up to oil and gas leasing. This is patently ridiculous, so extreme as to make me wonder 
who is pushing you around over their As I read the "multiple use" law, it extends to other 
than extractive uses ..it talks about protecting water quality and watersheds, protecting wildlife 
habitat, and providing opportunities for research, recreation ajid aesthetic value*. If you 
proceed to ignore the bw that governs you, you are essentially criminals, and leave yourself 
open to all kinds of ugly and entangling lasuits ihat uke up lime and taxpaye-r money Why 
not get il right uo*? 



/f4^M>^VV^V7V 



216 



I'm writing to oppose the BLM's proposal to Open Wilderness Study Area in the Grass 
Creek Resource Area to Hard Rock mining, motorized vehicle use & oil &. gas development. 
1 used to work in the Grass creek area & am familiar w/ its unique character & features. I 
urge the BLM to protect this area's potential National natural Landmark and make areas of 
critical envmtl. concern off limits to oil & gas leasing. The "town" of Grass Creek is an 
ugly & discouraging example of what happen with oil & gas develpmt. Instead, the BLM 
should emphasize improving riparian areas & the rangeland so as to increase the areas fish &. 
wildlife habitat - the area has tremendous potential to support wildlife w/ its mozaics of 
habitats Managing every acre as available for oil & gas development is short-sighted, 
damaging & a violation of multiple use. Please protect Grass Cr. Thank you. N Caroline 
Byrd xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 



358 



217 



Why is it so difficult for the BLM to manage the land properly? 

Where is the policy [illegible] in rather than demdish [sic] and destroy our natural resources? 

Right now the Grass Creek Resource Area is under serge by the plan to permit uncontrolled 

gas & oil development. 

We urge you to make the following changes. 



1.) 



Protect the following from oil development 

Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek SRMA 

Designate the Badlands SRMA as an ACEC 

Protect all areas included in the Conservationists' Alternative to the BLM's Wilderness 

Proposal including lands outside Wilderness Study Areas. Thanks 

til M Crenshaw [illegible] 

III Jack Crenshaw 



RECEIVED 



m i oss6 



218 



„ ,_ „ BURUU OF UMD BMAKMENT 
Mr. Bob Ross |_ wtttiAW, grawws 

Team- Loader 

Bureau of Land Management 

PO Box 119 

Woe land, Wycming 82401 



I am writing to you about ray concerns with tiie draft management 
plan for the Grass Greek Resource T^rea. 

#1 - Why do all of .the alternatives allow 100% of the resource 
area for oil and gas development? 

#2-1 waa happy to see three areas set apart as Areas erf (Critical 
Environmental Concern. The management proposed for these areas 
does not seem likely to sufficiently protect them. 

#3 - All areas included in the Conservationists' Alternative to 
the BLM's Wilderness proposal should be protected. 

#4 - The badlands SRMA should also recieve extra protection because 
of its frayile soils, and the scenic beauty. 

#5 - Overgrazing problems need to be solved with a definite t±BB- 
irame and definite goals. 



Thank you for this opportunity to comment. 



Mrs. Barbara .Ristow 




mw 



Aprils, 1995 

Mr Hob ROSS, Team Leader 
Bureau of Land Management 
PO Box 119 
Worland, WY 82401 

Re: Comments on Grass Creek Resource Area Draft Management Plan 

Dear Mr, Ross. 

1 wish to submit the following comments on the Grass Greet Resource Area Draft 
Management Plan. The area in question is extremely scenic and the range ofCffrrate and 
vegetation zones that it includes makes it of high value for the diversity of habitat and 
visual resources 

Overall, ttte draft management plan appears to abdicate any effort to protect non-oil and 
gas mineral values The system of management proposed for this area would allow up to 
1 00 percent of the Resource Area to be leased for oil and gas, and none of the alternatives 
considered in the planning document entertain any reduction in the area open to this 
activity The failure of the draft plan to afford sufficiently stringent protection to the two 
proposed Areas of Critical Environmental Concern is a serious shortcoming. Finally, at 
issue is the degradation ofToadlcss areas that were not included by the BLM in its 
designated Wilderness Study Areas, many of these areas should be included in the WSAs 
I hat BLM has proposed. 

In particular, the plan should be modified as follows: 

(1) The following Special Recreation Management Areas should be withdrawn from entry 
for oil and gas development in order to protect their essential non-fuel values: Absaroka 
Foothills, Badlands, Bighorn River, and Red Canyon, 

(2) ACEC status should be extended to the Badlands SRMA on account of its 
extraordinary scenic values and the fragile soils thai it contains. Such areas afford 
outstanding visual resource opportunities as well as valuable sites for paleontologies I 
study. 

(3) All areas still at issue in terms of their WSA status, including those in the 
"Conservationists' Alternative," should be withdrawn from any leasing for oil and gas or 
entry for other minerals Tins includes, of Course, all lands now formally designated as 
WSAs. Such withdrawal is essential to Fairly resolve the potential wilderness status of 
these lands 



Mr, Bob Ross, Team Leader 

4/5/95 

Page 2 



219.2 



(4) Specific range improvement goals, including a timeline tor accomplishment, should be 
included in the plan to address the impacts of excessive livestock grazing in the Resource 
Area Improving the health of the rangeland is essential to protecting the long-term 
agricultural base ofWyoming's ranching industry, even if this means temporarily reducing 
stocking levels or revising allotment management plans. 

In closing, I note that the oil and gas resources will always be available for development. 
should that prove necessary; the other values that these lands afford are fragile and must 
be protected if they are to be passed intact to the next generation. 

Thank you for your attention to these comments, and I urge you to reconsider the 

apparent pro-development direction and emphasis of the draft Management Plan 

Very truly yours, 



\jv^&V\ ^^JLwjUk 



Jonathan M, Teague 



359 




220 



April 3, 1995 

Mr- Bob Ross 

Bureau of Land Management 

P.O.Box 119 

Worland, Wyoming 82401 

Dear Mr. Ross: 

I am writing with reference to the draft management plan for the Grass Creek Re- 
source Area in the Bighorn Basin. I would like to propose the following as some 
changes that should be made to that management plan: 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas should be protected from oil devel- 
opment. 

The Badlands Special Recreation Management Areas should also be desig- 
nated an Area of Critical Environmental Concern because of its spectacu- 
lar scenic and extremely fragile soils. 

All areas included in the Conservationists' Alternative to the BLM's Wil- 
derness Proposal, including lands outside Wilderness Study Areas should 
he protected. 

• More definite goals to address the problems of overgrazing in the resource 

area should be provided as well as a timeline to accomplish those goals in Ihe 
next five years. 

Thank you for considering these proposals for the future enjoyment of Americans to 
follow us. 

Sincerely yours, 



Mary Thompson 



221 



Gladys J. Van Meter 

XXXXXXXXXXXXXXXXXX 

X X XXXXXXJt X XXX X XXX X XXXX X 

Bob Ross, Team Leader 
Bureau of Land Management 
Worland, Wyoming 82401 

Dear Mr. Ross, 

I am very concerned about what is being planned for the Grass Creek Resource Area. 
Such a beautiful area should be left alone. We are constantly destroying so many places in 
our Country, we should be trying to control the population !! 

The Absaroka Foothills, Badlands, Bighorn River &. Red Canyon Creek Special 
Recreation Management Areas should definitely be protected from Oil development. 

Badlands S.R.M.A. should also be designated an ACEC because it has extremely fragile 
soils. 

Protect all areas to the BLM's Wilderness proposal including lands outside Wilderness 
Study Areas, 

And to provide more definite goals to address the problems of overgrazing area. 
I love what's left of our beauty in this Country. We are gradually losing so much of it. 1 
urge you to pleas do what you can to save all of these areas I've mentioned. 

Sincerely, 
l<J Gladys J. Van Meter 

XXXX XXXXXJCXX xxxxxx 

xxxxxxxxxxxxxxxxxxxxxxxxx 



RICilVtO 



tfRirjl 



.Wu>- IA^Df.',itflflli ni 



222 



Dear Mr. Bob Rocs, 

I recently heard of the Bureau of Land Management's plan for Ihe Bighorn Bash. To my 
knowledge the plan atows for 100% of the resource area to be Seased for oil and gas development. 
Those areas, such as The Absaroka Foothffls. Badlands. Bighorn. River, and Red Canyon Creek 
Special Recreation Management Area, should be protected from this oil develop m ant The 
Badlands SftMA shouU be designated as an Area of Critical Environment Concern because of its 
spectacular scenic and ertremety fragile solh Aft areas Included In the Conservationists' 
Alernairve lo the Bureau of Land Management Wilderness Proposal should be protected Including 
lands outside of the Wilderness Study Areas Fbialy, one should provide more definite goals to 
address the problems of overgrazing In the resource area, and provide a timetne to accomplsh 
those goals in the nert five years I strong^ beleve that Ihese changes are needed to preserve 
our lands and I hops that these changes do gel proper consideration 
Sincere*/. 

Trscl Borgan 



223 



April 6, 1995 

Bob Ross 

BLM Team Leader 

P O Box 119 

Worland, WY 82401-0119 

We are writing regarding the BLM's Grass Creek Management Plan that threatened 
Absaroka Owl Creek Mts that some unique desert environment with increased oil &. gas 
development. 

It seems we the people must be ever vigilant regarding our public lands. The proposed 
resource management plan places unacceptable emphasis on providing motorized recreation 
activities. 

BLM needs to provide greater protection for potential natural landmarks. There are 
areas (you know what they are) of critical environmental concern in the resource area that 
should be off limits to oil & gas leasing & development. 

Hard rock mining withdrawals should be encouraged because of the antiquated 1872 
mining law. 

BLM should place a greater emphasis on managing h'ish &. Wildlife habitat. 

tn closing the BLM does not have the best interest of the land & the "people of the 
west" at heart. 

/s/ (Mrs) M. Temple 
til (Mr) C Temple 

XXXXX X X XXXX XXXX X 
XXXXXXXXXXXXXXXXXXX 



360 



RECEIVED 



APR I I 



BUREAU OF LAND KAMflEUEfJT 



124 



Bob Ross. Team Leader 
Bureau of Land Management 
PO. Box 119 
Wtirland. WY 82411] 

Dear Mr Ross. 

I am writing you this lener to implore you and the Bureau of Ljnd Management to amend the proposal I'oi 
oil and gas devdopmeni wiihin the Bighorn Basin Plan 

I was myself involved ".villi Hie oil industry some vru-s ago and worked on a number of wells throughout 
the state of Wyoming The areas when; this drilling is proposed arc ones of extreme beauty and deserve to 
besd aside for ciliwjns to apprcciaic and enjoy, I have visited these areas myself a number of times and 
have driven through ihcm on my wa\ to Montana regarding my former work. 

II is my belief that these areas were Ihey explored for hydrocarbons would realize Bole production 
However, the development of an oil induslry there would seriously compromise their value as a national 
resource and historically as areas considered by me a national treasure Areas such as these need to be 
conserved and set aside for the public benefit; as a place to visit and pursue recreation. 

It is my belief that these areas rank as the most beautiful wiihin the Slate of Wyoming. In these Limes of 
financial considerations, and budgetary problems it is simply loo easy to overlook Ihe long-lcrm benclil for 
The short-term quick fix 

To this end. if these areas are (tecflflAtSd for potential immediate financial gains, future RcneraLions will be 
deprived of this irreplaceable natural resource and the American public will be the ultimate losers. 

My belief concerning these mutters is that the Federal Cioverumem has the duty to protect our national 
treasures for present and future generations, 

To this end 1 ask [hat you modify the above plan mentioned to protect the Absaroka Foothills, Badlands, 
Big Horn River and the Red Canyon Creek Special Recreation Management Areas from future 
development of all kinds and preserve these areas for the American people. 

Thank you for your patience in tearing my request, 



Harvey M. Hoffman 



RECEIVED 




225 



Buros.u of Land Mans cement 
101 3 23rd 

!!?er1 ,-virj, v,y :■ ,?£,,;! 



This la a v-ecuest fctiafc the Urn. 
pi emeriti for the following reasons 



Creek Err. ft not b« im- 



(X) Preantor control ia not properly addressed. Without 
fsi'mflrs, fJLM ami proctor control program working together 
the vast IsnQ would soon become nothing more than's wasteland 
Goyotea, foxes, raccoons, skunks, and wolvfie wtould deplete 
the wild gsfte to lov numbers, plus there woult be tm increase 
of rrbieG nnd distemper. Look at Veil ovjt,vil Habitat, less 
hunters, lees pheasants,, lots of weeds, Where is nil the 
rftcrewtiorj promised t'hft hnsn't Ehouri up'? 

(?) There la no need for the tame horses sono v.lld ran/re. 
There .-re plenty of them In the Pryors. 3r.e OS the largest 
oeoiraent areas filling Yallowtail comas frosi that srea. 

O) L«nd should be manrzov oo tr-at maximum oil, gas, and 
iii-nor.-as cm: be hawmtsti, Th.-t ts the main loc-,1 tax Ws*. 
■'hen fanifira sti settlers curie in tunC etRrtfld farming and 
irt-lgatlriK. the nuaibtr jf v.ildlife .rj^] F 1r^"sij. Di f rer- 
an i finj.mals e--t 51 fferenl Feeo\ There ii p sneciia gHs So"" 
hfive csttle ,: ui sheet' graze or. the S8.ua Ijvad. The best is - 
Cuttle, sheep and srildllfe. This li-.ne has been utilized for 
over 100 jrB»r« "ny rAChers rnd cattlemen, Ts the drnft msde 
ta remove people including BLK personnel from Wyoming, so 
it will really turn into p vast wwste like the California 
tutfib.lfi vrter rt-fitfelnnc? 

Please do not mnkfl it hrrder to. ria business jr reduce 

our efficiency. 

Hesp&ctf ully, 
Rear-: wnliatjie 









RECEIVED 


i 00(\ 




APR I 1 B95 


Charles C TUekgF «£■■&!■ 't»# 


BQ 


UU OF LANO KAflMEl 


Jff 


Mi- Bob Rosy T earn Leader 


Bureau or Land management 


f"oa1 DM ice Boj< 1 19 


W©f-l»fieij Wyoming 6*e<01 




Hm: BLPT* i't(.<rin.lv relefiteed cm' ^ r t M=in^oenie:il L'lan 




; i -, ■■ :-i,. vx'-vj-.. Cii-L-.-li. Re- ■.'■ u i r c e Area, fiiahor-n £asm. 




t>t>hv n* Robs; 


: neve recently received a comniunicfitioti from thft SierrA Club 


rwg*rding the ibovi noted "draft," end r**l compelled t.« cor'teyt you 


in ^-. effort to urge you to consider the following points' 


it ;r- t>h» opinion ot the Club, ami myself that the ftbaWPWk* 


Foothills, Badlands, Bighorn River, and Red Cenyon Oe#k 5p&cial 


Rpcr-eation fi;i,nngement Pireas BTtould be protected from oil, and nalup*i 


gas devei'jpmenl . Due t* it's soi i fragility, tha BftdlsridB 3MRA should 


a i ?.o bo d#KignJ»t»d ftn AC' EC 


Prvtfttic.ii .:.f *I1 «r-0»ti nKlud^cJ in i'h» Ci 5n«# tval inn: »t«' 


fil t*rn4,tiv* to th» BLM- 1 * UildernBBS PrepO*ftl should bw man« manaator-y; 


thit p!''-''-*c tion pMMfMkina to All land'a outside Uild^>rne-^=i Study ftreas . 


fctftti'* defirnte goals need td ce initiated to address trie problems 


Ol cverqi'azinq in tht! rHinurLu afHd, dnti e t Jinel in» to sc CQWtll iSh 


th*ae goals over the next fiva years should be designed, and maid* 


available to the general puUlit, tl-i rough acproDnate channels, for 


four consideration of the atefjv* material will be greatly 


»ppr«<:i»tw>GI, rt.nd I hope that an equitable decision to all concerned 


will Ho Msdel 


Sine #i-ft3 


LsVaaA^ L*S~i *cAt- ' 


CHSHL.ES C - 1 UCKErc 


OOPVi FILE 



APR I l 



227 



April 10, 1995 

Bureau of Land Management 

Grass Creek Resource Area 

Attn. : Bob Koes 

P.O. Box 119 

Worland, Wyoming 82401-0119 

Rebecca Wampler 



Dear Hr. Ross: 

Ak a Wyoin.inE native and llfetiae user of the federal lande 
within the State, as a biologist and trained and experienced 
public lands administrator, and as a published nature writer 
and wildlife fllm-naker, I wish to express ray support for 
livestock grazing on the Grass Creek Resource Area, 

I protest the BLH's use of the current grazing leases numbers 
to determine animal units per month figures. No base line 
data cr grazing studies back up these reduced figures. 
Grazing does no harm to the resource, in spite of the 
myths currently in vogue that defame livestock on public 
lands. I request that the BLM choose to be fiscally 
responsible and reasonable and support an Industry that 
supports the Bureau back, local livestock grazing. 



sincerely. 



1 Rebecca Wampler 



361 



228 



4-6-95 

Bob Ross 

Team Leader 

Bureau of Land Management 

POBox 119 

Worland, Wyoming 

Mr. Ross, I am concerned that the recently released draft management plan for the 
Grass Creek Resource Area does not sufficiently protect the area from environmental 
harm. Please consider the following changes; 

1. The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek Special 
Management areas should be protected from oil development. 

2. The Badlands SRMA should be designated an ACEC because of its spectacular scenic 
qualities and fragile soils. 

3. Protect all areas included in the Conservationist's Alternative to the BLM Wilderness 
Proposal including lands outside Wilderness Study Areas, 

[page 2] 

4. Provide more definite goals to address the problems of overgrazing in the resource area 
with a timeline to accomplish those goals in the next five years. 

Thank you for your consideration. 



Sincerely yours, 

/s/ Bernard Kerosky 
xxxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXXX 



RE C E I V E D 



m 121996 



229 



Worland BLM 

Bob Ross, RHP Team Leader 

Box 119 

Worland, Wyoming 82403-0119 

Dear Mr. Ross: 

I would 1 ike to take this time to comment on the recent draft management plan 
for the Grass Creek Resource Area of the Big Horn Basin. 

Listed below arc the areas In which I object: 

Absolutely no credit given to the technologies in any of the multiple 
use Industries from which the environment benefits. 

Ihe loss of significant dollar revenues Lo all four counties (Park, Hot 
Springs. Washakie, and Big Horn) without any consideration for the 
impacts to the people and state economy. 

Inadequate range of alternatives from which to chose. 7~]% of the 
statements comparing the alternatives all read, "Same as Preferred." 
This violates the National Environmental Policy Act. (NEPA) . 

Clear bias AGAINST gracing. The Preferred Alternative reduces grazing 
by 25 percent. 

Unreasonable restrictions on - the Oil & Gas industry in the preferred 
alternative. Absolutely no consideration was given to the development 
and use of new technologies. No credit or value is assigned to 
produced water and wildlife habitat developed from oil and gas 
activities. 

The BlM's attempt to create more Wilderness without congressional 
consent by managing areas as though they are wilderness (defacto) when 
they aren't Areas such as Upper Cwl Creek, Badlands Red Canyon Creek. 



Motorized recreation 
management . 



being negatively impacted via wilderness 
Thank you for this opportunity to comment. 



Sine 



■iy. 



Ca^vvo. .SLuoaJ^ 



Connie Shwartz 



*> 



RECEIVED 



m\zi 



m§ 



Worland BLM 

Bob Ross, RMP Team Leader 

Box 119 

Worland, Wyoming 82401-0119 

Dear Mr. Ross: 

1 would like to take this time to comment on the recent draft management plan 
for the Grass Creek Resource Area of the Big Horn Basin. 

Listed below are the areas in which I object: 

Absolutely no credit given to the technologies in any of the multiple 
use industries from which the environment benefits. 

The loss of significant dollar revenues to all four counties (Park, Hot 
Springs, Washakie, and Big Horn) without any consideration for the 
impacts to the people and state economy. 

Inadequate range of alternatives from which to chose. 7~\% of the 
statements comparing the alternatives all read, "Same as Preferred." 
This Violates the National Environmental Policy Act (NEPA). 

Clear bias AGAINST grazing. The Preferred Alternative reduces gracing 
by ?S percent. 

Unreasonable restrictions on the Oil & Gas industry in the preferred 
alternative. Absolutely no consideration was given to the development 
and use of new technologies. No credit or value is assigned to 
produced water and wildl ife habitat developed from oil and gas 
activities. Extremely large areas are set aside as no surface 
occupancy and controlled, these designations economically prohibit oil 
and gas development and should therefore be changer! to allow reasonable 
development of at least one well per 40 acres. 

The BLM's attempt to create more Wilderness without congressional 
consent by managing areas as though they are wilderness (defacto) when 
they aren't Areas such as Upper Owl Creek, Badlands Red Canyon Creek. 



Motorized recreation 
management . 



negatively impacted via wilderness 
Thank you for this opportunity to comment. 



Sincerely, 



RECEIVED 



(WI2B86 



sm 



C. David Fridge 



April 7, 1995 



Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 

Worland, Wyoming 82401 



Dear Mr. Ross: 

I am writing to express my concern over the Bureau ' s draft 
management plan for the Grass Creek Resource Area. If the current 
plan is implemented It will permit virtually uncontrolled oil and 
gas _ development in this beautiful part of the state. I strongly 
believe that this is not appropriate and would like to suggest the 
following changes to the management plan; 

o The Absaroka Foothills, Badlands, Bighorn River, and Red 
Canyon Creek Special Recreation Management Area (SRKA) 
should be protected from oil development. 

o The Badlands SRMA should also be designated an ACEC 
because of its spectacular scenic and extremely fragile 
soils. 

o Protect all areas included in the conservationist 
Alternative to the BLM's wilderness Proposal including 
lands outside Wilderness Study Areas. 

o Provide mare definite goals to address the problems of 
overgrazing in the resource area, and provide a timeline 
to accomplish those goals in the next five years. 

Mr. Ross, as you know, the Grass Creek Resource Area is located in 
one of the most beautiful parts of Wyoming. To provide for a 
laizze faire system of management which allows 100% of the resource" 
area to be leased for oil and. gas development is not right. I ask 
you to consider revising the plan to address the items outlined 
above . 




362 




232 



April 11 , 1995 



cob ricsa, fll-lF Teem Lendor 
P.O. Box 1 1 9 
Worlund, My B&I01-O1 1 9 



HaTln,--, .-evicvjed fcl'ie proposed Grass Croak Management Plan 
va offer tjta fallowl-pr iKaft-.eniia, 

i , .,o cr-.,ul^ . :■ v\:.lue i:; . ivon z< t us inci".istriea for the 
aevslopsn&afc of improvements isuch as water feliftb directly 
beae;"It3 tl'-s land «j v/ilcllii's. 

2. 121s attempt tc rianu.&s tno land ;:; if it ware tflldaimesa, 

restricting uss by industries & j*ftfti*eAtioa aliSa t» 
un.~aiiscn&ble flj will devi-jtute our ill-s stiie. 



vJe are amais 
•at-jtoiatiVM 



to find 71jS Offfitt-t 
1.1. rasac.* " d-~«s as 



nenta soup snug 
rei-;rryd". 



4, With tlie 25^ cut in grazing, the restrections on 

Willing, timber, gas, oil tin recreation use there, will 
be a signifi*ant"los3 of revenues to Park, Hot Spring*, 
Washakie k Bi& Horn Counties. 

If the people in these counties den not awake a living just 
how do yon expect we eon support your jobs? ;«kere do you 
get your rr.oney from? WllJ do you want to jilll tho Goose? Vie 
urge 1 you to take a hard look & rewrite this total plan. Ihe 
eaoil07;da future £ lifestile of this entire area is at stake. 



ii-'icereij", 




■<< 


• CHIVED 




al 


SB 1 8KB 




mmmjUgaon 



233 



Bob Ross 

BLM Team Leader 

POB 116 

Worland, WY 82401-01 18 

Dear Mr, Ross: 



Re BLM Grass Creek Management Plan 

I . The BLM'fi Proposal to Open Wilderness Study Areas to Hard Rock Minerals Mining, 
motorized vehicle use, and oil and gas development is unacceptable. 

2 BLM should manage more of the resource area for semi-primitive, non-motorized 
recreation activities. 

3 BLM needs to provide greater protection for potential natural national landmarks 

4 Areas of critical environmental concern in the resource area should be off" limits to oil 
and gas leasing and development 

5 The South Fork of Owl Creek meets the criteria for a national wild and scenic river. 
6. Hard rock mineral withdrawals should be encouraged. 

7 The proposal to allow oil and gas leasing and development on every single area of 
legally available public lands is clearly excessive and violates BLM multiple use madates. 

8 More attention needs to be given to improving the condition of riparian areas and 
rangeland. 

9. BLM should place a greater emphasis on managing fish and wildlife habitat. 



Sincerely, 








oo* eU 


Office S ^ /u 


2 


34 


k 265 Nonh Bent 
vfH P.O. Box 875 

Powell. Wyoming 82435 
LLU [307) 754-4154 
wB FAX 307-754-9779 


<2» 




RECEIVED 
95 APS \U AH 9i 1 
MTJ uLN IkOftlAMO D.O. 


[^ctB^ 




4/13/9S 














Worland BLM 
V.&ob Rd55 
RMP T**m Leai. 
Box 119 

Wor land. WY 


er 
92401-01 19 












fir. &oh Ross 














l am writing 


to vou concern 


nq tnp Q 


■a^^ Creek ResuL 


re. «r„. 






J have some major abject ion 5 to trie current trnnrl ni 
obieer tives. Since these are multiple use lands you 
tiirf-, against gra? ing by reducing it -an unreasonable 

a 1 terna t i ve will also impair t motorized recreation ir 


amour t a.1 ong 
a negative 


_>nt 

with 

ferrpd 




Your- Preferred At t.ernative 
management with out rnnnre-s 
multiple use industries env 
vinlatinn nf the National E 
range of al ternatives from 
alternatives only stating s 


ivi ronmen 
r*hich to 
ame as pr 


appearance of wilderness 
ispnt. No credit is given t 
burie ( i ts . Thare bi^Kms to 

tal Policy Act with inadequa 
:hose with over /OX uf the 


a the 
be a 
te 




I col] Id qo on, but you shou 
preservationists that don ' 
the uties to dictate the- use 


vr*:„E 


drift by now, 
iving in Wyumir 
in my back yarr 


u should not 


tate 
be 




1 ma(-e my 1 iving in Wyoming 
^ee no thing bu t loss of rev 
Springs, Washakie, and Sig 

a larger revenue source tha 
thst the local business sul 
unemployment lines. 1 n<;p 
very tough un *mal 1 busina^i 

the U« load. 


L'liues (or the fuur C-OUn ties uf Park. Hot 
Hum with vaur Preferred Alternative. If 
t-s tu t he-ae counties you should figure nut 
n is available now tn keep the employees, 
i as mine support, from the welfare and 
Of Our current of future taw base can be 
^ps in this area that waul d have tn pirk up 




Thanl- vuu ffl 


ypur time. 












Rotaald G. Bl 


,vins 

























235 



BLM April 13, 1995 

Worland, Wyoming 

Grass Creek Resource Area 

Attn: Bob Ross RMP team Leader 

Sir 

About the draft plan about the Grass Creek Resource Area. 

I don't believe it gives any credit to the multipal use industries like logging, oil 
companies and grazing. Theyve developed road & water so some of the ground could better 
used as multiple use with very little damages. They are managing their own activities very 
well on their own, without all the restriction that the draft proposes. If they don't someone 
is ready to sue them. Through all the modern technologies the Industrie can develope some 
things that were not practical even 20 year ago. 

The reducing of grazing is cutting out a lot of ranches that have been in operation for 
years. There has been no mention of the local manager, thejancher , who is better informed 
about the ground than the person who has spent a livetime there? I believe the local people 
should be more involved in this draft, closing some of these road, are nothing but a back 
door way of controling private owned properties. Foot and horse back is a cop out. It 
eliminates 99% of the people. Is this multiple use? Those wild horses on Fifteenmile 
Creek, should be elimnated, as theyre not what I would call wild. Their ancestors arc 
escaped horse from around the area. More work horse blood than any. It would save 
several million dollars over the years. 
[page 2] 

This draft should be thrown out and rewritten with the impact of the local goverment and 
state, as the natives are the one affected, through their Iivelyhood and cultures 

Thank you 
/s/ Hugh Vass 

XXX X XXX X XXXXXXX X 
XXXXXXXXJCXXXXXXXX 

xxxxxx 



363 



WECIIV60 




mm 



WYOM 



Mr. Bob Boss 

RHP Team Leader 

Bureau of Land Management 

Post Office Box H9 

Borland, W v 82401-0119 



April 17, 1995 



□ear Mr. Roes; 

I'm writing today on behalf of the 600 plus Cody Country Chamber 
of Commerce members. 

The Cody Country Chamber of Commerce believes the Grass creel; 
Resource Area Management Plan is severely flawed and that the 
preferred alternative is not acceptable. 

Specifically we believe that there are undue restrictions on the 
oil and gas industry, which is critical to the long term survival 
of this region. The Yellowstone Development District, which is a 
four County Economic Development District formed under guidelines 
from the U.S. Department of commerce Economic Development 
Administration, has done extensive analysis on the economies of 
Park, Hot Springs, Fremont and Sublette Counties. The 
inescapable conclusion of this analysis is that when our 
employment base drops below 6% in mining, oil and gas, then we 
see sharp increases in the number of welfare cases and people 
living at or below poverty level. The restrictions proposed in 
the Grass Creek RMP will severely deter future oil and gas 
development and accordingly reduce the level of mining, oil and 
gas employment in Hot Springs and Park CountieG. This reduced 
exploration and development will also lead to significant loss of 
revenues to the counties of the Big Horn Basin, because of the 
loss of potential production and lease opportunities. 

we also believe it is inappropriate Cor the Grass Creek RMP to 
reduce the number of grazing AUM's by 25%. Despite the fact that 
there may already be these kinds of reductions occurring 
voluntarily by the livestock industry, it is poor planning to 
arbitrarily reduce these numbers in a resource management plan, 
which would foreclose the opportunity to increase those numbers 
should increased grazing be warranted and justified. 

Lastly, with the BLM's shift in emphasis from commodities use 
toward recreation, there needs to be a clear understanding that 
our recreation industry is tied very closely to commodity usage. 
People coming out west are looking for a western experience and 



The pndc of Buffalo Bill's Yellowstone Country' 

com ((u^rHVCHwnn^ovroMMKRc ]■: 



RECEIVED 



m 181906 



UMWOFUHtDMMiaiOn 



23S.2 



Kr. Bob Hobs 

Page 2 

April 17, 1995 



that includes finding cowboys on the range. You do not have 
cowboys on the range without cows on the range. It has also been 
clearly demonstrated that when commodity uses become more 
restricted, it is soon followed by other restrictions that impact 
access to public lands by recreation users. 

The Cody country Chamber of Commerce believes the Draft Grass 
craejc Resource Management Plan needs to be redrafted with, more 
consideration for the commodity users, the recreation industry 
and the economy of the counties within the resource area. 

[ards, 



wriw 



_BuxJl 



os! RMP Team Leader 
id iLM 



*Vy K240l-0ll<-:i 



237 



The intent of this letter is to adamantly oppose the preferred alternative for 
management Ofths Grass Creek Resource Area as outlined by your draft management 
plan. 

Plain and simple this plan is an outrage! This appears to be just another attempt bv 
the long arm of the. Federal Government CO restrict multiple use of public lands for the 
sake of the liberal preservationist agenda It also appears to bean attempt to set a 
precedence for future BLM land Control policies which do not adequately reflect the 

s or interests of the local inhabitants of these areas 



The land can be better managed for the good of most people from both an 
ECONOMICAL as well as ENVIRONMENTAL standpoint by multiple use concepts 
which are now in place 



A well halanced plan does not eliminate 25% of the cattle grazing I 
more deer and antelope which contribute little to the local economies in (his area 

The unreasonable restrictions on the Oil and Gas industry addressed in the 
Preferred Alternative are way out of line. No consideration was given to the development 
and use of new technologies or to the fact that this industry in particular has cleaned up its 
aci immensely in the last several years. This industry IS now operating in close proximity 
with the enviionmenta! concerns of all of us. We desperately need the economic funding 
for our local schools and expenses, not to mention the number of people working directly 
in this industry who contribute to the local economies and lax base The rest of the 
nations people need and use these resources as well 

It is clear that the BLM is way out of line when it attempts to create more 
Wilderness without congressional consent as it has done in areas such as Upper Owl 
Creek and Badlands Red Canyon Creek Again we are talking CONTROL issues and not 
sound management practices. 



This plan appears to be about as well (mentioned for the local hard V 
as the Spotted Owl was in the Northwest or the Wolf teintioduction farce i 
Yellowstone and Central Idaho Is this nol just another frontline maneuver i; 
expanding war for control of the West? 



irking folks 




■ 








RECEIVED 




238 




m. isms 


m 




uuoruuDuuutu 

OMmK 


April 17, 1995 


Worland BLM 


Bob Roes, RMP Team Leader 


p. 0. Box 119 


Norland, Wy 62-101-0119 


Regarding: Grass Creek Resource Area Plan 


T am opposed to your preferred Alternative in this draft 


plan, as I strongly feel it is too restrictive. At a time 


when our Wyoming economy desperately needs revenues -o finance 


our schools and governments, ve should not be slamrninq the 


door on oil and gas industry and ranchers dependent on 


the puulic landy for grazing. 


I feel the oil and gas industry, with it's new tech- 


nologies, should be given more consideration as they C«fl reduce 


the lirpact Of past years on our enviroment . They have done 


a great aeal as far as water development for wildlife. They 


re-claim the lands used, to better than before use. They 


d<j libtls damage as far as displacing wildlife. Most wild- 


life adjusts surprisingly well. 


I believe the preferred alternative reduceinq grazinq as 


much as 25% is too Much. I realize same allotments need 


some adjustments, and that monitoring by the BLM and ranchers 


can do rr.ore for the range conditions or. seasonal basis 


according to the rainfall and climate. 


It seems no me that by regulations, rather than by bills 


Ddsaed by Congress , you are attempting to gradually move, mo re 


and more public lands to wilderness designation, when in fact, 


they are not. 


T aosolutely believe we need to continue to have a 


multiple-use policy on public lands for the various industries 


and users in order for our country to generate enough revetue 


to reduce the National Debt. It's got to be our- No. I prior- 


ity; while careful management, r.oL extreme, over-sees our 


enviroment . 


"xfeA^ <S»k*- 


Shirley HaluB 



364 




2m 



a Jane Wostenberg 



Mr. Bob Ross, Team Leader 

PO Box 119 

Worland. Wyoming 82401 

Dear Bob, 

On April 3rd, Stan and I attended the Grass Creek Public Hearing Held at the Elks Club 
in Wodand We were impressed with the amount of speakers that evening, and the intelligence 
wfth which they sooke. It was Obvious they had studied your publications and that their rebuttals 
wore well thought out and reasonable 

Timbering, grazing, energy productions, recreation, culture and customs were all addressed, 
and most found discrepancies throughout the RMP What was .most disturbing was that your 
p.ior RMP*s didn't agree with the current one as far as the figurers you were using for oil 
production, grazing and timbering to mention a tew. 

It also seems that BLM currently holds the Idea that the so-called wild horses are drawing 
tourism It is our Feeling that people who come to the West, do so to see cowboys, cattle drives, 
brandings, mountains, and I can't tell you how many times Tve seen people parked on the side 
of the road to take a picture of the oil pump that is at the top of the hill going towards Ten Sleep. 
Tourists coma here to see what's still real about the West. They are sophisticated and know 
what is real and what is a "dog and pony" show. So are the people who live here 

Wo have unfortunately, been all to silent about what we are thinking up to now. which is part 
ol the reason things have gotten so messed up But now. because of your going the extra mile, 
by having public hearings, and open houses, as you did on the 3rd, you are heanng what is in 
the hearts and minds of the people who live here, and are trying to survive here We urge you to 
take what is so hard for people to say, seriously I would hope to see a board like you use to 
have with mambeis of the general public representing, as much as possible, all the different 
interests that are in our surrounding communities If these people had input to your RMP's there 
may not be as much to argue about once they are completed- We would like to thank you for 
the time and effort from all of you during the Grass Creek Public HoanngB. 



Styicerely, ^ 

Stan and Jane Wostenberg -' 




240 



KtAU ^gftBgWHgtK ■ GREAT PLAINS REGION 



COLUMBUS BUILDING 

23 NORTH SCOTT 

SHERIDAN, WYOMING B1801 



(307) (172.0425 
Fix (307) 674-6187 



April 17, 1995 

Bob Ross 

Team Leader 

P.O. BOX 119 

Worland, Wyoming 22401-0119 



The following are the Sierra Club's comments regarding the Grass 
creek Resource Management Plan and Draft Environmental Impact 
statement: 



Alte 



atives 



The BLM seems to feel that it does not need to examine the full 
range of alternatives for many for the resource uses currently 
occurring in Grass Creek. For instance, in all of the 
alternatives, 100% of the Resource Area is leased for oil and gas 
development. The BLM really needs to make a more concerted 
effort into flushing out a range of alternatives instead 
indicating that only one alternative is available. 

Wild and Scenic Rivers 

The South Fork of Owl Creek is very deserving of being found 
suitable for Wild and Scenic River designation- Owl Creek would 
make a spectacular addition to the wild and Scenic Rivers System 
because of the beautiful canyon where it is located- The South 
Fork of Owl Creek obviously has outstanding scenic values, and 
these values should have been recognized in your eligibility and 
suitability analysis. 

Oil and Gas 

The oil and gas leasing activities outlined in the plan will not 
protect the concept of multiple use. Leasing 100% of the legally 
available lands in the resource area is skewing multiple use in 
favor of just one use; oil and gas development. With the 
exception of the wilderness study areas, every single acra of 
land and mineral estate in the Resource Area is opened to oil and 
gas leasing. This includes Areas of critical Environments] 
concern, Special Recreation Management Areas, and important 



'Not blind npptutiion tu progress, but iippai'uum to blinA progress :" 



240.2 



wildlife areas. The BLH really needs to rethink this "lease 
"everything" mentality because it is not good for the resources. 

The meager stipulations outlined in the plan will do little to 
protect environmentally sensitive lands from the onslaught of oil 
and gas development. In fact, the Grass Creek Resource Area has 
gained a level of infamy for gutting four overlapping No surface 
occupancy stipulations along the North Fork of Owl creek. The 
Resource Area has a proven track record of being unable to 
protect lands through the use of stipulations. Thus, the use of 
the no lease designation is the only thing that will protect 
environmentally sensitive lands in the Resource Area. 

Grazing 

The BLM needs to be more specific with a timeline for getting 
grazing allotments in a better ecological condition. Although 
authorized use is being reduced in the draft plan, actual use is 
currently lower than authorized use and the new numbers are still 
too high. Because of the high percentage of Category "I" 
allotments in the Resource Area, the BLM must be more specific on 
how it will deal with the problem of overgrazing in Grass Creek. 
This is why a very specific timeline for improvements is needed. 

The BLM also needs to include very specific and standardized 
utilizations levels for both riparian and upland areas within 
Grass Creek Resource Area. Onse these utilization levels are 
reached, the BLM must insist that the cattle be removed from the 
allotment. We also believe that ranchers should monitor 
utilization levels and that the BLM role for its range 
conservationists be geared much more to enforcement. The BLM 
also need to dedicate some of the AUMs in the Resource Area to 
wildlife. 

Timber 

The cut proposed for the Resource Area appears much too high. Ho 
allocation was made to the protection of old growth timber and 
biodiversity. The BLM needs to reduce the cut on the Grass Creek 
Resource Area. With only 14,000 acres of commercial lands in the 
Resource Area, we view 300,000 bf of timber a year as being 
unsustainable. Proposed timber harvest levels would affect 
between 1,500 and 1,900 acres of land. We could find no 
discussion regarding regeneration rates, but it definitely 
appears that the Forestry practices are not being based on a 
sustained yield rate or that any portion of the commercial forest 
lands are being dedicated to being left in an old growth state. 

Recreation 

The BLM needs to manage more of the Resource Area for semi- 
primitive, nonmotorized recreation. Demand for this type of 
recreation is predicted to rise significantly. Once areas are 
developed with roads and other facilities, there is little 



240.3 



likelihood that lands will be returned to a natural condition 
conducive to this type of activity. The Badlands Special 
Recreation Management Area is a place where the BLM could 
designate a percentage of the land area for semi-primitive 
nonmotorized activity because much of the area still retains its 
natural character. 

National Natural Landmark Nominations 

The BLM needs to provide better protection for the Gooseberry 
Creek and East Ridge-Fifteen Mile Creek Badlands National Natural 
Landmark nominations. Although both of these areas for the most 
part are included in the Fifteen Mile Creek Watershed ACEC, the 
ACEC management prescriptions do not include protecting the 
outstanding natural and scenic values of these badlands. Instead 
the ACEC is strictly geared to improving water quality in the 
Fifteen Mile Creek Watershed. If water quality is the only 
management goal of this ACEC, then it could be detrimental to 
maintaining the badlands in a natural state. The badlands are 
obviously one of the major contributors to sediment load in 
Fifteen Mile Creek, and the goal of reducing sediment could 
adversely these beautiful features. We recommend that the 
management goals of the Fifteen Mile Creek ACEC be expanded to 
include protection of scenic and natural values. 

We appreciate this opportunity to comment. 




Kirk Koeps 

Associate Representative 



365 




2m 



April IS, 1993 



Bob Ross, RK? Team leader 

?.O.Sok 119 

Warland, Wyoming 32C01-C11S 

Dear Mr. &o«a; 

I | have read t&t Grass Crea^ Resource Area Managaxant FXaa Of 
tee choices, I would find Alternative B as being the least ob- 
jectionable, iiowever, I do not understand why the Federal Gov- 
ernment is spending so much money on this study when the U.S. is 
actually so far in debt that it may never repay ail of its 
loans. I think that all of these so-called problems and con- 
c^.-ns are iusz crumped up hot air. 

/lost of the land ia badlands where so few people travel there 
that ic has very little impact or. the environment, the du-hard. 
environmentalists have proven that they are actually out for 
power tnti care not a whit for practical solutions :v anything. 
rhe^ELl-; is playing into the har.ds of those that wish is take the 
public lands away from cr.e people. The public lands belong to 
all of the American people and not to a select group of power 
seeders using the environment as a sraoke scree.-. 

r.-.ere is iiO scientific proof that the national forests are over 
A^rviiLed, z.- that the oil ar.ci gas industries are destroying the 
_and. There is r,o real reason to lower the grazing allotments. 
The wild gar.e and tfc< wild horses arc not being threatened. Mi- 
nor adjustments whera problems do exist could be solved within 
the old Jramew^r*. Who is gcir.g to pay tha salaries of all the 
new people nt-uiid. to patrol Che whole area to ;r.e:-:e sure all cf 
the . uBt^titisr.s ar^ obeyed.' Doco the SMI hi.-.- _-_^h ar. increase 
in its budget? It seems to tie that budgets of government agen- 
cies are beir.g decreased not increased. 



not ta 



'^ng an 



crougnt 



= r-us ;.! 



"?sr.cora ' s Box" 



cal or yearly aojustmeuts due to 
being set up that will get worse with 
being opened, setting up very dfih- 
io: the future where Washington h^.-«aucrats 
will s.rwly impose more and more restrictions until the American 
pu-op_e wi!-l no isr.gwr h.d<< ticctsj to th&lr. land. £'* in the local 
pefple KO-iiihS for t.-..-. BLM w. 1 1 oe hurt, because thty d.re part 
of t.te American p-siic. T.tc gcvavhrnani is supposed to j. t.-.e 
servant cf the Sovereign l==ople, and not tht* other way around. 



241.2 



aLay 5 \e e rVi\-L r ' 0t * *»»«*«• ?»« pinions, which has 

££**;!• »2 -"--- - 5 n ay ' but l!: is a c °^°^^ W i th str on 3 

can't be •*<««* »i?t5?' ■ caA " gc cwspronisa with Freadon, One 

oara t se JuSl a little oit pregnant". 



Wyoming used 



■ o oe a 



iarg;i oil produce, but today, fceca.CS 
a- tne lr.pcscd restrictions 



wei 



fcr.a permits, etc., oil co~pe 



ana. time necessary to obtai 



all 



m 



*j5 car. actually drill • wildcat 



A'exas or Oklahoma for the same amount of coat and effort 
, .J? 4^" co i^ sz 9*tt the OK in Wyoxing on 3LM land. Tra" 
- 15 * l ***»iou«. Not only is the tax bast in Wyoming being eroded 
oy *asr.i.-.gtcr. U-.-eau.cra.ts , b'_i A.tariti needi all of its re- 
Sources f unc tinning in case of a war or 



emergency . 



nere is 



_ government going to gy. the fur.u.r.g to build roads 
to tne arefceoj.ofiicai sites and maintain the signs, etc 1 If 
these sites are built lor the ■•public", bath rooma wiU be 
r.ancea. Who is going to take care of t.-.em? Tf.e Federal Govern- 
ment is always pushing 
ins COxiftfl from? The 
pay :;r losing his own 
consider ail 
ron-cntaiist 
exist . 



its weig.... c.'a.r.a, but where ia the fund 
.3. citizen is tired of paying taxes to 
a own frL-edo-. 1 w;,:i urs* So.' the BI.H to ra 
he costs involved, and make the die-hard er.vi - 
« Up wiCh sc:e:.:.;:c ?;'Ooi thA* these prib !«::.= 



• e,*...„*j, d»4b very ^-oi ahcu: »w_-':-r.£ a balance to safeguari 
America's resources. j. hope that it will regain a good custo- 
cian in the tufure by being reasonable and logical. It should. 
2.0C be swayed by loudmouthed groups with large funding who onl 
se-,-!--. pevrer tc dictate their oMr. ter::s or the several Jfft people . 
Wyo.ting and America. 



RECEIVED 



tfRl9|99B 



£inra L_ L' ■''""-: 



U L L . Af!D Sal *«"CNT 



Hob Ross 

Bt.M Traam Leader 

P Box 1 1 9 

norland, Wy 82401 ^19 



Dei 



Mr, Ros 



We would like to take this opportunity to say that we find 
U\c BLM's proposal to open up wilderness study areas to hard 
rock minerals mining, motorized vehicle use, and oil and gas 
development unacceptable. 

The Owl Creek, Sheep Mountain, Red Butte and Hobcat Draw Badlands 
wilderness study areas should be managed to retain wilderness 
character whether Congress decides on wilderness designation or not 
and more of these resource areas should be managed for semi-priitiitivi 
n on -motorized recreational activities. 

The BLM needs to provide greater protection tor potential. National 
Natural Landmarks by prohibiting oil and gas leasing/development 
and hard rock mining and giving them a visual resource management 
classification of "VRM IT". 

We support the RLM's proposal to establish the Pitteenmile Creek, 
Metcetse Draw and Upper Owl Creek ACECs but want to see chese 
areas plated off limits to oil and g,is "leasing and mineral 
development. Please acknowledge and protect the extraordinary 
recreational and natural resource values of the Fi fteenmile 
Creek Watershed i\rea. 

We do not agree with the BLM'S determination that the South Pork 
of Owl Creek is "not eligible" for inclusion in the National Wild 
and Sottnin Rivers System and should be protected whether given this 
distinction or not. 

We support the BLM's proposal to remove the following important 
areas from mineral development: public lanes along the Bighorn 
River, the Legend Rock Petroglyph site, parts of the proposed 
Metnetae Draw Hock Art ACliC and all of the proposed Upper Owl 
Creek ACEC. Also, please consider extending the proposed mineral. 



RECEIVED ] 

1 I 



|9j 



242.2 



wcm™)»rw ^Tsam L eader 

April 16,~1395 
Page 3 

withdrawal to the four existing BLH-designatad Wilderness Study 
Areas in the planning area that will be without any protection if 
Congress decides against designation. 

The proposal to allow oil and gas leasing/development on every single 
acre of legally available public land is clearly excessive and violate 
the BLM's multiple-use mandate. 

We also feel that more attention needs to be given to improving the 
condition of riparian areas and rangeland. A more agressive 
use of coordinated range management techniques coupled with 
time-controlled grazing practices would greatly improve ecosystem 
health and biodiversity. Also, the BLM should place greater emphasis 
on managing fish and wildlife habitat. In reference to the wgfd's 
plan, such words as "to the extent possible" and "where appropriate" 
are- weak words and should be stricken. We support the wildlife 
prescriptions in Alternative C because i.t is the only alternative 
that provides adequate protection for all big game winter range. 



10^ 



*^7 



I 



366 



243 



April 18, 1995 

Mr. Ross, 

Sir, This letter is in regards to the Draft Management Plan for the 
Grass Creek Resource Area. 

I would encourage the BLM's Plan to reflect recreational user (non- 
motorized), habitat, and watershed. Hard rock mining, gas and oil leases, and use of 
motorized vehicles should be restricted in the area. I would also encourage that the present 
WSA's in this region be managed as such regardless of future Congressional action. It 
would be a loss to the state to lose the primitive or semi-primitive nature of this region. 

Respectfully yours, 
/s/ Mark David Johnson 



Mark David Johnson 
xxxxxxxx 

XX XXX XXX X XXXXXXXX 



244 



MICHAEL WALL 



Dear Bob- 
Please do what you can to modify the BLM draft Grass Creek Management Plan to 

maintain this area for Wilderness purposes and to eliminate motorized vehicle use, mining, 

oil and gas. 

Let's try to hold onto this area for as long as we can - hopefully forever. It's 

[page 2] 

to good to lose. Further intrusion of vehicles and mining will just ruin this beautiful area- 

Yours Truly 

/s/ Michael Wall 
xxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXX 

XXXXXXXXXXXXXXX XX 



APR2OS0 



2m 



Worland District BLM 

Bob Ross. RMP Team Leader 

P.O. Box 119 

Worland, WY 82401-0119 

Re: Grass Creek Drart EIS 

Dear Mr. Ross: 

I would like to comment on the Grass Creek Resource Area Resource Management Plan, Draft 
BIS. I feel the draft plan is a well planned out document and 1 strongly support the preferred 
alternative. This document is a good balance between resource extraction and protection. 

1 am very much in favor of the proposed ACEC areas (especially die Upper Owl Creek Area). 
ACEC designation will allow resource utilization, but only after special consideration to 
environmental conditions (critical wildlife habitat, significant archeologieal resources, unique 
plant species, outstanding scenic qualities, highly erosive soils, eie.) that make these areas 
important to the resource area. 

There are two issues I feel need further addressing in the Draft EIS: 

1 . Cultural Resource Management Areas . Several years back I remember reading about an 
extensive study of a significant Sheepeatcr Indian cultural site in the vicinity of Soapy 
Dale Peak; I believe the site was on public lands. Should this, or other Sheepeatcr 
Indian encampment or hunting sites on public lands be included in 3 cultural resource 
management area? 

2. Wild and Scenic Rivers. Appendix 1 reports none of the 123 waterways within the 
resource area were eligible for wild and scenic river Status. I feel the 12 mile segment 
of the South Fork Owl Creek from near Slab Creek (Sec. 27, T.43N., R.ltGW.) 
downstream to the eastern edge of Sec. 31, T.43N.. R.100W. should he evaluated as a 
wild river. This segment of river is 100% public land on the north and 100% Wind 
River Indian Reservation on the south. I feel the segment qualifies for wild river status 
under the following: 

a. Free Flowing. This segment is free flowing. There are no impoundments, 
diversions, or modifications to the natural waterway. 

b. C^Ktanding Remarkable Values. This segment of the river passes through the 
east-west Owl Creek Mountain uplift forming an exceptionally scenic canyon up 
to 1000 feet deep. This canyon exposes the geology of die area, unique due to 



245.2 



art uplift ed area buried by volcanic deposition. The canyon is important wildlife 
^lfor raptors and big game. 

Other Conflicts. All public lands in this segment are found in a power 
withdrawal, rninimizing conflicts with locatable minerals. Anchor Dam is 
immediately downstream and the potential for another impoundment in this 
segment would seem very low due to the existence of that dam and the nature of 
the area's geology. 



Again, I would like to express my opinion that the Grass Creek Resource Area Resource 
Management Plan is a well planned and well thought out document and I thank you very much 
for ihe opportunity to comment. 



Sincerely 




367 



246 



April 16-1995 



Worland B.L.M. 

Bob Ross, R.M.P. Team Leader Box 119 



Curtis Larsen 
x*xxxxxxxxxxxxxxxxxxxxxxxx 



Dear Mr. Ross 

Am writcing in defense of multple use concept of natural resources use by man. 
Resources were put here for mans use now and in the future. 

Haveing lived my life next to creation 1 have witnessed much change generaly for the 
better if tax payers are denied use of resources communities will dry up. 

I cannot believe that regulations imposed by federal agencies will preseve creation for 
present or future generations. 

As a youngster it was rare to sec game animals ranchers realized as well as timber 
mineral people that in turn took care game animals aren't rare in fact the population of game 
has increased many many times to where it i rare not to sec them. 

In its so called natural state much country burned eliminating undesireable growth of 
water robbing plans and woody growth. Fire of course like livegiving water can be 
devastating. However generally control of undesireables has increased carrying capacity of 
the land private or federal. Water retained by man made resevoirs spring development 
reseeding of oil or mineral sites has been distribution for domestic and wildlife. 

Realizing recreation has become a big business it has not contributed to facts or states, 
the developers of this country paid their own recreation with their own resources. Not that 
recreation is wrong, but who took care that recreation is possible. I do not believe it is 
constitunal to dry communities up with regulatons that takes a tax base away what is good 
for a community is I beleive what is good for the country. 

I am seventy eight years of age bom and live in Park and Hotspring all my life. The 
Indian saytng of don't judge a person until you have walked a mile in his moccasins 

Respectfully /s/ H. Curtis Larsen 






m&vsmam 



247 



April 18, I99 r i 



Bob Ross 

SLM Team Leader 

P.O. Box 119 

worland, WY 82401-0119 

Dear Mr. Ross: 

Although i now live in Colorado, I grew up in hock Springs and 
Green River, Wyoming, and attended college in Laramie. My 
husband and l have sp«nt many wonderful weeks enjoying the 
wilderness areas of northwest Wyoming. Therefore, what happens 
in these areas will always be of concern to us. Thus, the reason 
for writing is our seriouB concerns with the blm Grass Creek 
Management Plan, especially since this area 1b an integral part 
of the Greater Yellowstone Ecosystem. The policy of elevating 
mineral development and commodity production over all other uses 
is misguided to say the least. I would like to emphasize the 
following: 

1. The BLM's proposal to open Wilderness Study Areas to hard 
rock minerals mining, motorized vehicle use, and oil and gas 
development is unacceptable. Owl Creek, Sheep Mountain, Red 
Butte, and Bobcat Draw Badlands wilderness study areas should be 
managed to retain their wilderness character. 

? - The blm should manage more of the Resource Area for semi- 
primitive, non-motorized recreation activities. The proposed 
resource management plan places unacceptable emphasis on 
providing motorized recreation activities. Less than 8% of the 

public lands within the resource area would be managed to provide 
for the kinds of activities many people enjoy the most, such as 
backcountry hunting and fishing, hiking, camping, wildlife 
watching, sightseeing, nature study, and opportunities for 
solitude in natural environments. 

3. The BLM needs to provide greater protection for potential 
national natural landmarks. The Grass Creek Resource Area 
contains several candidate National Natural Landmarks, or nni.s. 
To protect these areas, oil and gas leasing and development and 
hard rock mining should be prohibited. 

i. Areas of critical environmental concern iD the Resource Area 
should be off limits to oil and gas leasing and development. The 
Federal Land Policy and Management Act requires the BLM to "give 
priority to the designation and protection of areas of critical 
environmental concern." I support the BLM'S proposal to establish 
the Fifteenmile Creek, Meeteetse Draw, and Upper Owl Creek ACECs. 
These areas should be placed off limits to oil and gas leasing 
and mineral development. Xn addition, the extraordinary 
recreational and natural resource values of the Fifteenmile Creek 



247.2 



watershed Area should be acknowledged and protected. 

5. The South Pork of Owl Creek meets the criteria for a National 
Wild and Scenic River. The South Fork of Owl Creek is an 
outstanding river resource undeniably entitled to legal 
protection as a Wild and Scenic River. At the least, it deserves 
to be protected from development threats such as oil and gas 
leasing, roads, and mineral development along the river corridor. 

6. Hard rock mineral withdrawals should be encouraged. T 
support the BLM's proposal to remove several important areas from 
mineral entry, but I also encourage the blm to consider extending 
the proposed mineral withdrawal to the four existing BLM- 
designated Wilderness Study Areas in the planning area. 

7. The proposal to allow oil and gas leasing and development of 
every single acre of legally-available public lands is clearly 
excessive and violates BLM's multiple use mandate. There is no 
mandate to lease everything as the BLM evidently claims. 
Multiple-use includes non-extractive uses such as protecting and 
managing wildlife habitat, maintaining healthy and functioning 
fisheries, protecting water quality and watersheds, providing 
opportunities for education and scientific research, recreation, 
and aesthetic values, and preserving important historic and 
cultural resources . 

8. More attention needs to be given to improving the condition 
of riparian areas and rangeland. A more aggressive use of 
coordinated range management techniques coupled with tirae- 
controllcd grazing practices would greatly improve ecosystem 
health and biodiversity. 

9. The BLM should place a greater emphasis on managing fish and 
wildlife habitat. I support Alternative C which is the only 
alternative that provides adequate protection for all big game 
winter range and allows the expansion of wildlife and fish into 
hiqh potential habitats. 

In summary, I support Alternative C and hope that the blm will 
also do so. This exceptional part of the Greater Yellowstone 
Ecosystem deserves better than leasing and development of the 
entire resource area. 

Thank you for your attention to these comments. 

Sincerely, 




cci Governor Gcringer, Sen. Simpson i. Thomas, and Rep. Cubin 




248 



Apnl 19, 1995 

Mr. Bob Ross 
BLM Team Leader 
Box 119 

Worland, WY 82401 

Dear Mr. Ross; 

We write today lo urge a serious reconsideration by the BLM of its Draft Grass Creek 
Management Plan. We are very concerned about the overall loss of wildlife habitat 
and the generally unlimited opening of the area to unrestricted hard rock mining, 
motorized vehicle use, and oil and gas development. 

Even the minuscule acreage designated as Wilderness Study Areas are to be 
open to the above-mentioned activities, much lo (heir lung-term detriment. We 
believe that Owl Creek, Sheep Mountain, Red Butte, and Bobcat Draw should be 
managed to retain their unique wilderness character. And, throughout the area 
there is too much emphasis on motorized recreation use. It is entirely possible thai 
Ihe WSA'5 will noi ultimately receive that designation from Congress, in which 
case the opportunity for semi-wild experiences and solitude in a natural 
environment will be virtually non-existent. 

We would also like lo see special attention paid to the portions of the Crass 
Creek region with potential for designation as National Natural Landmarks. In 
addition, area of Critical Hnviron mental Concern should be off limits to oil and gas 
leasing. They are Simply 1oo important in their present wild state to be sacrificed lo 
industrial destruction. We would also encourage the withdrawal of significant 
segments of the lands under question from Hard Rock Mineral exploitation. The 
law is an antiquated rip-off of the American public and will result in irreparable 
harm to Ihe area. Certainly the areas already removed from considcralion by the 
BLM are a good first step, but much more needs lo be done. 

And finally wc do nol see anywhere near enough specific emphasis on 
maintaining a healthy habitat for fish and wildlife. The present language has many 
"escape clauses" which will allow future decision makers to weasel out of their 
responsibililies m this regard, and we urge this language to become very specific in 
terms of species diversity and overall healthy populations m the region. We believe 
only Alternative C meels the necessary obligations we know are necessarv for the 
wildlife of the area. 

We thank you for your lime and consideration and hope you will lake our 
concerns most seriously. S\ a s*\ 

And y and Nancy Carson , , I / fl 

i 



368 



RECEIVED 




| 

; APR 2 1 Bffi 




IEAU OF LAHOKMUEKm' 



April 20, 1-395 



nee to the Grafis Creek 



Bob Ross, RV.F Tea;n Leader 

Bo.vll9 

Woriand BLM, Borland, Wy. 

834-C 1.-0119 

Dear Sin 

I am. writing this let 
Resource Area, 

RUQfa of the revanues in the four counties involved come 
from the oil Industry. This would have a great impact on the 
people otf these counties If severe restrictions on the Lil 
and gas industry are placed in the Grans Creek area by the BLM 

There also appears to be a strong bias by the BLM against 
srazina; by farmers and ranchers. It appears that land that 
is grazed is far healthier than lands that are left to the 
cle-cents in the Grass Creek area. 

We do not feel the Owl Creek a; 
could be considered a wilde: 
and I might add. similar to 



Grass Creek in general 
area, it is a semi -arid area, 
e rest of the state of Wyoming. 



The BLM appears to ba by-passing Congress in this adrni 
letrs-fcton, a reckless and deplorable situation or. the lives 
cf .tany people in our nation. 



Mid^e Rime! 



'«* 2 I BOB 



UK UND GANACEMENT 






250 



WYOMING RESOURCE COUNCIL 



woriand Dist. Office, blk 

fq llQX 1 1 9 
Woriand, WY 82401 



as a member of the Park Co. Tas 
Creek RMP draft SIS, 1 would l: 



thi 



appri 



process, I do think the proces 
tunning however- The task fore 
through the county commissioner, 
notice about the formation of a 
all but two members of the task 
Park Co. Multiple Use Ass., and 
of our members being on the Par 
Commission, the task Cdrce woul 
membership. I know it is not yo 
chooses for a task force, but y 
formation by getting public not 
asked to form such groups. Tha 
vt tha County for more broad ba 
groups, which I am aorft yon won 
Lhe EIS process. 



k Force reviewing the 


i^rasa 


ke to compliment the BI.M for 


involvement in the EIS 


s needs some democrat 


c 


e was nominated directly 


s , and they gave no p 


iblic 


task force. The res 


it was 


force vers members of the 


if it had not been for one 


k cd. Planning and zo 


nnq 


d probably been all o 


their 


ur function whom the county 


ou could democratize 


ts 


ice that counties are 


being 


t would enable a petitioning 


sed representation on 


these 


Id agree would better 


serve 



SES&. 



^H% ? , 



250.2 




WYOMING RESOURCE COUNCIL 



P.O. Box 2685 



Cody, Wyoming 82414 
April 15, 1995 



Mark Sawyer 
Park: County Planner 
1002 Sheridan Ave. 
Cody, Wy 62414 

Dear Mark: 

We would like to thank you for the opportunity to 
participate on the Park Co. task force formed to present the 
BLM with comments on the draft SIS for the Grass Creek 
BMP. It was' with reqrettable conflicts of the demand of 
running my buisisness that I was unable to make all the 
meetings . I would like to offer you some comments on the 
selection of task force members , and of the comments 
presented team leader Bob Ross, of the BLM. 

First the make up of the task force itself was far from 
representative of the make up of Park Co- It appeared of 
the members of the task force all except myself and Pete 
Bageley were members of the Park Co- Multiple Use Society, I 
think their entire board of directors was there. 
While 1 think it was appropriate for ail industry to be 
represented by their paid lobbyist Pat Childers , T think it 
was in appropriate for nonconsumptive resource users to be 
in such a minority - 



Second in th 



and come 
managemen 
in order 
Managemen 
histories 
was a cri 
agreed ab 
include s 
for bette 
communt ie 
(10)We ag 



oirm 
ers I fee 
to some 

that 
of listin 
we all 
1 burn cy 
tical par 
out the 
auction 
botta 
by list 
reed we w 



lents offered by the task force to the 

■ did make some positive compromises, 
onimon agreement about changes in resource 

i felt the ni.M needed to make - These were 
g in the comments letter. Fire 

. agreed that a burn policy related to the 
cle needed to be implemented , ( 1 )That fire 

■t of the regions ecological health. (5)We 

eed for effective mngt. of ORVs , to 

for violators . ( B ) We agreed about the need 

cal description of the listed plant 

ing the species compositions involved . 

ould like to see wild horses removed from 




250.3 



WYOMING RESOURCE COUNCIL 

P.O. Box 2685 Cody, Wyoming 82414 



the Grass Creek area and see the money and AUM dedicated to 
their management be used for native wildlife. 

Areas where Pete Dagely, a Biology Instructor at North West 
College, and myself a wildlife bioloqist with 13 years field 
work disagreed strongly and do not see that disagreement 
reflected in the commissioners comments are; (2)Fish Habitat 
no one with biological experience or education would make a 
statement like this, the health of any stream or lake is 
directley related to the ecological health of the entire 
watershed it serves, any enhancement of a fisherie requires 
the enhancement of the environment the fish live 
in. (3)?orest Mngt, while forestry is the art of growing 
trees for wood, the science of forest ecology is nowhere 
complete enough to make statements about managing forest for 
overall biological productivity. Managing a forest stand 
for tree production alone is often done in disregard of 
other forest values, water, fisheries, and wildlife 
communities. Harvesting of timber should not be determined 
by a forestry definition of maturity. We also strongly 
objected to the harvesting of firewood along any waterways, 
destert or other wise- Dead trees standing and downed trees 
are crucial wildlife habitat, especially in riparian areas. 
(4) There was strong disagreement about the need for grazing 
reform areas of the Grass Creek RMP suffer form over 
grazing, WYO Game and Fish can name areas of concern, and a 
reduction of AUMs and rest from grazing are the only proven 
methods of rehabilitating stressed range. The Holistic 
Grazing method has been around since the early seventies, 
and has yet to produce a single successful result off of 
irrigated pastures. It has infaet drawn a lot of negative 
criticism by range scientists. (6)We agree with 3LM 
recommendations for no surface occupancy, but feel that 
there maybe some room for compromise based on new automated 
technologies and these need to be discussed on an individual 
basis. we are opposed to the commissioners recommendation 
of rejecting the no-surfaco occupancy and timing 
limitations. (9)while we agree the water dishcarges from 
oil fields in some instances is beneficial these waters, 
their volumes, qualities, and uses need to bp better 
recognized and defined. {llJWe strongly disagree with the 
pretect that the direction of wildlife herd mngt be done 



369 



e^ffltec 




250.4 



WYOMING RE SOURCE COUNCIL 

P.O. Box 2685 Cody, Wyoming 82414 



only with trie agreement of live stock permittees. Hunting 
and huntable ypecies are a vital part of the states economy, 
and in no way second in value to federally Subsidized 
grazing on public lands. Any discussion of viidiify 
population targets must involve all affected parties and 
organizations . 

Lastly a couple of points not mentioned by Lhe commissioner 
that we thought important and that we had some degree of 
group agreement on. Sage Grouse, a bird characteristic of 
the region is in serious decline and in need of special 
attention in its habitat needs. Bighorn Sheep it is vitally 
important to maintain as much separation as possible between 
Bighorn and domestic sheep. Big Horn Sheep have little 
immunity to common domestic sheep diseases, and contact with 
these diseases can result in losses of Rig Horn lambs in 
excess of 95%. An ideal seperation would be 20 miles. in 
areas of public land use, Big Horn sheep are worth far more 
dollars to the states economy than domestic sheep and should 
be given preferance 



Sean Sheehan 
President 



RECEIVED 



mz i 1 



251 



April 19th, 1 y9B 



Hob Ross Tearr, Leader: 
C/0 B.L.M., Worland, 
nycmlng. K461 

[tear Bob R05S: 

As one of many whom have seen ashed to write about this "Grass Creek'' 
Resource Ar&a, from my own direct knowledge I want to express a very deep concern 
over the manner this whole issue is being nandeled. Vou and I both know *.ne B.- 
i.H, he? no documentation which shows your ayency has any right to Administrate 
or Jurisdict over Any nf our Wyoming Public Domain Lands. I have several letters 
from different heads of Lhe Bureau, stating there is no document in posession of 
the l,I.X which provides such rights as "To Administrate or JURIsniCT" over our 
Wyoming Public Domain Lands. You people seem to think or believe if you can fin- 
some Iso called author'ty! to Author several pages of retric which benefits the 
Rureau's position this should be excepted by the general public. Such shal'ow 
thlnfcfnfl is a norn for a large percentage of the "PLblic Servants" in the Bureau. 
The honest truth is when the big crunch comes and your overloaded Bureaucracy's 
Agencies will dump many thousands out in the Cob Market who will finally be for- 
ced to face the truth, "'What are they actuary uualifted for", and the answer nas 
to be, possibly as highly skilled in an ability to distort the honest facts, and 
such skills have no value 1n the average workplace, where honesty and h ard work 
with worthwhile skills are what is needed. Ttie end of the Washington D.C Bur- 
eaucrat ic Agencies is not Lu far off, and when our western states do take oack 
our States Rights to administrate and DurtwIJet over all lands within each States 
borders frcm the County level is fasti y approaching the day of arrivel. 



Fve-y one involved 
blind and deaf attitude w, 
can cram down our tirroeti 



in the B.L.M. attempt will one day have to account for 
ich.sana o' the 'tastern Elitests once again believes it 
! and we must except it. Our older residents arc not 



able to write or answer there protest, I have talked to wol ! over 25 or 30 who 
are unable to understand what r.oulcf allow the 9.1 M. to have any right to want to 
make such a radicle change, 1 agree with a strong "HO" to any change in the Grass 
Creek Resource Area. Just walk away quitely, your days are numbered, "Thank God 
for smal l favors. " 



n 



p-saw >\f\"?f-j 



.RECEIVED 



*Pfi24BS6 



ssa 



April 22, 1995 

Bob Ross 

BLM Team Leader 

POBox 119 

Worland. WY 82401-0119 

Dear Mr. Ross. 

1 write in order Ho voice my concern aboul lhe Grass Creek Resource Area's draft management 
plan. This plan is of course controversial in thai it has drawn criticism from both sides of die 
environmental battlefield. The BLM is lobe commended for some of the proposed changes Sat 
have been made, in particular lowering the level of slocking on these federal lands. 

However I have particular concerns about the future of the more wild areas in this study area, 
especially those thai are currently designated wilderness study areas. These anas represent 
prime wild lands for our state, and provision needs to be made for their protection and 
preservation. 1 am particularly concerned about the Owl Creek, Red Dutie, Sheep Mountain, 
and Bobcal draw badlands areas of [his study plan. Whey should be set aside permanently and 
managed for semi-primitive noo motorized recreation. It is extremely unfortunate dial so few 
areas have been so designated, especially in the lower altitude basins in this state. Any 
argument that this some how interferes with personal freedom ignores the fact that there are 
many more placet whore these individuals can go for dieir recreation. , .not every single mile of 
the state needs to be open to these people and their destructive machines. Like many olhers. I 
enjoy back country hiking in remote quiet spots. With only $% of the public lands in this area 
are currently managed for these activities. 

Remember, once lost. Wilderness never returns. The land is our future, lets preserve it for 
tomorrow rather Oian destroy it for short term profits of iarge multinational interests who care 
neither for the state <il Wyoming or the people who live here. 



Sincerely yours, 



&Ou 



Dear Bob Ross, Please designate Owl Creek. Sheep Mountain. Red Butte, and Bobcat Draw 
Badlands as wilderness . No oil, gas motorized vehicles. Wilderness is sharply diminishing - 
please save these areas. 

Thanks, 

hi Robert C. Murphy 

4/20 



370 



' . . 1 V E D 


1 


APR24BS5 


'-'', 


^ammi 


V. 


N 



254 



.g 82401-0119 



Leade; 
©X 119 

Worland, Wyomii 

Dear Mr, Soss, 

it is unacceptable to me to have W-.ldernoss study Areas 
open to Hard Rock Minerals Mining, Motorized Vehicle use, 
and Oil and Gas Development. 

I don't believe multiple use of public lands means 
cramming every possible public use onto every square inch of 
public land. Multiple use should include all types oi 
multiple use, yes, but some areas for industrial 
development, some areas for primitive lands, noma for 
recreation, some for agricultural uses and so on. Some 
areas can support several uses, but scrae areas are special 
and unique and need to be protected fur. the unique values of 
those lands . 

Semi-Primitive and non motorized tecreationa, 
activities are becoming fewer and fewer as those type of 
lands shrink due to politics and grocd. Short term gains 
should not blind us to their long term value. 

It is up to the agencies managing those lands to 
identify and protect those special values, even though 
public pressure is sometimes Intimidating. 

Areas of Critical Rnvironmental Concern should be 
protected from development at this point . Until a value 
ethic develops where our society ha*g a commitxent to 
respect those areas, companies should not be trusted to 
operate there. 

The RLM needs to take the initiative lo improve 
riparian areas and range land conditions. Perhaps more 
lessees could be persuaded to participate in Stewardship 
programs like HRM or CHM'S- Instead of being in the middle, 
BLK should take a proactive role in doing true ecosystem 
planning and stewardship with the users of the lands within 
their districts . 



J***« 



■X*. 



Barbara W. Parsons 



255 



B.L.M. 

Bob Ross-Team Leader 

Dear Sir 

We protest against the proposed reduction in the Grass Creek Resource Area. 

/s/ Charles & Mary Sheets 

XXXXXXXXXXX 

xxxxxxxxxxxxx 
xxxxx 



Affi 2 4 t995 



lUUAti OF UNO CAKASEMf IfT 



Bureau of Land Management 
Worland Distrid Office 
Ann. : RMP Team Leader 
FO Box IIP 
Worland, WY B240I 

LtdiM and Gentlemen, 

to reply to the article appearing m the Northern Wyoming Daily New* on April 20, 1995, it appears 
important thai I write lo you and t& you lo log ory powtion on the propoaed OraHi Creek Resource Area 
it Plan. 



Please tee that thin letter is logged u comin£ from a local resident, and that I am opposed lo the reduction k 
AUM'a of permitted livettock jrazing. For detoili relating to coy position, pleaae see tlie attached 
tfonacription of my comment! at the April 3 hearing. 








256.2 



Testimony of Lyle Spence at the HoarLnq on tho proponed management plan 
for that Grass Creek Resource Area, April 3, 1995 

Thank you for letting ua apeak, and thank you for hearing us. I want to 
apeak to the appearance that any proposed management plan must be 
predispoeed againat agriculture and the livestock industry in particular. 
My point is it shouldn't be bo predisposed. 

My name is Lyle Spence, and I live in the city of norland. I don't have 
an agricultural or mineral interest of any kind, and I don't hold any 
grazing permits. I am an avid outdoorsroan, and my wife and I spend 
virtually all Df our recreational tiroa either hunting or finning or 
otherwise enjoying the natural resources that are the subject of this 
hearing and this proposed management plan. I am telling you I have a 
very keen consumptive interest in the wildlife resources in question, and 
that is one of my qualifications for testifying here today. 

I also speak from the informed source of my employment with Farm Credit 
Services, which is a landing institution that deals almost exclusively 
with farmers and ranchers. I personally administer loans to farmers and 
ranchers throughout Northwest Wyoming. Theoe comments are my Own, but 
are founded in part on the information I have through my employment. 

•The reason I ara hare is that I think there ia an Area of critical 
Economic concern (ACEC) that ia negatively impacted by this proposal, and 
that "ACEC is the whole Grass Creek Resource Area. There ia a species 
living throughout that area who's long term survivability ia not 
adequately considered in this proposal. It's the species that manages 
the land and pays the taxes that build the roadst and schools, and which 
supports the communities and industries that stake this whole region 
habitable by all of us, and enjoyable to those who visit. That species 
is the agricultural producer. 

In last year's hearing on Rangeland Reform 1994, I provided an example of 
a typical ranch family and their historical financial performance in 
order to highlight their vulnerability to either increased grazing feee 
or a reduction of grazing allotments. I offered tD provide more examples 
for study by the BLM and the Department of Interior, but nobody asked for 
any more. In hopes that you are interested, r brought more with me 
today. I have in my hand a summary of a study of earnings efficiency of 
IB ranch operations in Northwest Wyoming. Five of the 18 ranches 
summarized here graze livestock in the Grasn Creek Resource Area. Now 
you may say that 18 ranches is not a lot, but those 18 ranches run 10,000 
cows, and summarized here are a combined total of 65 years of income 
statements on those ranches. If my math ia correct, this represents 
37,000 cow years of financial performance data, all occurring in the 
1990's, If I stacked those statements end-to-end they would reach 75 
feet in the air, and that is probably taller than the tallest building in 
Worland, which juet might be the BLM building. The point here is that 
this is a significant volume of data, and it's worth looking at. 



371 



256.3 



Grass Creek RA Management. Plan, L- Eponco, Page Two 



This summary shows that on average, these ranches had an earnings 
efficiency ratio of 22%. What I mean by that is that for every dollar 
generated in revenue, they had 22 cento left after expenses were paid, 
with that 22 cents they had to feed their families, they had to pay their 
debts, including payments on their land, they had to replace their 
capital as it wore out, and they had to improve their land and grow their 
business if possible. Lets relate this historical data to current 
economics. 

Last Friday I participated in a Beef Industry Symposium in this very 
room. There were • number of very qualified speakers on various issues 
related to the future of the cattle industry, and it was highly 
educational. Incidentally, I don't remember seeing anybody there from 
the BLK. The consensus of all experts in the field was that the next 
several years are going to be very hard on the cattle industry from the 
standpoint of profitability. The fact is that the fender cattle market 
today is 22% lower than It was a year ago. The fat cattle market today 
is 19% lower than it was a year ago. The costs of financing are 30 to 
35% higher than they were a year ago. The outlook for the foreseeable 
future is that prices will remain at roughly these same levels. In order 
to succeed, moat producers are going to have to find greater 
efficiencies, find new methods of reducing costs, and they cannot ba 
hampered by reoource reductions if they are to succeed. 

These people's historical margin of 22 cents is gone for the foreseeable 
future due to market conditions. Remember, that's the money with which 
they feed their families, pay their lenders, replace their capital, 
improve their land and build their business. I am not here to press the 
panic button this year, because most producers have the financial 
resiliency to withstand these conditions for some period of time. But 
you have to deal with the reality that this industry so fundamental to 
our communities cannot bear any more burdens while these families try to 
adjust to the current and foreseeable economic environment. 

The conclusion is inescapable that the economic burden of reduced AUM'a 
is something these people just don't have the margin to cope with. They 
can't have this resource limitation forced upon them if we expect them to 
remain viable, and contribute to a viable agricultural community. 



256=4 



Testimony on Crass Creek RA Management Plan, L. Spsnce, Page Three 



I want to close by asking you to do three thingst 

First, gather the data on this species I've been talking about, the 
agricultural producers. Figure out what influences their survival rate, 
and what makes them vulnerable to a decline in numbers. Believe that 
it's not that hard to do, because I've done it, and I am not very smart. 
I summarized 18 ranches between breakfast and lunch last Wednesday. It's 
probably easier than gathering data on the wildlife species that seem to 
be the focus of your concerns. I would invite anybody in this room to 
join with ue in putting their data in this sample. 

Second, I ask you to propose a resource management plan that 
realistically addresses the continuing viability of these agriculture 
producers. 

Finally, recognize that the human ecology of our community deserves as 
least as much respect and as much study as the wildlife ecology, maybe 
even more. 



257 



BLM 
Box 119 

Worland, Wy 82401 

Bob Ross - Team Leader: 

The tax bases in the counties of Wy. are well worth protecting. Our taxes have gone up 
24% in a very short time. Our natural resource based industries are very important in 
keeping our taxes in line, this also makes us a more inviting location for new businesses and 
homes. These things will help keep our children in Wy. 

Please do not allow more restrictions to our public lands. We need industry for jobs 
and we need freedom to hunt and fish these lands. We need not to be priced off the lands 
we own by the officials we hire. 

/s/ Josephine E. Layout 
/s/ Vernon C. Layout 

XXXXXXXXXXXXXXXXXX 

x x xxxx xxxx xx xxxxx 



258 



xxxxxxxxxxxx 

xxxxxxx 
April 21, 1995 

Bureau of Land Management, 
Worland District Office, 
Attn Team Leader, 

Dear Sir: 

I have been fallowing with inters -- and apprehension -- the discussions in the 
Northern Wyo. Daily News about the so-called Grasscreek Plan. 

Yesterday's report about the number of letters received from far-away places really 
irritated me. Most of the people who support such radically environamental projects, plans, 
and changes, in the way Wyoming people do things and manage their businesses and 
economy have never been here 
[page 2] 
or perhaps in many cases have: not even been west of the Mississipi. 

I believe, from what I have been able to learn, that the Grasscreek plan would 
severely affect the economy of the big Horn Basin, and consequently of Wyoming, in an 
adverse way. 

We have too much interference from Washington, D.C., and from environmentalists 
whose only thought is to promote their agendas. Of course, as has been pointed out, most of 
Wyoming's land belongs to the people. Why not let the peo ple who know the conditions and 
problems of the area be the ones to determine the uses of said land'.' 

Yours for a prosperous, well managed Wyoming, 
/s/ June Gossens 



372 



RECEIVED 



APR 2 41 



EAUOFUUDBUAUIiJiT 



2SS 



April IB, 1905 



Bob ROSS, Team Leader 
Bureau of Land Management 
PO Box 1 1 9 
Norland, wyonlng 83401 



I urge you to insure that Uie Atisaroka Foothills, Badlands, 
Biqhorn River, and Red Canyon Creek Special Recreation Manaqeraent 
areas be protected from oil development. 

All areas included in the Conservationists' Alternative to 
thft BLM ' g Wilderness Proposal including lands outside the Wilderne 
Study Areas should be protected, as well. 

I now live on the Central California coast, I have Cond 
memories of traveling the areas mentioned, and hope Lo introduce 
travel to the grandchildren, as Well. 

We await your considered attention to this matter. 






ZW^. 3fe7&e 



260 



Worland BLM, Bob Ross, 
Team leader 

Dear Sir 

I object lo absolully no credit given to the technologies in any of the multiple use industries 
from which the environment benefits 

I object to the loss of revenues to all four counties. 

I object to a inadequate range of alternatives to choose from 71 % of the statements 
comparing the alternatives, all read, same as preferred. This violates the environmental 
policy act. 

Object to unreasonable restrictions on olI and gas industries No credits or value is 
given to wildlife habitat or water. 

t object to any wilderness area restricting motorized recreation 

/&/ Dave Bouma 
One mad Wyg citizen 




APR25B95 



WPBHttrttTOMMMUKtll. 



, r 261 

epartment of Commerce 



Celeste Colgun, Director 



Division of Cultural Resources 



THE STATE ^SSH^^OF WYOMIN 

Jim Ceringer, Governor 



April 21, 199S 



P.O. Bo* 119 

Wetland, WY 82401 



Dear hi. Roast 

staff of the Wyoming State Historic Preservation Office have reviewed the 
above referenced document as it pertains to cultural reBOurces. A 
cwiprohonoiv* cultural resource overview is presented and the Preferred 
Alternative offers a favorable management plan for Che protection and 
preservation of archaeological and historic aites. 

We recommend that the viewSheds at the Legend Rock Petroglyph Site and the 
Hoctoctse Draw Rock Art Aran should be protected and preserved to the maximum 
extent posBible. The visual qualities surrounding these Kites contribute 
greatly to their cultural significance. In addition, ws urge the Bursnu of 
Land Management to carefully monitor visitation to these significant 
petroglyph sites. Experience has clearly shown that facilitated access 
generally leads to increased vandal ima, and that Bubetantial investment in 
year-round site pro taction /inter pro tat ion personnel end site otabi ligation 
moaoureo may bo required to ensure adverse effects do not occur. 

References are made to the development of cultural resource interpretive aiteo 
and public education strategies. We support the Bureau of Land Management in 
its efforts to increase public awareness about the significance and fragility 
of cultural resources. He would be pleased to cooperate with the BLM in these 

Pleaaa refBr to SHPO project control number *t29lRL80H on any future 
correspondence dealing with thin project. If you have any gueatic 
Karen Keaipton at 307-777-6292 or Judy Wolf, Deputy SHPO, at 307-777-G311 




>iy' 



x 1307) rn-iAi-L 



262 



Dear Sir, 

We arc against new management of federal lands. Our taxes are high enough. We are 
against this new government proposal. 

Thank you 
Dale D, Spomer 
Is/ Dale D Sportier 
Joy J. Spomer 
/S/ Joy J. Spomer 



373 




WMv vuj, &ctftk go.. 



REG E IV6D P. 0, BOX B2fl 

Fl VCRTON, WY S2501 

APR25B95 



SSICEAUOFLANaCAJUSfllEJiT 



2§S 
V\£ 



ns and comment s 



af the Nil Iber 



25 to 3S%. This wi 1 1 cost 
* is this consistant 



To: rtureau of Land Management 
Bob Ross, Team Laadfir 
P.O. Box 113 
Worland, WY 32401-0119 



The fol lowing are ihe g 
Catt 1 e Company . 

The EIS proposed to cut the AUM 1 
the U.S. Government 2 to 4 million dollar 
with the PL.PMA Act Sec. 102(A)(8) ? 

The Taylor Grazing Act (TC5AJ requiras the BLM to stabilize the 
livestock industry. The Els, however, calls tor a 25 to 35* cut in 
grazing. This can hardly be said to stabilize the livestock 
industry Pursuant to the EIS, the BLM is placing a greater focus 
an wildlife production than it is on livestock production. This 
switch m management is not in compliance with the TGA. 

The EIS will curtail oil, gas, a coal mining by the no visual 
occupancy. This will cost the U.S. Government millions of do Mars 
Does the BLM know what this cost will be? How is this consistani 
with the FLPMA Act Sec. 102(A)(9) ? 

The BLM has not considered the economic effects or tho EIS on 
one resource as to another (Page 14). This is a flaw in the 
document. As the change from the present multiple use, to the 
restrained grazing, oil, & mining, in favor of wildHre. The EIS 
favors wildlife over any other use of the land. The EIS does not 
address the total economic damage it will do to tne U.S. Government 
and the local governments, It, counties, schools, and cities that 
depend on the taxes and Pilt monies, Will this be addressed before 
the final plan? What will be the dollar amount of the EIS on all 
concerned tax ontities? 

On page SO the BLM proposes to do work on the range Ih 
fences, reservoirs anc springs. Several years ago the 8lm' tore 
down the sheep fence around the Hlllberry Cattle allotment, and 
left alot of the fence lying around and didn't clean it up 
Approximately 3 years ago the reservoir washed out on the 
allotment. It has not bsen repaired yet. What is the BLM floinq 
to do about this? y 

The EIS will increase the Fifteen Mile Horse Herd and expand 
It s area from 83,000 acres by over 39,000 acres, while cutting AUM 
for livestock. This Horse Herd is in a critical envi ronment f Map 
21 ) . Tms will in effect make Fifteen Mile into a quasi wi Iderness 



263.2 



of about 900 square miles. Is this consistant with the Horse & 
Burro Act? What are the reasons for limiting the AUM's on the 
allotment adjacent to the Horse Herd area? ]s this consistant with 
Sec. 201(A) of T'LPMA? 

Most of the EIS is based on the visual resource management 
approach. This is a subjective v i ew of tho BLM employee while 
look ing out the w1 ndow of his oi ckup. How do you measure his 
opinion? 

It is the view of the HillOerry Cattle Company that the EIS 
is so flawed that it should be completely redone. Also, the past 
management of the Horse Herd has not been satisfactory. They 
should be moved to McCullaugh Peak or Pryor Mountain, and out of 
the critical environment they are in. Has the BLM studied the 
feasibility of doing this? 

The EIS forces cuts in livestock grazing that are not 
supported by scientific evidence as required under FLPMA and Public 
Range! ands Improvement Act (PRIA) . 

A 25 to 35* cut in AUM ' s will cause us and many other ranchers 
not to be able to operate at a profit, and may put some of us 
operating in the Grass Creek area out of business. 

By using the EIS process to develop what amounts to allotment 
management plans (AMPs), the BLM is violating PRIA which requires 
AMPs to be developed in consultation, coordination and cooperation 
with the permittees. 

The Grass Creek resource area as the LIS proposes is not in 
the best interest of the Hillberry Cattle Company or the other 
ranchers involved. Therefore, we ask that the EIS be redone or the 
last EIS be substituted in it's place, as it worked and everyone 
was satisfied. Is this possible? 



Respectful ly Submi tted, 



fLU^^-J 



Darw in Hill ber r 
Hillberry Cattle Company 
P.O. Box 628 
Riverton, WY 82501 



PI ease answer 



*"U 



estions before the EIS is approved. 



Barbara Cubin / U.S. Congress 
Alan Simpson / U.S. Senate 
Craig Thomas / U.S. Represent at i 
Wyomi ng Governor Ger i nger 
Frank Falen / Lawyer 



RECEIVED 



SFR25B35 



2(14 



SWtEAUQF WNOf.J 



LA>:aFORD KEITH, JR. 

ATTORNEY AT LAW 



April 2Q, 1995 



Korlttnd District BLM 

Bob Ross 

RMP Team Leader 

P. O. Box 115 

Worland, WY 82401-0115 



Re: 



Dai t Mr 



Grass Crc-ck. Draft HIS 



Ross: 



I find the Grass Creek EIS to be severely flawed in most 
technical and specific areas, however, I will not try to delineate 
each specific area of concern at this time . More generally, I 
speak to the apparent philosophy behind the EIS. 

In reading this document, I cannot escape the conclusion that 
it is based upon the assumption that mgre wildlife and more 
recreation an rhe expense of any commercial venture whatsoever is 
desirable. I know of no statute which gives rise to this concept, 
and I do nor. think that the Worland bum office has the authority, 
direct or implied, to make this kind of determination. Your own 
document provides chat all major species of wildlife are 
increasing, and the trend in numbers is upward, it would therefore 
seem that the existing condition ia satisfactory. Your premise 
that: commercial operation should be curtailed i.n order to further 
enhance wildlife, ia a political decision beyond the scope of your 
authority . 

T believft that your sweeping paintbrush approach to critical 
habitat designation is arbitrary and capricious. I seriously doubt 
that it can bo supported when we yet to court, stud J. further 
believe: LhaL it constitutes a taking of private property without 
just compensat i on . Whi le I am sure you do not agree with this 
position, I assure you Chat we will test the court reaction if you 
proceed. 







281 



23 April 95 
Mr. Bob Ross 
BLM Team Leader 
Box 119 
Worland Wyo. - 82401-0119 

Dear Mr. Ross, 

I am asking you to help keep our militant preservationists from damaging the mission and 
image of those of us who consider ourselves lo be more moderate and rational 
environmentalists. We must draw boundaries to the "Yellows tone EcQ syflejn?'' somewhere 
north of Mexico, south of Canada and west of South Dakota and Nebraska! The hysterical 
"Biodiversity", "Friends of the Bow" etc. plus far too many employees of the NFWS, 
advocate preservation with no development and prefer stasis to economic productivity, I am 
a native Wyoming, nature lover, with an earth science (geology) education. The lack of 
scientific content in many of the militant criticisms, show that they are planning with their 
hear ts (and their lawyers!) and not their heads ! 
[page 2] 

If these ecoterrorists arc able to turn our complete state into a national park, none of us will 
be able to live here unless we work for the NPS or USFWS! Please stick to your "Grass 
Creek Resource Area" plan and ignore the preservationists. 

1 am sure you have noticed that some of these folks practice pious dissimulation and will be 
like dogs, plus publish false "facts and figures" to support their own agenda! 

I also support the BLM and believe that you have done a good job, considering the battle 
field of divergent views you have had to endure. 

Sincerely, 

/s/ Sanford G. Andrew 

xxxxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXX 



374 



RECEIVED 



APR 2 Gt995 



U EAUOFLANDBANMUEtn ' 



MEL GTNE5T, dps 



BLM 

o/o Bob R03B, Team Trader 

P.O. BOX 119 

Norland, wy. 82407-ojj9 



By threatening economic a<7cess on public lands ir. 
the Grass Cc'trek Resource Area o£ the 3ig Horn Basin you 
are threatening me and every other individual living in 
this part of the state in a very personal way. You j 
to severely cut off a major source ot revenue in our local 
tax base. With the limited population that we have, to 
irake up the difference by personal taxes would siqn a 
death certificate tor the entice region. An increase 
in Utxea to that extent would make it ur.Leasible Lb: 
businesses to function in an economically w^rkablt; way. 
The low denaity of population in a large area accounts 
for part of this, but the lack of income which would be 
produced by public lands if they were privately owned 
is a staggering piece of the tax pie. To severely restrict 
the source of income represented by multiple uses of public 
land would destroy the businesses which would be forced 
to make up the difference. No money, no jobs, no economy, 
no schools, no hospitals, no law enforcement or public 
services. Wyoming has no interest in becoming a ghost 
town of empty houses so the rest of the nation can visit ' 
en holidays and say, "How cjuaint. Isn't it rustic." 

If there is a specific case of misuse ot abuse in 
utilisation ot BT.M land, be specific about trying to address 
that specific situation, looking for a healthy interaction 
InstUWd of a blunderbuss arrogant one sided approach. 
T would think LhaL any "reasonable" person or agency would 
want to develope healthy interaction instead of fomenting 
confrontation. The word is reasonable, not reactionary 
or extremist, or even dogmatic. 



Me: Ginest 



2(M 



RECEIVED 



APR2GB95 



267 



April 20, 1995 

Mr. Bob Ross 

BLM Team Leader 

POBox 119 

Worland, WY 82401-0119 

Dear Mr. Ross, 

I'm writing in response lo the Bureau of Land Management's draft of the Grass 
Creek Management Plan. I understand that the plan Is partly the result of the 
bombardment by various saff-interest groups that would remove present 
environmental restrictions in the Grass Creek Resource Area. 

A person who feels an area must be exploited to be appreciated is harboring a serf 
centeredness that can only be rectified through time and education. In the meantime, 
if we allow the whims of self interest to go unchecked, we not only delay and possibly 
prevent the learning experience, we destroy the catalyst that inspires it. 

If Congress doesn't exhibit the foresight to designate Owl Creek, Sheep Mountain. 
Red Butte, and Bobcat Draw Badlands as wilderness, I only hope that the BLM can 
find it in their wisdom to maintain the wilderness character of these wilderness study 
areas. Further, if Congress fails in this attempt. I would like to see a change in the 
draft plan proposed by the BLM that currently would allow the areas to open up to 
motorized vehicle use. mining, oil and gas lease, road development and completely 
disallow any of these environmentally disturbing activities. 

I would like the BLM to protect the Gooseberry Badlands, East Ridge ■ Fifteen 
Creek Badlands, and Tatman Mountain from oil and gas leasing and hard rock mining 
as potential National Natural Landmarks with a visual resources management 
classification of "VRM II." I'm pleased to know that the BLM proposes to establish 
Fifteenmile Creek as areas of critical environmental concern. 1 would also like these 
ACECs protected from any oil and gas leasing and mineral development. We should 
also consider the protection of the Fifteenmile Creek Watershed Area. 

I believe the South Fork of Owl Creek meets the criteria as a National Wild and 
Scenic Rihver and should be considered as such Regardless of whether the South 
Fork of Owl Creek reaches this status or not, any oil and gas leasing, roads, and 
mineral development should be prohibited in the river corridor. 

Concerning riparian areas and rangeland, 1 would like to see continual 
improvement not simply maintenance in the Grass Creek Resource Area. Large 
portions of rangeland and riparian zones are degraded and unhealthy. More 



267.2 



aggresive planning, technique, and coordination should be employed to improve the 
health of these areas. 

Finally, the BLMs draft plan should not simply provide for and support habitat and 
wildlife populations only lo the extent possible," but should be in complete support of 
Alternative C that "allow[s] the expansion of wildlife and fish into high potential 
habitats." 

Only when the last 

tree has died 
And the last river 

been poisoned 
And the last fish been 

caught 
Will we realize that 

we cannot eat 

money. 



-19th Century Cree Indian Saying 

Sincerely, 

Robert E. Druchniak 



g, U/i^A^^L 



268 



April 22, 1995 

Dear Mr. Ross, 

I want to express my concerns regarding the BLM's Grass Creek Management Plan. 

The BLM's proposal to open wilderness study areas to hard rock mineral mining, 
motorized vehicle use, and oil and gas development is unacceptable. 

The Grass Creek Resource Area is one area of beauty remaining to us. Please use your 
position to help ensure that it stays this way. We can't afford to lose this important wildlife 
habitat and primitive recreation area. 

Sincerely, 

/s/ Anna L Stegemoeller 

Anna Stegemoeller 

xxxxxxxxxxxxxxxxxxxx 

xxxxxxxxxxxxxxxxxxxxx 



375 




SPIERING FARMS 

1170 BOAD 19, STAR ROUTE 
POWH t WYOMING 8?435 
307-754-4349 
April 25, 1995 



269 



Sot 
Box 


Ross 
119 


mi 


Lead 


sr 


Vor 


land 


wy. 


82^01 


-0119 



HE: Cjrass Creek Resource Area Management Comments 

The fcLM'si management plan for this area is totally unacceptable and 
in the future is going to cause a backlash that will be very detriment 
to the objectives that the BliB is trying to acheive. When such a 
severe reduction is proposed to the usea of an area that supports 
a vast variety of economies It is time to stop and assess ju3t who 
is behind it and what their real agenda is. This area and in fact all 
the west has been settled and maintained by the resources that could 
be utilized. This management plan la simply an effort to start the 
process of drying up the availability of resources and in the end 
the economic prosperity of our home state. This country haa enough 
wilderness and protected areas already and what it needs is a strong 
economy so the people of this nation can afford to enjoy these areas. 

I am totally opposed to any more protected areas, restrictions and 
attacks on our industries and way of life. 



Kelly Spioring 



RADISH 
GRASSES 

LFGUMFS 



SEED 

PRODUCTION 
SPECIALISTS 



D<2ir Mr. Ros: 

No, No, No - We do not need Bruce Babbit and his henchmen Idling us what to do with our 
federal lands - 

Good Grief - You live here in Wyoming, you must have friends and neighbors that need 
your protection - after all wg ajl na^ v^ur wages - 

I'm tired of people coming out here from everywhere else and telling us how what and why 
and we have absolutely no say in the metier - 

All of a suddent the west is up for grabs (so they think) and all the rich play boys and their 
bunnies want to play cowboy - 



We haven't done a bad job in the past 61 yrs - and will do alright in the future but restricting 
people from federal lands is not the way - 

Sincerely 

/$/ Bill 8l Beverly Kolacny xxxxxxxxxxxxxxxxxxxxxxx 

(over please) 
[page2j 
P.S. 

T tried to be nice in voicing our opinion - how ever if we were to set down and talk you 
would be treated to coffee and a lot of finger halting & loud arguements 

Also - here is one of our gripes - 

Folks who live in the slate nf Wyo -- are entitled to hold BLM, Forest or State lands - 
However - foreign or out of state owners should not hold these lands - 




9) y % 



William H. Price ii 

TIMBER CMEK RANCH 
174 S.D. fiJM 

CODY WYOMING 52414 
TEL. 1J07! 527-7673 
FAX. (3D7! 327-7673 

April 36, 1995 



Mr. Bob Ror.s 

Worland BLM 

Box 119 

Norland, Wyoming 82401-0119 

Dear Mr. Ross: 

He are writing to protest the proposed reduction of land use 
including potential limitations on oil and gas activities, ranching, 
etc. In the Grass Creek resource area. 

If the proposal were Lo go through, it would have, in my opinion, 
a serious adverse impact on the tax base and hence, the tax income 
for the entire Big Horn basin. 

For instance, I happen to be a trustee of West Park Hospital and as 
such am, of course, familiar with the financial aspects of the 
hospital. With a cut In the tax income Lhe hospital and 1 am 
sure oLher tax-supported institutions would be in severe financial 
straits, and may not be able to operate. 



W. H. Price IT 



WllP/jdp 



RECEIVED 



APR 2 8 1995 



.jAUOFLANOKJWMEMHff 



WYOMING 

Game And Fish Department 



n&r 



Bob Ross, Team Leader 

P , , Sox 1 ] fj 

Worlar.d, WY 82401-0119 



I would like to make a few comments on the draft EIS, concerning 
development of the t;rass Creek RM? . As you woll know, fisheries in 
r.he Grass Creek Resource Area are managed out. of the Cody Regions] 
Office. We have worked closely with Bl^M personnel in the past or. 
aquatic habitat concerns and fisheries development and management 
Hopefully, we can maintain this level of cooperation in the future 
to enhance fisheries in the Grass Creek Resource Area. 

In general, we support the objectives and preferrfid alternative* 
relating to aquatic habitat and fisheries management . Howeve>- wo 
question how the preferred alternatives will be implemented without 
an Aquatic Biologist on staff in the Worland Office '['he ob-i e<--- v<= 
under Wildlife and Fish Habitat Manac&^ent is to "maintain or 
enhance wetland habitat for wildiif* and f ish ... promote spcc_cs 
diversity and allow the expansion of wildlife and fish whe-e 
appropriate." The document states that numerous management plans, 
includes the Stream and Reservoir habitat management plans would be 
revised as necessary and implemented. Finally, under Fish Habitat 
the 3LM would 1) cooperate wiLh WGFO to establish minimum docIb for 
reservoirs, which could support fisheries and 2) maintain and 
improve riparian areas, reservoirs, .and streams to enhar.ee 
iisheriee pot.enr.i al 3 . The objectives and preferred alternatives to 
reach, these objectives appear to oc consistent with out fisheries 
management strategies. My question is, who will handle these 
aquatic considerations? 

To my knowledge, there is 110 Aquatic biologist, on staff for the 
Grass Creek Resource Aiea. In the past, we' have Stealfc with Chet 
Wheuless on fisheries iGGUeG. However, I understand ihat Chet'a 
title is Wildlife Biologist, and thai hit) duties aria wide ranging 
(i.e. not entirely ds voted to aquatics) . To effectively meet 
desired objectives, common to both agencies, will require an 
Aqust-.c Biologist with the expertise and experience to handle 
aquatic habitat and fisheries issues, as well as '.he time to commit 
to aquatic concerns. Without this ocsitior. I am afraid that your 



e.ctives will not be reached for" 
expertise to deal with aquatic issues. 21 _ack of manpower 10 
implement pro jesta/monitor aquaiic habitat, and 3) poor 
r:r,orir.na;ion w-th cooperating agencies (i.e. Game and Piahl . ' We 
woulc strongly encourage that an. Aquatic aiolog:eu be retained on 



376 



272.2 



staff to coordinate your aquatic habitat and fisher 



ies programs 



We did find some minor errors in the documenl on page 119. 
Paragraph 3, Column 2 should be reworded in the foil owing manner to 
eliminate these errors. Two Reservoirs or. public lands in ths 
planning area contain fish. Wardel Reservoir has been stocked in 
the past with walleye, but subsequent irrigation demands have 
reduced water levels in many years. Law water levels, resulting 
from the lack of a minimum pool agreement, have complicated 
fisheries management and reduced the success of these planus. 
Despite water level fluctuations, the reservoir continues to 
produce walleye and yellow perch, but at sub-optimal levels. The 
WGFD has terminated its stocking program until a minimum pool 
agreement can be negotiated. 

In paragraph 4 , column 2 delete the words an d some walleye . The 
1992 survey did not reveal that any walleye were present. 

In the last paragraph, delete the words and bullheads . Although 
bullheads would survive and do well , we would not advocate stocking 
of this species . 

T hope that these comments wil 1 help in the final formulation of 
the RMP. Please call if you have any questions or need additional 
information. 



Sincerely, 

Mike Welker 
Fisheries Biologist 
WY Game & Fish Dept. 
2820 State Hwy . 120 
Cody, WY 82414 
(527-71251 



273 



April 27, 1995 

Dear Mr Ross, 

lam against, the Bureau of Land Management's preferred Alternative for resource 
management in the Grass Creek Resource Area of the Big Horn Basin. 

We need the oil & gas exploration, the mining & the timbering. To say the least, the 
ranchers need the grazing lands, so we "can all" survive. 

Wyoming needs to keep the jobs, & the money they generate to keep this state alive & 
growing for generations to come. 

Thank you for listening. 

Sincerely 

Is/ [Clysta] Bormuth 

xxxxxxxxx 

[EDITORIAL NOTE: Portion of signature illegible.] 



274 



April 24, 1995 

Dear Sirs with the Team, and Bob Ross: 

I am writing to urge you to make the following changes in the BLM's Bighorn Basin 
Plan. 

Please protect the Absaroka Foothills, Badlands, Bighorn River & Red Canyon Creek 
Special Recreation Management Areas (SRMA) from any and all oil development. The 
Badlands SRMA should also be designated an ACEC because of its spectacular scenic and 
extremely fragile soils. 

Protect all areas included in the Conservationists' Alternative to the BLM's Wilderness 
Proposal including lands outside Wilderness Study Areas. Also please provide more definite 
goals to address the problems of overgrazing in the resource area, and provide a timeline to 
accomplish those goals in the next five years. 
thank you very much for your consideration in these matters. 

/s/ Konrad N. Besch 

xxxxxxxxxxxxxxxx 

xxxxxxxxxx 

xxxxxxxxxxx 



275 



Dear Sir: 

We do not want out side people telling us Wyoming natives what to do, how to do it 
and when. 

Folks who live here have done real well for the past 100 years and, will continue to do 
so. 

Federal lands are paid for by all the folks and we need multiple use for everyone - not 
just the rich. 

One thing that needs to be done is the out siders who are coming in & buying big 
glocks of land need to have their grazing permits jerked 

If they are not a full time resident no federal lands. 

When I speak of resident I mean 25 yrs of continuous residence here in the state - 
These are the people you need to talke to and have serve on your committies! Native 
Wyoming it's! 

If you listen to this and take my advice you'll be alright - Other wise you'll be on every 
Wyoming natives shit list. 

Weve lots of good ideas and would like to voice them - How ever full time (18 hrs.) job 
prevents that. Put us on your list. 

Bart Kolacny 

/s/ Bart Kolacny 4/23/95 

t^oydrena Kolacny 

/s/ Loydrena Kolacny 



377 




276 



To when it may concern, 

In review of the Grass Creek Resource Area Resource Managenent Plan 
Draft EIS I have ,., few coament-a to make regarding the Area of Critical 
Environment ill Concern, midlife management, and Grazing management. 

Firgt of all I juet want to remind you that if an acsc is created it will 
actually be a defacto wilderness area administered by the BLM and not 
Congress as the fiildemean law requires, in reading this document, and talking 
to blm employees it has been impressed upon ne that this area is already being 
managed like an ACEC just without the title, with this in mind why should we 
put this area Into an ACEC? Is it so the BLM will have more leverage for 
implemsnting restrictions on there permiteeo? I truly hope not; It oeenio to me 
that the main reason for creating those ACEC is to reduce aoil erosion. I think 
that anyone who has spent time in the Fifteen Mile drainage would agree with 
no when I aay that moat of the erosion is occurring as a geological/natural 
process regardless of grazing. It Is hard to imagine this drainage as ever 
being a functional riparian area aa described in the RMP-EIS. Along these 
lines in your list of alternatives I didn't see any referral to a change in 
grazing management to improve riparian habitat and decrease soil erosion. 
Possibly if you talked to the penaiteee in that area and got them to use their 
AUMh during the dormant months and give them a price creak since the quality 
of food wli: he less and the increased possibility of them having to haul 
water. This would let the grass have all of the growing season until the 
nutrients returned to the root system for the winter time to reot and there 
would be a substaincial amount of above ground blamass to trap soil sediments 
when runoff occurs. Any how it's ideas like this that I don't see in the BMP- 
EIS. Instead it's "make an ACEC and then we can do whatever we want" instead 
of trying ways to work with everyone Involved. Ever think about using 
Coordinated Resource Management. 

While reading this RKPlpg 199 specifically) I have noticed a huge trend 
that basically says that everything has to be managed to benefit wildlife 
while taking away AijMs, O+G ieaaea r Mining leaseo, and allowing only seasonal 
use on certain roads. Does the wildlife generate enough income to economically 
justify these huge reduction that are being auggeoted the "Preferred 
Alternative"? Is the BLM changing ita priorities and devoting entirely way to 
much money to managing wildlife while at the same time decreasing grazing AUMa 
instead of maintaining AUMs7 1 hope that we are not seeing a radical change in 
the current BLM priorities. On page 200 you have a chart that is for Wildlife 
Habitat Meeting Desired Plant Community Objectives this chart basically says 
that what you want on am land is not for range trend to reach a good or 
excellent state, or a return to climax community but instead you want the 
range to provide the Best possible cover and forage for wildlife. Thia in 
itself ia poor management to manage for the wildlife instead of the rangelands 



276.2 



for which they live upon, T think the BLM desperately needs to reevaluate it3 <( 
objectives concerning the wildlife management aspect of thia RMP. Before long 
you'll be takinq orders from the WY Game And Fish Dept (pg 69) . 

An across the board cut of 251 AUMa is one Of the worst management 
techniques I have aeen yet. The reasoning behind thia data is horrible, I see 
no evidence of qualified field information in this BMP. Instead you give 
reasons for AUM cuts auch as improvement of visual quality of lands, or to 
provide forage for wildlife and wild horses. There is no evidence of these 
rangelands being in such condition to grant the reduction of 25% of the, 
available ATJKa. It is obvious that if a permit is in poor condition that 
something needs to be done auch aa a different season of use, water 
improvements for better range utilization, fencing projects, or a reduction in 
AUMs but, an across the board cut is ridiculous!! What about the permitees 
that have signed an AMP that ia functioning well? Permitees like myself which 
have a functioning AMP have already too* large cuts in our ATJMs and if more 
were to come I would certainly be out of business. Don't you feel that if you 
cancelled your across the board cut and worked with the permitees that alot 
more could be accomplished and there wouldn't be near the hard feelings that 
would occur otherwise? Just one final note, if a permitee takes ncn-ue« for a 
few years due to financial straits or their own concern for rangeland health 
Js it right to take 25% of these AUMs away if the permitee is already doing 
the right thing when not being asked by the BlH to do this. In fact won't that 
leave an awful taste in the mouth of a permittee who thought he was doing 
right and trying to improve his range. So lets all try to get along by hashing 
things out instead of making huge and unnecessary decisions. 
Thank you for your time. Sincerely, 

- Slovy 

3S land ♦ Cattle, LLC 



HEC1IVBD 



tote Legislature 




Wyoming 5 
Hfy$ (he 



April 28, 1995 



Mr. Bob Ross, RMP Team Leader 
Worland ELM 
P.O. Box 119 
Worland, WY 82401 

Dear Mr. Ross: 

Please accept the following remarks as my comments on the Draft EIS for the Grass Creek Resource 
Area. As a state representative and a member of the Joint Appropriations Committee, I have 
studied the document from the perspective of Wyoming's interests in management of the Grass 
Creek area. 

Alternatives presented in the Draft EIS leave this reader with the feeling that each was deliberately 
designed to be unacceptable in some respect. Certainly the "Preferred Alternative" is unaccerjiaMc 
in most respects: 

1. It strikes hardest at oil and gas exploration and development when these activities are the 
least intrusive and possess the greatest potential for enhancing diversity of habitat. Has the 
Worland office of BLM completely ignored the significant improvements obtained in Oregon 
Basin through ccoperation among Marathon Oil, Desert Ranches, and the Cody Resource 
Area BLM? 

2. It continues the pretense of a "Wild Horse Herd" when any layman of long residence in the 
Big Horn Basin knows there is nothing distinctive about these horses except for those 
characteristics being promoted through BLM management practices. If you have any 
scientific or genetic evidence to present to the public that these "wild horses in the Grass 
Creek Resource Area" are not just descendants of draft and riding horses of early 
homesteaders, we may feel you are justified in assigning large areas for their protection. 

3. It undermines basic elements in the economy of the Big Horn Basin (forest products, grazing, 
minerals) and provides little or nothing in return. 

4. What in the world is behind the desire to create more "wilderness" in the least aesthetic area 
of the Big Horn Basin? Who or what causes the need for such a designation? How can the 
BLM assume a "Wilderness Management' stance on this area when there is no assurance 
what-so-ever that your recommendation will be approved by Congress? Is this an instance of 
Rule and Regulation replacing Law in this nation? Is the Worland office of the BLM still 
oblivious to the anger afoot in this country to which recommendations adversely affecting 
everyone bjil BLM employees only add fuel and rationale to the nutty extremists on both 
sides? 



In addition to being critical, I wish to commend the Draft EIS for its proactive recommdBHMtO 
protect small but significant areas containing artifacts. Can we, aa members of the p&&[4sMfiie 
that almost every square yard of the Grass Creek Resource Area has been observed by BLM 
personnel in preparing the Draft EIS? I'm troubled by the language of the narrative which uses 
"may," "might," "possibly" and other qualifiers which indicate lack of specifics as to what exists in 
the Grass Creek Resource Area. 

Since it appears we have only the four (4) alternatives from which to choose, 1 am forced to 
recommend Alternative "B." Wyorning is struggling to maintain adequate services to its residents 
and the other three choices would more severely impact these efforts. If the "Preferred Alternative" 
is selected, can we be assured that those who make this decision will remain in Wyoming to assist 
in paying the significantly increased taxes which result from it? I ask this question because it 
appears that the Grass Creek Resource Area decision will set the course for other BLM adnuraitered 
areas in Wyorning. 

Tnank you for the Ofjr»rtunity to comment. Governor Gcringer will likely ask for a delayed 
decision to permit elected commissioners of the four (4) counties affected to provide another 
alternative for consideration. 

Sincerely, 



UJ. 



378 



1- 



RECE I VE D 

WW - I B96 
BUREAU Of LAND UAaMtaO: 



27S 



77$ N. Locust Streel 
P.O. So* 29 
Oltowo. Ohio iSB?S 

Ph. i\9523373? 
fan t\9$Z$47$Q 



Puunl Munn, k 



Mr. Bob Rosb, Team Leader 
Bureau at Land Management 
Worland District Office 
P.O. Box 119 
Worland, Wyoming B2401-0119 

R.E. Grass Creek Resource Area Management Plan - D.E.I.S, 

Dear Mr. Ross: 

Management of our public lands and the unique quality of life found 
in the Grass Creek Resource Area are very important to the citizens 
of Wyoming and the Public. Therefore management of those lands 
must be flexible, founded on valid research, broadly considered, 
and provide for the maximum economic return for the Public. 

The DEIS thaL is printed does not provide the consideration of 
sustaining the area at the present level of economic activity, 
custom, culture, livestock grazing, oil and gas development, 
recreation and timbering. Therefore I strongly urge you to 
reconsider the DEIS and provide the following in the final draft: 

1. Allow increaoed timbering ta utilize the existing 66% 
mature forest timber, utilizing various methods including 
selective cutting that will allow the maximum monetary 
return to the Government and local communities f wildlife 
protection and other recreation. 

2 . Expand the use of fire treatment in the entire resource 
area to a minimum of the average fire treatment of the 
past 5-10 years. (approximately 2000 acres) 

3. Maintain the livestock grazing AUM'S as they are 
presently authorized for both the permitted aum ' s and 
actual uae listed for 1990. Manage individual allotment 
on their own basis and not as a whole if there is a 
problem. You state "In general resource conditions on 
public lands in the planning area, including range 
vegetation, watershed and wildlife habitat are not the 
result of livestock grazing alone and are not in a state 
of such poor condition or downward trend that they cannot 
be maintained or enhanced or that would warrant 
elimination of livestock grazing on public lands. " 
Therefore, the proposed reductions of AUM's is HOT 
WARRA NTED I Every effort should be made to keep ranching 
viable in the resource area. 




278.2 



4. Off Read Vehicle management must have a more clearly 
defined designation and have a strong enforcement 
program for violations. The present plan does not 
address this issue ! 

5. A predator control program must be developed and 
implemented for the resource area which considers 
livestock, wildlife and human beings. The program 
must consider the safety of the multiple users, and 
if necessary the predators should be removed or 
eliminated . Without such a program it will be 
almost impassible to expand the bird populations in 
the resource area. 

6. The unreasonable restriction placed on the oil and 
gas industry in the preferred alternative Bhould be 
eliminated. It appears the Mo Surface Occupancy and 
Controlled Surface Use are not warranted as these 
concerns are already covered by your standard lease 
agreement. These restrictions have an extremely 
severe impact on the economic stability of the area 
and affects revenues for the federal government, 
State of Wyoming and individual businesses and 
industries of the four counties involved with this 
resource area. We need to provide jobs not 
eliminate theml 

7. Consideration and comments attempting to create more 
Wilderness without congressional consent is in 
violation of current laws ; attempting to do so by 
declaration of the Areas of Critical Environmental 
Concern (ACEC) should be stricken from the document. 

8. There is no valid reason to expand the Wild Horse 
Herd, which is now costing the taxpayers over $15 
million dollars to administer the program per year. 
Your management should be to maintain the herd at 
the level of 100 horses as stated in your 1989 
summary. Building roadB into the area that is of 
such special environmental concern and expanding the 
number of horses is not a wise use of tax money 1 

9. Adequate alternatives have not been provided. 71% 
of the statements comparing alternatives all read 
"Same as Preferred." This is in violation of the 
National Environmental Policy Act (NEPA) . 

Mr. Ross, the DEIS as published is a clear attempt to reduce 
multiple use, particularly timbering, oil & gas development and 
livestock grazing. TheBe are industries that provide significant 




278.3 



revenues to the entire area and the Government. By your own agency 
statement "the area ia functioning rather well." Therefore, Mr 
Ross it should be your responsibility to develop a plan that 
maintains the resource area, that provides for enhancement of all 
multiple uses and not the economic degradation and disaster that 
the present plan proposes. 

Please provide details of how you propose to incorporate these 
suggestions into the plan and bring some reasonableness to the 
DEIS. 




Thomas H. Patric 



BUREAU OF LAND MANAGE 
WORLAND DISTRICT OFFICE 
P./O.BOXH9 
WORLAND WYO. 82401 



Q£> Bob Ross 



RECEIVED 

MAY - 11995 

L I 

BUREAU Of Lr.XDKAf.Aaa EH. 
I nau'.iu . r^liwli 



279 



Grass creek Resource area: 

Here arc some feelings and comments about our land in this area 
the wild life has run on this land for years, so why penalize the rancher by taking the 
AUMS away? 

The rancher helps manage the wild fi&, by developing good water, feed salt and we know 
the wild life do eat the salt and feed. 

If you get rid of the livestock it would bring in more predators, in this area 
Some of your ideas do more harm than good when you turned the fox back In this area 
they killed off most ol the Pheasant , Rabbits and Sage chickens. So having more 
predators, is not a good idea. 

There ia no justification for cutting the AUM units per month the land is not over grazed!! 
The main problem is in the years when we had a drought. Ilia! is not the rancher's fault. 
We are the ones that lose in those years, because wc pay the rent and can only run a sort 
time when there is no grass or little water. 

Or maybe you should aland behind your lease, by guarantee that there is plenty of grass. 
and rain. We Iwth know you can not control the weather I Nether can we We just leam to 
adjust our lives to live in this, country. 

If we have to cut 35% of our AUM.S we will no longer be in business, then there is no 
BBad m have a BLM office or employees, you hotter think of things like that as well !!!! 
most of the small towns in this area do depend on the ranch income, wc pay a lot in taxes 
to the county and state and federal government Most of us buy feed , gas, and shop for 
our families in your towns, where will that money come from to support the towns 
merchants!?? 

We can tell you about the hunters thai have destroyed, property and animals at our 
expense. 

I'hey shot holes in water tanks, so the wild life and Ktoek could not drink, why?? who 
knows. 

Why do they shool holes in the B.L.M signs '.'? or cut the wire on your fence when was 
the last time a BLM personnel came around your fence line who is the one to maintain 
your fence'? We are the one,s that do the work 



JQNES.AND JONES RANCH 



379 



• RECEIVED 



«*-IB5B 



Paige and Shane Smith 



280 



Bob Ross 

BLM Team LcadLT 

P.O. Box 1 19 

Worland, WY 82401-0119 

Dear Mr, Ross; 

RE: Grass Creek Draft Management Plan 

We are writing to express several concerns regarding ihe BLM's Draft Management Plan for the 
Grass Creek Resource Area. Our primary concern is that the BLM should be very selective 
when determining which portions of this Resource Area will be made available for oil and gas 
leasing and development. The following is alntcd in the Buffalo Resource Area's Lighthouse 
Coal Bed Methane E.A 

"An oil and gas lease grants the lessee the right and privilege to drill for, mine, extract, 
remove and dispose of oil and gas deposits in the leased lands subject to Ihe terms and 
conditions in the lease. Because the Secretary of the Interior has the authority and 
responsibility to protect the environment within federal oil and gas leases, restrictions arc 
imposed on the lease terms." The E.A, provides further that stipulations may be put on a 
lease, however "none of the stipulations empower the Secretary of the Interior to deny all 
drilling activity because of environmental concerns." 

These statements arc truly a wakeup call to the reality associated with oil and gas leasing - once 
the lines of approval are drawn on the map, its a done deal. Therefore, we recommend, at a 
minimum, that the following areas be excluded from leasing : 

Owl Creek WSA 

Sheep Mountain WSA 

Red Butte WSA 

Bobcat Draw Badlands WSA 

Gooseberry Badlands NNL 

East Ridge-Fifteen mile Creek Badlands NNL 

Tatman Mountain NNL 

Fifteenmile Creek Watershed ACEC 

Meeteeise Draw ACEC 

Upper Owl Creek ACEC 

South Fork of Owl Creek river corridor 

These areas have already been identified by the BLM for their unique quaJities. Therefore, it 
seems counterproductive to even consider having leasing applications submitted for them. Ao 



Mr. Bob Ross 
April 24, 1995 
Page 2 



280.2 



inordinate amount of time would then be spent by BLM employees and a concerned public 
trying to determine all stipulations needed to attempt to minimize impacts from exploration and 
production within these areas. Even then, there are no guarantees that the stipulations will 
protect the areas from permanent alteration. 

In addition, we recommend that the BLM give more specific consideration to ensuring that this 
plan actually enhances wildlife habitat by adopting Alternative C. 

Thank you for the opportunity to comment 



Sincerely, 



\ a^s. WG^ 



Paige Smith 



CAMENZIND PRODUCTIONS 



Mr, Bob Ross 
BLM Team Leader 
P. O. Box 119 
Worland, WTO. 
82401 



Dear Mr. Ross, 



-Eran7 j ramgnT^rj, PK D, 



2S1 



RECEIVED 




April 20, 1995 



Please accept these comments as a response to the current BLM Grass 
Creek Management Plan. 

I support Alternative 'C for its protection of wildlife resources in the Plan. 
But beyond that, the Proposals to open up virtually every acre of the Unit 
to oil, gas and hard rock leasing is absolutely unacceptable. None of the 
Wilderness study areas should be touched, regardless of their final 
designation, but to do so before their status is determined is a mockery of 
the intent and purpose of wilderness study and designation legislation. 

In addition, no more areas should be opened to roadways and off road 
vehicle use. The vast majority of Wyoming's public lands are already 
open to vehicles, to open more is contrary to the concept of multiple use. 
There has to remain a few desert environments free of vehicles where 
individuals can still recreate in the peace and quiet of nature. And in so 
providing, we also insure habitat for Wyoming's unparalleled wildlife 
populations- probably our greatest long-term assets. 

There is too much critical wildlife habitat in this area to jeopardize it with 
extractive uses and permanent vehicular access routes. Lets save some of 
the Old Wyoming before it all looks like a RV recreation site or oil or gas 

field. 

Thank you for considering these comments. 



Sincerely, 

Franz J. Camenzind, Ph.D. 




P.O. Box HH • Jackson, Wyoming 8300 1 ■ USA • (307) 733-1806 



"SsceTvTd " 1 










282 








in 


m 


8'Jl'enu nr La lit) 
101 -S22 


HflTingr-mm 


» 








lt*4 Orjn Crw< 


it UUtlen 


» 








»OIH With Bumn 


i'0-ai*t*d w 

i lending 

or itii' ft 

rd Id ptcv 


Lit, nr = ftor 


WMJMl 


;/«{,« 


OCP 10 


lidlri In thn 


cloi Ian i « 
staff of 


" f ! ■ 3 ii = o n t. 
M Morn BUS) II 


Ksii: 


HEL 




rmngcy world u 


lir;;,; 


i„':HL"':.T 


S 


niv' 7b" 


!;!:*•„„,. 


and tucmul i gu 


£r°:*:: 


living 


r out o 


*ae iui 

l BL-H an 


FortTf 


'itil firm hive 
luring owned mi 

*q ptomt! „r<r i- 


u t in*t 1 1 


I Ida tod into 
« h;.M li--. fnr 


rullur.i 
UH«:i«l Y 


nr- . Tfl* 


rr»»m Ing 


rifJi»i ln tnis 

Mint to-ali i.app 
ao.n :□( |uet i 

01 III. U.S.A. fl 


O (lloducl, 


-nJy LU» Agric 

providi no lu 

Already * «e . 

yed by rein 

llil.i deoon 


;:"S 


Gun ,n. 
how fin* 


1 r « <j I B - 


",';',";, ";';»r: 


I*»i**(ti' 


ft4»»VB.|«d"«e 


».»•„» 


: ■::";:, 


"..'■""., 


i-i!ltd citdinqir 
COnErul led By- r, 


£i?i*ii: 


'.■vi::!i'; 


'::!;!: 


•55.' 





380 



282.2 



In (jummiiry, we in ftgr 1 culture nee in direct confrontation 
vith those who would na ver log a tree, preserve everything 
that jw on thie earth, There is no way that this can be done, 
I would like you folks to continue to work out, a practical 
program with our agricultural people that will Insure that our 
people in this country and I. he World will have a adequate diet 
to sustain themselves. ZIOPLE_F2RST- predators and endangered 




onald E. Beck* 
A Concerned Citi 



[Included with this letter was an article from the Readers Digest.-ED.] 



RECEIVED 



f-l 



William J. Miu-er 



283 



April 28, 1995 



Mr. Boh Ross 

Bureau of Land Management 

P. O. Box 119 

Worland, WYS2-10I 



Dear Mr. Ross: 

Plcaso accept my compliments on the draft management plan for the referenced area. 
Although I do not agree with all aspects of the plan, for Instance the designation of the Areas of 
Critical Environmental Concern and the limitation on off-road vehicle use, 1 believe vou have 
achieved a reasonable balance for resource management in most of the plan. 

It is worth noting that in dealing with natural resource issues, you havf; not simply taken a 
position to satisfy the "environmt>nial community," but have mrugni/.ed that there are other 
members of the "public" that also have interests and rights in the public lands. Many times it is 
easy to forgpl lhal public lands are for the public and are to be managed for multiple use. not 
tor the single-minded agenda of a well funded few who have no appreciation or understanding 
of the fundamental needs and requirements of all of the people of the American west, be they 
the rancher, farmer, oilman, Tecreabonist, hunter, miner, conservationist, etc. 

Please continue to recognize the importance of the local community in your consideration of 
comments and observations on your management plan. These people are the Lrue stewards 
and custodians of Lhis land and resource, and in the vast majority of cases have done a good 
job. 



Special interests, whether they are environmental groups or natural resource users, cannot be 
allowed to have greater influence than the local community simply because they have bigger 
budgets. 

Sincerely, 



J&sg+rt/^et&o 



284 




Pamela Perry 



3/26795 

Bob Ross, Team Leader 
Bureau of Land Management 

P.O.Box 119 

Worland, Wyoming 62401 



Dear Mr. Ross: 

I am concerned about the Bureau of Land Management's recently released draft 
management plan for the Grass Creek Resource Area of the Bighorn 
Basin. 1 am vigorously opposed to the plan's allowance for virtually uncontrolled 

oil and gas development in this beautiful region. 

Specifically, I urge you to make the following changes: 

The Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek 
Special Recreation Management Areas (SRMA) should be protected from 
oil development. 

The 3adlands SRMA should also be designated an Area of Critical 
Environmental Concern because of Its spectacular scenery and extremely 

fragile soils. 

Protect all areas included in the Conservationists' Alternative to the BLM's 
Wilderness Proposal including lands outside Wilderness Study Areas. 

Provide more definite goals to address the problems of overgrazing in the 
resource area, and provide a timeline to accomplish those goals in the 
next five years. 

Thank you Tor your attention to this. 

Sincerely, 



#*#t* 



RECEIVED 



MAY - I 1995 



Mr. Bob Ross 
BLM Team Leader 
P.O. Box 119 
Worland, WY 82401-0119 

Dear Mr. Ross; 



285 



April 26 1995 



I understand the management plan for the Grass Creek area falls far short of protecting 
some of the most interesting and unique areas in the state. 

The Grass Creek area affords some opportunities to protect wildlife and resources for 
future generations to enjoy and utilize but only if those areas are managed and 
monitored properly now. This includes not only the scenery and habitat but also 
priceless natural landmarks and ancient geological features which need protection 
from oil and gas exploration and production and uncontrolled use. 

Those areas of critical concerns should be withdrawn from exploration for oil and gas 
hard rock mining and unmonrtored land use. 

I urge you to consider and incorporate the following major concerns in your plans; 

" Provide greater protection for potential national natural landmarks. 

* Protect areas of critical environmental concern from oil and gas leasing and 
development. 

* include the South Fork of Owl Creek in the recommendation for wild and scenic 
rivers, 

* Withdraw hard rock mineral development in critical areas. 

* Restrict oil and gas leases and development to proper multiple use criteria 

* Improve range and riparian areas. 

* Manage and monitor with increased emphasis the fish and wildlife habitats 

Please take whatever actions available to you to protect this critical area while there is 
still something to protect. Do not let this area be destroyed, 



Sincerely, 



Charles H. Nations 



(formerly of Lander, WY) 



381 



286 



Grass Creek Resource Area 



I support Alternative C. Minerals including oil & gas should not be depleted -- no even 
sought - until our countrymen stop wasting them! Recreation motors should be banned! 
Overgrazing - especially along streams - & overharvesting of timber should be banned! 

Respectfully, /s/ Bob Morris, xxxxxk xxxxxxxx 



phiceivcd 




m»\m 


Ml 


IBEAUOFUWOMBJUm 



A A Production, Inc 



April 25. 1955 

Mr Bob Ross-Team Leader 

Bureau of l.and Management (BLM) 

Grass Creek Resource Area 

P.O Box 119 

Worland, WY 82401 -Oil 9 

Re: Written Response to Grass Creek Resource Area Draft R. 
Environmental Impact Statement Dated September, \% 



Management Plan (RMP) and 



A A Production, Inc. [A A) of the letterhead address is submitting it's written comments on the 
subject RMP A A is committed to the protection of the ecosystem and environment of the RMP 
area. We look forward to cooperating with the BLM and the public to continue this commitment 

A A instructs the BLM to turn down all alternatives (A through D) and to return the RMP bacfc to 
commirtee. While sympathetic with other industries concerns, this recommendation is based on the 
following, but not all, views from an oil and gas company perspective 

1 The plan is not "balanced" as the BLM asserts. Economic development does not an ecosystem 
destroy. It will be very costly to the petroleum industry in terms of jobs and asset value loss to 
increase the current onerous regulatory environment The RMP yields 100 much to requests by 
environmental organizations for unrealistic regulation recommendations. 

2. The RMP would encourage Canadian gas imports exempt from Canadian federal environmental 
regulations and Mexican gas imports also exempt from environmental regulations with the result of 
increasing environmental degradation of the world 

3. The RMFsmerits should not be discussed with industry in shon hearings. The committee or team 
that constructs the RM? should include contracted experienced and recognized petroleum industry 
consulting petroleum engineers, landmen, geophysicists, geologists, planners, and field supervisors 
to work with the existing environmental specialists that were used. The scoping statement was not 
sent to A A or its predecessors. 

4. The RMP does not contain enough scientific data. Specifically, petroleum entrapment concepts 
do not include hydrodynamic or "basin-cenlcrcd" concepts. Thus, the area considered prospective 
for natural gas development is too small. Also, the projections for well drilling do not take into 
account larger recoverable resource estimates and larger projections for future drilling that are 
publicly available. 



287.2 



Attached to this letter, A A's comments are further listed in the following exhibits; 

Exhibit I: National and International Economic Impacts of the RMP 

Exhibit IT: Local Economic Impacts of the RMP 

Exhibit III: Specific Recommendations for the BLM for reconstructing the RMP 

Natural gas is a major fuel consumed by the United States (U.S.) and the entire world. In the U.S. 
it is used in most homes, schools, businesses, and factories and is increasing in use as a vehicle fuel. 
It's advantages are that natural gas is perhaps the most efficient, clean burning, and transportable of 
all fuels. IntheU.S. andin Western Wyoming it is very abundant and easily extractable. Curiously, 
the U.S. displays a "self flagillative" attitude towards domestic natural gas as the U.S. encourages 
imports from Canada satisfying 12% of national consumption (soon to be 15%). The Federal 
government is now looking at encouraging Mexican imports of natural gas. The U.S. Federal Energy 
Regulatory Commission hampers natural gas transportation while the Canadian Government 
augments the cost of transportation of Canadian imports. 

Locally, in the western half of Wyoming, population is on the rise. This population growth 
encourages additional consumption of natural gas. The proved reserves in the RMP area are on the 
decline. If increased natural gas demand is not met with increased Wyoming proved natural gas 
reserves then this demand will likely be met by Canadian imports. The current triple blows of rapidly 
declining spot gas prices, rapidly increasing Canadian gas imports, and sharply increased 
environmental regulations will probably prove further crippling to the domestic industry. A A is 
highly impacted by the BLM regulation in the RMP area as this area may become uneconomic for 
consideration as a "corporate growth" area. A A's sole business is natural gas production and sales. 

We look forward to cooperating with the BLM in achieving a high degree of ecosystem protection. 
We ask the BLM to consider carefully our enclosed comments. 

Very Truly Yours, 



Don Greenwood 
Manager of Geology 



Karen Kennedy 

Wyoming Independent Producers Association 

P.O. Box 2325 

Gillette, WY 82717 

Alex Woodruff 

Independent Petroleum Assocation of Mountain States 

620 Denver Club Bldg., 518 17th Street 

Denver, CO 80202-4167 



[Included with this letter were copies of pages from the World OH, the RMOJ, (he Well 
Servicing, the Odessa American, and the QU & Gas Joumal.-ED. 



287.3 



EXHIBIT I 

NATIONAL AND INTERNATIONAL IMPACTS OF THE RMP 

THE RMP IN COMBINATION WITH OTHER RMPs' ... 

Encourages imports of natural gas exempt from environmental regulations. 

Degrades the world environment. 

Increases the Federal Deficit 

Decreases new technology development for more efficient natural gas reserve extraction. 

Decreases the number of higher paying skilled jobs in America. 

Reduces the number of students in American Universities. 

- Reduces the total federal tax collections. 
Reduces private investment in the U.S. 

Accelerates the decline of U.S. proved natural gas reserves. 

Increases Federal Bureaucracy 

Increases the ratio of federal employees supported by private sector employed citizens. 

Discourages new business formation in the natural gas industry, 

Increases the distance and danger of natural gas transportation from source lo consumption. 

Decreases the immediate availability of natural fuel supply during future international crises. 

Adds unnecessary regulation to an already high degree of environmental regulation. 

Causes the country to become more socialistic and less democratic. 

- Transfers more well drilling decisions from private corporations to the Federal Government. 
Encourages ignorance of published reports detailing large gas resources available in the 
Western U.S. for development. 



382 



287.4 



EXHIBIT II 

LOCAL IMPACTS OF THE RMP 



Reduces the value of oil and natural gas assets in the RMP area. 

Reduces the funds available for environmental remediation in the RMP area. 

Weakens the natural gas businesses operating in the RMP area. 

Reduces the number of private sector jobs in the RMP area to offset the cost of new 

regulations. 

Increases the number of federal government jobs. 

Reduces travel, hotel, restaurant, and college business in the RMP area. 

Lessens the amount of immediately available natural gas for rising consumption, 

Diverts more private sector attention from improved natural gas development technology 

to being devoted to BLM communications. 

Causes much more pipe and electrical line miles per individual well. 

Increases the "crowding" in existing pipe and electrical line corridors 



287.5 



EXHIBIT III 

SPECIFIC RECOMMENDATIONS FOR THE RMP 

The BLM is directed to... 

Return the RMP "back to committee'' for further "balancing" of ecosystem and public needs. 

Recruit private sector gas industry consultants with each having a rninimum of 1 5 years in 

private sector oil and gas well drilling experience Include the following specialties: 

Petroleum engineer, petroleum landman, pipeline engineer, petroleum planner, petroleum 

geologist, production foreman, oilfield contractor, and petroleum environmental consultant 

Share Environmental Coalition and Siena Club complaint with IPAMS, RMOGA, RMAO. 

SPE, WTPA, and service company and oil and gas company volunteers. 

Similar to TIPRO (Texas Independent Producers Royalty Organization) convene an annual 

"retreat" once a year with environmental special interest groups volunteers and industry 

volunteers to discuss issues 

Meet with "like" governmental regulatory departments of Canada and Mexico in the field to 

develop similar environmental regulations for oil and gas production (create "a level playing 

field"). 

Implore the Secretary of the Department of Interior, a cabinet member, to recommend to the 

President and Congress to halt imports to the U.S. of oil and gas that does not meet similar 

environmental regulatory standards to L"S. regulations, 

Rely on projections for development of natural gas in the RMP and how that natural gas is 

trapped on studies conducted and published by The United States Geological Survey (also m 

the Department of Interior). The U.S.G.S. has studied the Green River Basin far longer and has 

more resources for studying the Green River than the BLM, 





RECEIVED | 




1 
ww- lets 1 

. .._ ■ i 


BU 


CAU OF I....D -:;:.. . I ; 



288 



April 20, 1995 



Area RKP EIS draft 



Bureau of T.and Management 

Box 119 

Worland, WY 02-101-0119 

Attn: Bob Boas, Team Leader 

Grass Creek Resourc 

Dear Mr. Snaa: 

As a native of Wyoming (6B years' worth), and a Park Co. 
resident for almost forty years, I feel qualified to offer 
ray opinion regarding fche above-r.amed draft proposal that 
involves such a vast area of northwest Wyoming, if for no 
other reason than longevity. 

I would like to urge you and your co-drafters to try to 
maintain the status quo, as far as use by the people of 
Wyoming Cor grazing, oil, gas and possible other mineral 
development . Wyomi ng/ci ti sens/a 11 great economic need Cor 
these uses, and have improved their rare of the environment 
over the last twenty years tremendously. 

I realize that these are public lands, but do not concede 
that they belong to citizens for no other reasons than 
recreation or protection of wild life and environment. 
Wyoming ranchers have long been caretakers Of the land and 
■wild life, having a far greater incentive to take good care. 

tyjors truly 



Dorothy/ Dixon 



K £ C i 1 V E D 


1 


MAY - 1 1995 


1 


■ .:,.« Or L'.igi/SHKJE 


:NI ', 



289 



Mr, Bob Ross, Team Leader 
Bureau of Land Management 
Box IIS 
Worland. WY 62401-0119 

Dear M r . Ross: 



RE: Grass Creek Resource Area 



The purpose of this letter is lo oppose more restrictions on Wyoming's public lands. 
Your document is tilled with restrictions thai your agency is not authorized io impose. We 
speak with the authority ot the Constitution ot the United States ol America and thai of the great 
state of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belongs to our state as well. Prudent management ol our resources Is sound business 
practice and our businesses operate with that in mind. We have managed the affairs of our state 
quite well. 

This plan does not consider the needs of the ciiizens o r businesses ot Wyoming. 

I oppose this document i n its entirely. 

Additional comments: 




383 




2 S 3 



Ann: RMP Team Leader 
Bureau of Land Management 
Wot land District Office 
P.O. Box 119 

Worland. Wy 81401 

Dear Ladies and Gen tlemen: 



Tlit following arc my reason: for being against tuch proposed reduction. 

1. I have had the privilejje of doinfi ranch appraisals in this area for ID yean 1 have ico) lie good years with 
abundant* Of moisture and then followed by some years of drought. This land respond* to moisture and it is 
inconceivable to nc thai one can protect into the future and derive at 3 predetermined amount of sums. I 
would aerce there have been isolated iruaancca where the land had been overgrazed, but these are minor and 
can be corrected with individual operator! versus making across the board cuts. 

2. The wildlife has not declined from range conditions, in fact, for most species they have improved Wildlife is 
not the reason to be culling aunts. 1 cherish (he wildlife population of Wyoming. I cannot visualize this plan 
improving the wildlife populations. For that mailer, why iihould the populations of wildlife be increased when 
they are in balance at this time, 

3. By reducing Bums, you arc taking the life blood away from the randier. The only thing he can sell it livestock 
which is utilizing tbc range forage. When the forage is reduced, his income is reduced and hii ability to 
withstand the economic cycles is diminishrd. I believe when tlic economic vkbiliiy Li reduced for the rancher, 
the long term affects on the wildlife will also diminish. It will force the rancher to eliminaic grazing by 
wildlife on deeded lands in order to conserve the production for his Irvestcck. When this occurs, the wintering 
ofdecrandcJJtherrfaonnieadOTlana^wilLbeEjeaUyn^ Whai suffers? It will be these 
soma wildlife taut you are trying to increase. The winter feed won't be available for them. 

4. We have seen the land ownership change over the past 5-7 years to more consolidated units. The ranches and 
farm units are getting larger and the smaller units arc being absorbed. When this occurs, there will be fewer 
people controlling how deeded land will be used. They will have the authority to control large blocks of land 
or use whatever means available to them lo restrict access, restrict grazing of wildlife, or whatever agenda they 
consider viable to them. By making the proposed reductions, you arc adding fuel to the fire and reducing the 
economic life blood of Hie smaller ranching family to survive. Eventually, they will be forced to sell out to ihc 
larger arid more control oriented operators. This will be doing the opposite of what you visualize this plan is 

inclined in Mccorciplisti 



Buicau of Land Management 
April 28. 1995 
Page -2 



290.2 



5. Incentives should be given the rancher to develop water to better utilize the existing forage. I have seen areas 
Ln this stan: where water has been piped to the ridges where livestock do not graze. Since the pipeline was 
constructed, livestock on: utilizing these areas and there is less pressure ou the lower riparian areas. 

6. I would like to sex more individual management plana developed versus nuking a broad management plan for 
the enure urea More cooperation is needed and less confrontation 

Very truly yours, 



C_--^5— «*- 



291 



Dear Mr. Ross, 

I am against, the Bureau of Land Management's preferred alternative for resource 
management in the Grass Creek Resource Area of the Big Hom Basin. 

I was under, the evidently mistaken impression, we were all pulling together, to develop 
more oil & Gas exploration, so we would never be at the mercy of foreign Countries again. 

Mining & Timbering is also big issues here, to say the least. 

How about the high cost to the ranchers for lease grazing? They have had to reduce 
their herd sizes to compensate. This is going to result in higher prices in the markets. 
People cant afford the prices now, let alone when they rise, 

Wyoming needs to keep the jobs, and the money they generate, to keep this state alive 
& growing, for generations to come. 

Thank you for listening 

Sincerely, 

f$t Donna Duggcr 



292 



April 29, 1995 

Dear Mr, Ross, 

I am against the Bureau of Land Management's preferred alternative for resource 
management in the Grass Creek Resource Area of the Big Horn Basin. 

We need the Oil & Gas exploration, the mining & timbering. The ranchers are already 
paying higher grazing fees, which is not right, 

Wyoming needs to keep the jobs, & the money they generate, to keep the State of 
Wyoming, alive & growing for generations to come. 

Thank you for listening. 

Sincerely, 

/s/ Jim Duggcr 



384 




293 



f-.fj. BtJfc 1J 



tVe*t »#*':-« .'i-s+a &r#* Dltliis 

F«iga ;;■*-- -Man age(<nt»rrl oU j#st tv 
i.tndsr the pre^rarnsd ml t»Ki*t 
i.iit> last a#titetK« »t t i-i i. ■-■ po 

someone at* fines mso—nj/Ktwrn m 
'■nrj* it: not only undo 

StClBfltlS-tft, but aitSC" 



( Ai a quite good. 

•Wfi 1 lttlO re-,'.! '11 

tf ,-e-il m»<w*lng writ 
igetncrvt pr in: ipl t s 

idAblu by natural rc-ou' 
tt nul.UJe At. I straw. 



The 



anaipBntfflfit ubje-.tiv 
c.ro vest v i rt i >'" i m 

dii, lit,[j! i.'insjiit dL ion 
riC'd tn i mp 1 / (smphw 



?1 1 



'..'1 : 



hp Burrtau i" grantuh-Bly sinter--; in 
.s>d wtt^Uctiva pf managing to 



the? health «nd pi-odtrct t vity 
ecosystems, fchtwi r«r tainly a ■ J e 
program must b« imp! OfflOrtt«d thfl 
the at. l ted a] twrruMve-B. 



rhp fore*l! .u- 



slet l ; 



g up to c mpatbi t ity be 
1 1 itsatBc; problomsi old 
>r>e' vlt 1 ©n of the stands 



rtve above ftttttaitwvt »t«t«s t,h» pi*t*bt»«i* clsarly 
fi'ici-aely, and siheuld HhftviflB hfrcewfi- the princi 
wot 1 vat lonel f»«tw fof (J«U#f Wi-n LfI0 t'tsatmrant 
^j it*r n at ive»j ni 1 .-i f which ahm-il ri be implatnentBd 



klj 



f>fej*K%.H 



is fa>:'- 











293.2 




C 


3D*V LUMBER 
P.O. Box 
Cody, Wyo 
324 1 J 


INC. 
u i n 9 




rAX-307 327-K 


IS 




pHGNe:-3o:'- 


■>27-7103 


Mr. Bote ROffiS 




Page « 


3 4-:-::P 


-^S 


Ho^^vcir' a qui i 


k pevisw of ta 


slffi !■■(, p-age 196 


ind icataws 


that i itt ie ac 


t j on 


will be t 


BtkBTt, even '..inder 


ell twriuit, ive & 


wh-ich its the most 


ambit ious 


:.■[ fcN'B four itltern&t ivsra 


p; yseniotf. Under 


;bs prefer 


'Bfcl al tar nat ive 


it the end oi 


cal wr«Jiai'' ye^r 


2603 


< 10 years 


hence) 300 Serw 


j Of mature 


and ©v#r m#turs 


forest will b 


s :onver terd to y 


sung forests. 


At this rate, 


SO ffl 


:r GLv per y 


»ar , 40-3 years w 


3ul d paisffl 


before* the? 12, 


100 


acres of m 


-it ur e artel ovftt nn« 


l,i,iv e i- i rtibsr 


w ou 1 d b e-! c: o rt VL'rt eti 


under the 


prefer r «ci a 1 1 er n at i ve . This 


surely cannot 


be c 


-•nsidered 


'urf- !er r~e?d" for e 


at 


management ' ' ' 


AH 


?r nat i ve E 


; the most aggrta 


BS i ve 


al tern at i v», *i 


cut Id 


require '5 


■i years to conve 


■t the mature 


and over mat ur© for 


S»t to a y 


:>ung for »»t» Cl« 


9 r 1. y 


unacceptabl &. 










C 1 »*r I y. the i 


b.jec 


j ivea for 


forKMt fn«nftQ«m#n 


fc in t h i s 


document are r 


el at 


Wei y soun 


1, The br<aafcm®n 


tsi dJacu»*«d 


are appropr £»' 


o fo 


the spec 


i.tas of coni.:&vn. 


Tfr« 


ffij3.pl i cat ion find imp I amenta* i 


:-n of sound %i I V 


i.-ultural 


pr j. ml i p 1 es» fa] 


i fa 


r short of 


a sat is Factory 


-, : ,i ijf.iofl l-o 


thM prob l ems 


Pont 


if led for 


thg ovi=itinfj CC« 


imrc i«il forest 


I f our fundamental 


purpose i 


■- truly to make 


rn.ir forests 


permanent 1 y ustsfu) 


to (Tian^in 


d, theri we mu»fc 


j._i ■? much 


bettor job ol 


choc 


aing and c 


arryin-si out the 


fci" eatmenta 


ffiOttt App-fOpr 1 < 


ite t 


i. the cond 


It ions- pr9v*i 1 in 


i wUhln our 


CO»wer c j ;a] fas 




lands. 

Char 
For« 


les. L. Wr igl-it 
star 





-RECEIVED 



Mtf-2 1995 



^$. .0 S Q3C 119 



C/O Boh Ros& 
Creek Area Draf 



294 



Worland Wy 32401-0119 
Fax (307} 347-E195 

I ob jeer, to Che significant financial impacts ta businesses, 
individuals (and consequently to the tax base) ,and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state, governments. 

I appreciate the opportunity to contribute to the very Important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. T 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Pish, and return all managed animal production to 
the Private sector. 

I object to the data collection procedures cited for aum 
utilization, and suitability. This should be completely redone. 

I object to the small amount of land considered for suburban 
expansion . 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Sspecially those Imbedded with the 8LM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
and support our communities through taxes. 



I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
emphasis iias been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

: object to the proposed blanket restrictions contained in Off-Road 
Vehicle Management. 



294.2 



I object Co the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray " Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



385 



2»5 



April 27, 1995 

Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P Box 1 19 
Worland, WY 82401-0119 



Dear Mr. Ross: 



RE: Grass Creek Resource Area 



The purpose of this letter is to oppose more restrictions on Wyoming's public lands. 
Your document is filled with retrictions that your agency is not authorized to impose. We 
speak with the authority of the Constitution of the United States of America and that of the 
great state of Wyoming. 

The resources in Wyoming belong to Wyoming, and therefore, the control and usage of 
our land belongs to our state as well. Prudent management of our resources is sound 
business practice and our businesses operate with that in mind. We have managed the affairs 
of our state quite well. 

This plan does not consider the needs of the citizens or businesses of Wyoming. 

I oppose this document in its entirety. 

Additional Comments; 

We need to Get these Environmelalists & Rccrcalionast Educated to who is Supporting 
Them. There is no one that would have anything if it weren't for agriculture. 

Signed: /s/ Geo. Ellis 
Address: xxxxxxxxxx* xxxxxxx 
City, State &. ZIP: xxxxxxxxxxxxxxxxx 




p^ E -4&?^LL|AREA CHAMBER «f COMMERCE 



296 



ffl7 &,H Mji: 

i' u. Hux m 

LOVfcLL- WYOMING 



May J . IS9B 

Bob Ross. RMP Team Leader 
Worland District BLM 
P.O. Bos 119 
Worland, WY 62401-01 IS 



Dear 



Ross , 



The Lovell Area Chamber or Commerce Board uT Directors is 
concerned with the Grass Creek Resource Management Plan. 
The Agriculture and the Livestock Industry are essential 
to the economy of Wyoming. The dollars generated from one 
business to another are overwhelming. 

According to the 1991 University of Wyoming study, "impact of 
Agriculture on Wyoming's Economy" by Robert Kletcher, David 
T. Taylor and Brett Moline, agriculture contributes SI. 4 
billion to the state's economy. Eighty-two percent of all 
Wyoming agriculture revenues are derived from the livestock 
industry. Cutting back of grazing permits will have a drastic 
effect on Wyoming's agricultural economy. 

Forty-nine percent of the total oil production in Big Horn 
County is mined from federal lands. The revenues received 
from oil and gas leases are a mainstay for local economy and 
school funding . 

The Love II Aree chamber Board of Directors would ask that the 
Grass Creek Resource Management Plan take these Tacts ami 
many others under consideration. 




297 



5-2-95 

Dear Mr Ross, 

Please allow mc to list my thoughts regarding the Grass Creek Management Plan: (T am 
a frequent visitor to many of the Grass Creek sections.) 

1. BLM needs to continue its aggressive management toward restoration of plans and 
animals, and protection of watersheds. 

2. I would like BLM to provide for wildlife as written in Alternative C. 

3. I believe the paleontological expanse has yet to be realized within this Resource 
Area. Any mining, gas-oil development, increase in roads would be a geological crime. 

4. I support your 3 ACECs but these must be off limits to industrial 
lcasings/developmem. The values of the Fifteenmile Creek Watershed Area - if protected - 
could be an example to the rest of the state. 

In summary, 1 request that the Grass Creek Management Plan exclude any type of 
industrial development, road enhancement, and NOT yield to the multiple-use extremists who 
are wanting Wyoming to become a sovereign State. 



1804 Hwy 14 
Shell, WY 82441 



Sincerely 

/s/ Fran Ghilders 



DECEIVED 



298 



Randall R. Taylor 



03 May 1995 



Mr. Boo Rasa, Te^m L e dder 
U.S. Bureau of Land Management 
P. a. Box 119 
War land. WY 82^01-0119 



Oca- Mr. Ross and Members cf the Planning Team: 

Please consider the following comments on ths Grass Creek Draf> 
Management a lan. 

I believe the BLM has performed a good jnb in developing the EIE 
There w ili always be some negative publicity from any plan; I 
hope the team members can use sound criteria in preservinc our 
long term resources and not be swayed by short term pressures. 
Whe-e possible, changes in pubic grazing policy need to be phaseo 
over a period of time to give leasees time to make adjustments in 
their operations. Grazing policy needs to be developed in 
OQOp«rrUan with lassoes to take advantage of their input and to 
work with them in preserving resources. Through this Cooperation 
the value of wildlife habitat and observation of resources must 
he given the prime consideration that is past due. 

The management of off road nor.or vehicles needs to be highly 
restrictive to prevent damage to resources, reduction of wiidli'e 
habitat, and to preserve the outdoor experience that pecule leave 
the towns to experience. Motor vehicle race tracks, tne roar f 
engines, and damage to vegetation should be appropriately 
celegatsd to areas least impacted by these activities' they 
should not be a part of the majority of the BLM lands' in tne 
Grass Creek Resource Area. 

Off road vehicle management needs to be a combination gf 
Alternatives A and C. Maintain closure ot QHV5 in the 
wilderness study areas, and limit all other DRY use to a few 
designated roads other than the open area near Worland. 

Limiting to designated roads (rather than existing roads and 
trails) la a key issue tnat will make enforcement more feasible'. 
In light of the explosion in off road vehicles, additions" 
attention is critically needed to prevent abuses, 

On a permanent bssis over- ths-snaw vehicles need to have the same 
requirements and limitations as all other vehicles, wintertime 
wildlife harassment or use of these vehicles for huntlnn sirolv 
cannot oe tolerated. 



386 



ass. 2 



•^ansging suitable areas for bighorn sheep habitat is an essential 
part cf a responsible plan. Your efforts in this matter are 
sppreciatea. Cooperation with other involved agencies in this 
natter is of crime importance. 



Management of deer , 
alternative C in sc 
cooperative manner 



elk, and maose habitat needs to follow 
far as this can be worked nut In h 
lith land owners and g r 5Zing leasees in the 



Acqjlring water wftlls end developing otne^ water sources is an 
example the BLM ' s responsiole exercise of their mandated 
stewaraship. J agree that man/ roads and trails need to be 
closed to motorized vehicles to protect watersheds. 

In regard to management of the wildhorse tmrii, I see modest 
benefit at a severe cost. These animals are hare en the range 
that could be more beneficially used by wildlife and livestock. 
we already have an abundance of wildhorses; I cannot see this as 
a priority, especially considering the cost, 

I strongly support the plans to negotiate land exchanges to 
ennance wildlife habitat in the upper Owl, Cottonwood, 
Gooseberry, and Grass Creek drainages. One consideration is that 
private holdings have often served as sanctuaries for wildlife 
because of the protection offered. Care must b& taken -^p 
limir^t motor:zed access to these areas. 

The upper Owl Creek zrea needs to have the flCEC designation to 
allow for better protection of the resources in this area . 

In the management of wildlife, soil and water, vegetation, and 
scenic resources, -- ■■■ 




In the management, nf f Irs*,, consideration should be given to 
allowing the natural plant succession that comes from fires, 
while saving money on fire control. 

I completely disagree with the classification of "semiprimitiva 
motorized" recreation use. There is nothing semiprimitive about 
people running around our public land areas on four-wheelers and 
motorcycles ; rather these represent the epitome of man " s threat 
tc natural areas. 

T he 603, 150 acres available for "semiprimi tive motorized" listed 
on page 120 is an abuse of publio lands, and constitutes the 
greatest threat we currently have to deal with ar\ public lands. 



298.3 



Ef TOftS to expand aspen stands are greatly nppr eciated . 

Thank you for your efforts in this important wnr k . There are 
rrany people who support and appreciate your work. 



<3 

Rftnrtal 1 R. T» 



"age 3 



299 



XXXXXXXXXXX 

April 27, 1995 

BL.M. 

To whom it may concern: 

You have asked for comments about "The Grass Creek Resource Management plan". It 
seems the plan has been drawn up without any thought or input of the people it will directly 
affect. 

I fed the people of the area so designated as Grass Creek should be directly involved in 
makeing any decisions of the area in question 

The plan as presently written is unacceptable to my way of thinking. 

Sincerely 

/s/ Shirley M Brown 



MAY-2HE 



lEfAUOFlABDyWUttB 



(forroll K. ffirouin 



300 



Bureau of Land Manageme 
1-0.1 S. 23rd. 
Worla.nd, Wyoming 



To whom it may concern: 

It is my understanding you have asked far public input oon-cerning 
The Grass Creek Resource Management Plan. 



My personal feelings are, as presently 

strapped! And I rea.lly do not c 

that we, as voters might a 
anything about it. 



•ritten, it should be 
«a*= tut Senator Simpson's remark' 
Li like it because we can't do 



of the Esend. tor's statements but I 

o feel such statements do reflect the general feeling burea 



1 realize you ha 

•1 such sta 

crats and politicians h; 



ir constituents. 



If the Grass Creek ares is in need or revision of Its managemen 
then the people directly affected should be the ones that have 
the opportunity of making the major deeisionG concorning that 
management I 




Carroll t- Broyji- 



387 



41906 



'tasi^m' 







m% 



a Production Inc 



Dcnvtr CO 0O2ir 



RE: Grass Creek RMP/DEIS 

Worland District, Wyoming 

Bob Rose, Team Lcadci 
Bureau of land Management 
P.O.Box 119 
Worland, WY 82401-9871 

Dear Mr, Ross; 

Having reviewed tlic Grass Creek Draft Environmental Impa 
Management plan |RMP], Texaco offers the following comments; 



Statement [DEJSj and Resource 



Texaco supports Alternative B in the DEIS as the best management approach for the Crass Creek 
Resource Area. This approach would rely primarily on standard lease lenns and conditions foi 
protection of wildlife and Other sensitive values. Adequate resource protection would be prodded 
while allowing optimum opportunities for exploration and development. 

We oppose BLM's Preferred Alternative. This approach would double the use of restrictive lease 
stipulations. The DEIS fails to demonstrate the need for increased restrictions or that less restrictive 
measures were considered but found insufficient. Not does the DEIS adequately consider use of 
mitigation. This would significantly reduce environmental impacts resulting from oil and gas activities. 

A section should be added to the Appendix that would describe the various lease stipulations, 
parameters of tttcir use, and conditions under which waivers, exceptions or modifications may be 
granted. This should be standard format and will provide greater predictability to operators. 

Through the use of Conditional Surface Use [CSV] stipulations. BLM would place seasonal 
restrictions on operation and maintenance of production facilities. This new CSU stipulation would be 
used on 6] ,001) acres of winter range, birthing areas and migration corridors. Texaco mils to sec how 
additional security for big game and their predators is adequate justification for such restrictions. 
Mitigation measures could reduce the impact on wildlife and eliminate need for seasonal restrictions. If 
facilities arc shut down in winter months this will lead to lost production and revenues Reservoirs 
could be damaged, increasing workover activity, operating cost and delays 

The Preferred Alternative would limit surface disturbance to less Chan 20% in sage grouse habitat. 
There is no basis for such restrictions. Nor docs BLM discuss the current condition of sage grouse 
habitat or reasons for population declines- What impact do other surface activities have on habitat 
[e.g., recreation, grazing]? Why focus solely on oil and gas development? This issue should be 
addressed on a case by case basis, not through automatic thresholds 

Many of the proposed ACEC's have significant potential for oil and gas development. Such 
designation could negatively affect opportunities for such development. The BLM should document 
how these proposed ACEC's meet designation criteria under BLM Manual Section 1613, If such 
criteria are not met, perhaps ACEC designations arc unnecessary 



Grass Creek RMP/DEIS 
May 2, 1995 
Page 2 



301.2 



• Geologic information used in the DEIS to develop the reasonably foreseeable development scenario 
should be updated. Information thai reflects industry's focus on gas development in recent years 
should be incorporated. 

• Existing lease rights must be recognized. Old leases with standards terms will not be subject to 
seasonal restrictions exceeding 60 days unless BLM proves oil and gas development will cause "undue 
degradation" to the environment. 

• BLM indicates in the RMP/DEIS that historic resources in ten oil and gas fields, including Little Grass 
Creek, would be managed lor scientific and public use. This program would purportedly improve 
knowledge of the historic significance of fields and facilitate approval of future development and 
reclamation activities. In July, 1994 the Petroleum Association of Wyoming [PAW] posed several 
questions regarding this program: 

1 . How does BLM justify this reallocation of time and resources when areas such as southwest 
Wyoming are in disparate need of arch surveys for APD's, rights-of-ways, etc.? 

2. Explain the need for examining these fields for listing, 

3. Clarify the benefits derived from listing these fields. Would there be any incentive to spur operator 
participation? How would designations affect post-production abandonment procedures'' 

4. How will BLM handle consultation under Section 106 of the National Historic Preservation Act 
fNHPA} to consider effects of undertakings on listed districts, sites, etc. when proposed operations 
arc similar in scope to prior operations? Will BLM impose restrictions that inhibit an operator's 
ability to replace or update old equipment, or to pursue new technology which might extend 
production? 

Apparently BLM has failed to respond to PAW's questions. Texaco would not support this proposed 
program without knowing what BLM response to these questions would be. 

• It does not appear that the Section on socio-economic benefits of oil and gas development was a 
significant factor in developing BLM's Preferred Alternative. BLM should document the cost of 
administering the minerals program along with industry's financial contribution to local, state and 
federal treasuries. "Net" risks to the environment from oil and gas activity should be assessed after 
considering avoidance and mitigation. The cost of increased restrictions on oil and gas operators 
should be weighed against benefits derived. 

Texaco appreciates this opportunity to comment. 

Very truly yours, 



Terry Belton 

Land Representative 









RECEIVED 


302 




MAY -3«B 1 


u 


EAU Of UftD HASAKHEtfl 




BLM 

C/0 Bob Ross 
Grass Creek A 
P. O. Box 119 
Worland, WY 

Dear Sir: 

I am writing 
comment perk 

Attached is a 
Wyoming. As 
of the people 
preface to this 
propaganda ut_ 
unfortunate tn, 
undermine the 

1 do not agrc 
manipulation 
message. I ar 
detract from tl 
would be incli 

There are man 
viewpoint and 
counted as one 

Sincerely. _ 


rea Draft ESS 
82401-0119 

n reference to the Grass Creek Area Resource Management Plan Draft HIS 
d which ends May 7, 1995. 

Wpy of a message sent to all employees of Marathon Oil Company in Cody, 
an employee of Marathon, 1 find this tactic offensive and manipulative. Many 
*ho signed and mailed this form letter have not even read the Draft BIS. The 
form letter contains inaccuracies and misrepresentations which is typical of the 
lized various Multiple Use committees and their branch sub-committees. It is 
it so many people can be persuaded by such a committee which in time will 
very principles and values these people think they are supporting. 

c with this in principle or in content and am embarraised hy this willful 
y the Marathon employee(s) who drafted this form letter and accompanying 
l further embarrassed by the number of grammatical errors which in my mind 
e intelligence of the author and those who sign their names to this form letter and 
ted to discredit their input from consideration. 

i residents in Cody, including Marathon employees, who do not agree with this 
who support the Grass Creek Area Draft £IS. 1 would like my voice to be 
of those in favor of the restrictions as outlined in this HIS. 








NAME. WITHHELD 


by I 1 










[EDITORIAL S0TE: Thta Letter is printed without attachment . J 



303 



April 29, 1995 
PO Box 3271 
Laramie, WY 82071 
William L. Baker 

Bob Ross 

BLM Team Leader 

POBox 119 

Worland, WY 82401-01 19 

Dear Mr. Ross, 

I am writing to protest the appauling draft Grass Creek Management Plan, ll is most 
important to me that you refocus the plan to place more emphasis on "ecosystem 
management" meaning you think first about the health of the ecosystems you are directed to 
manage. I cannot see where you have through first about the health of any of the ecosystems 
in the Grass Creek Area. 

Opening nearly all areas to oil and gas development, taking meager steps to restore 
overgrazed rangelands, emphasizing motorized recreation and hard rock mining, and failing 
to designated a comprehensive network of fully-protected Research Natural Areas are all 
signs of business- as- usual in BLM management. 

Step into the present and give us a plan with more than lip-service to your real charge - to 
serve more than the extractive resource tndustries-to serve a broad public and the ecosystems 
themselves. 

•Sincerely, 

1st William L. Baker 



388 




Curtis C (Parsons 

<P. O. tomtit? 
(Big <Pmey, 'Wycnauig 83113 

(307)27tr3}H Cffitt el >«)?}??<> IW -Horn, 



%m 



Mr. Bob Rosa, RMP Team Leader 
Bureau of Land Management 
P. 0. Box 119 
Worlaad, Wyoming 82101-0119 



2ear Mr. Rosa : 



RE: Grass Creek RMP 

Please register my objections tn the Grass Creek Resource 
Management Plan and associated draft SIS. The restri at i ons being 
placed on oil and gas leasing and field operations are not 
consieter.t with good multiple use practice and will serve to 
reduce income both to the Federal Government and the state of 
Wyoming. The proposed NSO area is particularly troublesome. 
Thin has the practical effect of withdrawing these lands from oil 
and gas leasing for a very specialized use and appears to be an 
effort to create a quasi-wildQrnQss designation simply to keep 
out oil and qas operations. 

Until the state of Wyoming 1b able to substantially broaden 
its economic base, we simply cannot afford further restrictions 
on oil and gas leasing. 



Sincerely, M 

ao. u^ 

CurLia C. Parsons 



CCF/rgt 
cc: File 



RECEIVED 




BEAU OF UNO MANMtUbtt 



305 



ack Van Baal en 



April 28. 1995 



Mr. Bob Ross 

BLM Team Lnnder 

P.O. Box 119 

Norland. WY B2401-0119 

Dear- Mr , Ross i 



Thi 



U 



addresses the proposed management plan for the 
Grass Creek Resource Ai ea . As you know, this areu constitutes an 
integral portion of the Greater Yellowstone Ecosystem. For this 
reason the plan is critical tc the continued integrity of one of 
the nation's most valuablft natural areas. While the BLM is to be 
commended for some of its proposals, others are totally 
unacceptable, at least in their present tana. This plon in even 
more critical in view of the fact that it will govern the 
management of the resource area for the next 10 to fifteen 
years. 

The following must be considered in connection with the 
proposed plan; 

1. Present proposals to open wilderness study areas to 
mining, motorized vehicle traffic and oil and gas development are 
so extensive as to be totally unacceptable. At a minimum. Owl 
Creek, Sheep Mountain, Red Burte and Bobcat Draw Badlands 
wilderness study areas should be managed to retain their 
wilderness character. This is essential even if Congress should 
decide against wilderneas designation for theae areas. Whether 
or not these areas are designated wilderness, they are so 
spectacular that they should be permanently placed off limits to 
mining, oil and gas development and motorized vehicle traffic. 



Tim areas which th« proposed pla 
-private, nonmotorized recreation act J 



intends to manage for 
are who] ly 
inadequate. Even though demand for these kinds of areas is 
predicted to rise markedly, only about 8% of the public lands in 
the Resource Area are to be managed to provide hiking, camping 
wildlife viewing, nature study and solitude. It is crucial that 
the areas devoted to these uses be significantly expanded. 
Furthermore, if Congress should elect not to desiqnate all the 
present study area* as wilderness a raault which seems likely 
at this time — the importance of managing theae areas for aemi 
private, nonmotorized use will be even greater. 



3. One of the most shocking and surprising aspects ot rhc 
■ jposeii plan is its allowance of oil and gas leasing and 
clopment on every last acre ol available public landa. Not 
excessive, but it clearly violates the 



is this 



, every 
atent. ly 



305.2 



Sure a 



multiple use Mandate 



4. There are several areas or" critical environmental 
concern in the Resource Area. All of these should be oft limits 
to oil and gas leasing and development. The BLM is to be 
commended for its proposal to designate Fifteenrrule Creek., 
Meeteetse Draw and Upper Owl Creek as areas of critical 
environmental concern, However, it is essential that these 
areas also be off limits to Ol 1 and gas leasing and mineral 
development. Furthermore Fiftecnmile Creek Watershed Area must 
be protected to maintain its extraordinary recreational and 
natural resource values. 

5. The South Fork of Owl Creek certainly is eligible for 

Wild and Scenic River treatment. Your- determination to the 
contrary is erroneous . It should be reversed and this 
extraordinary waterway should be accorded the legal protection 
which It clearly deserves. Even if it is not granted this 
deserved designation, it must nevertheless be protected from the 
devastating incursion of oil and gas leasing, roads and mineral 
development generally. 

6. The proposal to close a few areas to mining and mineral 
entry under the archaic 19B2 Mining Law is also commendable. 
Nevertheless, there are other areas which must be similarly 
protected against mining activities. All four of the existing 
Wi Iderness Study Areas must be protected aaainst mining and 
mineral entry. 

7 . In view of the prop OS a 1 ' s assessment that only about 
one-half of the riparian habitat in the area is properly 
functioning, it is difficult to comprehend why virtually no 
attention is to bo directed at improving the condition of this 
habitat. More attention to riparian habitat improvement is 
required. Moreover, the plan's apparent lack of provision for 
improvement of large areas of degraded and abused ranae 1 and is 
also beyond understanding. While recent improvements in grazing 
practices are gratifying, the Bureau should nevertheless 
institute more aggressive use or" coordinated range management 
Techniques together with time controlled grazing practices to 
improve ecosystem health and biodiversity. 

6. The attempts to condition adequate management of fish 
and wi Idl i f e habitat by such qual if i ers as "to the extent 
possible" and "where appropriate" are inappropriate. These 
important values should be fully recognized and pursued with all 
necessary vigor. Only the wildlife prescriptions of Alternative 
C of the proposed plan incorporate the requirements that should 
constitute the final plan's minimum wildlife objectives. 



305.3 



I trust that you will find the above comments useful. 
7 J lease advise me with respect to further developments in reaard 
to the management plan. 

Jack Van Baal en 




389 



MAY- 3885 



»™ll^&^ k B £ea Draft EIS 



306 



'.0 Uox 119 

Norland Wy 82401-0119 
Fax (307) 347-6195 

T object to the significant financial impacts to businesses, 
individuals (ar.d consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. ' 

I appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object to the reduction of Grazing AUKs prooosed in the 
Alternatives, Seal, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. 1 
recommend eliminating all "Wild Horse Management" areas in the 
Brass Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

I object to the data collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 

I object to the small amount of land considered for suburban 
expansion , 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

1 object to restrictions that hamper the current Drimary businesses 
and individuals who use federally administered lands to are 
generate income and support our cornmuni ties through taxes. 

7 object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
ampbaeifl has been placed on new technology and new information to 
mitigate and reclaim any impacts, 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

I object to the proposed blanket restrictions contained in Off -Road 
Vehicle Management. 



306.2 

I object to the small consideration given to the economic inrpacts 
to businesses and also tax bases. Beneficial impacts cf businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black- footed ferret inferences. 




Bffi SI ' Qt; 1J f^ l rf riW&UIS qw^RDS IMC 



MAY - 3 1995 



l) Era QF LAUD EmmuhI 



F.I 

307 




Worland BLM 

ATTN: Mr. Bob Ross. RMP Team Leader 

Box 119 

WorlantLWY 82401-01 1 9 

Dear Mr- Ro3s, 

1 am very concerned about some of the management options being considered for the 
Grass Creek Resource Area. It seems that most of these options will seriously impact oil / 
gas and ranching operations that have been in place for decades. Both industries have 
proven to be good stewards of the land and this planned cut back of their activities is a 
real slam to their integrity as well as a devastating economic slam to the area economy 
Jugt where are we supposed W make up the significant revenues chat will be lost if the 
'preferred alternative" is implemented. Are we really willing to put the important mineral 
revenues that make Up the bulk of funding for educating your children and mine on the 
sacrificial altar of yet more wilderness areas. 

Mr. Ross, I was bom and raised in this area and have a real love for it The last thing 1 
want to see happen is w have anybody ruin it. The industries that currently utilize this area 
have done an excellent job of promoting water and wildlife habitat in conjunction with 
their use of the land. It does not seem fair to not give some credit and consideration here 
What is of even greater concern is that so much of the preservation movement is based not 
in the western states being most affected, but in the big moneyed eastern states. They do 
not have a clue (or concern) about how their directives will affect those that have to live 
with them. I seriously doubt they are willing to bail us out of the ensuing economic 
hardships. 

Thank you for giving me an opportunity to "vent" Please use soma common sense in 
determining the future management of this area There is some middle ground to be found, 
but it hasn't been indicated in the current management proposals 




308 



3-May-95 



Bob Ross (BLM) 



We have lived & raised our children in the Big Horn Basin I have been here 50 years. 

I wish our public lands to be just that public lands. 

We don't need !he restriction &, we do not need new management. 

In Grass Creek or anywhere. 

ft/ Sharon Hallman 
Everett Hallman 
Sandra Hollman 



390 




309 



C/o Bob Ross 
Creek Area Draft Els 

id Wy 82401-0119 
107) 347-6195 

> the significant financial imnacts to businesses 
,and consequently to the tax base!, and the effected 
counties and comnunitias due to restrictions proposed within all of 
the alternativee, and recommend that a new preferred alternative Ee 
r^r^nS-? th % hel P o£ ^"Kidgeable community individuals ana 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. minerals 

I appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. cooc una my 

I abject to the reduction of Grazing AUMs proposed in the 
Alternatives. Heal, current scientific data should be used to make 
management decisions on each allotment . Targets should be cl=arlv 
established and stated. 

I object to the expansion of "Wild Horse Management" areas I 
recommend eliminating all "Wild Horse Management" areas in ' the 
Grass Creek area RMe. Return all wild animal management to the 
the"private factor "" d r8tum a11 maM 9 ed animal production to 

LjfKff to j he J da ," collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 



to the small amount of land considered for suburban 



I abject 
expansion . 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives 
Especially those imbedded with the BLM Administered land™ 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 

I object to the severe and undue humber and level of restrictions 

SL h S " r ? aC h Dl h 3turb >"== i" a " °E the alternatives: £t enoSgh 

ri-iaace and ™S ? CCd °" ° 8W ce =""°i°9y and new information to 
mitigate and reclaim any impacts. 

l°?i e .- C f° th , e blas , £or "creation disturbance and the bias 
against minerals, grazing and recreation. 

veScIe'Mana^mJn? 08 ^ "'^ »***«««»" stained in Off -Road 



309.2 

I object bo the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences 



{k 




•i- 1 U U-- 



C/0 Bab Ross 
as s Creek Area Draft EIS 
Box 119 

and Wy 82401-0119 
Fax (307) 347-6195 

I object to the significant financial impacts to businesses, 
individuals (and consequently to the tax base) , and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement . Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area rmp. Return all wild animal, management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 



I object 
utilizatio 



to 



the data collection procedures cited for acim 
and suitability. This should be completely redone. 



to the small 



nt of land considered for suburban 



I object 
expand ion . 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 



I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives , Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

I object to the proposed blanket restrictions contained in Off-Road 
Vehicle Management . 



310.2 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife Bpecies, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 

9S~ 



^A ^k,^ , . 



Jatizh ' ' 



foff 



391 



311 



May 2, 1995 

Worland BLM 

Bob Ross, RMP Team Leader 

Box 119 

Worland, WY 82401 0119 

Dear Mr. Ross; 

The proposed management plan for the Grass Creek Resource Area contains aspects that I 
am against. 

T oppose the Plan's obvious disregard of the past and present benefits brought to the area by 
multiple use management. The local counties surrounding the resource area stand to lose a 
substantia] amount of revenue under the Preferred Alternative. Reduced grazing, 
unreasonable restrictions on the oil and gas industry and increased limitations on motorized 
recreation are all moves in the wrong direction. 

The BIjn should not manage Grass Creek REsource ARca as an unofficial wilderness area. 

Please keep common sense a main 

[page 2] 

ingredient in your management plan by encouraging multiple use activities and doing away 

with excessive restrictions on the resource area. 

Thank you. 

Sincaerely, 

/s/ Linda Tokarczyk 
xxxxxxxxxxxxxx 

XXXXXXXXXXXKXXXX 



Hi 




PO Box 280 
Slory. WY 328*2 
(307) 6S3-2B42 



Wilderness 
Association 



Bob Robs, Team Leader 
Bureau of Land Management 
P.O. Box 110 
Worland, WY 82401 



Please accept these comments from the Wyoming Wilderness Association (WWW on me Grass 
Creek Resource Aree draft mariagemBnt plan. 

The Bighorn Basin Is a treasured and unique area in Wyoming that contains a murtituda of non- 
consumpive resources that will require careful management and protection. The Grass Creek 
RA specifically has some Of the test examples of badlands, rock art, and ecological transistion 
zones -from desert to high alpine forest. 

Red Butte Wilderness Study Area, Sheep Mount a in WS A, Bobcat Draw WSA and Owl Creek 
WSA are all under the management of the Grass Creek RA- These areas - whether 
recommended By the BLM or not for wilderness designation - should be protected for their 
unique and primitive resources, The Citizens Wilderness Proposal for Wyoming BLM Unds no! 
only recommends these tremendous areas for wilderness designation, but expands the 
boundaries to contain and protect entire ecosystems. Ecosytem management a mandated 
management format for the BLM, recognizes wilderness as a vital component of any effort to 
achieve healthy functioning ecosystems. Wilderness provides the anchor that must hold the 
ecosystem together as the BLM works to restore and heal fta damage wrought on our deserts 
forest and watersheds. 

it is ludicrous that the draft management plan's ettematrve contain only alternatives for 1 00% oil 
and gas development. Surely, there are areas that must be set aside from o i g development 
tor some of the other multiple uses such as foot, horse and wheelchair travel hunting and 
fishing, camping, non-motorized boating, outfitting and guiding, scientific study educational 
programs, archeoiogic and paleotofogic study and exploration, photography, livestock orazlna 
wildlife and plant habitat. v 



Potential tor oil and gas occurrence in areas set aside as WSA's in the 1 9S0"S Is low lo 
moderate, with development Improbable due to the great depth of reserves and No Surface 
Occupancy stipulations on steep slopes (BLM, 1930). Wilderness and spocial values would b 
eliminated or greatly impaired should oil and gas development or exploration occur within one 
mile of the WSA's or other special resource areas 



312.2 



Owl Creek WSA provides crucial Habitat for bighorn sheep, moose, mule deer and elk. The 
harlequin duck {candidate for federal listing) occurs in the area. Two of the area's streams are 
important fisheries for rainbow, brook and Yellowstone cutthroat trout. The area also contains 
many rare and unique plant species that wilf require special protective management. The 
Citizens' Proposal has included sections of BLM lands containing Castle Rocks and other areas 
to protect a more contiguous and interesting ecosystem pushing the proposal to nearly 9,000 
acres. 

Bobcat Draw WSA, the only area recommended for wilderness designation by the BLM-Grass 
Creek RA, but the boundaries fell short of protecting entire ecosystems of the East Ridge Area 
and the Big Draw area. The Citizens Proposal recommends the extension of wilderness 
designation to include nearly 30,000 acres providing protection for solorful badlands sited t>y the 
National Park Service as potential National Natural Landmarks, the most comrehensive 
vertebrate fossil znation of nay rock in the world, crucial habitat for mule deer, golden eagles and 
sage grouse. 

Sheep Mountain WSA, not recommended by the BLM, has been recommended by the Citizens' 
Proposal for approximately 24.000 acres. Some of the most striking and unspoiled badlands 
formations are found here. Several vegetative classes of the Wyoming Basin Province 
Ecoregion which is not included in the NWPS, are in the area (BLM 1990). Crucial winter range 
i& provided for mule deer and pronghom antelope. 

Red Butte WSA, also net recommeded by the BLM, has about 24, 000 acres worthy of 
recommendation by the Citizens' Proposal. Internationally significant paleontoiogtcal resources 
and unusually beautiful badlands scenery typlifies Red Butte. Ferruginous hawks and burrowing 
owls, both species needed special management have been documented in the area (Ritter, 
1991). The loss ol wilderness values due to oji and gas development would be immense. 

The Red Canyon Creek Special Recreation Management Areas, the Absaroka Foothills, all 
badlands formations, and area surrounding the Bighorn River should be off-limits to oil and gas 
development. 

The Badlands SRMA should be designated an ACEC due to its fragile soil, unique formation 
resource delightful for exploration and scenery. 

All areas in the Citizens' Proposal should be protected. Should you require further information 
concerning the Citizens' Wilderness Proposal for Wyoming BLM Lands, please do not hesitate to 



Thank you lor this opportunity to comment 
Sincerely, 



Liz Howell 




?3R (3 



C/O Bob Ross 
reck Area Dtt 



1 Wy 82401 -0113 
7) 347-6195 



? ? h ^ e f t , t °. the s i9^ ifi «r.c financial impacts to businesses 
individuals (and consequently Co eke tax base), and the effected 
counties and communities due to res trier, inns proposed within ail off 
the alternatives, and recommend that a new preferred alterna-ive be 
created with the help of knew Isdee able community individuals ard 
representatives from grazing, recreation, oil and gas and miner*] a 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very imDcrtar- 
C-rasE Creek Area Environmental Incact Statement.. Please *ind rttv 
comments below. * ' * 

: object to the reduction of Grassing AUMs proposed la th* 
Alternatives. Real, current scientific data should be use- co make 
management decisions on each allotment. Taraets should be c'earlv 
established and stated. " J 

1 object to the expansion of "Wild Horse Management " areas r 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production =0 
the Private sector. 

I object to the data collection procedures cited fo- KM 
utilization, and suitability. This should be completely redcr.e.' 

small amcur.t of land considered for suburban 

I object to the lack of discussion about impacts to the va"ue of 
private, state and county -anas by the various alternatives 
cspena-ly those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to art 
generate income and support our communities through taxes . 



I object tc the severe and undue number and 

en Surtace Disturbance in all of the altt 

emphasis has beer, placed on new technology and 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturb 
against minerals, grazing and recreation. 



eve_ OS restrictions 
>:ot enough 



nee and the b>.< 



X object to the propo 
Vehicle Management , 



restrictions ccp.l 



ineri in Of; -Read 



392 



313.2 



I object Co the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- niack-faoted ferret inferences. 



MAY-pJI! 



C/0 Bob Ross 

'reek Area Drait SIS 



314 



t£AU OF LAND MNMEKCo c 119 

WWB """""V a a- la a k Wy 82401-01-9 

Fax (307) 347-5195 

I object, to the significant: financial impacts to businesses, 
individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend chat a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the vary important 
Crass Creek Area Environmental Impact Statement. Please find my 
comments below, 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Gras3 Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production CO 
the Private sector. 

I object to the data collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 



mall amount of land consider 



for suburban 



I object to the 
expansion. 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

(Qj that hamper the current primary businesses 
use federally administered lands to are 
generate income and support our communities through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives . Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts, 



T object to the ; 
against minerals , 



for recreation disturbance and the bias 
ling and recreation, 



I object to the proposed blanket ; 

Vshicle Management. 



sstrictions contained in Off-Road 



314.2 



I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

-I abject the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 




1EAU OF UNO MANUEI HT 



315 



BLM 

C/0 Bob Ross 

Grass Creek Area Draft EIS 

P.O. Box 1 19 

Norland, WY 82401-0119 

Gentlemen: 

I object to the significant financial impacts to businesses, individuals 
(and consequently to the tax base), and the affected counties and cormunities 
due to restrictions proposed within all of the alternatives, and recommend 
that a new preferred alternative bo created with the help of knowledgeable 
community individuals and representatives from grazing, recreation oil and 
gas and minerals industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important Grass Creek 
Area Environmental Impact Statement. Please Find my comments below: 

1. 1 object to the lack of discussion about impacts to th« value of 
private state and county lands by the various alternatives 
Especially those imbedded with the 31 H Administered lands. 

Z. I cM*Ct to restrictions that hamper the current primary businesses and 
individuals who use federally administered lands to generate income and 
support our communities throuqh taxes. 

3. 1 object to the severe and undue number and level of restrictions on 
Surface Disturbance in all of the alternatives. Not enough emphasis 
has been placed on new technology and new Information to mitiqate and 
reclaim any impacts. 

«. 1 object to the bias for recreation disturbance and the bias aaainst 
minerals, grazing and recreation. 



S. 



1 object to the proposed blanket restrictions conta- 
Vehicle Management. 



6. I object to the s 
businesses and als 
also be factored 

Very truly >qurs, A 



Stt*ve H. Daniels 



all consideration given to the economic impacts Lo 
tax bases. Beneficial impacts of businesses should 



393 



RECEIVED 



CT- 



U BEAU Of LAND KUAtttDIT 



316 



Bureau of Land Management 

c/o Bob Ross 

P. 0. Box 119 

Norland, Wyoming B2401-0119 

Re; Grass Creek Area Draft EIS 

Dear Mr, Ross: 

I object to the significant financial impacts to businesses, individuals (and 
consequently to the tax base), and the effected counties and communities due 
to restrictions proposed within all of the alternatives, and recommend that 
a new preferred alternative be created with the help of knowledgeable 
community Individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important Grass Creek 
Area Environmental Impact Statement. Please find my comments below. 

1 object to the expansion of "Wild Horse Management" areas. 1 recommend 
eliminating all "Wild Horse Management" areas in the Grass Creek area RMP. 
Return all wild animal management to the State Game and Fish, and return all 
managed animal production to the Private sector. 

1 object to the lack of discussion about impacts to the value of private, 
state and county lands by the various alternatives. Especially those 
imbedded with the BI.H Administered lands. 

1 object to restrictions that hamper the current primary businesses and 
individuals who use federally administered lands to generate income and 
support our communities through taxes. 

[ object to the severe and undue number and level of restrictions on Surface 
Disturbance in all of the alternatives. Not enough emphasis has been placed 
on new technology and new information to mitigate and reclaim any impacts. 
I feel this is especially true for oil and gas development impact and 
mitigation. 

I object to the proposed blanket restrictions contained in Off-Road Vehicle 
Management. 

I object to the small consideration given to the economic impacts to 
businesses and also tax bases, Beneficial impacts of businesses should also 
be factored in. 

1 object to the discussion of threatened, endangered and candidate wildlife 
species, specifically unsubstantiated Sray Wolf inferences, and Prairie dog, 
Black-Footed Ferret inferences. 



&L&~»i. 





RECEIVED 


i 




"w-im 


3u 


HUJ OF USD 1 



317 



BLM 

C/0 Bob Ross 

Grass Creek Area Draft EIS 

P.O. Box 119 

Worland, WY 82401-0119 

Gentlemen; 

I object to the significant financial impacts to businesses, individuals 
(and consequently to the tax base), and the affected counties and communities 
due to restrictions proposed within all of the alternatives, and recommend 
that a new preferred alternative be created with the help of knowledgeable 
community individuals and representatives from grazing, recreation, oil and 
yas and minerals industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important Grass Creek 
Area Environmental Impact Statement. Please find my comments below; 

I. I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives 
Especially those imbedded with the BLM Administered lands. 

?. I object to restrictions that hamper the current primary businesses and 
individuals who use federally administered lands to generate income and 
support our communities through taxes. 

3. 1 object to the severe and undue number and level of restrictions on 
Surface Disturbance in all of the alternatives. Not enough emphasis 
has been placed on new technology and new information to mitigate and 
reclaim any impacts. 



anket restricts 



tfWt 
contained in Off-Road 



1 object to the bias for recreation disturbance and the b 
minerals, grazing and recreation. 

I object to the proposed I 
Vehicle Management. 

I object to the small consideration given to the economic impacts to 
businesses and also tax bases. Beneficial impacts of businesses should 
also be factored in. 




illio 0. Yan^er 



RECEIVED 



318 



BLM c/o Bob Ross 

Grass Creek Area Draft EIS 

P.O. Box 119 

Worland, WY 8Z401-OI19 



Dear Mr. Ross: 



I would like to take this opportunity to contribute my comments to the Grass 
Creek Area Environmental Impact Statement. 

I object to the significant financial Impacts to businesses, individuals (and 
consequently to the tax base), and the effected counties and communities due to 
restrictions proposed within all of the alternatives, and recommend that a new 
preferred alternative to created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil, gas and minerals, 
industry, timber and local and state governments. 

I object to the bias for recreation disturbance and the bias against minerals, 

grazing and recreation. It would seem that some peoples idea of "outdoor 

fitting in a city park watching the squirrels. 



recreation" 
I 



bject to the severe and undue number and level of restrictions on Surface 
uiiturbance In all on the alternatives. Not enough emphasis has been placed on 
new technology and new information to mitigate and reclaim any impacts. I am 
employed by an oil company and everyday see the multitude of restrictions placed 
on oil development and exploration. But I also know that most companies are very 
concerned about the environmental impacL. 

I object to the minimal consideration given to the economic impact to businesses 
and also tax bases. With local and state governments continually looking at a 
shrinking tax base, the Grass Creek EIS will only contribute to that. This 
proposal will contribute to the loss of jobs and Income for Wyoming families. 
Whatever happened to good "ol conmon sense". It seems that the only solution to 
a problem anymore is "more restrictions'. 

] recommend that the economic impact of this be carefully reviewed and that this 
undue federal expansion of restrictions be stoppe d! 1 What ever happened to "of 
the people, by the people, for the people"? It doesn't say "for a few people". 



ihank you for your time. 

(%m, &Uu* JSkiA" 

Lloy Bene Greb 




319 



BLM C/O Bab Ross 

Grass Creek Area Draft EIS 

P.O 3ox 119 

Worland Wy B2401-0119 

Fax (307) 347-6195 

Dear Mr. Ross: 

I appreciate the opportunity Lo contribute to the very import art 
Grass Creek Area Environmental Impact Statement. Please find my 
objections listed below: J 

I object to the significant financial impacts to businesses 
individuals (and consecruent ly to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and strongly recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation oil and 
gaa and minerals industry, timber and local and state governments. 

I object to the reduction of Grazina AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas I 
recommend eliminating all "wild Horse Management" areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Fish where it truly belongs, and return all managed 



al production to the Private sector. 



I object 
utilizatic 
redone . 

I object 
expansion . 



to 



the data collection 
and suitability, This 



procedures cited for AUM 
should really be completely 



iO the small amount of land considered for suburban 
More land needs to be made available for expansion! 



I object to the lad 
private, state and 
especially those imbedded 



of discussion about impacts to the value of 

county lands by the various alternatives, 

'th the BLM Administered lands. 



I object to restrictions that hamper the current primary businesses 
ana individuals who use federally administered lands to generate 
income and support our communities through taxes. Knowing the 
dwindling oil production rates wo see annually and their subsequent 
reduced tax revanuna, we should not curtail other husiness- 
generaced income; this would in essence be "cutting out own 



I ob-'cc 



i the severe and undue number and level of restrict! 



394 



319.2 



on Surface Disturbance in all of Che alternatives. Not enough, 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. Minerals are facing an 
ever-increasing tax burden in a state already with one of the 
highest mineral tax rates. This scenario needs to be gradually 
reversed thereby allowing tax incentives for the mineral industry. 

I object to the proposed blanket restrictions contained in Off -Road 
Vehicle Management. 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be considered. 

I object to the lack of detailed descriptions for restrictions. 

I object cc the discussion of threatened, endangered and candidate 
wildl i £e species , specifically unsubstantiated Gray Wolf 
inferences, and Prairie dog, Black-Footed Ferret inferences. 

I would very much appreciate your consideration of my comments. 
Thank you! 



Sincerely, 



Terry K. Skinner 



320 



B.L.M 
Re: Grass Creek Resource Area 

Attn Bob Ross- 
Please be advised that I for one, object to the above referred to 
Proposal^ We cannot tolerate any more Federal Controls pver pir Wup.omg :amds/ Fpr 
anv. purposes - This environmental and endangered species programs are completely out of 
line with the genera! nature of our country. Please Mr Ross, Lets be realistic about controls 
and stop this madness before it destroys all the confidence we have in our Federal 
Government, (any any wc have Left in it.) 

Sincerely 

/s/ James E|Uison 

PS Maybe in the next election we can finish cleaning up the mess in Washington 

Ml 





C/0 Bob Ross 
Creek Area Draft. EIS 
lox 119 
WGriar.d Wy 02401-0119 
Fax (307) 347-G195 



321 



I object to the 



ignificant financial Impacts to but 



individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement- Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific daca should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. * 

I object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horae Management" areas in ths 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

I object to the data collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 

small amount of land considered for suburban 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives 
Especially those .imbedded with the BLM Administered lands. 

Z object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreacion. 

I object to the proposed blanket restrictions contained in Of f -Road 
Vehicle Management. 



321.2 

I object to the small cons iderat ion given to the economic imoacts 

tZ^^nXg^tL*""- Bene£icial *™ °"S.iS£ 

I object the lack of detailed descriptions for restrictions. 

5,?5??S* to the discussion of Threatened, endangered and candidate 
wildlife species specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences 




395 



w"-im 

I 2o__EiH 



322 



C/O Bob Ross 
Creek Area Draft Els 
P.O B OX 119 
Worland Wy 82401-0119 
Fax (307) 347-S195 

I object to the significant financial impacts to businesses 
individuals (and consequently to the tax base), and the effected 
counties and comnunities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement . Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMJ?. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

I object to the data collection procedures cited for al*M 
utilization, and suitability. This should be completely redone. 



nsidered for suburban 



I object to the small amount of land 
expansion . 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives . 
Especially those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, gr*2ing and recreation. 

I object to the proposed blanket restrictions contained in Off-Road 
Vehicle Management. 



322.2 

I object to the small consideration given to th» .™ mJr i 

to businesses and also tax bases bLS«S«i ii™ t™*?" impacts 

should also be factored in ' impacts of businesses 

I object the lack o£ detailed descriptions for restricts 




323 



Gibbons Company, Inc. 



BLM 

Worland District Office 

Attention Bob Ross - 

Dear Mr, Ross 

As a businessman representing Gibbons Co Inc Ford NewHolland Dealership in Worland, 
I ani dependent on the economy of the area, and do oppose the Grass Creek Resource plan_ 

Why because the restriction it places on grazing, mineral and oil development timber 
industry recreation etc. The continued use of Federa land for these purposes is vital to our 
economy_ 

Bob lets work toward these goals, not against us_ 

Sincerely - 

fsf Terrell Gibbons 



Hh Greater Yellowstone Coalition 



324 



Bob Sobs 
BLM Or as* Cr 

P.O. FOX 1 l« 



Dear Boh Ro; 



May |, IMS 



Please accept the fo ; lowing comments regarding tne r.rass Creek 
Resource Management p' an Drift Environmental Impact Statement on 
behaiT of the Greater Yellowstone Coalition. (JVC is a reliant] 
conservation sroup dedicated to -.he sound management of the ' 
Yel lows tone ecosvs tem. 



he Greater 



COSYST1M Ma.va<^ 



KENT 



rea tOCRA. ires within the Gre 
] and as such deserves careful management 
to assure the future health of the ecosys 



Trie Grass Creek Re*; 
Yellowstone ecosystem and 
appropriate dec 

This resource area offers ecozoncs ranain R from desert basins'and 
baJ and* to h,gh alpine tundra iri til several zones in between. Th.s 
widu d.vurswy of ecosystems provides important habitat to the 
varied p. ants and animals of the Greater Yellowstone ecosystem. 

En particular, species such as grizzly beers black bear, 
bobca . lynx, bighorn sheep, moose, mule deer-. elk, matter, small 
mammals. Fox. coyotes and a wide range of waterfowl, raptors and 
son* birds are key components of the ecosystem, in order to achieve 
the ecosystem management goals proposed by the Bureau of Land 
Management. CYC Suggest* that the BLM consider these conse- «. a • ic- 
a.ie.n;.t Ivs recommendations Tor the Crass Creek Resource Management 

Although we agree with the SI.M that people and their social 
and economic needs, are an integral par: of ecu I or lea I systems *e 
rat. that this document overwhelm! n s l y prioritizes human uses o^er 
others. People are part of every ecosystem on earth e.ow «e also 
recognize that the health of these ecosystems benefits human 
society, tor as go the creatures and eco 
we must be Careful rot to extfluda 
Cun>ideiat ior, of the eco 



| go the pecple 
e*c lude the bio lop !c needs i 
eede of the earth's inhabitants. 



i we tnereiore suggest that you consider a Conservation 

• 1)(trasiVV4fl '!fl IBfl HliTW tOi examu « r | Blt^ll [ttffl -e^mt"? 

thai 100^ of the legally available lands be leased tor oil and ga= 
Trts i.- not in the spirit of »hat FLPHA directed as J(; adequate 
ranjte ot alternatives. 



■ 'Afifj M«M - 2J\ ijj.tt'41 • F\x : 
'. WY ttfMj ■ J0T, is« nea • kax »t. 



396 



324.2 



CONSERVATION ALTERNATIVE 



1, The GCRA should recommend for wilderness designation proposed by 
the Citizens' Alternative Wilderness Proposal including: Red Butte, 
Sheep Mountain, Bobcat Draw, and Owl Creek. This small area 
comprising only 6% of the Resource Area should be managed for 
primitive recreation and natural history study to retain their 
wilderness character. 

2, The Areas of Critical Environmental Concern (ACEC) proposed by 
the draft RMP including Fifteenmilc Creek, Upper Owl Creek and 
Meeteetse Draw should be protected with better stipulations. 
According to the Federal Land Policy and Management Act (FLPMA), 
ACECs should be managed as public lands where "special management 
attention is required to protect and prevent irreparable damage to 
important historic, cultural or scenic values, fish and wildlife 
resources or other natural systems or processes...." Given this 
mandate, we consider it inappropriate to lease \QQ% of these ACECs 
for oil and gas. Mineral development inevitably causes substantial 
surface disturbance with increasing road density, drill pad 
development and waste pit impacts. 

3, Range management must reflect the plant and wildlife needs as 
well as those of the livestock on each allotment- Given that nearly 
half of the grazing allotments are in "I" category, there is 
obvious 1 y a need to see serious change on the range. We support 
seasonal changes in put on/take off dates as well as more intensive 
monitoring to show when certain areas, especially riparian areas, 
reach utilization. Range monitoring is essential to meet the 
standards and guidel ines required by FLPMA and reflected in the 
RMP. GYC is not convinced the BLM will be able to achieve the 
increase in proper functioning riparian habitat with the continued 
level of grazing prescribed in the preferred alternative. 

According to the RMP the FiFteenmile drainage is the largest 
sediment-producing tributary to the Bighorn River. Erosion caused 
by historic overgrazing has caused serious siltation and streambank 
cuts that may never heal under the current grazing use. We propose 
that the BLM implement the riparian standards drafted by the 
Beaverhead National Forest (see enclosure). However, in some areas 
of severe non-functioning riparian systems total rest may be 
necessary to allow recovery of the herbaceous plants. 

The 60 percent uti I ization used in the GCRMP is excessive 
according to these guidelines. In "high sensitivity" areas such as 
"I" category allotments the recommendation is to allow no more than 
\0% streambank disturbance above what occurs naturally. In 
addition, by its own intrinsic problems utilization is not always 
a good ind i cat or of streambank stability or riparian heal th. We 
recommend that each al lotraent undergo a proper revi ew and 
adjustment in grazing use. This may involve a further decrease in 
AUMs than is proposed in the preferred alternative, but the trade- 
off could mean an increased productivity of the land, the water 
table and improved health of the ecosystem. 



324.3 



4. Wildlife habitat is an important use of all public lands and one 
that conservationists support. Wildlife has proven itself to be a 
large attraction to visitors to Wyoming as well as residents for 
consumptive as we 1 1 as non-consumptive use- Photographers, hunters, 
hikers, birders and f i slier s are regular users of Wyoming' s BLM 
lands and yet the preferred alternative does not reflect those 
demands . The BLM must manage beyond Wyoming Game and Fish herd 
objectives and look at ways to provide the necessary forage for the 
diverse game and non-game species in the GCRA . Many of the wildlife 
populations in the resource area are impacted by the severe over- 
grazing, the high road density in certain areas, and the excessive 
logging. Allowing for wi Idl ife population expansion "where 
appropriate" or "to the extent possible" as stated in the preferred 
alternative is not representative of the ecosystem management the 
BLM has proposed. 

Crucial winter range is the deciding factor to the survival 
and longterm health of all wildlife species. We support the 
condi t ions of Alternative C in this case rather than simply 
protecting the crucial winter range of a few select species. 

5. Mineral development of sensitive lands has been demons trated to 
impact the surface and subsurface values of the resource area. We 
recommend Lotal hardrock mineral withdrawl of sensitive areas Euch 
as the ACECs, WSAs, and cultural resource sites such as Legend Rock 
in perpetuity. 

Oil and gas leasing has been indiscriminate on BLM lands 
around the state with an average of 9556 of all available lands 
leased. This is not multiple use management, this is 
industrialization of the nation's public lands. Such a high level 
of possible development would preclude other uses from taking place 
on those lands affected. Hydrogen sulfide gas has been a chronic 
problem on oil field production sites in the Bighorn Basin. H2s 
poisoned areas would mean that neither wildl ife nor people would be 
able to access certain areas of the GCRA. We support true multiple 
use management and therefore encourage the reduction of active 
leases in sensitive areas by retiring expired leases as they come 
up. An inventory of the crucial winter ranges, ACECs, high density 
recreation sites and cultural resource sites would provide the BLM 
with a representative way of deciding which areas to withdraw. 

6. Cumulative effects analysis (CEA) should be an integral part of 
this analysis and yet so many of the sensitive resources on the 
GCRA would be impacted. We consider a CEA essential to the future 
management of the Grass Creek ecosystem. 

With the Geographic Information System now available, the BLM 
is able to overlay the resource inventory with condition and needs 
to determine how best to manage these resources in the future. We 
encourage the BLM to take advantage of this technology to allow the 
best decisions to be made for the ecosystems. 



324.4 



7. wilderness Study Areas and wild and Scenic River review should 
have more direction for what will be the future management of the 
areas affected in the event that Congress doesn't designate such 
areas. In particular, we consider that the WSAs should be managed 
to protect their wilderness quality even if Congress does not act 
to designate them as wilderness. In addition, the Upper South Fork 
Owl Creek should be recommended for National Wild and Scenic River 
status. We reviewed the criteria and disagree with the decision 
made by the BLM that the Upper South Fork Owl Creek not be 
recommended to the National Wild and Scenic River System. The South 
Fork Owl creek's spectacular canyon country would be a welcome 
addition to join the Clarks' Fork as one of Wyoming's Wild and 
Scenic Rivers. 



In concl us ion , we encourage you to 
seriously and include these recommendat io 
on the environmental analysis. 



consider these comments 
is in your final decision 



Meredith Taylor ' 
WY Field Representative 



■ ■ — .- DBAJT ■ . 

B2AVEKHEAD KATIOKAi FOBEST 
1992 



324.5 



O-TUIENT AS OF 6/2/92 
2WTKCOUCTI0H 

Kalor emphasis is being placed on riparian condition* in relationship Co 
livestock grazing nation-wide, Th* Beaverhead Rational Forest Flan addre»«ed 
the relation Iniportinca of riparian >mu. Ho««v«, forage utilization wu Cb« 
only criteria identified that wu assigned quantifiable standards. Monitoring 
iinc« the plan was completed in 19B6 has Identified that streasnbank stability, 
stubble height, and condition of palatable browse apocioa appear much MOT* .„. 
critical to riparian health and function ;rhan forage utilization. • ,_. 

OBJECTIVE 

Objective of these guidelines is to address screaobank stability, atubble 
height (vegetative cover) , and palatable brows • utilization in meaningful, 
MwunbU terms chat meets goals and objective* specified in Chapter II of tha 
Forest Plan. 



Review of available information, and on the ground application, and monitoring 
indicates that streambank stability, stubble height remaining after livestock 
are removed from an allotment and the growing season ends, And use on palatable 
browse species, In addition to forage utilization, are all critical to 

restoration or maintenance of riparian values. 

The following guidelines are provided. Jhey are not designed to achieve the 
riparian condition that might theoretically exist in the total absence of 
grazing by livestock or wildlife. Thav recog nise that there are trada-offs 
incurred when grazing occurs in riparian ■exe-aa . Composition and density of - — 
plant 'species may change. Streaabenks will be Impacted, Individual stroaoo 
also have a natural level of instability that is char ao tori stic of that system, 
independent of grazing pressure. 

These guidelines are designed to be used' in those instances where impacts of 
ungulate grazing are being evaluated on riparian areas. They can be applied to 
both llvefitock and wildlife. Xeep in mind the dynamic factors present in 
nature, Vegetation will change over time, depending upon diaturbance factors 
such as fir* frequency, weather, other uses, and natural succession, ** veil—as — 
pazing pressure. Impact of all factors ;must be considered through 
interdisciplinary interaction when evaluating existing, potential and desired 
condition. . 



XA, 



Desired future condition,nust be based on site specific evaluation. JJor^ 
t riparian area can be located alonr^alaost any stream, or alonfc a nearby 
'aeream'vrth s jailer charactorlstics^th ac will h elp indicate what the desired, 
future condition" should be for the area in Question . Base specific standards 
on what Is necessary. to achieve tha dosirea 1 tuture condition for the area In 
question. ' ' ,. ..':_!_,. 



397 



324.6 



Guidelines presented here are professional estimates of actions necessary Co 
achieve Forest tl*& Goals and Objectives; Coals and 'objective* arc paramount. 
These guidelines, as applied to address sito specific needs, must be monitored 
over time to ensure they are' meeting forest Plan objective* relating to 
riparian function, va.ze.-c quantity and quality, fisheries, vegetation and othar 
Lssues and concern*. 

Size of the individual areas of concern muat bo determined from site specific 
evaluation. Riparian arose on cha Beaverhead normally relate no llnisr ■ 
distance along a straam, or to large meadows related to high water tables and 
cold air drainage. Minimum size recommended for consid eration in normal 
^lrc^flstaacas la 1A ailo of .tre^ lapgtK or 5 acres of meadow. Document 
£oc'u»rs that load to decisions based on bth«r vise*. Small areas are common 
within essentially all livestock grazing allotments ■ where impacts arc obvious. 
These impact* normally relate to livestock croeslngo, or "traps" immediately 
adjacent to fences. If these areas are located only in isolated instances, do T 
not base total allotment management on this disturbance. If they are critical I 
to naet objectives, then protect them fr-on animal use by fancing or other 
means. Opportunity or need to 'deviate from the guidelines Specified below nay 
also bo identified on a site specific basis during interdisciplinary 
discussions, jw-iiTPPnt the reasons for making those decision* in National 
Environmental Policy Act evaluation. . ■ ,_ , \ . 

CuTPELIMES : ■[ _ '"'__• 

Slto specific guidelines will be prescribed to meat Specific Issues and 
'concerns identified Through the Interdisciplinary Process for all allotments 
during evaluation and development of AliotKontj- Management Plane, In general, "* : , 
chase guidelines will incorporate the following as a minimum: 

streahb&MK stabili.T^ ': Sank stability la critical to.. ntaincain or Improve - ■ — ■** 
riparian condition. Iho importance of 5-traambank stability relates to existing 
condition,, specific factors unique to that stream, and desired future 
condition, Riparian areas Heading special consideration (ie- highly sensitive, 
or those with sensitive fish or plant species, current condition relates Co 
heavy past abuses that need to b* corrected as soon as feasible, sensitive 
soils, etc) will require less' streanbank damage to achieve desired future 
condition than tho»c that appear leas sensitive (is- those with common . _„ . 

vegetation, conunon or no fish present, stable soils, etc.)- Use guidelines ■'fe'i- 
researched by David' Rosgen in estimating the amount of streambank that should ■ 
be stfible'under normal, ungraded conditions. Use cha following guidelines as ' ^ 
the basis for decisions, depending on riparian sensitivity: 

High sensitivity: Allow no Bore than 10a streaabanls disturbance above whet ,_--: 
occurs nat ura 1 ly . " - y$l 

Moderate sensitivity: Allow no -more than 25<k .streajrbank-dlsturbance ab ove' ' '^~u 
what occurs naturally. . """* ' ~~; 

Low sensitivity: ■ Allow no mora than frO» atrearobank disturbance above, wha t 
occurs naturally. 



STUBBLE HEIGHT: The height of standing herbaesoua vegetation remaining v^bQH- «r 
the flood plain at the end of the livestock (traj O aB ■e.n nr* " r r wt F season. ; 
wbio hayer ends last , "will protect soils and straambanks during exposure to high '' 
flows , " and ' filter out sediment and build straafflbanles over time. In this 
instance, the flood plain should relate to the area that la anticipated to be" 
flooded during normal high water, up to J5 year events, 

High se nsitivity: Maintain 6 inches of stubble height at the end of the 
saason. ; * -t"«*y." 

Moderate sensitivity! Maintain at least 4 inches of*ntubbl» height *t,?he '.' 
end Of the season. _ ..... , .. ",' ,' 

' Low sensitivity; Maintain at least 3 inches of stubble height at Iche end 
of the season. $ u£ 

fifiOUSE UTILIZATION: Control of utilization of woody species is critical to the ' 
gcnaral health and regeneration of plants such as willows, aspen, dogwood, etc. ' 
Woody vegetation procecca riparian areas. from strDambank trampling, protects 
soils, provides cover important, to fisheries values, and has important wildlife 
values , Information indicator that use exceeding 40e will prevent Improve ment 
ia the condition of woody vegetation, and ponr condi tion plants may not respond 
lf_ u»e exceeds .20% . Interdisciplinary review will identify if the sit*. Is 
actually capable of supporting woody vegetation, and assign the percent. of use 
to be considered »e the and of the livestock grazing season. Additional 
monitoring is required before plants initiate growth the following season to 
evaluate additional browse impacts by wintering wildlifo, We may need to work 
with KDFUP to reduce wildlife number* if- that use is- identified as tho limiting 
factor. Additional action, such as use of prescribed burning, may help 
stimulate regeneration end condition. ,, . . _. . 

Qnnrf re ndition woody Vegetation (751+ of standing stoma are living, 
"hedging" is not readily evident) : Allow up to a total of 40» utilisation 
on annual growth by livestock and wildlife. 

Fair Condition .Woody Vegetation (50-75% of standing stems era living, 
. "hedging* affects are evident) : Allow up to* a total of 30* utilization on 
'annual' growth by livestock and wildlife. 

■ Poor. Condition Woody Vegetation flesa than 50* of standing stem are 
living, "bttdging" effect* «ra prevalent, with umbrella shaped shrubs 
common): Allow up to a total of 20* utilization on annual growth by 
livestock and wildlife. ' 

HONIToaiNC AND MODIFICATION '■' , . 

Monitor the grating system whllw livestock are using each pantura. Mov* the a 
when an y an? -of r>1 » ">"""■ ■"•tfnT^ \j, r eached. Hormal.ly, one of the above 
criteria will -surface, na. the determining factor for a l lowable use in each ' 
pasture or allotment, . 
factors mc -uti lize 



-Che 5BBT 



:'be attai ned If you wait until all 



-Establish permanent transects, to evaluate condition over time. Use 'the 
Beaverhead National Forest approved Riparian Phot? Point transects to noi 



the response of key elamants, auch a* width/depth ratio, amount of under£}tj?4.8 

banks', etc, ever time.,- Use eoodat* .plot* to monitor the response of riparian 
vegetation. ■ . 

The 75* atreaabank stability,. 4 inches b*? stubbl*. height, etc, ar* noni coring - 
cools, not objectives. If monitoring identifies, that Forest Plan and 
.it,. specific objeotivaa are not -being mot under the prescription developed 
under the, intardiscip linary process, Chan you need to. back off more (ie-use 90% 
s-treastoenk stability instead of 75%, etc'.). If, over time, conditions laprpve 
to aeVc these objectives, and the desire la to oaintain it at' that condition 
rather than Improving^ it,j you may ..be. ablo to back off slightly. MonitoringTiB 
the';k>yv If things-are aovinR towa r ds- "ofejacclves, ■ y ou are usJng the rlgh£ 
oanagamentt If you see a downward trend or can't determine an upward tread 
over' time, then you' n»ed. to manage for leas impacts!. ■ _.,- / 



*f E .;i» 



-r- ,: 



C/O Bob Ross 
Creek Area Draft SIS 
dox 119 
WOrland Wy 8240^-01.19 
Fax (.10?) 347-E195 

I object to the significant financial inpacts to businesses, 
individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend chat a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments . 

I appreciate the opportunity to contribute to the very important 
Grass Creek: Area Environmental Impact Statement . Please find my 

comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be cleariv 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass "reek area RMP. Return all wild animal management to tha 
State Came and Fish, and return all managed animal production to 
the Private sector . 

I object to the data collection procedures cited for AUM 

utilisation, and suitability. This should be completely redone. 



nt of land considered for suburban 



I object tc the smal" 

expansion. 

I object tc the lack: of discussion about impacts to the value of 
private, state and county lands by the various alternatives . 
Especially those imbedded with the KUW Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our commur.itiea through taxes. 

I object tu the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives . Not enough 
emphasis has been placed on new technology and new information CO 
mitigate and reclaim any impacts- 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

I Cif-Road 



398 



325.2 



I object ~o che small consideration giver. Cc the economic impacts 
"o businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

Z object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstanfi a ted Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



^^£^iM£ , 




326 



Tc BlM C/0 3ob Ross 
Sr«S9 Creek Are.i Draft FI$ 
r Dox 113 
Horlond Wy 82*101 -0119 

Fax (307) 347-6195 

I object to the significant financial iiipacts to businesses,, individuals (and 
consequently to the tax base), and the effecLetl counties and communities due to 
restrictions proposed within all of the alternatives, and recommend that a new 
preferred alternative be created with the help of knowledgeable Luitiiiurii Ly 
individuals and representatives from grazing, recreation, uil and gas and 
minerals industry, timber and Total and state governments . 

i appreciate the opportunity to contribute to the very ifflpurUflL Grass Creek 
Area trw irurimenul Impact Statement. Please find my comments below. 

I object to the reduction u r Grazing AUHs proposed in the Alternatives Real. 
current scientific data should be used to make management decisions on each 
allotment Targets Should be clearly established and stated. 

I object to the expansion of "Wild Horse Management" areas, t recommend 
e'lijiinating all "Wild Horse Management" areas in the Grass Creek area rmp. 
Return all wild animal nidridyanent to the State Game and Fish, and return all 
managed animal production to the Private sector. 

1 object to the lack of discjssion about impacts to the value of private. 
state and county lands by tne various alternatives, especially those Imbedded 
with Lne BLM Administered lands. 

1 object to restrictions that hamper the current primary businesses and 
individuals who use federally administered lands to generate income and 
support our communities through taxes. 

1 object to the severe and undue number and level of restrictions on Surface 
Disturbance in all of the alternatives. Not enough emphasis has been placed 
on new technology and new information to mitigate and reclaim any impacts, 

I object to the bias for recreation disturbance and the bias against 
minerals, grazing and recreation. 

I object to the proposed blanket restrlct'ans contained 1n Off-Road Vehicle 
Management. 

I oDject to the sma'l consiceratiDn given to the economic impacts to 
businesses and also tax bases Beneficial impacts or businesses should alsc 
be factored in. 

I object to the lack of detailed descriptions for restrictions 

1 object to the discission of th-eatened, endangered and candidate wildlife 
species, specifically unsubstantiated Gray Wolf inferences, and Prairie dog. 
Blflnk'J-ooted Terret Inferences. 



HUE BftUING FARMERS TEL :3U7527-F.056 



May 0<T'J5 13:53 No. 002 



m-im 



Webster Ranch Company 

72 RD 3KD 

Meeteetse . Wy . 82433 

Kay 4, 1995 



327 



sob Rose, RMP Team Leader 

Borland BLM Office 

P.O. Box 119 

norland. My. 82401-0119 

Dear Mr. Soasi 

Webster Ranch has been family owned and operated since 1900 and has 
three grazing allotments in the Grass Creek Resource Area. Through it's 
directors, Webster Ranch objects tc several issuc3 contained in the Reaouree 
Management Plan Draft Environmental Statement (DEIS) for the Grass Creek 
Resource Area ■ 



IS general, the DEIS "preferred alternative" is an effort to shift the 
D-ior"CV of use for public lands from that of livestock, mineral and timber 
industries to wildlife. These industries car. and have co-existed 
success: u~_ly with wildlife over the years and provide the tax base with which 
the surrounding communities, including Meeteetse, rely upon. Local culture 
and customs are not being taken into account and will obviously be negatively 
aftected if the "preferred alternative' of the DETS is enacted. It is 
imoossible that a projected 32V increase in tourism (which itself is 
tin! 1 kely) will offset the loss to local economies that the "preferred 
alternative" would cause. According to the BLM definition of s£g£X £Z£R 
management. , "social and local economic well beir.g" must be taken into 
account . The "preferred alternative" of the DE'S does not fulfill this 
reeu i rement . 

As for the alternatives given within Table 2 of the DEIS, 71* of the 
statements for comparison read "same as preferred", giving an inadequate 
range of alternatives in which to choose (in violation ol the National 
Environmental Protection Act). Even Che alternative described as "current", 
by reducing authorized grazing by 301, does not reflect the current 
situation. Why when by the BLM's own studies the majority of allotmonta ore 
341 fa'-r to excellent condition (table 3-4) would a 30% reduction in grazing 
be required? 



Other npricific areas of opposition to the 



Di : ;. 



are i 



sedlmen 



1. Designating the Fifteen Mile Watershed an Area of 
ical Environmental Concern (ACEC) because of 
a-ion to the Bighorn River (p. 1S1) 



The BLM should not be able to create & defacto wilderness area, with 
similar restrictions as wilderness arca3, without congressional consent. The 
fifteen Mile watershed contains 900 square miles and the majority^ of _ grazing 
land used by Webster Ranch within the Crass Creek Res< 



rea on ACEC < 



uld severely lii 



lurCe Area. Designstinq 
of Webster Ranch allotments. if 



DHvL BALLING FflRMERS TEL :30??27-5056 



May 04'95 13 : 54 No. 002 P. 02 

327.2 

creating a AC3C for the entire area would only reduce sedimentation by IV, 
why penalize allotments that are properly managed? 

2. Effects of the DEIS on Livestock Grazinq 

Much of the wording in the "preferred alternative" is ambiguous and can 
be interpreted differently. For example, what is the definition of "poor 
vegetative condition" Co. 36)? 



The suitability data used 
grazing has been deemed by 



or the proposed reduction in authorized 
BLM itself as unreliable and invalid, 
therefore, table 3-5, Appendix 3 is inaccurate and should not be included or 
used in the final Resource Management Plan. The proposed 35% overall 
reduction in authorized grazing h*s no justification except in specific cases 
and only when subjective criteria i3 used. Total Webster Ranch allotments 
are projected to be cut by 1364 AOKs or 37% (Appendix 3, p. 253-254). ADM 
availability is the basis used for appraisal and long term planning and must 
not be reduced based or. invalid criteria. 

3 . overall Wild Horse Management Objectives 

The "wild horse" herd with the Grase Creek Resource Management Area 1b 
not a true wild horse population. The ancestors of these horses were 
domestic turn outs or runaways. They are more detrimental to public lands 
than properly managed livestock, why should the SLM be allowed to spend IS 
million dollars, take an additional 2300 AUMs from livestock and double their 
habitat area when an authentic wild horse herd resides in the Pryor Mountains 
100 miles away? 

In closing, if Che preferred alternative ie enacted as is in the DRTS, 
it would be catastrophic to the families and economies within and surrounding 
the Grass Creek Resource Management area. Also, any changes to livestock, 
mi neral or t imber usage on pubi ic lands s hou t d be based upon sub j ec t ive , 
accurate data with the cer.mil nation of local, county and state organizations. 
Please take these comments into account for the final Resource Maaageaest 
Plan. 

Sincerely, 



Dan Webster, President- 



l Webster, FT 



Gene Webster, Vice President 



Charles Webster, Secretary 



Governor Jim Geringer 
Representative Barb Cubir. 
Representative John DeWitt 
Senator Alan Simpson 



Brian Webster, Treasurer 



Senator Craig Thomas 
Dick Loper 
Ed Webster 



399 




i (V-m i{ Jjttj^. LmI> 



328 



u I 



T/Ui'j', 



May 1, 15"?= 



Bob Ross, BLM Lesoer 
F'.D.B. 119 

Worl and, WV 32401-01 19 
FAX! 307-347-6195 

Wt licive fuiluwtiJ tlit reports in the Vesper S-T arid cither sources 
rnntprni ng your* Grass Crct?\? Resource Area ManjigRinpnt PI an DEIS. 
We've read that the area i e cornpri sed ot either 1.5 or 1.8 
itii 1 1 i on JtrBb and that you propose to upei. all of it for oi 1 and 
gar. leasing and intensive grarinn because vciu feel MiCh -jh action 
1 s requi red by 1 ah or i ntent of Congress. 

However , wt? ' ve al so read: "By 1 an, mul ti pie use i nr 1 urie^ much 

more than just mining, grazing, timber i_uLLing, Ii mineral 

dewel opment . As def j red hy CnnQro's, mul ti pi P-use Includes non- 
ej; tr di_ t i ve uses such as protetti ng & manaqi n<j wildlife habitat, 
maintaining healthy S> functioning fisheries, protecting water 
qual 1 ty & water shtds, provi ding nppartuni tiac far education & 
scipnti fir research, recreation, fc aesthetic values, h preserving 
jinportont historic h cultural resources. " 

Somet i mes huir>ans come onl y =.1 owl y to acfcnowl edging new real i t ies. 
We wor li hard to construct a framework of comprehension and then 
find it suddenly has become obsolete while our attention was 
el tewhere. Last century we bt>l ieved ne had too few peop] i_- and 

i imi tl ess 1 and and natural r esuur i_ii^. Dtvtsl upnieti t was patriotic: 
failure to extract resources was wa""tpfi.ll- 

But then-eiisti ng development te 
the conversion of roost. of the 
owner shi p by Jef f er soni an smal 1 t ft 
thi* day, it's more prof i table for 
zed rates than 



inolDgy rpnrlprpij uripi ofitdble 
federal laudt. into private 
ners or entrepreneurs. And to 
-esource— users on pubi ic lands 

to lease at subsidized rates than to pur chase, inai ntain, and pav 

property tasies. 

So it happened that ownership of the federal lands was retained 
by the American people. But mi e our lands being managed for the 
long-term benefit o* the 7.Z0 * million owners and their heirs, or 
for the short-term highest prof 1 1 of special , of ten corporate, 
i ntfTlttl? Hast y S> short -si gf\ teri management deci sions have led 
to th» dammina of rivar-3 without Honest accounting of true costs, 
to the degradation of riparian corridors, to the wasteful uoe or 
pa! lutlon uf pr klilus water , and to development that creates a 
multiplicity of roads destructi ve to wildlife habitat. 



328.2 



Please help maintain bi odi verst tv. Please help insure that the 
native plant '■.pRrip-; needed to sustain native animal species will 
be preserved. Please help provide the required solitude And 
protection needed by these native animal species. 

— L'ontrol the Sprawl D -f mineral deve] cipment ; 

— Prevent, random DRV r oad-maki nej; 

— Protect water quality h riparian corridors from over- 
grazing. 

Please offer the strongest passible protection (by placing off- 
limits to mineral development) to: 

— the three ACEC"*.: Upper Uwl Creek, Me^teetse Draw Rock 
Art Area, & Fifteenmiie Creek; 

— the three potential NNL'sr Tatman Mountain, Cast Ri dge- 
Fi+teen Hrppk Badlands, & Gooseberry Badlands; 

— the potentially eligible S. rork of Owl Creek as a Wild 
!< Scenic river; 

— the four WSA'si Red Butte, Bobcat Draw Badlands, Sheep 
Mountain, fc Owl Creek. 

At this time you h*ve the power and opportunity to protect one 
portion of F,arth (the only planet we've got) for only the 
immediate future - the next lO to 15 years. Prospects for the 

more distant future are depressing. But that is not a valid 

excuse for abdicating responsibility. Pleaco look to long-term 
sustainable resources rather than short-term quick profit at any 
cost of degradation. Please don't take the attitude that you'll 
be retired and living somewhere else, and that it's your 
replacement whu will have to wrestle with problems that have been 
allowed to develop. 

The ideal of sustainable resource on Public Lands has numerous 
vocal opponents: many in the agricultural community and mineral 
i ndu&tr y , other I oes of f ederetl government and regu ] at i on , group s 
who feel that God will intervene any day now and repair any 
damages that might impact adversely Upon the chosen. Wise 

management on your part wi 11 ultimatel y benefit al 1 of these 
interests — and all of the rest of u«i ton* 

Si ncerel y. 



jCcc *- vZe^A+wJUxMlZL*^ 



Leo h. Rose 



329 



May 4, 1995 

Mr. Bob Ross 
RMP Team Leader 
P.O. Box 119 
Worland, WY 82401-0119 

Mr. Bob Ross, 

This letter is to opose the Grass Creek REsource Draft Land Use Plan. I believe it is the 
gradual encroachment of the rights of the citizens of Wyoming, and would cause serious 
problems for the economy of the entire Big Hom Basin, not just the livestock people that 
have gracing permits in the area. 

I do not beleive Wild horses shold come before people. T think the fifteen mile herd should 
be cut down to fit their present range or better yet should be eliminated altogether. 1 do not 
believe oil and gas exploration should be curtailed in any way. 



Sincerely 



/s/ Chester Mercer 
xxxxxxxxxxxxxxxxxxxxx 



WK-5B66 



330 



ttl EAUOf IAN0 HMIMEttHt | 



Hay 4. 1995 



Bureau of Lard Management 

C/'O Bob Ross 

Grass Creel: Area Draft EIS 

P.O. Box 119 

Worland, WY 82401-0119 

Pax (307) 347-6195 

Mr. Ross: 

I appreciate the ooporLuniLy to contribute to the very important Grass Creek 
Ared Environmental Impact Statement. Please find ny comments below. 

I object to the significant financial impacts (both direct and through 
reduction of the tax base) to Businesses, individuals, and the affected 
counties and comnunities due to restrictions proposed within all of the 
alternatives. J recommend that a nw preferred alternative be created with 
Lhe help of Knowledgeable private individuals and representatives from 
recreational groups, local and state governments, oil and gas. minerals, 
grazing and timber Industries. 

I object to the reduction of Grazing AUMs proposed In the Alternatives. 
Real, current scientific data should be used to rake management decisions on 
each allotment. Targets should be clearly established and stated. 

I object to the expansion of "Wild Horse Management' areas I recommend 
eliminating all "Wild Horse Management" areas in the Grass Creek area ftKP 
and returning all wild g<wie and non-game animal management to the Wyoming 
State Game and Fish department 

I object to the data collection procedures cited for ADM utilization, and 
suitability. This should be completely redone. 

1 object to the small amount of land considered for suburban expansion. 

1 object to the Tack of discussion about impacts to the value of private, 
state and county lands by the various alternatives. This is especially 
important for those lands surrounded by BLM administered lands 

! object to arbitrary restrictions that will hamper the current primary 
businesses and individuals who use federally administered lands to generate 
income and support our communities through taxes. 



400 



fW 05 '95 37: IS J 



330.2 



Mr. Bob Ross 
May 4. 1995 
Page 2 

I object to the severe and undue number and level of restrictions on Surface 
Disturbance in all of the alternatives. Not enough emphasis has been placed 
on new technology and new information to mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias against 
minerals and grazing. 

I object to the proposed blanket restrictions contained in the Off-Road 
Vehicle Management plans. 

I object to the small consideration given to the economic impacts the 
Alternatives would have on businesses and the area's tax base . Beneficial 
Impacts of businesses should also be factored in. 

I object to the lack of detailed descriptions for many of the restrictions 
which may be imposed. 

I object to the discussion of threatened, endangered and candidate wildlife 
species, specifically unsubstantiated Gray Wolf inferences, as well as 
Prairie Dog and Black-Footed Ferret inferences. 

Finally. I believe 1t 1s Imperative that more consideration be given to 
fostering the economic well being of the residents in and near the Grass 
Creek Resource area and that less emphasis should be placed on natural 
resource preservation issues championed mostly t>y those who have little or 
no vested interest 1n the area. While all Americans are truly the owners of 
these public lands, few directly depend on them for their livelihood. This 
is not to say that we who prosper through the use of these resources wish to 
see development at any cost in terms of damage to the resource. We only ask 
that reasonable access to the resources be allowed and that reasonable 
regulations be applied which reflect the technical and economic realities of 
today and recognize that the resources found on the public lands can be 
utilized without undue damage. 




ELM C/0 Bob Ross 

Grass Creek Area Draft Els 

P.O Box 119 

Worland Wy S2401-0119 

Fax (307) 347-6195 



Kir -5 Kb 



331 



I object to the significant financial impacts to businesses, 
individuala (and consequently to the tax base) ,and the effected 
counties and communities cue to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with, the help of Knowledgeable community' individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

L appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions on each a": lot-merit . Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas. 7 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
t.he Private sector. 

T. object to the data collection procedures cited for AUN 
utilization, and suitability. This should be completely redone. 



land considered for suburban 



I object to the small amount 
expansion . 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the HLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 

I object to the severe and undue number anti level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and Lhe bias 
against minerals, gra2ing and recreation. 

I object to the proposed blanket restrictions contained in. Off-Road 
Vehicle Management. 



331.2 



I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discuBsion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



O^Jdtyb 




To HLM C/O Bob Rcss 

Grass Creek Area Draft ! 
P.O Box 119 

Worland Wy 824C1-0119 
Fax (307; 347-6195 

I object Co Che significant financial impacts co businesses, 
individuals (and consequently tc the tax bass), and the effeccsd 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
reoresen.tatives from grazing, recreation, oil and gas -and minerals 
industry, timber ar.d local and state 90verrjr.sr.ts . 

I appreciate the opportunity to contribute tc the vary important 

Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used tc make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

I cbject to the expansion of "Wild Horse Management » areas. 1 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game ar.d Fish, and return all managed animal production tc 

the Private sector . 

I cbject to the dats collection procedures cited for AU>1 
utilisation, and suitability. This should be completely redone. 



332 



tne sma__ 



land considered for subu 



I object to the lack of discussion about impacts to the value of 
private j state and county lands by the various alternatives . 
Especially those imbedded with the ELM Administered lands. 

1 object to restrictions that hamper the current primary businesses 
and individual a who use federally administered lands to are 
generate income and support our communities through taxes. 

2 object to the severe and undue number and level of restrictions 
on Surface Disturbance in all cf the alternatives . Not er.cugh 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 



i object 



the bias 



sn disturbanc 



bias 



I cb;ect to the pro 
Vehicle Management 



401 



I abject to the small consideration giver, to the econotrii332 ct 2 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of derailed descriptions for restrictions. 

I object co the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie doc- Black-footed ferret inferences. 



^ 



ijrn 



%M 



ELM C/0 3cb S.oss 

Grass Creek Ar=£ Draft E 
= .C Box 113 

Wcrlsnd Wy 02-G1.-O11S 
.-ax [307) 347*5195 



(KT-5 19',', 



333 



.cia. impacts tc businesses, 
be :a:( bass), and Che effected 



I ooject to Che significant 

individuals (and consequently 

counties and communities due to restrictions prccosed withi; 

Che alternatives, and recommend that a. n«W preferred alternative be 

created with the help of knowledgeable community individuals and 

representatives from" grazing, rscreatioa, oil and gas and minerals 

industry, timber and local and state governments, 

I appreciate the opportunity to contribute: to Che very important 
Grass Creek A^rea Environmental Impact Statement. Please rir.d my 
conmer.es below. 

i object tc Che reduction of Grazing AuMs proposed in the 
Alternatives. Real, current scientific data should hi usod tc make 
rr.snc.gerr.ent decisions on each allotment. Target^ should he clearly 
established and stated. 

I object to the expansion of "Wild Horse Managament" areas. " 
recommend elirr.inating ail "Wild Horse Mar.agarrie.it" areas in the 
Grass Craek area P.MP . Return all wild animal management to the 
State Game and Fish, and return ail managed animal production to 
the Private sector. 



icn, and suitabi 
: to the small 



cue ehj 

of land considered Cor 



T object tc the lack cf discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the 5"_M Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered land3 to are 
generate incoma and support our communities through taxes. 

I object to the severe and uncU^ number and level cf rsscricticn.s 
on surface Disturbance in ail of the alternatives - Not enough 
a:t-c'ir.zs~$ has been placed on new technology and new in format icn to 
minigac-a and reclaim ar.v imcacts . 



I object to the bias fcr recreation disturbance 
against minerals, grating and recreation. 



t.ie 



I object tc the prcccs 
Vehitia Hanaqsment , 






I object to the small consideration given to the economi333ic2 
to businesses and also tax bases . Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black -footed ferret inferences. 



£ pQ;f+/-^ui a± uLL 



I RECEIVED 
war- 5 895 



334 



To 8LH C/O Bob Ross 

Grass Creek Area Draft 
P.O Box 119 

Korland Wy 82401-0119 
Fax (307) 347-6195 

I object to the significant financial impacts to businesses, 
individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a now preferred alternative be 
created with Che help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

I appreciate the opportunity to contribute cc the very important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object tc the reduction of Grazing AOMs proposed in Che 
Alternatives . Real, current scientific data should be used to make 
management decisions on each allotment. Targets should be clearly 
established and stated. 

.1 object cc the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Kcrse Management" areas in the 
Grass Creek area RHP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production tc 
the Private sector. 

I object to the data collection procedures cited for MJM 

utilisation, and suitability. This shculd be completely redone. 

r object 
expansion 



the small amount of land considered for suburban 



1 object to the lack of discussion about impacts to the value cf 
private, state and county lands by the various alternatives. 
Especially those imbedded with the 3LX Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands tc are 
generate income and support our comirur.icies through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Hot enough 
emphasis has been placed on new technology and now information to 

mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, grazing and merest ion . 



T object to the proposed blanket restr 
Vehicle Management. 



tticns contained : 



402 



334.2 

I ocjsct: to the small consideration given no the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



Jjz^ yt&J Jr. 



tvlUCEIVEP 



'LIS 



uQH&o] Gulch Coal Company 



335 



Box 653 Powolt, WY8243S 



Mr . Bob Ross, Team Leader 
bureau of Land Management 
Norland Mttrlei Office 
P.O. Bo* i i l J 
Worlaad, WyowiiuS 62401-0119 

RE: Crass Creek Resource k\ 

U'jur Mr. Kusai 

First, we acknowledge that rctsc-t 
or enhance their viability and i 
beneiit. MaiiflgeiueuL uiusl seek t 
will provide for the long term e 
: fcdcr; 



; to 



'■i imniin i. l 



I Management Plan DKIS < 



so doing all The multiple users o£ the area will 
gain the greatest return from those tusources that 
ntlnuation of the economic stability in the area, 
gOvarmMRE, State of Wyoming, counties and local 



i of the dot 



Hid the Preferred Alternatives presented for the most part 
do not give a positive direction to the majority of multiples uses except for wildlife 
and sage grouse-. In Sect the direction of the proposed plan indicates that if the 
Preferred Alternatives arfi all accepted* the Crass Creek Keaource Area will experience 
substantial economic losses, particularly the ail £ gas industry und livestock industries. 

The plan dons not follow your comments (page 8) " The principles of ecosystem managecen r , 
used in BLM'a day to day management o£ the public lands and resources, include recognition 
that praople and their social and economic need are an lntetral part of ecological systems." 

The cahle on page lso(table 17) indicates the forage available for livestock in the 
preterrc-d alter native ah.OVS.nt a 25S reduction of authorized grazing with a corresponding 
25% reduction of active preference and a whcpplnp, /i_2X reduction from the actual use of 
19D0. How does this show the recognition of the economic need of the people when you 
propose to eliminate lb% of the grazing? How can the Statement (page 160 preferred 
alternative) "Craai:i£ use would be adjusted BE a constant rate during the analysis period, 
teaching anticipated levels as activity plans are implemented." when there is no supporting 
documentation to justify the reductions! The reductions proposed indicate that all 
allotments fire targeted tor reduction when. In fact, soma have already had substantial 
reductions, also there has beer, recent changes in management programs designed to increase 
grass production on chose allotments for the benefit on not, only the operator, but the 
wildlife and environment ss a whole. 

The proposed plan as stated above will only provide a slow death to many at the smaller 
operator*, communities, businesses and people residing in the resource area. If Current 
Hindi tions indicate ttiefle reductions arc necessary, it needs to be mad? known "up front" 
at this time rather than small reductions each year over the next 15 years! 



Spring Gulch Coal Company 



335.2 



ens 



:n be 



Please- cur-lain why the Wild Horse Herd 
your personnel are unable to manage this hard as the'/ should i 
the perm.jte.es to maintain their livestock within their allot™ 
trespass if they do not, and yet, for your agency to he able i 
yni; just expand the area! This seems to be in conflict with ; 
'tteria than your permittees. There Hoes not appear 



ny 



fri 



the pn 



aiun. 



Bos 653 Powell. WY 82435 



thcr than the fact tha 
naged. Van require 
and are cited for 
tinge their "wild horse 
operating under difrer 
-c benefit to the publi 



beinp. proposed on the Oil £ GftS industry arc excessive! 

l.t.y reduce revenues throughout the. resource, area 
ch in turn will cause substantial economic losses to community, business, county 
•erwneiits, state governments and even the federal government. Lt is apparent that the 
se conditions in your, leases cover the concerns within the resource area without hnvit 
i proposed additional restriction of "No Surface Occupancy or Controlled-surf ace ust." 

: final decision on the timber aspect of the EIS should be changed to allow a larger 

ves of timber which you state la "flfi % mature." A. wt«a use of the timher product 

to harvest the crces, using current methods such aa selective cutting, that will alio' 

■ new growth, wildlife protection and maintain the economic base ot the ares. This is 
in - win situation rather than restricted proposals listed !u the plan. 



'1te management nepds to he expended and 
;re#toient per year than the 500 proposed 
lubstantially lees that the averape troa 
nil not even control the 
her year. It is ironic th 



rion would exceed proburn level 
for age production , and bi ological dlv. 



C-r number of acres cor.sidere.d lor fin 

is alarming to loam that your proposa: 

wev*g« treatment of the past 10 years or so. The 500 a< 

roaohment of limber pine and juuiperfpage 196) oi 1900 ; 

(also page 196) "Within three years, herb* 



grasj 



Vntxr 



nt limited to 
of th Si 



■ £ei 



-iU 



^cres? 



repl , 

would imp ri 



Is. nenerally, 

Why then ! 



■"&- 



rx.t^.U, 



ouae papulation 1a Well founded, however, If someone would 
ie real issues of! why the population is not recovering they would find chat the 
result of the decline is not because of UvfistncJ* grazing bui there has bean a substantial 
increase of laudators in the resource area. There is no pjLatl identiiied in tlie F.TK 
that addresser, predator control, in fact, it appears there is a willingness to increase 
predators, (page 201) " The Northern Rocky Mountain Crey Wolf is not anticipated ro 
establish packs within the planning area. But if packs were formed, the protection of 
big name animal by Seasonal limitations would b«n«£lt tile wolves by preserving their t-tpv." 
Would nor rhese wolves also prey on the sagt grouae population and therefore be subject 
to some type of a control plan? 

Consideration of building a road up the fifteen mile creek area re view the wild horsua 
is nor a realistic decision. The road would have to be built in an area of critical 
euvriot-.mental eancern and would need to he an all weather road. The soil type In the 
majority of the area ia not favorable to roads, especially when there ts a little hit of 
moisture. How do you pioposfl m police the off road travel in that area when there so 
many mile* of highly irrodnble soils? 



Spri ng Gulch Coal Company 



335.3 



Box 653 PowbII. WY 82435 



Mr. Ross, it appears the majority cf the proposed "Preferred Alternatives" give direction 
to a more restrictive multiple use without adequate consideration of the negative 
economic impacts that are being created by r_he proposals that will restrict the Oil f, Gas 
Industry, Timher harvesting, Livestock grazing and the customs and culture that has 
been developed in this area from the early 1890's tu the present. It appears that the 
multiple ueere in the resource area are not being considered a part of the "public". 

The direction of the plan appears to be in conflict with your statements that the area is 
presently functioning fairly well. Therefore it 1s rer-(?mmenr!ed that the plan as it is 
presently written be revised to provide a more positive, direction that will at least 
maintain the various multiple uses that are identified at the levels indicated in L990. 



I.f '-hese recommendations are incorporated it will provide I 
the citizens, businesses, industries and various government 
resource area. i believe the Bureau has a rcGnonsibil try i 
1* not diminished in any manner below that identified in tl 



i U ed : 



%^..f.-/Jd(L< v- 



403 



BLM C/0 Bob Ross 
Grass Creek Area Draf 
?.0 Box 119 
Norland Wy 82401-01 
Fa^c (307) 347-S19S 



RECEIVED 



m~st 



336 



X object to the significant financial impacts to businesses, 
individuals (and consequently to the tax base) , and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledge able community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments . 

I appreciate the opportunity to contribute to the 
Grass Creek Area Environmental Impact Statement, 
comments below. 

I object to the reduction of Grazing AUMs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions en each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" araas. I 
recommend eliminating ail "Wild Horse Management" areas in the 
Grass Creek area RM? . Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

Z object to the data collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 

Z Object to the ■mall amount o£ land considered for suburban 
expansion. 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded "with the BLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use rederally administered lands to are 
generate income and support cur communities through taxes. 



I object to the severe and 'undue number and level c 
en Surface Disturbance in all of the alternatives 
e-phasis has beer, placed on new technology and new 
mitigate and reclaim any impacts. 



: object to the bias for 
against minerals, grazing 

; cb'ac- to the proposed bis 
Vehicle Management. 



recreation dis t urbane 
nd recreation. 

Jest restrictions ccnta 



restrictions 

Met enough 

formation to 



and the bias 
;d in Off-Road 



336 2 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



-Iw/W /% 



£&g4&£~- 



337 



To KM C/0 Bob Ross 

Grass Creek Area Draft SIS 
P.O Box 119 

Worland Wy 624G1-C115 
Fax (307) 347-5155 

I object to the significant financial impacts to businesses, 
individuals [and consequently to the ta;-: baseband the effected 

counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 

industry, timber and local and state governments . 

1 appreciate the opportunity to contribute to the vary important 
Grass Creek Area Environmental Impact Statement. Please find my 
comments below. 

I object to the reduction of Grazing AXJHs proposed in the 
Alternatives. Real, current scientific data should be used to make 
management decisions cr. each allotment. Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management" areas, Z 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RM3. P.scum all wild animal management to the 
State Game and Fish, and return all managed animal production tc 
the Private sector. 



object to the 
ilization, and su 



collection procedures cited for AUM 
ity. This should be completely redone. 



I object to the small amount of land considered for suburban 
expansion. 

I cbject to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the currant primary businesses 
and individuals who use federally administered lands to are 
generate income and support cur communities through taxes. 

I cbject to the severe and undue number and level of restrictions 
on Surface Disturbance in all of zha alternatives . Net enough 
emphasis has been placed on new technology and new information to 
micigata and reclaim any imoaets . 



e^e 



to the 



bias f< 
grasi" 



■ recreation disturbance 
and recreation. 



j:d the bias 



cb;ect to the propessd blanks 
ehicle Management. 



ictiens contained 



337 2 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Black- footed ferret inferences. 



-I^?z- 



/%n 



404 



RECEIVED 




338 



To SLM C/O Bob Rosa 

Grass CTfteJC Area Draft SIS 
9.0 Box 119 

Worlaasfi My 82401-013.9 

F»X (307) 347-6195 

I object; to the significant fir.ar.ci3I impacts to businesses, 
individuals (and consequently to the tax base) , and che effected 
counties and communities due to restrict Lens proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with the help of knowledgeable ccmrau.ni.ty individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state goverr.ir.er.ts . 

I appreciate the opportunity to contribute co the very important 
Grass Creek Area Environmental Impact Scacemenc . Please find my 
comments below. 

I Object; to che reduction of Grazing ACJMs proposed in the 
Aitsmacives. Real, current scientific data should be used to make 
manacatr-ant decisions on each allotment. Targets should be clearly 

established and stated. 

I object to the expansion, of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management " areas in the 
Grass Creek area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 



cbject 



to 



the 
and su 



data 
.tabil: 



col 



etion procecures cited 
This should be completely 



for AUM 

rscor.2 . 



suburban 



I object to the lack of discussion ab-ouc impacts to the value of 
private, szace and county lands by the various alternatives , 
Especially those imbedded with the blm Administered lands. 

I ch;eco to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income and support our communities through taxes. 



I object to the severe and undue number and 1 
or. Surface Disturbance in all of the altem 
emphasis has been placed en new technology an 

mitigacs and reclaim ar.v impacts. 



3 the bias Jar 
serais, grating 



r-craaticr. 



vei o" restrictions 
elves Net enough 
new Information to 



bar.ee and the bias 
cncal.ned in Off-Road 



nic jSipac CI 



I object to the small consideration, given to the econc 

to businesses and also tax bases. Beneficial impacts of businesses 

should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I abject to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Cray Wolf 
inferences, and prairie dog- Black-footed ferret inferences. 



339 



To BiM C/C Bob Ross 

Grass Creek Area Draft EI? 
P.O Box 113 

Borland Wy 32401-0119 
Fax (307) 347-6195 

I cbject to the significant financial impacts co businesses, 
individuals (and consequently co the tax baseband the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a new preferred alternative be 
created with che help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and state governments. 

Z appreciate che opportunity to contribute to the very import anc 
Grass Creek Area Environmental Impact Scatement . Please find my 
comments below. 

1 object tc the reduction of Gracing AjMs proposed in th« 
Alternatives. Real, current scientific data should be used to make 
management decisions on each allotment . Targets should be clearly 
established and stated. 

I object to the expansion of "Wild Horse Management'' araas . I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area RMP . Return all wild animal management to the 
State Game and Fish, and recum all managed animal production to 
the Private sector. 

I object to the data collection prccedures cited for AUM 
utilization, and suitability. This should be completely redone. 

1 object to the small amount of land considered for suburban 

I object co the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded "with the BLM Administered lands. 

Z object to restrictions chat hamper che current primary businesses 
and individuals who use federally administered lands to are 
generate income and support cur communities through taxes. 

I object to the severe and undue number and level of restrictions 
en Surface Cisturbar.ee in all of the alternatives. Net enough 
er.pr.asis has been placed en new technology and new information to 
mitigate and reclaim any impacts. 

I object to the bias for recreation disturbance and the bias 
against minerals, gracing and recreacicn. 

I object tc che proposed blanket restrictions contained in Off-Road 
Vehicle Management. 



I cbject to the small consideration given to che econorrutc^W.prfc'r? 
to businesses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack, of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dog- Slack-footed ferret inferences.. 



( yjjXX^^ \_ Jbo-r^i/s 



405 



BfcM C/0 3cb Ross 

Grass Creak Ar=a Craf: 
P.O Sox US 
Worlaad wy B24C1-011 

Fax (307} 347-6IS5 



RECEIVED 



■51995 ! 



K4@ 



I object ta the sicr-.izica.it: financial irc.'ca.czs tc busir.esses, 
individuals (and consequently to the tax base) , and the effected 
countlas and conrnuzutieA duo zo restrictions proposed within ail oS 
the a:r.ertiAtive9, and reccrrmencl that a new preferred altemacivc be 
created with the help of knowledgeable ccrrjr.--L-.ity individuals and 
rsoresar.tatives from grazing, r»crea*. Lor., oil and gas and minerals 
industry, timber one local and stats governments. 

I appreciate the oppor~ur.i_y to contribute to the very important 
Grass Creek Area Bnv±recn»n.e* T Impact Sr.aterr.er.::. Piaass find my 
conw.eats bslcw. 

I object to the reduction of Grazing A"Ji-*s proposed in r.he 
ftlcesrmtivM . Real, current scientific data should be \i*s-i to make 
managenant decisions on each allotment. Targets should be clearly 
establrshud and statsd. 

: cbject co the expansion of "Wild Horse Mar.ac'iT.er.c" arsas . I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek area BMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 



to the data collection procedures 
fl, and suirabilizv. This should be rjnmp 



cad for ACM 



: ebjece to the 5~all a-cur.t of land considered for suburban 
expansion. 

I object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives . 
Especially ihuse imbedded with the elm Administered lands. 

I object to restrictions chat hamper the current primary businesses 
and individuals who use federally administered lands to are 
generate income arc support our communities chrough taxes. 

I object to the severe and undue number and level c-f restrictions 
on Surface Disturbance in all of the alternatives . Net enough 
er.cr^sis has been placed on new techr.alcgy and new infomation to 

mitigate and reclaim any impacts . 






: to the bias : 
minerals, grasi 



recreation disturbance and the bia 



I ob;ecc to the proposed blanket 
Vehicle Managemenr , 






I object to the small consideration given to the eccr.omi3*r l t « , 2 
to busir.esses and also tax bases. Beneficial impacts of businesses 
should also be factored in. 

I object the lack, of detailed descriptions far restrictions. 

I cbject to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie deg- 3lack-focted ferret inferences. 





SM*! qs 



341 



Hr, Bob Rogg, Teaii Leader 
Bureau o[ Land Management 
Vorland district Office 
P.O. Box 119 
Vl«*lnnd. Wyoming 82401-0119 

R,E. Grass Creek Resource Ai 



i Management Plan - D.E.T.S, 



Hue quality of life found In tin; 
nc to the eitiaens of Wyoming and 
lands must be flexible, founded ( 
□vide for the naxiraum economic 



Dear Hr . Rosa : 

Management of Oiir public lands and the un! 
Grass Creek Resource Ares are very Import; 
the Public. Therefore aansgement of thoe* 
valid research, broadly considered, and pi 
return for the Public. 

The DEIS that is printed doea not provide the conel deration of sustaining the 
area at the present level of economic activity, custom, culture, livestock 
grazing, oil and gan development, recreation and timbering. Therefore I 
Ptrnngly urge you to reconsider the DEIS and provide the following in the finul 
draft: 

1. Allow increased timbering to utilize the existing 861 nature forest 
timber, utilizing various methoda including selective cutting that will 
allow the maximum monetary return En the Government and local communities, 
wildlife protection and other recreation . 

2. Expand the use of fire treatment in the entire resource area to a 
minimum of the average fire treatment of the past 5-10 years. ( approx- 
imately 2000 acre*.) 

3. Maintain the livestock graaing AUH'S as they are presently authorized for 
both the permitted Bum's and actual use listed for 1990. Manage 
individual allotment on their own basin and not as a vhole if there is a 
problem. You state " In general resource conditions on public lands In the 
planning area, including range vegetation, watershed and wildlife habitat 
are not the result of livestock grazing alone and are not in a state of 
such poor condition or downward trend that they cannot be maintained or 
enhanced or that would warrant elimination of livestock arazing on 

public lands." Therefore, the proposed reductions of AUM's Is NOT 
WARRANTED ! Every effort should be made to keep ranching viable in the 
resource area. 



must have a more clearly defined designation 
program for violations. The present plan 



Off Road Vehicle oanagi 
and have a strong anfoi 
does not address thin issu 

, A predator control program must be developed and implemented for the 
resource area which considers livestock, wildlife and human bclngti. The 
program must consider the safety or the multiple users, and If 
necessary the predators should be removed or eliminated. Without such 
a progrso It will be almost Impossible to expand the bird populations in 
the resource area. 



341.2 



md gas industry in 
It appears the Ho 



6. The unreasonable restriction placed On the ell ; 
the preferred alternative should be eliminated. 

Surface Occupancy and Controlled Surface Uae are not warranted a* 
these concerns are already covered by your standard lease agreement. 
Theme restrictions have an extremely severe impact on the economic 
stability of the area and affects revenues for the federal government, 
State of Wyoming and individual businesses and industries of the four 
counties involved vd th this resource area. We need to provide Jobs 
not eliminate them! 

?. Consideration and comments attempting to create roor Wilderness 
without congressional consent is in violation of current laws; 
attempting to do so by declaration of the Areas of Critical Environ- 
mental Concern (ACEC) should be stricken from the docuitanc. 

fl, TheTQ is no valid reason to expand the Wild Horse Herd, which la now 
coating the taxpayers over $13 million dollars to administer Che 
program per year. Your management should be to maintain the herd at t! 
level of 100 hnrBes as stated in your 1989 summary, building roads 
Into the area rhat is of such special environmental concern and 
expanding the number of horses is not a wise use of tax moneyl 

9. Adequate alternatives have not been provided. 712 of the statements 
comparing alternatives all read "Same as Preferred." This is in 
violation of the National Environmental Policy Act(NEPA). 

Mr. Ross, the DEIS as published is a clear attempt to reduce multiple use, 
particularity timbering, oil 6 gax development and livestock grazing. 
These are industries that provide significant revenues to Che entire area and 
the Government, By your own agency statement "the area is functioning rather 
well." Therefore, Mr. Ross it should be your responsibility to develop a plan 
that maintains the resource area, that provides for enhancement of all 
multiple ubps and cot the economic degregation and disaster that the present 
plan proposes. 

Please provide details of hov you propose to incorporate these suggestions 
i:itu the plan and bring some reasonableness to the DEIS. 



y/fu^uuA^ 




406 



Hff-51995 



T; 8LM C/Q Bob ROSS 

Grass Crssk Area Draft E: 

?.0 3cx 115 

tfcrlaad Wy 32401-011? 

"ax (307) 347-5195 

I otoj«ce U the significant financial impacts co businesses, 
ir.civicuals (and consequently to the tax base) , and cha effected 
ewmeies and cocnmunifcias due to restrictions proposed within all of 
the alsaraacives, and racoRBTtend that a new preferred al-emative be 
create wich the help of Iciowledgeabi? comrninity individuals and 
rp.Drasfintacivss from" grazing, rscreaLion, oil and ca3 and minerals 
industry, ti.mb«r And local and staca gcverr.r.ants . 

I aoprac:iaz= the opportunity to contribute tc eh 
Grass Creek Area Environmental Inpact Statement. 
comments below, 

1 Object to the reduction ot" Grazing AUMs proposed in the 
A."_terr.£tivss . Real, current scientific data should be used to rr.ake 
managartwnc decisions on each allotment Targets should be clearly 
established and seated. 

I ob-iect CO the expansion o; "Mild Horse Management" areas. I 
recommend eliminating all "Mild Horse Management" areas in the 
Grass Craek area RM3>. Return all wild animal cnaaagaraenc to the 
State Gam* and Fish, and return ail managed animal production to 
the Private sector. 

I object to the data 
utilization, and auicabili 



342 



Co the sn-.al 



land considered 



expansion 



Z cb-5C" to the lack of discussion abcut impacts to the value nf. 
private, state and county lands by the various altamatives. 
^specially those imbedded with the 3LM Administered lands. 

I object to restrictions that hamper the current primary businesses 
anc " individuals who use federally admi n istered lands to are 
Generate income and support cur communities through taxes. 

Z object to che severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Wot enough 
ertDfcasifl has been placed en new technology and new information to 
mitigate and reclaim any inpacts. 



bias for recreation disturbance 
, crazing and reersacicn. 



trv; 



bias 



ject tc t'r.3 proposed blanket 
cle Xanaqement . 



iCticns C".--ined in Cff-Road 



342.2 



I object to the small consideration give to the economic impacts 
to businesses and also tax bases. Beneficial impacts to business 
should also be factored in. 

I object to the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog- Black-footed ferret inferences. 

/s/ Trenton D. Thull 

To Whom it may concern: 

I really do not understand why these changes include people 
other than Wyoming residents, and Frankly there is no sense in 
having wildlife reserves, if nobody is allowed to observe the 
wildlife. Wyoming is a beautiful state, and all the changes you 
propose, would change the face of Wyoming forever. We might as 
well not even have wildlife if nobody can view it. 

Sincerely, 

/s/ Trenton De Wayne Thull 



>r- 



HAY-5! 



O ™T O 



IVHJUt Of IAKD HMMESf :« ' j 



Worland ULM 
BobHo*. 
RMPTe.im leader 

Bon 119 

Woibmd.WYS24t.l-i 



Hvlnsedm 



11 ihc Giass ("reel; Rwwuiao Area Plan 



The WildemeSJ M Aw ttOl suit thai surrounding areas need 10 manned fur bOPMd 0D designated 
Wilderness Rata. Wiftrw. areas should be anal^ed for US imp** on surrounding areas 
| mittcnuw" include il.e decease in wldJ.fc haWm. the to of prodwuvnv. and H* loss of bic^mm 
d„ e .0 nMfcauM K*^ ^on TM Wldcnm Art to. om MU thai bufier .real are wM«ry Tta 

ACn»H Limitation fol dStlflWltad Wflderncss provided n budl in buita If people are dnaiirtjcd from 
lunmmnflfl ROiM llBji need Have ibe aHeniaUvA to locate to the interior of the designed WHawaew 

In !he EA. it appears ihai the BLM has chom its *«nion. and prov.ded oruj the evidence ihai suppons 
the" preferred direction 

Wtan in me uuty* an new tuehnoiogiei pmBaifuj andwomtota. ewwems addnwid? The nuln» H 

v«v weak .11 provid.i* m ..pttiie in icchuolofciLi, u. benrfll* Fro... mdu.lrj w.«l.« throuBhW U« 

plasoing poewi Btftn nsftlsg UW Bi»1 doeiatoB, currcm twtuxdojKs and ll«« effictj need to he 

analysed This should alsu be prodded in a lupplcmem and ICvlOWOd 0) Uic pubbc 

Tbe soaryiui .s vc n - W* M provdiug a.. aoqiHWae BN^IS M nrrounduit eouw.es. com.nuiul.es and 
mwiiod* pnmm Thai "too vsto » bo prowtod with the aouirtw pnrt.apci.ng mthc soirJ ualyid 

Curre,,. WV ^"""^ ;l " :lh5,S IV KlS, ' d ,,| * ,,, lh!0, > n °' rC!,i "' Ca *°° C0 "'" > f"! * 
,,„„, „ „|t 1 ISPS ..u.,1 H-wwin-c dnrtopiiiian doll..r, and fomid luat the econuiln. -imL-nn, of the ii\ 

it more dep«Ktoni upon Federal lands Om Bw »fttmcy hnd onpoally drtwaod. Piotl decia.ons need id to 
made bmed upon solid economic iwpoSB 

II II OBfonmUO Iba so mueh lilW r.nd POnqi ha^ hcor, spent 10 prodi.ee a doc,r.>eni tbM reflects the 
l-,,c £« «*or .to- « fu.il ...n,e ,1 „np,em=nnWe ,nd J^r.es. alinnaUva Prior to the BM pkOM 
SS * tevdopini nddn.nni.l .UoRUttiVOI WDJCh arc viaWo. .utplcmeotable and provide mam.er.a.KC o» 
turrent couiniodui prududioil 



j Fliu/crka 




344 



2 May 1995 



Dear Worland BLM • 



This letter is on the Grasscreek Resource area. 

I feel that there is a clear bias against grazing. The Preferred Alternative reduces it by 25%. 
Is that much necessary? It also violates NEPA. It has a very wide range to choose from us 
[sic] many reading "same as preferred. 

i don't think we need any more wilderness areas or ones managed as wilderness. I belive we 
need to use the ones that we have more. 

People are part of the ecosystem. We need to remember that when we talk about loss of 
revenues to the people & economy. 



Please consider this letter. 



Sincerely - 

ft! Tonya Tysvcr 



407 



345 



2 May 1995 



To the BLM - 



I am writing in regard to the Grass Creek Resource Area. 

I believe that we have enough wilderness areas now. I don't agree that motorized 
vehicle have a negative impact but I also don't think we need more areas managed as if they 
were wilderness. 

Technologies in any multiple use industries from which the enviroment benefits need to 
be given credit when its due. 

We need to keep in mind the people are part of this earth. We need consideration of 
what the loss of revenue to the counties will do to the People & economy. 

I hope you will consider this when you make your decision. 

Sincerely - 

/si Albert Tysver 




346 



May 3. 1995 

Bob Ross 

BLM Team Leader 

P.O. Box 119 

Worland, WYS2401-0119 

Dear Bob, 

I would like to lake the opportunity to comment on tilt Grass Cretk Management 
Plan. 

la my opinion: 

1. The South Fork of Owl Creek should he eligible for a wild and scenic river 
designation. 

2. The study area does not need more or improved roads, but the roads that are 
there should not be closed. 

3. TheTe should be a way of protecting the area from off-road vehicle abuse, the 
BLM should find a way lo prosecute offenders, there should be a way other than just 
closing the roads. 

4. The 1872 Mining Law needs revised before anymore mining leases are given. 

5. The proposal to allow oil and gas leasing on every available parcel of land should 
be discouraged. Some leasing might be necessary but not a wholesale give away. 

6. Riparian habitat should be protected and improved at all costs. Wildlife habitat 
Improvement should be the primary goal, not cattle grazing casements, The cattle and wild 
horses have done a lot of damage to this fragile ecosystem and these numbers should be 
greatly reduced. 1 would like to see the BLM and Wyoming Game and Fish work more 
closely to improve wildlife habitat. 



(7 9 / 

^James A- Milck 



SU-l CO Bob Ross 
Grass Creek Area Draft = 
e.o 3ox IIS 

Wcrland Wy 83401-0119 
Fax (307} 347-5132 



RECEIVED 



MAY-5B86 



BUREAU OF UND ■ANAGEHENT 



347 



Z abject to the significant financial impacts to businesses, 
individuals (and consequently to the tax base) , and the effected 
counties and communities due to reetrlcLions proposed vichin all of 
the alternate vas, and recommend that a new preferred, alternative be 
created with the help cf knowledgeable community individuals and 
representatives from grazing, recreation, oil and. gas and minerals 
industry, timber and Local and stats gcverrments- 



I appreciate the opportunity t 
Grass Creek Area Environmental 
cccements below. 



contribute to the very important 
Impact Statement. Pleis* rind my 



I object: to the reduction of Grazing A"_"Hs proposed in the 
Alternatives . Real, current scientific data should be used to make 
management decisions or. each allotment. Targets should be clearly 

established and seated. 

I cbja-cr to the expansion of "Wild Horse Management" areas , I 
recommend eliminating all "Wild Horse Management" arecs in the 
Grass Creek area RK? . Return all wi Id animal management to the 
State Game and Fish, and return ail managed animal production to 
the Private sector. 

lercicn procedures cited for A'JM 
This should bs completely redone. 

z object; to the small amount of land considered for suburban 

expir.sim.. 

I cbjaco to the lack of discussion about impacts za the valus of 
privets, state and ccuncy lands by the various alternatives . 
Especially these imbedded with cha BLM Administered lands. 

I object to restrictions that hamper the current primary businesses 
and individuals who use federally administered lands co are 
generate income and supper" our communities throuch taxes. 



I object to t.ie severe and undue numoer and 
en Surface Disturbance in all of z : '.e alt! 
exph.ee is has been placed on new technology 
mitigate and reclaim any impacts. 

t object to the; bias fcr recreation dis 
against minerals, grasing and recreation.. 

I cb;eci to the proposed blar-ke;; restriction 



estricticns 
Jior. enough 
oraiatior. ;.a 



347.2 



I object to the small consideration give to the economic impacts 
to businesses and also tax bases. Beneficial impacts to business 
should also be factored in. 

I object to the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog- Slack-footed ferret inferences. 

)s) Connie J. Thull 

Please let me know why people from out of State who probably 
haven't even heard of Grass Creek, Wyo. Should be allowed a say 
in what goes on in our land, I realize it is goverment owned, 
but realistically how many of them will ever come out to see it 
or really care? Seems to me they keep trying to tell us whats 
best for our land and they have never heard of Grass Creek Wyo. 

)s) Connie Thull 
xxxxxxxxxxxxxxxxxxxx 

XXXXXXXXXXXXXXXXXXXX 

xxxxxxxxxx 



408 




348 



Mr. Bob Hobs, Teeun Leader 
Bureau of Land Management 
Worland District Office 
P.O. Box 119 
Worland, Wyoming 82401-0119 

H.F. Grass Creek Resource Area Management Plan - D.E.I.S. 

Dear Mr. Ross: 

Management of our public lands and the unique quality at life found 
in the Grass Creek Resource Area are very important, to the citizens 
of Wyoming and the Public Therefore management of those lands 
must be flexible, founded on valid research, broadly considered, 
and provide for the maximum economic return for the Public. 

The DEIS that is printed does not provide the consideration of 
sustaining the area at the present level of economic activity, 
custom, culture, livestock grazing, oil and gas development, 
recreation and timbering. Therefore I strongly urge yau to 
reconsider the DEIS and provide the following in the final draft: 

1. Allow increased timbering to utilize the existing 66% 
mature forest timber, utilizing various methods including 
selective cutting that will allow the maximum monetary 
return to the Government and local communities, wildlife 
protection and other recreation. 

2. Expand the use of fire treatment in the entire resource 
area to a minimum of the average fire treatment of the 
past 5-10 years. (approximately 200 acres) 

3. Maintain the livestock grazing AUM'S as they are 
presently authorized for both the permitted aum' s and 
actual use listed for 1990. Manage individual allotment 
on their own basis and not as a whole if there is a 
problem. You state "In general resource conditions on 
public lands in the planning area, including range 
vegetation, watershed and wildlife habitat are not the 
result of livestock grazing alone and are not in a state 
of such poor condition or downward trend that they cannot 
be maintained or enhanced or that would warrant 
elimination of livestock grazing on public lands. " 
Therefore , the proposed reductions of AUM ' s is $QT 
WARRANTED I Every effort should be made to keep ranching 
viable in the resource area. 



348.2 



Off Road Vehicle management mu3t have a more clearly 
defined designation and have a strong enforcement 
program for violations. The present plan does not 
address this issue! 

A predator control program must be developed and 
implemented for the resource area which considers 
livestock, wildlife and human beings. The program 
must consider the safety of the multiple users, and 
if necessary the predators should be removed or 
eliminated. Without such a program it will be 
almost impossible to expand the bird populations in 
the resource area . 

The unreasonable restriction placed on the oil and 
gas industry in the preferred alternative should be 
eliminated. It appears the No Surface Occupancy and 
Controlled Surface Use are not warranted as these 
concerns are already covered by your standard lease 
agreement. These restrictions have an extremely 
severe impact on the economic stability of the area 
and affects revenues for the federal government, 
State of Wyoming and individual businesses and 
industries of the four counties involved with this 
resource area . We need to provide jobs not 
eliminate them! 

Consideration and comments attempting to create more 
Wilderness without congressional consent is in 
violation of current laws; attempting to do so by 
declaration of the Areas of Critical Environmental 
Concern (ACEC) should be stricken from the document. 

There is no valid reason to expand the Wild Elcrse 
Herd, which is now costing the taxpayers over S15 
million dollars to administer the program per year. 
Your management should be to maintain the herd at 
the level of 100 horses as stated in your 1989 
summary . Building roads into the area that is of 
such special environmental concern and expanding the 
number of horses is not a wise use of tax money 1 

Adequate alternatives have not been provided. 71% 
of the statements comparing al ternatives all read 
"Same as Preferred." This is in violation of the 
National Environmental Policy Act (NEPA) . 



Mr. Ross, th 

multiple use, 

livestock grazing. These are industries that provide significant 

revenues to the entire area and the Government. By your own agency 



DEIS as published is a clear attempt to reduce 
particularly timbering, oil & gas development and 



348.3 



statement "the area is functioning rather well." Therefore, Mr 
Ross it should be your responsioility to develop a plan that 
maintains the resource area, that provides for enhancement of all 
multiple uses and not the economic degradation and disaster that 
the present plan proposes. 

Please provide details of how you propose to incorporate these 
suggestions into the plan and bring some reasonableness to the 
DEIS. 

Respectfully, 



ijOayr^ </^3^T 



Lt! SHEEP COMPANY dba 



m-5sm 



c0>^^: 



RECEIVED 

MICHAtLVT.MUWk . ^<11 E**? 

— . Q IE 

wSWSujJDMSiGiiaiT 

— T307] 347-2002 • Bo> 699. Worlard, Wyoming B2401 



349 



May5. 199? 

Mr. Dob Ross. Team Leader 
DuTeau of Land Management 
P.O.Box 119 
Worland, WY 82401-0119 

Re: Comments on the Grass Creek Resource Area RMP DEIS 

Dear Mr, Ross: 



i am going lo categorize my comments as coming primarily from two areas. First. 
I intend to deal with an issue which 1 believe has led to much of the criticism of the 
document; that is, the lack of a BLM policy to continually update its own policies and 
regulations. Second. I believe the BLM continues to lay groundwork to potentially 
challenge private property rights through the use of innocuous appearing policy contained 
in the document, 

There is no aspect of this work that threatens its success more than ihe fact that, in 
several areas, significant change is proposed. { This could be called the big bang 
approach. Only change your management document every 12 years and when you do, 
load all the changes you can think of into the new document,} lithe BLM had had a 
successful policy of communication, consultation and coordination with the public and 
the users of public lands since implementation of the 1983 Grass Creek MFP. mere 
should have been no surprises, and certainly no large change of policy, in this RMP. I 
believe this document should not be one of change, rather, it should be a compilation of 
changes implemented since the previous management document was written. I .ei me be 
specific. 

I, On page 66. the RMP proposes to expand the wild horse area by about 31,400 
acres, a .18% increase. Your previous management policy with this wild horse 
range has oeen to restrict livestock grazing to winter sheep. Even though your 
intent is not to change class of livestock and season of use in the expanded area, 
previous experience with the BLM indicates that such a change could be likely in 
the future. That being the case, this proposed action represents a significant 
change and should no: have been in this document. It should have been handled 
as an ongoing matter between users, the public and the BLM, 'I "his RMP would 



409 



349.2 



then have been the proper medium to reflect the change that could have been 
made previously. 

2. On page 190. the RMP indicates a 35% cut in grazing utilization. Ifihisis 
reflective of" current management policy, why has there been such an outcry? If 
this is new policy, it should not have been in this document Similar to mv 
previous observation, this issue should have been previously handled with the 
three C's, co mm uni cation, consultation and communication. 

3. On page 1 78, this RMP proposes to expand the "controlled surface use' 1 
designation lor oil and gas exploration by more than twice the acreage from 
previous polity (your current management numbers don't add properly, so I am 
making an assumption in my calculation). Where did this come from? Why 
hasn't the BLM told the oil and gas industry about this before? This ".-presents a 
failure of current BI.M management not tu have been addressing this issue on an 
ongoing basis. 

If the BLM had truly been trying to improve their own public land policies in the 
past, none of the three proposed changes above would have been necessary because Ihcy 
would have already been included in previous efforts by the BLM. The fact thai 
significant change is being proposed in litis RMP demonstrates that the BLM is not using 
the three C"s. 

The next logical question is what does this document contain thai offers a means 

to continuous improvement to the policies it contains. Woefully little. I'm afraid, i can 
find only one paragraph that defines that policy. On page 5, the RMP states "After 
completion, the Grass Creek RMP will be kcpl current through minor maintenance, or 
through amendments and revisions, as the demands on public lands and resources change, 
as the land and resource conditions change, or as new information is acquired." 

I think the BLM should expand and emphasize this policy in the RMP. The 
present language has the appearance of being obligatory without any intent to be followed 
later. This RMP would do well to include a section to this subject defining how process 
improvement will be accomplished with a focus on the land, the user and the public, 

With regard to my second concern involving private property rights, it appears to 
me that the RMP creates the aura of unnecessary win/lose situations in several of its 
existing and proposed policies. When there's an atmosphere of the BLM winning and the 
private property owner losing, 1 just can't believe much cooperation follows. The 
progress that the L.U. Sheep Company has made on its range has been through 
cooperation with the BLM as well as the Wyoming Game and Fish Department and the 
State of Wyoming. It was done with a win/win attitude, ll would have been difficult to 
do it otherwise. Again, to be specific to the RMP: 



349.3 



1 . On page II , the RMP stales 'Iherc must be public and administrative access so 
uses and management actions can occur." That is a policy statement and implies 
access through condemnation and that is win/lose. A policy statement on access 
should create some flexibility for the Bl .M to accomplish access on a win/win 
basis. 

2. On page 30. again on the issue of access, the RMP stales "BI.M would pursue 
a combination of motorized and rionniotorized vehicle access in theEnos Creek, 
upper Cottonwood Creek, and upper South Fork of Owl Creek areas." I'll make 
two comments about this quote. One, your response is likely to be lhat it is 
Current policy and is in the BLM's MFP. Well. 1 say the MFP has never gone 
through a public hearing process and a iol of your policy is now coming under 
scrutiny as il appears in this RMP. Two. although the BLM has shown no 
inclination to condemn access in these areas, the L.U. Sheep Company found out 
that it only took one U.S. Forest Service supervisor to, on his own, decided to 
enhance economic develcpmcnl near the Shoshone Forest and condemn our Grass 
Creek road for public access. The language on page 30 is threatening to me and 
that is what defines an win/lose situation. 

3. The expansion of the wild horse area previously discussed is a win/lose 
situation. There is threat of an eventual loss in grazing rights. 

I have now commented on what I see are the major deficiencies of the RMP. 1 
include now two lesser comments: 

1, Reference is made to the "Dickie" Allotment on the tables on pages 233, 239, 
and 262. The name of that allotment is in error and should be the "LIT 
Allotment. It is correct as presented on page 266. 

2. Table 3-4 in appendix 3 (Ecological Condition Class and Acreage) needs a 
comment. The area covered by this RMP is dominated by a fire ecology. I have 
been led to believe that the variation of plant composition of any site on the L. U. 
Sheep Company ranch is influenced more by when the site was last burned (or 
treated by chemicals) than by any other effect. An ecological condition 
classification only categorizes the variation of plant composition as a site evolves 
from a state of just having been burned to being in extreme need of burning i.e. as 
that site develops a heavy cover of sagebrush, juniper and limber pine. EcologfcaJ 
condition classes should not, therefor, include the adjectives "poor," "fair," and 
"good" because fire ecology is a natural process and doesn't really address the 
health of the range. Poor, fair and good carry' significant implecation as to the 
health of the land and that's not proper. The RMP's ecological condition table 
still uses those words when categorizing this time influenced process of change. 
More thought should he given to changing them. 

1 "hank you for the opportunity to comment. 



349.4 



Sincerely, 



/4& ^C- 



Mikc Mealy 



MRY 05 '95 10: Elfin I10C 30V5BVO343 




havs 



350 



Bob Ross 

ss Creek Area Draft EIS 
land. WY 32401 



inks for allowing the public to comment on this EIS- I have reviewed this 
nument and believe that the writers must he Isolationists or misanthropic 
to*ard their 'follow man'. How about Just allocating \}l acre per family of 
nutans and letting the rest of the U.S. revert to animal use only?7 Ridiculous, 
rltht? Well, I believe that your approach/directives toward the Grass Creek EIS 
Ana to be similarly absurd. 

I r sve worked the geology of the Grass Creek Area as both a development geologist 
anc an exploration geologist for the oil and gas Industry. Your directives 
tovard surface occupancy are short-sighted and will ultimately result 1n severe 
eccnomic failures for the people of this region. Not only will your directives 
cut tail/terminated future, nan-disruptive seismic acquisition In the area (and 
thereby curtailing future exploration), but it will also negatively Impact 
furjther development within existing field areas. 

Whij 1s It that the rest of the country struggles to adjust to environmental and 
societal changes while the offices of the federal government have decided to stop 
working with the constituents of the public domain? Granted, it is much easier 
to proclaim large areas of the public lands off limits to the public(thereby 
elimnatmg the very reason your office was created)- It is a much more 
difficult Job to listen to the desires of the public and make sound decisions 
bas>d on the facts at the time of need. Is the BLM scared of the challenge to 
mak3 intelligent. Interactive decisions? Perhaps since your elected bosses no 
lorjer listen to the needs of the public, you feel that the BLH office need not 
listen either. Leave lands open to the public sector. Do not let the abusive 
natjre of a few curtail the efforts and enjoyment of all. 

I uork for i very cyclical Industry and have seen many colleagues become 
-neiployed, due 1n part to increased governmental restrictions. This Industry 
'ery carefully watched in terms of environmental awareness. Any abuses of the 
t are not allowed to happen In today's climate. What are the real reasons for 
you£- non-use policies for the vast majority of the publics' land? Maybe you 
t drive a vehicle fueled by gasoline purchased by you, or drive on highways, 
oat your house, or pump your water, but I do. As a member of the public, I 
needs that your policies towards my lands do not best address. Perhaps the 
ce of the BLH needs to be more directly accountable to the people. ANY 
EST10NS? K y 



ild like to hear my specific suggestions as to the more problematic 
if your EIS study, 3 would be glad to voice them. As 1s, I cannot 
e present effort. 



if you wou 

:on lone the present effort 




410 



■w 

C/C 3cB Rooi 
Crasa Crook 
P.O. Box IV 

fax (307) I< 



I viah tc 

(5CAEIS). 

potential fc 
la at beat 
bean couiplo" i 
ara enploys . 



youi 



hAB-.H 



1 u» apecif 

cil ::,i gai 

Unit vtll 



Lose dli 
indiasii 

'.■mil BKhit 
ihaapherde! 

i.?j;ayor bui 

indication 



dollar blw 
paying, be, 



REC E \ V E D 



MV-5BS5 



351 



Xrea Draft e:s 

8240J-O119 



i naant on tha very important Oraae Creak Jii*ea Envii-onjoonta.1 Impact Statement 

: Isaac find ay comments bo low. in case theta ic any confusion, thin letter 

be critical of tha overly restrictive nature of this document, and itn 

negatively impact the entire eontnunity. Your job ao otcward of theoe land" 

ifiicuit; however, your parforvanca on this Mttor doaa not appear to hava 

o or raaponsive to the needa and concerna oC the eatixn puilic by whom you 

for dees your work port cad good things for the future as far aa the 

ral, and aeathetia viability of thia aroa. Tha football coach who eharea 

much firmer grasp of hia domain than you do o; youro. 

:ally against the land use rcctrictlona which I feel will unfairly burden the 
itiduazry. Aa far aa I can determine, elanst SOi of t -tier a 1 ly - attain:. □ torrid 
■a subject to new and Btringant rtitrlctiom u a reeult of your work. 

potential raatrlctiona nun v»g u « and without dot ail, and thus opan to 
?n (road: political down the road. Blanket raatrictione for off-road vehiclee 

acquisition of new data which nay lead to new drilling, aa wall as limit the 
nount an Exploration campaign without a huge incremental oont of doing 
idua aurfaee occupancy restrictions prohibit activity on lands leased by an 
r company regordlaGa of whether they are a prudent and conscienticua owner. 
-t for a producing lease is vary minor today eoepasad to tha past, and by law 
; Eonmantally responsible. Teehnolooy has created opportunities for lnee and 
■icii your. Moat unp.-oduotivg wallaitaa mora than a few yaazu old ua 

front the undisturbed flanking acreage. Many wellhead areas on producing 

it less of a profile than 4 highway rest stop, rural agricultural water tank. 

Liar, or beekeepers' bases. Furthermore, this surface uaa provides 

-bile landfl for all Americana without tha US* Of Federal tax dollars. My 

gats millions Df dollars in environmental spending eacn year, ouch of it 

lump our attitude and track record with those of paat offenders is an 

closed-mindadnaBa which must have pervadad during tha formulation of 



agencies make money for tha American people. The BLM ia in the 
nviabla position Of being able to aake money for the good of the country, 
rally managing the reeourceB for their ultimate economic and environmental 
policies of increasing the coat for discovering new hydrocarbon roaorvao, 
tha highest royalty ratoo of any other leasehold irt America [with the 
Indian lande), will suraly aoon tranaform your ugancy into another Federal 
hole while driving yat mora of our economy overseas and eliminating high- 
.a jabs for Americana. Kith anywhere from 60-80% of the tax base from many 
.ties derived from hydrocarbon extraction, the future for our area appaara 
en your CCASIS, unload somehow the carrying capacity for summer visitors sf 
allowetone Area can be expanded by an order of magnitude- "he OCABXS needs 
=h harder look at the potential, and grave, economic conditions whioh will 
: oeourcu-bcwaa induatrieu by publiahing this document in ita present form. 
will not only affect federal land, but all surrounding ianda to tha point 



asrily for all of the tenets of the currently fashionable, multiple i 
wsvemer-t , bdt that movement hae in part been fueled by the government ■ a failure 
itlngulah between relative impacts of uflcro of govtrnaenfc Lands. It also la a rnsn 
• the gcvarvnent'a failure to distinguish between reBponsible and irreaponslblo uoo: 
Rithor than individually asaeaf) iropaaLo and the need to control them, you hava chorion 



Again, plaa 



OS '95 03:3bfrtt HOC 3U' 7 Sfa7b34r 



351.2 



all res our co- baaed economic concerns and attempted to shut them ail out or 
amatrlng their operatlo.iB that economic viability Ifl impossible. Far this, 
iclentlet-politlCianB' are paid top dollar with no accountability ta their 
it* «i inyen, the American people. 

iroea and innovative thinking once nada the United Itates THI world leader. 

the thinking ia dona overseas, and you are attempting to make auuiy of our 

both renewable and nan - renewable, off-limits. Thia despite there 

rirontnentally conscious provisions to allow resource development by prudent 
The solution 13 not to raatrlct development, but to encourage it in a way 
factory to tha long-term well-being of the nation. It is in thia reepoct 
ency, and our government, 1q failing. 



aider thia com 
] opportunity t 






with 



iA 



03/07.'B5 10:10 FAX 1 3I>T H33 252i 



IN ElM, Lyrnan. prmnfynt • SHS Fl-T-ti SneVtU rml Vitr rr*,;d. 



RECEIVED 



MAY - 8 1995 



WYOMIN© 
STOCK GROWERJ 
ASSOCIATION l w ""» g ja D .sa Mt »"" i 

113 EAST 20TM STREET ■ P. O. BOX ^D6 
CHEYENNE, WYOMING 82003 



3S2 

TIT 



XX 



Phone 307-^.18-3942 
Fax 307-G3S-35Z4 



May 6, 1995 



XT. Bob Ross, Team Leader 
P.O. Box US 

Worlacd, Ky B2401-0119 



(307) 317-6195 



Dear Mr. Ross, 

The Hyoirir.9 stock Growers Association {W5GA> , which repre-entc 
over 1,500 ranching families in the etaze of Wyomixig, would like 
-o te*« this opportunity to conuat on the draft eis for the 
Grass Creek Resource Area in northwestern wyom.ir.g_ 

WSGA is not ia favor of a reduction in the number of A'JMs 
available for livestock grazing, as outlined in the BLM's 
alternative managamani. strategies. As a result., we find that 
none of the alternatives are acceptable, and would suggest the 
BLK consider a management altamaLiv e that does not reduce the 
number of aoms available for livestock grazing. 

for example, the preferred alternative would decrease forage 
available for livestock grazing about 35 percent and would place 
'temporary reductions in the amount of fornge available for 
livestock grazing" due to surface disturbances for a variety of 
-o.isono, and to meet desired plant community objectives for 
wilSlli*. habitat . 

Al-crr.aLive Ji would reduce the authorised grszina use by 30 
percent, which i» described further as a ".moderate reduction ■ 
Wc do not agree that this is a moderate reduction, but rather has 
a significant impact. Alternative 8 would reduce the authorized 
grazing use by 38 percent; and Alternative C would reduce 
authorized grazing use by 47 percent- As stated previously a 
reduction in grazing is not an acceptable solution! 

The Wyoming Stack Growers Association ii supporr-'ve of the 
multiple use concept, however these altemacivcs support multiple 
use la name only, not in principle. All of thft alternatives 
out-ined in the draft EIS will result ia a significant decrease 
ie ..he amount of authorized grazing use for livestock 



$*4K&4Ut of le/yomixp'o, gov fauttuf St*U£ ?8?2 



10:10 PAX 1 307 835 2524 



352.2 



livjsteA »at»r d.v eiop!r£nt:a . M indlMt J r S S T^S if "he 

SautZ S4ct B ="S^cIi i Son^ p01 ' llvesto< * «*«*«■ -« tta 

a ='"=>-(- on cne local economy, we suqqest the Bun ye 

S'u".^^ 10 ™ "* not decrsKe the S-* 3"aS5iS us. 

Sincerely, 

SiS3 y 0axr » tBi: »'-»eibal, Bxec-ative Director 
WYOMING STOCK GROWERS -ASSOCIATION 



411 



mx 05 '33 1S:4Z 




S3SS 



Bureau o£ Land Management 
Graoo Creek Area Draft BIS 
p. o. Box 119 
Norland, Wyoming 82401-0119 

fittn: Bob Roan 

Dear Mr. Robe; 



document . Hy 

I object: to the significant financial impacts to buGinecscG, Individuals (and 
consequently to the tax baae), and the affected counties and communities due to 
restrictions proposed within all of the alternatives, and recommend that a new 
pref err«d alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and gaa and 
minerals industry, timber, and local and statu governments. 

1 appreciate thi opportunity to contribute! to the very important Crape Creek Area 
Environmental Impact Statement. Pi cane find my comment ■ b»low. Any 
Environmental Impact Statement should be n balAncad review and consideration of 
the overall environment. Environment means tho ubolg , not just plants and 
animald. At present this draft is biased against people and their quality of 
life. Thio quality ahould bv moauured in jobe, taxes, ability to grow, raiaa a 
family and be able to ace those offspring live and work in the area. Aa auch, 
1 object to the following: 



*) 



the 



all . 



unt of land considered for suburban expansion 



the lack of discussion about impacto to the value of private, atate and 
county lands by th« various alternatives, especially thocc imbedded with 
the BLH administered londa 

restrictions that hamper the current primary businesses and individuals 
who uii federally administered lande to generate income and support our 
communities through taxes 

the severe and undue number and level of restrictions on Surface 
Disturbance in all of the alternatives; not enough emphasis has been 
placed an new technology and new information to mitigate and reclaim any 



353.2 



thw small consideration given to the eco 
also tax banes. Beneficial impacts of bui 



impacts to businesses and 
aea should also be factored 



t ) the reduction of grazing AUMs proposed in the alternatives,- real, current 
scientific data should bg used to make management decisions on each 
allotment, and targets should be clearly established and utated. 

In addition, I feel: 

1) The "Wild Horaa Manngnnwnt ■ are&a should not be expanded, but rather, 
eliminated in thia Grass Creek area RHP. Further, we should return all 
wild animal management to the State Game and Fioh Department, and return 
all managed animal production to the private sector. 



The descriptions for restrictions 



ot adequately detailed. 



s^jtSZ^/- 



4 



RECEIVED 



Mff-81 



3i4 



GUaabeth Q&tarer 




May 6, 1995 

Mr. Bob Ross 
BLM Team Leader 
P.O. Box 119 
Worland, WY 82401-0119 

Dear Bob, 

1 write to you today regarding the BLM's draft management plan for the Grass Creek 
Resource Area. Clearly, there are great pressures mounting on your agency to open up 
all lands to mineral development and commodity production in the short term. 
However, I believe it is imperative that the BLM consider the long term effects of such 
actions that would remove restrictions needed to protect wildlife habitat and fisheries, 
undeveloped recreational opportunities, cultural and historical resources and water 
quality. Doing so will protect Wyoming's greatest assets that are the keys to the state's 
economic future into the next century. 

Given the current congressional mood, 1 don't believe that designation of WSAs as 
Wilderness Areas is a priority that will find great support in the near future. In fact, it 
is quite possible that Congress will choose not to designate these areas as wilderness. If 
that proves true, under your draft management plan, these areas will be opened up to 
oil and gas development, hard rock mineral mining, road development And other 
conflicting uses. As these lands represent only 6% of all the public lands in the resource 
area and ana the only areas that provide a seoti-priiru'tivc wilderness experience, they 
should be protected from such development regardless of what Congress does. 
Otherwise, only a mere 9500 acres would be protected from development, less than 1% 
of the public lands in the resource area. 

! wholeheartedly support the draft plan's proposal for the three Areas of Critical 
Environmental Concern: Fifteen mile Creek Watershed, Meeteetse Draw and Upper Owl 
Creek. However, to truly "protect and prevent irreparable damage to important 
historic, cultural, or scenic values, fish and wildlife resources or other natural systems 
or processes", 1 believe these areas should also be placed off limits to oil and gas leasing 
and mineral development. 1 agree with your proposal to remove some areas from hard 
rock mineral development, but this effort should go further by assuring protection for 
the lands included in the WSAs and ACECs from such development A policy that 
turns lands into industrialized, single-use areas does not meet the requirements of 
multiple-use and sustained yield under which BLM must operate. As defined by 



354.2 



Congress, multiple-use includes maintaining healthy and func honing fisheries, 
protecting water quality and watersheds, providing opportunities for education and 
scientific research, recreation and aesthetic values, and preserving important historic 
and cultural resources. Protecting these areus will help fulfill this mandate. 

In addition, the BLM needs to provide greater protection for potential National Natural 
Laiidirtarks. These include the Gooseberry Badlands, East Ridge - r'ifteenmile Creek 
Badlands and Tatman Mountain. These areas should be protected from oil and gas 
development and hard rock mineral development, as well as be protected with a visual 
resource management classification of V~RM 11. The South Fork of Owl Creek also 
should be protected from development in the river corridor and should be considered 
for Wild and Scenic River status. 

Also, the BLM should focus more attention and resources on riparian restoration and on 
identifying and preventing sources of riparian degradation. A more aggresivc use of 
CRM management techniques and time-controlled grazing practices should also be 
pursued. 

Finally, the BLM plan should clearly provide for fish and wildlife habitat. Doing so 
only "to the extent possible"' or "where appropriate" ranks these provisions behind all 
other land uses, making them marginal at best. 1 ask that you choose the wildlife 
prescriptions in Alternative C to adequately protect winter range for all big game 

animals. 

I am aware that there axe industry-supported efforts underway to attack the portions of 
the plan that do manage to protect some of the resources in the area from development, 
and thai such efforts are characterizing the proposed plan as over-zealous 
preservationist federal nonsense that will reduce Wyoming to an uninhabited 
protectorate. I will argue, however, that pursuing a course that continues to emphasize 
the development and exploitation of natural resources at the expense of other uses will 
only serve to continue Wyoming's role as a colonial state, dependent upon foreign 
industry and markets for its, economic future. These lands are public lands, for all the 
people, and they should be managed to serve their needs. Protecting even these 
relatively small areas from development and misuse will be a step in the right direction 
toward that effort. 

Thank you for you time and consideration. 




412 



MW IP u95 




355 



STATU Of WYOMING 
OI-TKR OF THE GOVERNOR 



Ma V 5, 1995 



STATU CAJTTOL ¥. 

(.HKYENNL, \ 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Box 119 
Worlsnd, WY 82401 



Dear Mr. Ross: 



Enclosed you will find comments from various state agencies on the Grass 
Creek Resource Area Management Plan. ! am pleased to share these comments with 
you. In addition, my oral comments made at your hearing on April 3rd constitute a 
portion of the official response of the State of Wyoming. 

We remain extremely concerned that the proposed action has not recognised 
the input of the citizens of the Big Horn Basin. Furthermore, the economic analysis 
of the proposed action and alternatives is inaccurate and woefully inadequate to 
property reflect the potential impacts on local communities and the State. 

It is my understanding that County Commissioners from the four affected 
counties have requested the opportunity to work with you in a process designed to 
correct, enhance and validate the economic analysis. The State of Wyoming is 
committed to working with the counties and others in this process. We are requesting 
that the Bureau of Land Management postpone any further action until this analysis 
is completed. 

Following your review of this new economic data, a proposed action must be 
developed thai is designed to meet the socio-economic needs of these communities 
as well as the environmental needs of the resource. We further request that a new 
hearing be held on this revised proposed action. 



^PROD.STATV ' 



355.2 



Mr. Bob Ross 
May 5, 1995 
Page 2 - Grass Creek RMP 



It is my hope to be present at the next scheduled meeting between the Bureau 
of Land Management and the affected counties to discuss the state's involvement in 
this process. 

Sincerely, 

'Jim Magsgna 

Federal Land Policy Director 



JM:jh 
Enclosures 



OukcWuteSeiii 



AHJIEUUulujTk 



\ "\ 1 ' 355.3 

. vYyoming 



state Identifier Number: 9 
February 22, 



i-OBl{a} 
1995 



Wyoming State Clearinghouse 
Attn: Julie Hamilton 
Office of the Governor 
State Capitol 
Cheyenne, WY 82002 

Dear Ms. Hamilton: 

This letter provides my comments on the "Grass creek Resource 
Area Resource Management Plan" prepared by the 3LM Norland District 
Office. My comments are restricted to one thought on ecosystems 
management (Page a) and a brief discussion of the various sections 
pertaining to Cultural Resources- T understand that the 
Clearinghouse will distribute these comments. 

Page 8: Ecosystems and Ecosystem Management. BLM recognizes 
in their definition and management objectives that humans are an 
integral component in ecosystems. It is commendable that they make 
explicit this fact. Human behavior and patterns of culture change 
have influenced the dynamics of Wyoming ecosystems for over 11,000 
years. We cannot assume that humans have had an "impact" on the 
environment only since Euroamerican contact. 

Cultural Resource matters are addressed on pages iea-107, 1D3, 
189, 202, 207, and 212. Generally speaking, I believe that the 
pertinent issues are adequately stated. The only suggestion I have 
would be for the document to recognize that BLM has signed a 
Programmatic Agreement (PA) with the Advisory Council for Historic 
Preservation and the State Historic Preservation OCfice, This pa 
is intended to streamline the Section 106 process under the 
National Historic Preservation Act, while still providing 
appropriate measures for significant cultural properties. The 
document was signed last year and guidelines are in place for its 
execution. I fully expect that Wyoming will see some benefits from 
this effort in 1995. 

Thar.k yon for the opportunity to comment. 

Sincerely, 



Mark E. Miller, Ph.D. 
Stats Archaeologist 



u 




r~, ,~ 355.4 

Department of Commerce 

Celeste Colgan, Director 
Division of Cultural Resources 



RPf"v"ED 



OFFICE 



COPY 



E STATE ^^SgSSjS^OF WYOMING " 

Jim Certttget Governor 



April 21, 199S 

H- . Bob Rosa, Team Leader 
8ureau of tand Management! 
P.O. Box 119 
norland, WY B2401 



Dear Mr. robs: 

Staff of the Wyoming Stat* Historic Preaervatlan Office have reviewad the 
above referenced document ad it portaina to cultural resources. A 
comprehensive Cultural rooource overview la presented and the Preferred 
Alternative offera a favorable management plan for the protection and 
preservation of archaeological and historic sitea. 

We recommend that the viewoheda at the Legend Rock Petroglyph Sit* and tha 
Maeteetoa Draw Rook Art Area should be protected and preserved to the maximi 
extant possible. Tha visual qualities o unrounding theec sites contribute 
greatly to their cultural uignif icance. In addition, we urge the Bureau of 
Land Management to carefully monitor visitation to theao aignificant 
petroglyph sitao. Experience haa cloarly shown chat facilitated acensa 
generally Leads to increased vandalism, and that substantial investment in 
year-round Bite protection/ interpretation personnel and site stabilization 
moanureo may to required to ensure adverne effects do not occur. 



References are made 
and public education 
its efforta to incra 



o the development of cultural raaou; 

Btrategieo. We support the Bureau i 

Be public awareness about the aigni; 

we would oe pleased to cooperate 



. the 3LK U 



ieaee refer to SHPO project control number #1291RX.B014 on any f'Jt 
orreDpondar.ee dealing with thin project. If you have any quoatio 
:aren Kenypton at 307-777-6292 or J'-dy wolf, Deputy SHPO, at 307-777-631 



: ^4j, {*"k 



JTKiXilqsrtw 



a, office of i 



state uapitel 



Djutlt HuildinR. 4IJi Flou 



413 



— — «— ™— 




355.5 



OF WYOMING 



d/uvcie .2/es*€H<:e vc/rts/t&->r**oyi 



700 W 2 1ST STREET 



STEVE ELLENBECKEH. 

CH*ihmam 
OOUG DOUGHTY 



13071771-7*27 
FAX 13071 777-5700 
~rVI307)777-74!7 

MEMORANDUM 



CSnMISSONtR 



ALEXI.ELIOPULOS 

GH4F COUNSEL AND 
COMMISSION 5ECKFTMY 
STEPHEN G, OXLEY 

ADMINISTRATOR 



MS JULIE HAMILTON 
POLICY ANALYST 
GOVERNOR'S OFFICE 

JON F. JACQUOT 

ENGINEERING SUPERVISOR 
PUBLIC SERVICE COMMISSION 

MARCH 24, 1995 






#- 



BUREAU OP LAND MANAGEMENT GRASS CREEK 
RESOURCE AREA MANAGEMENT PLAN, STATE 
IDENTIFIER NO. 90-081 (a) 



Please forgive the lateness of this response to your request to comment on 
the referenced maltcr. The Commission requests that no unreasonable' restrictions 
be placed on the provision of utility service or on the construction of utility and 
pipeline facilities as a result of the implementation of the proposed plan. 

Tne Commission would prefer that the Bureau of Land Management avoid 
mandatory undergrounding of electrical utility facilities as a management 
objective, The cost of constructing, operating and maintaining underground lines 
is generally higher than the cost of comparable overhead facilities and the 
reliability is not as good. The Commission's general policy is that those who cause 
the higher costs of undergrounding electrical lines should pay the difference. If 
the additional costs are not borne by those who cause them, the ratepayers of the 
affected utility would be unfairly discriminated against when burdened with 
paying the additional costs. 

The Commission requests that, when mineral leasing is being done, the 
costs of relocating any utility and pipeline facilities to accommodate mineral 
production be borne by the lessee. If those costs are not borne by the lessee, those 
costs would fall unfairly on the ratepayers of the affected utility or pipeline. 



355.6 



The Commission requests that, in cases involving oil and gas leasing, the 
Bureau of Land Management not restrict the construction of utility and pipeline 
facilities necessary for the exploration and production of oil and gas. 

The Commission requests that, when the Bureau of Land Management sells 

or exchanges lands, the rights of the utilities and pipeline operators holding right- 
of-way easements from the private landowner and right-of-way grants from the 
Bureau of Land Management be protected. The Commission suggests that the 
private land owners acquiring Bureau of Land Management lands give new right- 
of-way easements to the utilities and pipeline operators for their existing facilities, 
and that, when the Bureau of Land Management acquires private lands, it issue 
new right-of-way grants to the utilities and pipeline operators for their existing 
facilities. 

Where consiruction is undertaken, the Bureau of Land Management or 

those managing the construction should contact and coordinate with the utilities 
and pipeline operators serving and otherwise present in the area to prevent 
contact with and damage to utility and pipeline facilities. If it becomes necessary 
for utility or pipeline facilities to be modified or relocated, the cost of modifying or 
relocating any utility and pipeline facilities to accommodate construction, should 
be borne by the Bureau of Land Management or those benefiting from Ihe 
construction. If not, those costs would fall unfairly on the ratepayers of Ihe 
affected utility or pipeline. 

The Bureau of Land Management should make provisions requiring those 
with timber operations to contact and coordinate with the utilities and pipeline 
operators serving or otherwise present in the area to prevent contact with and 
damage to utility and pipeline facilities. This should also apply to those clearing 
future right-of-ways. Consideration should also be given to the establishment of 
utility corridors through timbered areas, with maintenance of cleared areas for 
construction. 



WYOMING 

Game and Fish Department 



April 12, 1995 



HI 



355.7 



GOVERNOR'' 
OFPCI 



EIS 6163 

Bureau of Land Management 

Worland District office 

Draft Environmental impact 

Statement 

Grass Creek Resource Area 

Resource Management Plan 

SIN: 9Q-081(a) 



WYOMING STATE CLEARINGHOUSE 
ATTN: JULIE HAMILTON 
OFFICE OF THE GOVERNOR 
STATE CAPITOL 
CHEYENNE, WY 82002 

Dear Ms, Hamilton: 

The staff of the Wyoming Game and Fish Department has 
reviewed the draft environmental impact statement for the Grass 
Creek Resource Area Resouce Management Plan. We offer the 
following comments for your consideration pursuant to the 

National Environmental Policy Act. 

Ter restrial considerations : 

The draft EIS is well written and addresses most of our 
scoping comments (Joe White's letter of 12/30/91). The 
preferred alternative is a good balance between commodity use 
and environmental protection. It places greater emphasis on 
resource protection than Alternative A ("no action" — existing 
management under the 1983 Management Framework Plan) or 
Alternative B (commodity emphasis) , yet is not nearly as 
restrictive as Alternative c (non-commodity emphasis) . Our 
specific comments follow: 

l) RE: Page 21 and Map 4, Page 85 (fire suppression) — Limited 
wildfire suppression is proposed on 744,400 acres of public 
land and full suppression is proposed on 219,800 acres. In 
recent years, most prescribed burns designed to enhance 
wildlife habitat (e.g., Cottonwood, Blue, Grass Creeks) were 
done in the full-suppression zone on Map 4. Given continued 
budget declines and the trend to seek outside funding (e.g., 
RMEF) , it seems costs could be reduced by managing wildfire 



355.8 



Ms. Julie Hamilton 

April 12, 1995 

Page 2 - EIS 6163 



to achieve the objectives of prescribed burns where 
opportunity permits. For example, the current plan would 
require full suppression of a fire in the Enos Creek 
drainage. Yet, prescribed burns are planned there in the 
next few years. Prescribed fire is an important tool for 
accomplishing resource management objectives, but should not 
exclude the possibility of managing wildfire. We suggest 
flexibility to manage wildfire where appropriate, to achieve 
the objectives of prescribed burns. 

RE: Page 26 (Aspen Management) . The preferred alternative 
indicates silvicultural practices and timber harvest would 
emphasize improvement of aspen when possible. We support 
this objective because aspen is important habitat for many 
species of wildlife. In fact, we recommend BLM attempt to 
increase acreage of aspen stands in addition to maintaining 
existing stands. 

RE: Page 26 (security Cover) . Forest management should 
consider size and effectiveness of residual security areas 
as well as the size of cut areas. Recent literature 
suggests at least 250 acres of contiguous uncut timber are 
necessary to function effectively as security cover. Road 
management can sometimes lessen the impact of too little 
hiding cover; BLM should continue to recommend road 
management policies designed to improve/maintain 
effectiveness of residual cover. 

RE: Page 29 (Public Access) . The preferred alternative 
states BLM will work, to maintain or improve existing 
opportunities for public access. The RMP should state this 
includes foot and horseback access in addition to vehicular 
access. Motorized access is not necessarily a high priority 
in many parts of the planning area, but foot/horseback 
access is. we will continue to support BLM's efforts to 
secure and improve public access. 

RE: Pages 32-33 (Land Exchanges) . The RMP lists general 
areas whore exchanges would be pursued. Land exchanges can 
be designed to benefit both the private landowner and public 
resource users. we encourage BLM to develop a streamlined, 
more efficient land exchange process. Improved efficiency 
and shorter processing times would be supported by 
landowners/permittees, and by sportsmen groups, other 
agencies, and the public where the outcome secures 
protection of important public resources or improved access. 



414 



355.9 



Ms. Julie Hamilton 
April 12, 1995 

Page 3 - SIS 616 



There are existing circumstances in which subdivision of 
important wildlife resources could take place if exchanges 
are not completed soon . Any land ownership adj ustments 
should evaluate potential loss of important wildlife habitat 
or other negative impacts to wildlife resources before being 
pursued. 

6) RE: Pages 36-42 (Grazing Monitoring). The RHP will continue 
grazing management similar to ongoing practices. There will 
be no adj ustments in amounts , kinds , season of use , 
authorized preference, etc. , without monitoring data and 
consultation/negotiation with permittees and other affected 
interests. Effective monitoring is essential. We support 
more active involvement of permittees in monitoring, but BLM 
must ultimately assure proper monitoring and grazing 
practices. 

7) RE: (Combined Utilization Levels) . The preferred alternative 
identifies guidelines to conserve residual forage in 
important big game seasonal habitats; we support this. 
Without specific data to al locate forage in each allotment , 
adherence to utilization levels is a reasonable alternative. 
However, we recommend specific utilization thresholds rather 
than ranges, particularly in arid sites. The thresholds 
should be the lower end of the current ranges specified. 
For example, 35% utilization would be more appropriate than 
a range of 30%-50%. 

8) RE: Page 44 (Wildlife Mitigation and No Surface Occupancy). 
The preferred alternative establishes different levels of 
habitat protection through various leasing -stipulations. 
WGFD participated in developing these. Less than 2% of the 
planning area (20,200 acres) is recommended for leasing 
under a stipulation of "no surface occupancy" (NSO) . This 
includes the Bighorn River corridor, Legend Rock cultural 
site, south Fork Owl Creek Canyon, and high-elevation ridge 
complexes at the extreme southwest. These areas have 
inordinate wildlife value. The NSO designation maintains 
the option for exploration and future oil extraction with 
improvements in horizontal-drilling technology. WGFD 
supports BLM's NSO recommendation for the 20,200 acres. 

9) RE: (Protective Stipulations). Controlled Surface USE (CSU) 
and Timing Limitations (TU) are designed to avoid or 
minimize conflicts that inevitably happen when APDs are 
submitted for drilling in sensitive habitats. CSU 



355.10 



Ms. Julie Hamilton 

April 12, 1995 

Page 4 - EIS 6163 



stipulations cover less than 12 i of the planning area 
(13 8, a 00 acres) and TL stipulations cover 34% . The 

preferred alternative applies protective stipulations 
throughout approximately 48% of the planning area; therefore 
52% would be available for leasing under Standard Terms and 
Conditions. We support BLM's application of these 
stipulations. To avoid protracted analyses and conflicts, 
industry should be notified at the outset where stipulations 
apply and the specific terms of those stipulations as is 
currently accomplished through the lease sale process. 

10) RE: Pages 47-49 (ORV Management) . The preferred alternative 
identifies 4 special recreation management areas (SRMAs) 
(see Map IB, page 99) where off-highway vehicle use would be 
limited to designated roads and trails. ORV use would be 
restricted to existing roads and trails elsewhere throughout 
the planning area, except vehicle use would be prohibited 
within the Duck Swamp interpretive site, Worland rifle 
range, and pending wilderness Study Areas (WSAs) . This mix 
of permitted uses will maintain or increase opportunities 
for ORV use while lessening conflicts with other resource 
values. We support this type of management and encourage 
8LM personnel to rigorously enforce ORV restrictions so they 
are effective. This is especially critical during high-use 
periods including fall hunting seasons, holiday weekends, 
etc. 

11) RE: Table 2 (Recreation Management, Reservoirs) . Table 2 
addresses the need for facility development (e.g. , trail 
heads, boat ramps, campgrounds) and interpretive signing in 
various locations throughout the planning area. We support 
these efforts, which are often jointly funded. We believe 
limited development of facilities would be beneficial at 
Wardell and Harrington Reservoirs, which are small and 
cannot accommodate a large increase in use. We also 
recommend completion of facilities at Harrington Reservoir 
before development of the fishery. In particular, access to 
this reservoir should be control ] ed with a designated 
parking area. 

12) RE: Pages 5 5-61 (Vegetation Objectives) . Desired Plant 
Community (DPC) objectives have been defined for several 
native plant communities and wildlife seasonal habitats. 
This was a cooperative effort. The approach seems valid, 
measurable, and should help prioritize monitoring, habitat 
treatments, and use of personnel time. 



355.11 



Ms, Julie Hamilton 

April 12, 1995 

Page 5 - EIS 6163 



13) RE: Page 66 (Wild Horse Management). Under the preferred 
alternative, BLM would increase the Wild Horse Management 
Area (WHMA) by approximately 38% (31, 400 acres) . The 
additional area extends north of the current WHMA and is 
heavily used by wild horses. The herd si2e objective would 
remain between 70-160 mature animals until revision of the 
wild horse management plan is completed. The management 
plan emphasizes gathering strays outside the designated WHMA 
and those that wander onto private lands. Additional water 
sources developed within the expanded WHMA would benefit 
pronghorn and other wildlife in the area. We encourage BLM 
to maintain horse numbers at the low end of the range of 
70-160 adults, in part because persistent drought has 
reduced plant vigor in recent years. 

14) RE: Pages 69-7 3 (WGFD Herd Objectives) . The preferred 
alternative states BLM will maintain or enhance habitat for 
existing and WGFD "objective" wildlife populations. The RMP 
should acknowledge these objectives are periodically 
reviewed and may change based on habitat conditions, public 
input, and consultation with federal land management 
agencies. The following statement would be more 
appropriate: "BLM will provide suitable habitat and forage 
to meet WGFD strategic plan population objectives which are 
developed through public input and consultation with federal 
land management agencies, and are based upon habitat 
capability and availability." 

15) RE: Page 76 (ACEC Designations). The preferred alternative 
would create an ACEC on 17,100 acres of public land in the 
upper Owl Creek drainage (see map 21, page 102) . This 
corresponds closely with the 20,200-acre NSO designation 
(excludes South Fork Owl Creek canyon) . ACEC status will 
focus management emphasis on the unique wildlife habitat 
which exists there. Another ACEC (274,300 acres) described 
for the Fifteenmile drainage (Page 74) would be managed 
similarly to the "Save Ocean Lake" campaign which has been 
highly successful in Fremont County. A primary objective is 
to reduce sediment problems within the Fifteenmile drainage. 
This effort will be costly, long-term, and rather 
comprehensive. We support the proposed ACEC designations . 
The final RMP should include discussions of management 
actions planned to rehabilitate the Fifteenmile watershed so 



355.12 



Ms. Julie Hamilton 

April 12, 1995 

Page 6 - EIS 6163 



the reader gains a better understanding of the scope of this 
effort. We request to be a major participant in the 
design/conduct of special projects in this drainage. 

16) RE: Table 3 (Constraints on Surface Disturbing Activities) . 
Management constraints intended to benefit wildlife include 
measures to protect overlapping and important big game 
crucial winter ranges and parturition areas, sage grouse 
leks, raptor nests, and riparian habitats along the Bighorn 
River. We support these provisions. 

17) Re: Pages 103-152 (Corrections). 

i. Page 109 (Access). No agreement has been reached among 
WGFD and affected landowners regarding road management 
along the upper South Fork of Owl Creek. 

ii. Page 111 (Rights-of-way) . The three proposed actions 
should be updated to reflect recent accomplishments. 

iii. Page 119, Tables 6 & 7 (Recreation Use). It is not 
clear how the figures presented in Tables 6 and 7 (page 
119) were calculated. For the final RMP, we recommend 
BLM recreation planners contact the WGFD for up-to-date 
figures that can be included in these tables, 

iv. Page 131 (Aspen Distribution) . Text indicates the 
planning area contains approximately 2 00 acres of aspen 
on public land. This underestimates current aspen 
distribution; the figure should be checked and revised. 

v. Page 134 (Bighorn Sheep winter Forage) . winter browse 
requirements are described collectively for bighorn 
sheep, mule deer, and pronghorn. Sheep have 
substantially different winter browse needs and should 
be listed separately, 

vi. Page 139, (Wild Horse Objectives). Text indicates, 
"with an October 19 91 estimate of 15 8 horses in the 
WHMA, the herd appears in good condition although range 
conditions are generally rated as static or downward in 
trend. " If recent drought conditions have contributed 
to this downward trend, the herd should be managed at 
the lower end of the 70-160 adult horse objective until 
range conditions improve. We suggest incorporating 
this provision. 



415 



355.13 



Ms. JUlie Hamilton 

April 12, 199 5 

Page 7 - EIS 6163 



vii. page 150 (T&E Species, Grizzly Bears). The section on 
grizzly bears vastly understates the amount of grizzly 
activity in the planning area. The western portion of 
the area is Situation 5 habitat; however, grizzly 
presence on the Wood River and Gooseberry Creek has 
increased markedly in the past 5 years. Observations 
have extended into the Middle Fork of Owl Creek. BUI 
should clearly acknowledge the bear situation and make 
preparations for dealing with bear habitat issues in 
coming years. 

viii. Page 150 (T&E Species, wolves). Wolf observations 
reported in the past 20 years have been along the 
fringe or edge of the planning area rather than the 
western quarter. It is certainly possible wolves could 
disperse from Yellowstone into the western edge of the 
planning area within the next 10 years. This should be 
considered in the analysis. 

ix. Page 150 (T&E Species, candidate Species). We 
icommend the final EIS/RMP incorporate the Biological 

Our 



Assessment on T&E species (prepared by BUI) , 
Non-Game Section in Lander should also be consulted. 



18) RE J Page 1B7 (Biological Diversity), The conclusion that 
biological diversity, overall forest structural diversity, 
and associated habitat values all decline as forests grow 
older is a generalization. Diversity can (and does) 
increase in areas where varying ecological conditions are 
intermingled and direct succession accordingly. 

The BLM has done a good job of identifying and addressing 
issues and concerns which we (and others) identified during 
scoping. Many of the actions recommended to benefit wildlife 
were developed jointly by the BLM and WGFD through local 
coordination. Successful implementation will depend on 
continued support and cooperation between BLM and WGFD. 

Aquatic Considerations : 

The Grass Creek Resource Area contains several streams that 
range from WGFD Class 3 to Class 5 trout streams. Several of 
these waters are important fisheries on a regional level within 
the state or at a local level. The Resource Area is bordered by 
a Class i section of the Bighorn River. Class 1 trout streams 



355.14 



Ms. Julie Hamilton 

April 12, 199 5 

Page 8 - EIS 6163 



are considered fisheries of national importance. Besides trout 
fisheries, many of these streams serve as important habitat for 
Wyoming's native minnows and suckers. 

Although alternative C would provide the greatest benefits 
for fisheries resources, the additional benefits appear to be 
negligible compared to the preferred alternative. Therefore, we 
can support the implementation of the preferred alternative 
from the fisheries standpoint. 

We strongly encourage and support the improvement of range 
conditions as well as riparian conditions. Such improvement 
would reduce sedimentation and avoid or minimize related fishery 
impacts. Well developed riparian zones provide a variety of 
benefits to all water- related resources and users. These 
benefits include, though are not limited to bank stabilization, 
improved water quality, improved fish habitat, elevated water 
tables, increased bank storage capacity, higher late summer 
stream flows and higher forage production. 

rt has been our experience that stipulations on oil and gas 
leases do not always adequately protect fisheries resources. 
Stipulations often provide protection during exploration but 
fail to provide adequate protection during field development and 
production. We recommend BLM, through the RMP, identify 
measures to address this concern. 

We support the emphasis the BLM has placed on acquiring 
access to public lands near the Bighorn and Greybull Rivers. We 
would only suggest that any new road development be constructed 
in such a manner as to minimize potential erosion in these 
watersheds. 

When exploring the possibility of developing islands in 
reservoirs for waterfowl habitat, consideration should be given 
to designs and locations that will not result in a large 
increase in piscivorous bird populations that could be 
detrimental to fish populations in the area. 

The BLM had recognized Fifteen Mile Creek as the largest 

contributor of sediment into the Bighorn River. We support land 
management actions that the BLM is proposing to improve riparian 
areas and water quality in this drainage. We hope that the BLH 
will continue to work with WGFD and others in identifying and 
implementing land management actions that can further alleviate 
the sedimentation problem. 



355.15 



Ms. Julie Hamilton 

April 12, 1995 

Page 9 - EIS 6163 



It would be beneficial if the Wild and Scenic Rivers 
designation process was better explained. It is unclear to us 
how the Wood River could not qualify for consideration for Wild 
and Scenic status. We are not implying that the Wood River 
should be considered, only that we would like to see the 
rationale for not qualifying for consideration. 



Thank you for the opportunity to comment. 



JW:TC:as 

cc: Wildlife, 




Fish, HATS Divisions 



Ft E C E I V E D 




AftM BUREAU FEDERATION 

P O. Box 1348 

Vyoming 32070 • (307) 745-4U3S 



356 



Worland. WY 82401-0119 



Dear Mr. Koss: 



The following are the comments oi' the Wyoming Farm Bureau Federation on the Draft 
Grass Creek Environmental Impact Statement (DEIS). The Wyoming Farm Burcai. Federation 
is a non-profit general agricultural urbanization dedicated whelping agricultural producers. Many 
of our members are federal permittees in the Grass Creek Resource Management Area. We feci 
Impacts of the proposals outlined in the DEIS would harm agricultural producers. 

As a representati va of the livestock industry we find the document treats livestock and the 
ranchers that manage than as "second class citizens." On page 7 of Ihe document, under the 
General Criteria section, the DF.IS lists as a consideration, "Livestock grazing practices that are 
compatible with other resource management objectives." We question why livestock grazing is 
being singled out to measure for compatibility. Why aren't other multiple uses compared to their 
compatibility to livestock grazing? Section 1502,14 of the Council on Environmental Quality 
fCEQj Guidelines require thai Ihe alternative secaort of the EIS be the "heart of the 
environmental impact statement." However, alternatives which arc baaed only on how livestock 
grazing coq be compatible with other resource management objectives does not provide the public 
with adequate information on which to base a sound decision, '[his DEIS, also under that same 
section, seeks opportunities for enhancing recreation. The DIES ducsn't provide any information 
about enhancing other multiple use activities, which a«aui, appears 10 violate the requirements 
of It 1502.14 of the CEQ Guidelines. 

Under the Selection of IPreferrnl Alternative section on page 7 of the DIES, it claims that the 
preferred alternative answers the question "-Is there consistency with land use and resource 
tnaaageBHiEi plan.-:, programs, mid polici^ of other federal agendas, stale and local governments, 
and Native American tribes (emphasis added)?" The Strategic Plan for Wvorrane s Agricultural 
Incusin- W'JQ-^iWO l hereafter referred .to as the Han) lists as a limiting factor 61' beef production 
"Federal policies which limit grazing" (Plan, page 24) and "Federal land policies limit expansion 
of sheep tanges" (Plan, page 37) as a limitation for sheep production. One of the Plan's goals 
for the beef industry is to insure no net loss of federal and state AI 'Ms. One goal listed lor the 
sheep industry is to increase stock sheep numbers to 1.5 million head. Tl« DEIS appears to 
ignore this Plan and instead of seeking 10 enhance livestock production, as outlined in the Plan, 
it seeks [0 reduce or eliminate livestock grazing. No attempt appears luive been inside to address 
issue*, and problems for livestock pruducers in the Grass Creek Resource Area. 



In Wyoming call r.fi00-<J42-8325 



416 



Grass Creek DEIS Comments 
WyFB 

Base 2 

Under this same section of the DEIS, the document discusses improving the management of 
ecosystems that cross administrative boundaries and sustaining the productivity and diversity 01 
ecosystems 1 here »rc no maps, however, nor any docu.nenu.tion on where these ecosystems are 
and winch ecosystems the BLM is supposed to sustain. One „f the bas.c reqinremenrs under 
NEPA. as outlined in Sierra CM) v. Morion, 510 F .2d 813, 820. (5th Or. 1975) is tat the 
orocess is intended to make die NEPA "an environmental full disclosure law. The lack ol 
definitions for ecosystems does not allow for objective measurement of ecosystem productivity 
and diversity. Without an objective measure, the full environmental impacts cannot be mcasured- 
-nor even guessed at. 

Page 8 of the document elaborates further upon ecosystem management, hut it doesn't provide 
the reviewing pnbiic with any better understanding of the concept. 

Page 8 of die document also discusses the development of mitigation needs. The document is 
unclear as to what the BLM considers a "surface-disturbing and other disrupt™ activities It 
is unclear in die definition section whether normal animal husbandry practices such as Tence 
repair or construction, water development or even grazing would be considered a_ surlace- 
disturbing" activity and need to be mitigated. Mitigation measures could add a significant cost 
to'grazing on federal lands, which in turn would affect how grazing is earned out in the resource 
area The document needs to indicate more precisely what government officials considered a 
"surtace-disnirbing" activity and which activities are not considered surface disturbing activities. 
If "surface-disturbing" activities will be applied extensively to agricultural practices, then the 
DEIS needs to address the economic and environmental impact such an action would have. 

On page 11 under Issue 1. Vocation Management .he document states that "Reduction in 
vegetation and undesirable changes in plant composition can alToc. forage availability, wildlife 
habitat, ami overall plant and animal diversity." The document doesn't provide the reader with 
a„v information on current plant and animal diversity trends for the RMP area. The same 
problem exists for Issue 2: special Management Area Designations. In this section the 
document states "In some places, unique resources and biological diversity are in danger ol being 
lost- ill other places, special management may be required to protect a naniral process or 
ecosystem...* (emphasis added). Again, we question what base line data ,s used to determine 
.rends for ties, special management area designation. What level is die BLM using to "elernnne 
whether biological diversity is in danger or being lost? Without this information provided, the 
public cannot make an informed decision, nor can land managers, which is a clear violation ol 
§ 1502.16 of the CF.Q Guidelines, 

The statement in paragraph 1 on page 1 4 of the document continues to cany forward the idea that 
livestock -razing is considered a "sacrifice use" on the public lands. The document requires 
managers to allow livestock grazing as long as the livestock don't excessively conflict with other 
management objectives. The term "excessively conflict" is not defined, however the intent o the 
DIES is clear in that if other uses cannot co-exist with livestock, livestock will go. 11 is 
questionable whether that type of action reflects the wishes of Congress to manage the federal 
range in a multiple use fashion. 



356.2 



Cirass Crixk ORIS Comments 
WvFB 



356.3 



Under Table 2 on page 19, the document says that adverse effects would be avoided on land and 
resource values listed in tie National Park Service inventories. The document is silent as to 
where diese areas might be and to what extent there are "possible National Natural Landmarks" 
which will be avoided. The public is left to speculate on how many such landmarks exist in the 
area, where these landmarks might be located and what these landmarks arc. The public is also 
left to wonder what "adverse effects" are going to be avoided. Based on die lack of information 
provided in the document, one cannot help but wonder how the document concludes under fable 
16 on page 175 that "There would be no significant adverse effects on lands and resources 
identified by the NPS as possible National Natural Landmarks." 

Tabic 2 on pages 20 and 2] of the document suggest lhat limited suppression of fires would 
occur in much of the resource area and on page 22 of the document travel restrictions lor lire 
suppression on lands north of Highway 431 would occur. Tabic 16 of the document ignores the 
environmental consequences of this action, .so again the public is left to speculate as to what the 
consequences are for this decision. For example what happens if a fire occurs on private land, 
and the private landowner seeks to immediately extinguish this tire bul it spreads to public land 
in a limited tire suppression area, with travel restrictions. Will the landowner or local 
governmental agencies be asked to pay for the additional costs associated with fighting a fire 
under such restrictions? If so. what impact will this have on local governmental entities'; 

On page 24 of the document, the authors state, "The. management of forest and woodland 
resources would be consistent with ecosystem management principles." Which principles might 
these be? 

Under the landownership adjustment section of Table 2, we read that the BLM will pursue 
purchase of 16.000 acres of privately-owned land (page ii). We question why the BLM finds 
it so important to acquire private land, but places sever restrictions on minsters of the public- 
domain to private hands, even diough such transfers would greatly facilitate private land 
management decisions. Reciprocity does not seem to be a factor. 

I able 2 on page 35 states that a management objective for livestock grazing is to "Improve forage 
production and range condition to benefit livestock, wildlife, wild horses and watersheds." 
(emphasis added). We find no requirement thai wildlife and wild hotse management be used to 
benefit livestock. Why? Indeed we find that In Table 16, on page 176, livestock AUMs will be 
reduced 43.850. or around 35%. We question why thus docurnem tries to mislead die public into 
believing that livestock grazing will be managed to benefit livestock, when it is apparent that 
wildlife and wild horses are the beneficiaries of these reduced AUMs. 

On page 36. Table 2, the document states that "The level of actual livestock grazing would not 
exceed active preference. Currently active preference is 101,451 AUMs per year." The 
document does not provide an analysis as to the difference between active preference and 
authorized use. Again, we refer back to the state Plan for agriculture, which recommends 
expansion i>t' the state's sheep numbers and no lose of federal AUMs, and we question what 
attempts the BLM lias made to work with livestock producers, local and slate officials to achieve 
the goals outlined in the Plan. 



:ek DEIS Comments 



Grass C. 
WyFB 

page 4 

Pages 40 and 41 point out that livestock grazing will be restricted or limited on over 365.000 
acres to accommodate wildlife. We find no such requirement for wildhlc. It is clear that 
livestock will be cut and restricted to benefit wildlife. 

We find the DEIS leans heavily in favor of recreation development, will, no clear indication as 
to what die potential need for recreation truly is. In Table 2. page 4'), the document wants to 
"enhance opportunities for primitive recreation." The 1990 State Comprehensive Outdoor 
Recreation Plan (SCORP) suggests that resident participation in primitive recreation activities .s 
stable to downward trending (SCORP. page 35). The Table 15 Assumptions for Analysis By 
Alternative for recreation management (page 168) also points out that the BLM will increase 
camping by 85%. hiking by 81% and sightseeing by 102% oyer current estimated levels. Again 
die 1990 SCORP document stales that "Noticeable decreases in camping, sightseeing, and 
picnicking arc nuled." 

In addition, there are other errors in the recreational aspect of the document. 

ESTIMATED RECREATIONAL USE FOR CALENDAR YEAR 1990 ON ALL PLANNING 
AREA LANDS is shown in Table 6. (Pages 118-119). This table FOR ALL LANDS IN THE 
PIANN1NC AREA indicates that use is 256.400 Visitor Use Days. ESTIMATED 
RECREATIONAL USE FOR CALENDAR YEAR 1990 ON PI.rBI.IC LANDS IN THE 
PLANNING AREA is shown in Table 7 (Pages 1 19-120). This table for PUBLIC LANDS IN 
THE PLANNING AREA indicates that use is 81.175 Visitor Use Days. Thus these two tables 
reveal that only 31.65 percem nrdie Visitor Use Days are on Public Lands. A footnote at the 
end of Table dedicates "Extrapolations of the amount of noneonsumplivc and consumptive use 
unVmi place on all lands in the planning area are based on the professional judgement of BLM 
recreation specialists." Table 7 contains a footnote which indicates "Extrapolation ot the amount 
of noneonsumplivc and consumptive use taking place on public lands in the planning area are 
based on professional judgement of BLM recreation specialists." Strangely, the BLM has faded 
to point out lhat I'ullv 55.55 of the Visitor Use Days on all planning ajcjjands is fishing, with 
the data in die LIS indicating only 4 percent ofthe Visitor. Use Days involved in fishing occurred 
on public lands. Table 9 (Page 128! indicates Stream System Total Miles are 1299 and Stream 
Svstem Public Miles are 506 (or 28 percent). This Table is very unclear because It shows the 
miles for the Big Horn River (as a total of .he drainage ?) but does not break-out tbc miles ol 
the Big Horn River itself in die planning area. Table 10 (Page 129) fails lo identify public miles 
by DEQ Class or WG&F Class, which prevents the public train being able to assess the 
government's contentions will, any degree of reliability. 

Table 6 is claimed to be an estimate of the recreational use on all planning area lands, while 
Table 7 is said lo be an estimate of the recreational use on public lands in the planning area. The 
dam from .hose Tables appears on page 123. bu. is attrihu.ed lo the "four counly area". It .s 
impossible to determine from reviewing Hie F.IS what the actual situation is. Therefore the reader 
ofthe EIS is left lo speculate aboul the veracity ofthe document. It is impossible to respond in 
these inconsistencies. 



356.4 



Grass Creek DEIS Comments 

WyFB 

page 5 

The document on page 69. Table 2. indicates that a management objective is to maintain or 
enhance habitat for existing and Wyoming Game and Fish (WO&F) Department objective 
wildlife populations. We question why this is being done. 

Wilillilc-The EIS (Page 190) indicates AUMs will be reduced for adjustments from constraints 
protecting elk. moose and bighorn sheep habitat, bul the government has failed to show that there 
is a demand greater lhandte objective numbers of these species. The 1991 Annual Report o the 
WG&F Department reveals that hunter numbers are below the objective number in most of the 
areas near or adjacent to, the planning area. If harvest la not going lo be a mechanism for 
regulatinc numbers, then the government is planning fot objectives which have no logical basts. 
Tile planning area is not an island surrounded by water. It is contained within an area where 
choices can be made. For example the 1991 WG&F Annual Report indicates the following tor 
the Stale of Wyoming: 



356.5 



Population 
Objective 1990 



Hunters 
Objective 1990 



Pronghorn 
Elk 

Mule deer 
Moose 
Bighorn sheep 



384.660 
73,435 

515,550 
11.825 
8.395 



413.243 
82,128 

542.793 
12.767 
7,069 



90,303 

59,195 

156,794 

1.679 

515 



41.528 
.18.810 
86.145 
1.883 

374 



The 1990 population for pronghorn. elk. mule deer and moose exceeded the objective number 
The objective for 1990 exceeded the number of hunters for pronghorn, elk. mule deer and 
bighorn sheep The EIS is devoid of any information explaining what the specific population or 
huntet objectives arc for the planning area, which also means there is no indication or how this 
"island" is gui.m to be managed to reach those objectives. The render cannot be expected to 
guea as to what management is being planned for the area While die EIS refers to a WG&F 
Su-ategic Planning document that document does not identify the objectives for the planning area 
as such. Therefore it is impossible to determine how the data found in the DEIS was arrived at. 

fable 1 4 on "BIG GAME POPULATIONS ON CRITICAL WINTER. RANGE AND BIRTHING 
K-\NGE 1 990" reveals little, until it is subjected to further calculation. Those calculations reveal 
that ol' the 98 870 actes of critical winter range for Bighorn sheep, elk and moose, only 31,779 
acres are public lands, or only 32.1 percent. This would indicate 67.9 percent are on private or 
other lands. For birthinu ranee, the calculation indicates only 13,775 of 55,100 acres are on 
public lands or 25 percent, while 75 percent are on private or other lands. For all species shown 
on Table 14 public lands account for 54.25 percent of the lands which are critical winter range, 
and 30.9 percent of the birthing range is on public lands. Therefore the federal government s 



417 



Grass Creek DEIS Comments 

WyFB 

page 6 

desire to impost livestock grazing constraints for Bighorn sheep, elk and moose are unfair, given 
the fact dial most of the critical winter habitat and birthing areas exist on lands which are not 
public lands. Reductions of livestock grazing on public lands, which impose a burden on die 
other lands, has not been addressed in die IUS. We request that such an analysis be provided. 

Because the DKIS has many serious inadequacies, we feel this document needs to be rewritten 
and reissued as a Draft Environmental Impact Statement alter the inadequacies arc addressed. 

I hank you for the opportunity to comment on the documeni. 

Sincerely. 



356.6 



^ |k|» 



Ken Hamilton. 
Administrative Assistant 

c.c. Congressional Delegation 
Ron Michsli 
WSGA 
WWOA 



RECEIVED 




SSI 



BU EAUOFLANDyANAGtM 



May 4, 1995 



RESOURCE PROVIDERS CUUFTION 
DarreN Barnes 
Distnct Manger 
Bureau of Land Managemen; 
POBox 119 
Woriand.WY 82407-0119 

Dear Mr Barnes 



The Wyoming Resource Providers Coalition I WRP(') would like to express further concern over 
ihe content of the Grass Creek Draft EIS Within the document, the BLM fails to gtv« credit to 
the technologies used by industries which benefit the environment The DEIS contains 
unreasonable restrictions on the Oil & gas industry in the Preferred Alternative It gives ahsolutely 
no consideration to the development and use of new technologies and no credit or value is 
assigned to produced water and wildlife habitat developed from oil and gas activities 

The DF.1S noi onl\ restricts industry access, but at the same time, it will cause a significant loss of 
dollar revenues to all tour counties (Park, Hot Springs, Washakie, and Big Horn) The BLM has 
not given any consideration to the economic impacts that will affect the people of the Grass Creek 
Resource Area or the state's economy The BLM needs to consult with these counties and then 
concerns must be considered The BLM should provide these counties with economic studies 
that address the economic impacts created by the adoption of the DEIS within each county. 

There is an inadequate range of alternatives from which to choose For example. 71 W of the 
statements comparing the alternatives all read. "Same as Preferred " This violates the National 
Environmental Policy Act Also, not only is the DEIS biased against oil & gas leasing, it is clearly 
bias AGAINST grazing The Preferred Alternative reduces grazing by 25 percent This is totally 
unreason able 1 

The BLM is [educing the publics access even further by managing areas, such as Upper Owl 
Creek and Badlands Red Canyon Creek, as Wilderness, without congressional consent They are 
not wilderness areas and should not be considered as such These defactn wilderness areas 
negatively impact motorized recreation 

In general, the WRPC would tike to see the BLM work with the counties to produce an 
alternative or plan that will protect the communities economic stability and ability to survive The 
DEIS should be rewritten to incorporated these issues 



Dallas Skects Vald« 
State Coordinator 



P.O. Box 70t - Laramie , Wyoming 82070 ■ (307) 745-0996 



b f c e i v 5 o 

r 


( 


I M«Y - E Wi 




I 
ottAU or i 


--J 


. , ,id 


JLr 


'Vi 1' '''!.. 'i 


L.-.-J,,, 


J. 1- :.■■ 


m, „,:t< 


.,- ».,, 


,,,-,( $ ■ 


..,,,,.. 


f ei " *i 



358 



: . iub:t- fC"' ' i« I .!-■. ■: " "- VS« . :■■.. - t<* I 

■r,= r.,i , ;.p,.s uAft* i(v--v UiK's 8r-ii'j| ( iid 

Li -■ I'lJlitlMvaciJ '■:-■- '-'..■: i ■=•:'■■ rr *■.-.-. ,f -,,■■, | 
fcr-j»-j ■' .'..'-I'M l»«i ■■..■,■:. ■--, ti.fl u^/oM f 



PETROLEUM ASSOCIATION OF WYOMIN 

a division oi Rocky Mountain OH ana Gas Association 



£59 



Cflspsr. Wyomin | 
1307) ? 34-5333 
fa* (307)266-21 9 



MAY - 8 S95 



Bu «f au o r i a ^ d r; -V r, AG L il tHT 



Mr- Rob Ross, Team Leader 
Bureau of Land Management 
P O Box 119 
Korland, Wyoming 82101-0119 

Dear Mr. Ross: 

Below are comments of the Petroleum Association of Wyoming (PAW), 
a division of the Rooky Mountain Oil and Gas Association with 
respect to the Gruss crack Resource Area Resource Management Plan 
Draft Environmental Tmpact Statement (Draft EIS) . PAW, a division 
of the Rocky Mountain oil and Gas Association (RMOCA) , represents 
a membership which accounts for over 90% of the oil and gas 
exploration, production and transportation in the state of Wyoming. 

PAW appreciates the time and effort spent by BLM in preparing the 
Draft EIS as well as an opportunity to provide the oil and gas 
industry's input to a planning document which will determine the 
future of the oil and gas industry to access the Grass Creek 
Resource Area for exploration, production and transportation 
activities. However, specific concerns with the Draft EIS, as 
discussed with you during our meeting on March 20, are reiterated 
be 1 ow . 



Wyoming has been blessed with 
Since 1B84, the oil and ga: 
produced and transported 
successfully cohabitated with 



i abundance of natural resources, 
industry has explored, drilled, 
s products. The industry has 
ldlife, endangered species, and 



Industry docs not believe the Preferred 
Alternative, contained in the Draft fclis, acknowledges those 
accomplishments by arbitrarily doubling the use of restrictive 
lease stipulations in the Grass Creek Resource Area. 

Specifically within the document, we do not support the general 
statement that there "appears to be sensitive or conflicting 
resource values" which apparently justifies BLM's need to expand 
oi 1 and gas leasing or operational restrictions. Therefore, the 
general statement does not meet the analysis or policy requirements 
outlined within NEPA. PAW failed to identify a discussion within 
the Draft EIS of specific resources to be safeguarded nor a 
discussion of the perceived conflicts between the specific resource 
and oil and gas activities. An examination of the less restrictive 
measures must be a fundamental element of the discussion within the 
Draft KTS. 



418 



359.2 



951 Werner Court. Suite 100 
Casper, Wyoming 82601 



Mr. Bob Ross 

Page 2 

May 5, 1995 



Therefore, ELM has not complied with these requirements and has 
failed to comply with NEPA requirements and BLW Manual 1674 - 
Supplemental Program Guidance for Fluid Minerals. 



^Pales.nto logical... and Natu ral History R esources 



16 Cultural 
Management 

The Dnft EIS indicates that historic resources within ten oil and 
gas fields would be managed for scientific and public use. The 
purpose of the program appears to focus on improved knowledge of 
the historic significance of the fields and to facilitate the 
approval of future development and reclamation activities. 
However, in a letter dated July 20, 1994, (attached) to Mr. Mike 
Bies, PAW posed several questions reqardiriq this proqram which have 
yet to be answered. Specifically: 



1) 



How does BLM justify this reallocation of time and resources 
when areas such as southwest Wyoming are in desperate need of 
archaeological surveys for APD'S, Rights-of-way, etc.? 



Expl a 



the need to examine these fields for listing. 



3) Clarify the benefits derived from listing these fields. Would 
there be any incentives to spur operator participation? Elow 
would designations affect post-production abandonment 
procedures? 

4) How does BIM plan to handle the National Historic Preservation 
Act (NHPA) Section 106 consultation requirements to consider 
possible effects of undertakings on listed districts, sites, 
buildings, structures or objects, especially when the proposed 
new operation is the same or similar in scope tu prior 
activities and operations? specifically, will BLM impose 
restrictions that inhibit an operator's ability to replace or 
update old equipment or to pursue new technology which might 
extend production? 

Because of BLM's failed response to PAW's letter, we do not support 
this program. 

Page 3 4- - Rig hts-of-way 

Industry supports the preferred alternative approach to rights-of- 
way management along routes to Yellowstone National Park. However, 
these rights-of-way must not be subject to increased restrictions 
to protect scenic values. 



359.3 



951 Werner Court, Suite 100 
Casper. Wyoming 82501 . 



Mr. Dob Ross 

Page 3 

May 5, 1995 



use N e s t ing Habitat 



Page 61 - DPC Objecti ves for. £a 

Under the preferred alternative, BI.M would impose a limit on total 
surface disturbance to less than 20% in sage grouse habitat. It 
appears the 20% objective would include habitat affected by direct 
surface disturbance and areas affected by indirect and human 
presence activities. Does the 20% objective baseline data assune 
optimum habitat or does the best science available used to prepare 
the Draft EIS indicate a percentage closer to the 20% objective? 
Certainly if the disturbance area was already at 20% then 
clarification as to whether other multiple-use activities would be 
subject to a "no surface occupancy" constraint, or is energy and 
mineral activities the only use to bear the burden. 

Industry can find no basis offered in the Draft EIS for such 
potentially burdensome mitigation. Therefore, we oppose the impact 
threshold concept and favor a case-by-case analysis which takes 
into account site-specific opportunities for mitigating adverse 
affects on sage grouse. 

Page 74 - Special M anagement Are as 

Many of the proposed Areas of Critical Environmental Concern (ACEC) 
have significant potential for ail and gas exploration and 
development. According to the US Bureau of Mines 1990 Known 
Minerol Deposit Areas (KMDA) for oil and Gas in Wyominq indicates 
the Grass Creek Resource Area to contain High Value KMDA and 
Moderate-Value KMDA. High value is defined as an area that 
includes mineral deposits (developed and undeveloped) and mineral 
occurrences having cumulative productions and/or identified 
resources of more than Si million. Moderate value is defined as an 
area that includes mineral deposits (developed and undeveloped) and 
mineral occurrences having cumulative production and/or identified 
resources less than SI million- 

The criteria within DLM's Manual 1613 requires ACEC's to have 
specific relevance and importance in order to qualify for 
designation. Because industry is unclear how these proposed 
designations meet the criteria described in BLM Manual 1613, and 
regardless of the relevance in terms of resource values as 
described on pp. 151 & 152 we remain opposed to any new designation 
of ACEC's. 



- Gec-rjhj 

Rather than prohibit geophysical activity on snow or fro2en ground, 
PAH recommends language consistent with the approved statewide 
Programmatic Agreement for Geophysical Operations. The revised 
Programmatic Agreement currently under consideration states "if 
snow cover in any 100 ft x 100 ft area in the 'area of potential 



359.4 



951 Werner Court, Suite 100 
Caspar. Wyoming 82601 



Mr. Bob Ross 

Page 4 

May 5, 1995 



affect' Is greater than 30%, Class TTT inventory of that area is 
precluded." Industry supports BLM adopting the revised 
Programmatic Agreement language for the Draft EIS. 

Page 79 - Wildlife Resource s 

Industry emphatically opposes the creation of a Controlled Surface 
Use stipulation which would place seasonal limitations on the 
operation and maintenance ol oil and gas producing facilities in 
newly discovered fields. This proposed stipulation would apply to 
approximately 61,000 acres of winter ranges, birthing areas and 
migration corridors (page 191). No justification for a CSU is 
provided in the Draft EIS, other than "additional security would be 
imposed for big game species and their predators . " 

Advanced technology and successful mitigation measures, such as: 
submersible pumps, automated facilities and road access controls 
are used without resorting to a seasonal break in operations. 
Therefore, the Draft EIS must consider advancements in oil and gas 
technology (i.e. introduction of Co2 injection wells). 
Additionally, there is no supporting documentation offered to 
confirm such restrictions would result in any additional benefits 
to wildlife. 



v egetation, and scenic 



On Page 82 - Wildlife, soil and w< 
resoucce_s_ 

Industry cannot support a "no surface occupancy" stipulation ,l.n an 
area with moderate to high potential far oil and gas (1990 Us 
Bureau of Mines KMDA) when the Draft EIS has not adequately 
addressed where mitigation measures have failed in this area and 
therefore, are left with no alternative but to restrict oil and gas 
exploration and development . PAK supports timing 1 imitation 
stipulations where appropriate. 



onomics 



A comprehensive analysis of the socio-economic benefits of oil and 
gas development act iv i t i es in the resource area must be a ma j or 
component of the decision-making process. However, the information 
provided appears to play an insignificant role in the development 
of the preferred alternative. It is obvious at a moment's glance 
that the four proposed alternatives will impact access for oil and 
gas exploration and production. Consequent! y , with each 
alternative, tax and royalty revenues to communities will be 
impacted. 



PAW recommends the Draft BIS compare, 
analysis, the costs of administering the r 



in its socio-economic 
inerals program as well 



359.5 



951 Wornor Court. Suite 100 
Casper, Wyoming B2S01 






Mr. Bob Robs 
Page 5 

May 5, 1993 



as industry's financial contributions to local, state and federal 
treasuries. The analysis must also include a risk assessment and 
cost/benefit analysis to determine whether the benefits outweigh 
the risks of allowing less restrictive oil and gas development in 
the resource area. A copy of the Expanded Moxa Arch Area Natural 
Gas Development DEIS's section on socia-economics is attached as an 
example of a framework to develop an analysis which reflects the 
benefits of oil and gas in the Grass Creek Resource Area. 



Pace 2 73 - Appendix 



Development (RFD) 



Of 



Natural gas is becoming the energy of choice for many because 
its clean burning qualities. Therefore, the race is on to produce 
from areas containing high concentrations of natural gas. Demand 
for gas is expected to continue risinq, as a result of new 
technologies, expanding research and development projects, and due 
to a more environmentally conscious society. However, BLM needs to 
update the geologic information used to develop the RFD analysis 
because it does not reflect recent industry focus on gas 
development. Updated information is needed before decisions 
affecting opportunities to explore for and deve] op oil and gas 
resources are made. 



pa ge 295 - Glossary 

A Controlled Surface Use definition needs to be added to the 
Glossary section of the Draft EIS. We were unable to identify a 
definition in this section. 



Pa ge 2 9 9 - Ref e ren ces 

During PAW's March 20 meeting with BLM, you mentioned that numerou 
publications and sources were used in the decision making process 
However, only 7 are cited in the Draft EIS. All references shouL 
be contained in this section, please review and update. 



Page 2 - Requirement: Surface-disturbing activition vould be 
limited or avoided within 500 feet of surfaae water and (or) 
riparian areas. BIM discusses a 500 foot avoidance of surface 
water and(or) riparian area. Industry has proven its ability to 
conduct best management practices near streams and/or wetlands 
without degrading the quality of water or causing soil erosion. 
The forest products industry conducts its business within 250 feet 
of strcamside zones and has proven, through best management 



419 



359.6 



951 Werner Court, Suite iQO 
Casper. Wyoming H2601 



Mr. Bob BOSS 

Page 6 

May 5, 1995 



practices, natural resources industries are sensitive and 
responsive to maintaining water quality. Unless BLM has scientific 
evidence to justify any avoidance area regardless of historical 
practices, PAW strongly opposes the arbitrary 500 foot buffer zone 
restriction of surface water and(or) riparian area. 

Page 7 ■ Requirement: Based on site-specific env i ronmental 
analyses, surface- disturbing or disruptive activities would be 
prohibited during certain period of the year within 0.5 mile of 
raptor neate or the visual horizon of nests, whichever is closer. 
The factors and decision/decision criteria appear to be 
nonappl Lcable to the requirement and suggest a rewrite. 

Page 6 - Requirement: Based on site- specific environmental 
analyses, surface-disturbing or disruptive activities would be 
prohibited on overlapping and important big game crucial winter 
ranges, migration corridors, and parturition areas. The statement 
contained in the decision/decision criteria where "no exceptions 
will be granted. . .would block or disrupt animal migrations" loaves 
industry with serious concerns. Ridge tops are generally most 
topographically acceptable areas to drill . Wil 1 BLM allow 
occupancy on steep slopes or narrow canyon bottoms in these 
situations? Only science-based focts and decisions should play 
into this proposed requirement. 

page 16 - Requirement: Seasonal restrictio; 

surface-disturbing activities or disruptivr 

uses in areas within 0.5 mile of raptor nests or visual horizon of 

nests, whichever is closer. The "no surface occupancy" restriction 

for biq game crucial winter ranges and "seasonal" restrictions 

placed on raptor nests appear to be transposed. This issue needs 

to be reviewed and corrected. 



genera 1 Comments 

BLM must also address how the Draft K1S will affect existing lease 
rights. BLM policy provides that existing lease rights cannot be 
changed by a new plan. Voluntary compliance to the new plan should 
be sought from lessees if activities are initiated. Regardless, 
BTM should specify in the Draft BIS if and how valid existing lease 
rights could be impacted by new leasing decisions. Specifically, 
potential conditions of approval for operations and other changes 
should bo identified. 

The Draft EIS should clarify RU-rs pol icy on visual resource 
management requirements applied on federal lands or to BLM-approved 
mineral development on split-estate lands. It is PAW's 
understanding that surface uses on split-estate lands are 
determined by the surface owner and not the federal government. 



359.7 



951 Werner Court, Suito KM 
Caaper, Wyoming 82601 



Mr. Bob Ross 

Page 7 

May 5, 1995 



In conclusion, the federal deficit has topped $i ■ 5 trillion. 
Congress must aggressively seek a more streamlined government, and 
work with natural resource industries to promote extraction of 
domestic resources in an effort to stabilize economies and reduce 
the deficit. History has proven extraction of natural resources 
can be accomplished in an environmentally sound manner for the good 
of Wyoming, its residents and its wildlife. 

PAW apprec i ates the opportunity to comment on the Grass Creek 
Resource Area Resource Management Plan Draft Environmental Impact 
Statement (Draft ETG) . The petroleum industry looks forward to 
maintaining its long standing partnership with the BLM. in the Crass 
Creek area and the state of Wyoming. 

Sincerely 



1v ojjiu 'S prima ja 

Kathy Springer ' 



Attachments: 1) PAW letter to Mike Bies dated 7-20-94 

2) Expanded Moxa Arch Nat. Gas Development DEIS 
pp 3-73 through 3-79 



US Senator Alan Simpson 

US Senator Craig Thomas 

US Congresswoman Barbara Cubin 

Governor Jim Geringer 

John Kauchich 

Dave Petrie 

Terry Nimmo 

Claire Mosolcy 



Aa 



PETrtOLEUM ASSOCIATION OF WYOMING 59,8 

a oiria'On ot Rocky Mountain OtlanoGaa Association 

,- .. e flu. inn RcnflW T MMM Ca*y Schulla 

35lWom.(C~n.Sun.1O0 !„<*». D™o» K>H* 

OH*. Wyoming 82801 twm. K c*>t*i IMlSflV 

(307) 23«-5333 Aasooaf OvrcK* AssxiaU Dine** 

fa* (307) 286-2189 



July 20, 1994 



Hr. Hike Bies 

Bureau of Land Management 

norland District office 

p o Box 119 

norland, Wyoming 82401-0199 

Dear Mike: 

Thanks to you and Dave tor taking the time to neat me In Shoshoni 

JS £lk about the nomination of oil fields to the National Register 

5 r^££r."uss ft tt sartas l, s 

d p.trote U m Ur Ass C o°or. e "o" 10 o n f %JSF5m. *• «"" •«■""■" 

clarification to the following Issues: 

n The oil and ga. industry has spent literally millions of 
JLn.S to obtain cultural resource clearance because ve understand 
that B^< has limited archeological manpower. How does BIX justify 
.£?. Allocation of time and resources when areas such as 
southwest iTyo-in, are in 'desperate need of arch surveys for APD-s, 
rights-of-ways, etc.? 

21 Please explain the "need" to examine those fields for "sting. 
iLflfllio fro. Tu>e rhetoric associated with development of land use 
o?ans and organized environmental group opposition to industry 
prelects, we^rc unsure there is public support for designation and 
E ?ir™noe of fiftv year old fields for any purpose. People in 
"'" "S gas industr^ are proud of their role and contributions 
to woming history. However willing industry is to saving 
reprSntalive examples of their lifework for prosperity, .any in 
III general public do not share that sentiment. 

a) Pleas, clarify the benefits derived from H«i»t '^ "'"'l 

' ,y!! „ h. ant Incentives to spur operator participation? For 

Bould there be a„ y i„„„tives to sp p« ^ suoh a= 

ffUft? '«--- as -'-ass 

»?w »n™,?2 clearlv idenUfy, di.cuss and resolve outstanding 
!^ues SiS af^ted'operStcrs'prior to taking action to list any 
producing field. 



359.9 



951 Werner Court, Suite 100 
Casps', Wyoming &2601 



i the 



to handle tne National Historic preservatio 
, consultation requirements to consider 
undertakings on listed districts, sites 



4) Kdw does BLM plan to handle 
Act (KHPA) Section 106 consults' 

possible effects of undertakings on usira bm>vi w.«i b 
buildings, structures or objects, especially when the propose 
operation is the same or similar in scope to prior actlvitieo ..«« 
operations? Specifically, will BUI impose restrictions that 
inhibit an operator's ability to replace or update old equipment or 
to pursue new technology which might extend production? 

We discussed, during our meeting, the idea of a BLH "Petroleum 
Museum' 1 which would highlight local and regional geology, history 
of production, exploration and production techniques and new 
technology. BUt might include identification of benefits 

associated with the energy industry, important events and people, 
and self-guided outdoor tours through historic equipment. Industry 
might know of various oilfield equipment which could be used in the 
museum. Of course we'd have to identify what type of 

equipment/artifacts would best be suited in a "Petroleum Museum", 
where the equipment/artifacts are currently located, who owns then 
and are the individuals and/or companies willing to house then in 
a Museum. 

He also talked about the existing efforts of folks in norland and 
Themopolis who are actively working to preserve the oil and gas 
industry's history. You mentioned Greybull as a potential 

location. Let's try to get together, tour these sites, and talk 
about Industry's role in providing additional 'historic" artifacts 
that would highlight industry's role in Wyoming. 

Mike, thanks again to you and Dave for meeting me in shoshoni. we 

appreciate that BLH recognizes the importance of the oil and gas 
industry to Wyoming, let's make sure we preserve the past, but 
allow for development to continue in the future. Let me know what 
your schedule looks like for a tourl 



Sincerely, 



ec: J.s. Kauchich 
Bob Anderson 



[Included wiUi ttritfJeuer were pages from the Expanded Moxa Arch Area Santral Cos 
DfVilapmtnrDEIS - April 1995--HD.} 



420 




BIG HORN RANCH 

DoLoyd & Lorraine Quarberg 



360 



712 Wait Sunnys.de Linr 



TVurrnopoiis. Wyo 



; 62143 307/«H4.577fl 



Bureau o! t_a"d Management 
3ob Rcss. Team Leader 
PC Bo* 119 
Woriand WV 83401-01 19 



RE: Grass C reek Resource Management Plan 

Dear Mr Ross. 

I tm opposed lo (he Grass Creex Management Plan as prouosec in Ine Draft EIS (EtS) dated 
September 1994 and wish the objection so noted for ihe following -easons 

"he EIS treats agn 

comoaliDle with clt 

be ng singled ou! Ic measure (or compatibility Discnmm alien 

oa'agrapn 1 



as a second class user Page 7 'L veatoc< grazing practices lhalare 
ource management objectives * We question wny livestock grazing is 



ElSooesnol consider the Strateg i c Plan lor W yoming's Ao n cultural Indu st ry 1993-2J0C , (Wan), 
The Plan Nats as a limit. ng lactor of beef production "Federal policies which limit grazing - (Plan, 
page 2*1 and 'Federal land policies 'imit expansion of sneeo ranges' (Plan, page 37) as a 
limitation for sheep production. One of the Plans gcaJs for the beef industry is to insure no net 
Fail of Icosral and stale AUIUIl One goal listed for ihe sheep Industry is lo incnaae stock 
sheep numbers to 1,8 million head. The EIS appears lo ignore the Plan and muleaC of seeking 
io enhance livestock production as ojllined in the =lan it seeks to reduce or eliminate livestock 
g-a/rna 



:he E 5 Suggests improving Ihe 'ecosyst^T 
loesn'l provde us w th maps outlining whici 



" is an important manacemen'. consideration but it 
'ecosysierns' will be managed 



The EIS IpageS) discuss the deve'opmeni of mitigation needs The documenl is unclear as to 
what t.ie BLM considers a "surface - disturbing and other disruptive aclvilies " II is unclear in 
trie definition section whether normal animal husbanary practices such as fencu repair or 
construction water development cr even grazing would be considered a "surface-disturbing" 
activity and would neec to be miligalec 

The EIS discusses management for "biological diversity' wilhoul providing baseline data as to 
what level of 'Oio-diversily" the managers are going to manage lor What measurements will 



Bureau of Land MeBOgcmcfll 
Ma> 5. 1995 



isfu, or unsuccessful'' Is this a Vide to the horizon" 



360.2 



determine whether BLM it 
management goal? 

The EIS on page 35 says that 3 managemer-1 ooject-ve fcr livestock grazing is to "Improve 
forage production ana range conditions to benefit livestock, wildlife, wild horses., and 
watersheds " (emphasis added) Ws coulc find no requirement that wildlife and wild horse 
management be used to benefit livestoc* WHY' indeed we find that in table 16, page 1 76, 
livestock AUMs will be reduced to 43,550 or about 35%. We Question why this cocument tries to 
mislead the public into believing that livestock grazing will be managed to benefit livestock, 
when it is apparent that wildlife and wild norses are the beneficiaries of these reduced AUMs. 

We find the CIS leans neavily in favor of recreation development with nc clear indication as to 
what the potential need tor recreation really is In table 2, page 49, the report wants to enhance 
opportunities for primitive recreation." The 199C State Comprehensive Outdoor Recreation Plan 
(SCORPl suggests thai resident participation in pnmitive recreation activities is stable to 
downward trending {SCQR'f 1 , page 35) Table 1 5 "Assumptions for Analysis by Alternative" for 
'Recreation Management' ipage "53) also pc:nts out that the BLM increase camping by B5%. 
hiking by 81% and sightseeing by '02% over current estimated levels. Again, the 1990 SCORP 
document states that "Noticeable decreases in camping sightseeing, and picnicking is noted." 

The EIS (page 19a) indicates AUMs will Be reduced for adjustments from constraints protecting 
elk, moose, and bighorn sheep habitat, but the'e is no evidence to show there la a demand 
greater than the objective numbers of these species The 1991 Annual Report of the Wyoming 
Game and Fish Department (WG& C ) reveals that the hunter numbers are below the oojeclive 
number in most of the areas near, or adjacent to. the planning area If harvest is not going lo be 
a mechanism for regulating numbers, then the government is planning for objectives which have 
no logical basis. The planning area is not an island surrounded by water It is contained within 
an area where choices can be made For example, the ' 991 WGAF Annual Report indicates the 
following for the State of Wyomirg: 





POPULATION 




HUNTERS 




Objective 


199C 


Objective 


1990 


ANTF10PF 


384.660 


413.243 


90 303 


41.528 


ELK 


73,435 


82.128 


S9.195 


48,810 


MULE DEER 


515,550 


542,793 


156.794 


86,145 


MOOSE 


11,825 


12 767 




1,6/9 1,933 


B'CHORN SHEEP 


8.395 


7 06S 




515 374 



The 199C papulation for antelope, elk, mule deer and moose exceed the objective numbers, 
while the objective for 1990 hunters exceeded t"e actual number ol hunters for the same 
species The EIS is devoid of any information expia.ning what the specific population or hunter 
objectives are for the planning area, whrcr also means there is no indication ol how this 'islanc' 



360.3 



Bureau of (.and MSI 
Pag, 3 



iS going to be managed to reacn those objectives We cannot be expec.ee to guess what 
management is being planned for the area While the EIS refers to a WG&F Strategic Planning 
documenl that document does not identify the objectives for the planning area. Therefore, it is 
impossible to determine how ihe data found in the EIS was arrived at 

In summation, it would aapnar to me that there Is no evicence lo indicate a change in the 
present system is needed. The range is In better shape that it has been fcr "-any years and is 
continuing to improve This demonstrates that the farmer and raicner the stewards of ihe land, 
realize the need for and are making changes lor the betterment of Ine land Wildlife populations 
as indicatea above, have grown lo some of the highest numbers ever recorded in our States 
history, proving that wildlife, livestock, timber, minerals, and recreation car- and do thrive 
together 

The livestock, timber and minerals industry are the users that "pay t _ eir way" regarding the 
pub.ic lanes anc they are ihe ones that are being r estncted or el tninated m some cases These 
are also the industries that contribute most to our economy provding ;obs ana our tax base, yet 
are given the least, if any serious consideration. WHY? 

The emphasis apoears to be 'what needs to be done to increase the wildlife population," yet 1 
lound nc -mention of predator control. The fox and coyote pcp-lalions nave become so 
abundant that tney are rapidly devouring the game birds plus they a r e having an oceasing 
effect on the number of deer and antelope fawns lhal survive. I see this on nearly a daily basis 
on my small ranching ope-ation, surely it had not gone unnoticed in Ine research fa- the EIS, 
why was it ignored'' Is it part of the unwritten intent or agenda that oris of the mam purposes of 
wiidli'e is to f eed the predators and now the even more demanding wolf 

Trlr DRAFT EiS IS INACCURATE. INCOMPLETE ANO INADEQUATE: It NEEDS TO BE 
WITHDRAWN AND REOONr 



rberg / 



RECEIVED 




361 



Bob Ross 

BLM Team Leader 

PO. Box 119 

Worland, WY 82401-0119 



Dear Mr. Ross: 



fay I, 



As citizens of the Big Horn Basin, we truly enjoy the wildlands of the badland 
country that surrounds our home. We, therefore, encourage you to place the most 
emphasis on managing the Grass Creek Resource Area to the benefit of wildlife, 
fish, and environmentally sound riparian areas and rangeland. Wedonot 
want to see the rancher thrown off trie land, but we do want Our land to be strictly 
managed for good soil and habitat Grazing use should be subordinate and 
compatible with wildlife as the top priority. 

Please do not open Wilderness Study Areas to mining, oil and gas 
developement, or motorized vehicle use. These are some of our favorite places to find 
peace and solitude, and we don't want them ruined 

We care about the future of our land and don't want it sacrificed to the oil, gas, 
and mining industry. Pteaseimplement policies that will prevent its degradation and 
preserve it for the future. Yes, preservation is the key to a healthy earth for us and for 
our children 

Sincerely, 

Jennifer S. and Neil O. Miller 



421 



mk 



5/5/95 
Pennoyer and Son Inc. 
Owl Creek Rt. 

Thermopolis, WY 82401 

To. Worland BLM, Bob Ross, RMP Team Leader. 

We have 3 allottments, 0613, 0614, 0615 we own in the Grass Creek Resource area 
plus lease 2 other allottments 0573, and 0575 in this area. Grazing is our biggest concern 
but. multiple use and oil and gas are right there with grazing. From what you have listed in 
parts of the preferred alternatives and other alternatives, there could be drastic economical 
problems in the 4 counties that the resource area management plan, encompasses. Over 50% 
of the other alternatives read "same as the preferred". 

The suitability tables on Pages 251-254 need to be taken out of the draft. If these tables 
are used there would be drastic economical problems for users. Also this information is not 
correct because on one of the actual grazng use 5 year periods we were in drought one year 
and had to take half of our stock to Powder River for grazing. On 2 of our mountain 
allottments these tables show a 50% cut in AUM's. A 10% cut in a spring and fall 
allottment where we hven't even had 30% utilization during the grazing period. We feci that 
your tryim to manage for wildlife and not livestock on the mtn. allottments. We have no 
argument witli the BLM's right to make adjustments in AUM's if they have the data 

0) 
[page 2] 

to support such adjustments, and the data is based on research actually done out on ilic range 
or land. Also another option that the BLM never considered in the draft was coordinated 
resource mangment (CRM), which should be considered if they are looking to address all the 
alternatives in grazing. 

Dad came to this part of the country in 1939 and we didn't have hardly any deer, elk or 
ant. in this area, Now we have lots of game and predators so we must be doing something 
right with our management. But by your Preferred Alternative it reduces livestock grazing 
by 25%, so it look like your against grazing and livestock in general. Like on page 37, 
paragraph 1 under preferred alt. what is the definition, of excessive soil erosion or poor 
vcgitaiion or definition of wildlife nubmers, You can not plan ahead with statement like 
these. Paragraph 3. page 37 you also need data to support this statement. Page 39 
paragraph 3 Preferred Alt. you don't want solid numbers because it locks both the BLm and 
permittee to a solid percent for the next 10 years or however long it takes. Page 40 
paragraph 4 Preferred Alt. seems water development would benefit both wildlife and 
livestock so why restrict it. 

On recreation management Page 52 paragraph 1 in preferred alt. we fee! we don't need 
trailheads or more people coming into this area, we favor Alt. A. Also paragraph 6 on this 
page, the signs are nice, but alot of the 

(2) 
[page 3] 

time they get some people lost in the back country or they use the road in the winter time 
and become stranded. 

Oil and gas exploration has to many restrictions being imposed on them. They bring in 
a large percentage of income to the 4 counties. The mountain country or upper Owl Creeks 
should have more restrictions than the elevations because of the times you can get to these 



362.2 



areas. But what your proposing could cause a large dollar change in the method of 
extracting oil from this area, and all of the land users will feel this economic impact. 

Some mistakes we have found arc on Page 110, themap of roads, the upper road on 
North Fork of Owl Creek is not a County road, page 269 allottment 0573 which we lease, 
doesn't have any developed springs that we know of on 990 acres of contour furrow. On 
page 109 under Land and Realty paragraphs 3 and 4, to your knooooooowledge these are not 
any exclusive easement or agreements for public access to the South Fork of Owl Creek 
across our lands. 

Sincerely 

Pennoyer and Son Inc 

/s/ Arnold Pennoyer 




363 



INTERSTATE PIPELINE COMPANY 



May 5, 1995 

Mr, Bob Ross, Team Leader 
Bureau of Land Management 
P.O. Bo* 119 
Worland, WY 82401-01 19 

Rq: Resource Management Plan 
Grass Greet Resource Area 

OttarMr. Ross: 

WltlWon Basin Initiate Pipeline Company [Willistun Basin), is owner and operator of approximately forty 
miles of underground natural gas pipeline and associated facilities within the Grass Creek Resource Area. 
Due lo litis inlertWl we hereby respectfully submit the following uomrranis concerning the Bureau of Land 
Management's Draft fcnvirormKntal Impact Statement (FIS) for the Crass Creek Resource Area dated 
September 1991. 

Williston Basin's primary concern Is maintaining the ability to satisfy natural gas ma-ke; demands. This 
involves mainlining our existing pipeline tysiem 35 well as possible future system upgrades. Such efforts 
may entail activity in the Crass Creek Resource Area, on pipeline systems currently existing on federal surface 
under -ighl-of-way grant pe-mit numbers WYC-044.777, WYOO*5126, WYW-022025 and W731 63. The 
transportation and marketing «f oil and natural gas via underground pipeline systems is arguably the least 
environmentally disruptive of transportation options. I able 8 on oaga 126 o ; the f IS appears 10 grossly 
exaggerate the potential rone-term impact from pipeline transportation. With modern pipeline construction 
techniques, it is hard 10 comprehend how an underground pipeline ca" impart sucn a soil loss relative to 
activities such as access road development. It is equally puzzling thai such impact can be considered 
permanent given consideration to modem reclamation procedures. Excluding Inc initial, short-term 
construction phase, underground pipelines have very little Impact on visual, noise and air quality values. For 
this rtMOn, Williston Basm would like to go on record as opposing any restrictions or additional burdens 
which may evolve from Ihis scoping process that would eflect future pipeline activity. 



Williston Basin would li 
making process. 



Kespert fully submitted, 

Willistun Basin Interstate Pipeline Company 



o thank the Bl M for providing ihis opportunity to be invoked in the decision 



n Johnson/ 
Manager 
Safety and tnv iron mental Ar'ain 



364 



May 5, 1995 

Bob Ross R.M.P. Team Leader 

Re: Grass Creek REsource Area, Resource Management Plan Draft Environmental Impact 

Statement. 
I think the Wiilderness Study Areas should be abolished. The B.L.M. is trying to create 
these areas and set them aside strictly for wild life preservation. This is not multip le use . 
The BLM is assuming too much authority by way of regulations, restrictions and 
specifications. This is unconstitutional. They (BLM) make policies and pass them off as 
laws.. All policy making should include county and state commissions. Also no cuts in 
AUMs anywhere in G.R.A. The Riparian areas should be left as is for the same reasons as 
W.S.A. Absolutely rjo. fencin g vff of any water or water ways in G.R.A. 

hi Mary Vass 



422 



385 



XXXJtXXXXXXXXKXXXXXXXX 

5/5/95 
BLM_Bob Ross; 

I agree with everything Arnold Pennoyer put in his letter about allotments, 0613, 0614, 
0615. We've practiced conservative stock manage- men t and developed water resources. 
Never have abused the land like some I have witnessed, 

I have watched your different tactics through the years-always trying to change 
something-then an another plan crops up--and still nothing works-I guess. 

E feel the Department of Interior is trying to break the west - make a complete wild 
animal resort - I suggest you put radio collors on all of you plus these different groups 

that know so much - so we can track your bouts. 

I'm totally against this Grass Creek Resource plan - You're restricting our power lines, 
minerals & oil, grazing and everything else. When there is no revenue coming in our four 
counties will be flat busted May your wages also and I hope BABBIT too. 

Sincerely 

f&f La Vonnc Pennoyer 



m( 



BUNtAUOFUSflKftNAGniENi 



366 



MOT SPRINGS COUNTY FARM BUREAU 

, THE GEM OF AGKJCUL HJRE 

51* Vapahnc Street Thennopohs. Wionunj! S21-1" 



Bureau ef Lnml MOM 
BobKoss. 'I cam Lead 
P.O Bo* UV 
Worl.ind.WT H24II1- 



c Miinuccmcnt Plan 



Thu Hoc Spruifc* Co. Fare: Bureau, representing 1 10 members, U opposed cc 
MsflagerMfit Pian 05 proposed in ths Dr.trr E!S lEISi dared Scnlcnibcr l'W-l 
noted for th; FoUowllW reanuns 



Tnu EIS Itcols ugpncalture as a second d 
Wl(Jl oilier resource man^cment obj«eu 
measure Tor wwontihilicy Discnminam 



i uwr Hag? 7 "Livestock |rumg pflfltlOW tbflt .lie Jottip.1l ill le 
i " We question v-tn iiicsto;k pjay-inj; is beiiui singled out to 
It continued on pafjc 14 paragraph 1 



FI5 does not consider the SlMtW C r|; ir. IW U vnmm.;':. Agricultu ral Industry l'JW-3['HH) (Pl.ui) The 
Plan lists as a Iboltlttg lac-lor ol'beel prediction "federal policies which limit fira/mg" (Plan, page 24) 
and "Federal land policies limit expansion of she*)} ranges" (Plan, pa^e 27) ds a limitation for sheep 
prcdui-liOn One pftive Plans (joal? for theheef industri is m insiucnu net less of federal una stuie AU'NU 
One goal listed to; the sheep industry U to increase stock sheep number," to 1 j rmllinn head. The ElS 
apjwuis to ignore lite Piia and instead ufwwkittg ;e enhance Liva Slock erodesta as outlined ir. the Plan 
it seek) to reduce or eliminate livestock gfazBijj. 



The EIS liuggelll improving iJiL'"ci:(jsvstcnw' is an 

proiidc us with mapi outlining which "ecosystems' 



management ijoiisiJcjuIlOii 



TlwsEIS (pageS) discuss (hodowiopmeniof mltigMlOII needs ThefkwunWttU m unclear as to «hat the 
BLM considers a "surface - disturbing and ether disruptive BOtiVitK*" It is unclear In the definition 
(eetion whether normal annual husbandry practise! such as fence repair or construction, water 
development or even paring would be considered 3 "smlaie-diilurhtog" aaivit\ nnri would need to he 
mitigated 



The EIS discusses BaaBflSCTW 
of "bie-divarBtj." Ihc mariBgorj 
Bl.M is successful m 



divcrsilv " without providing baseline dl 
anuus I'm Whlll nwlWtireiueBti will dele 
fill" lsrrusa"ndeuithehuii/.un"uiiuiiisi.-menL(|oal7 



' b-.c'.Of.K:. 
e cuing to 






The EIS on page 3? says tha; a manjeei'jerit objetlne lor livwKSik grading is to "Improve forage 
production and range conditions lu benefit lnwtwk. wildlife, wild hurjes. and wuk'ndiL'ds." (emphasis 
added). Wa could Tine no requirement that wildlife and wild horse monnjiomciit be used to benefit 
livestock WHY'' Indeed we find tnat * table lii.pa^e I7n. livestock AUMs will be reduced 10 4?. 850 or 
«VoUt3i% We question w!i> thi.v document Irici to uuslead ihc public into believing that livestock 
(raging "ill he managed to benefit Itvewwli, when n if uppurum thai wiUllil'e and wild hof.W are the 
henclici.ViM of tlie.se reduced Al uVb 



366.2 



Bureau of Land Management 

Page: 

MayS. 1995 



We find the HS leans hea^Jv in Tavor of re ores lion developOHnl with no dear indication as to what the 
potential need for recreation really is. Ir, table 2, pa fi e 49. the ruport want! to ■ enhance tippoaurutios for 
pnm.Uve recreation ' rhe 1 990 State Comprehend Outdoor Rcereaticn Plan <SCOKP) siMgCWB ihut 
resident pameipatinn in primitive recrcatwn activities is Mabls to downward trending tSCORP paga 33) 
Taolc I S "AHunptiorM fa, Analvais by Alternative" for "Recruattcn Manawinenf (pane I S8j alio pOtflK 
out thai the BLM inoresu camping hy B5%, liiking by *1% and stghismng bv 102% over QWrcnl 
csumated leveb Again, the WO SCORP dormant sates that -Noticeable decreases ir 
sightseeing, and picnicking 13 noted " 



11 i.::iiiipiLij.. 



The EIS (page 190) indicates AlTMs will he reduced for adjustments from constraints protecting elk 
moOSC, and btshorn sheep habitat, but Ihore is no cadence to show there is a demand greater than the 
objective numbers oftnwe speetes. Tlie ['m Aaaual Rcponof the Wyoming Game and F, s h Dcparlmcnl 
{WG&rl reveals that the hunler nilnibers arc below ihc object! vc numbet tn most of ltd areas near, ttr 
ad,aceni |o. the pianning area If harvest is not going to be a mechanism for regulating numbcr.s. then the 
government is pianning for objectives wliich have no logical basis Tho olanr.ing area'is nut an island 
surrounded by water. It ,. contained williin an area where choices can be made' For example, the W\ 
WG&F.^ruiual Repcti indicates the following for the Slate of Wyoming 







POPULATION 




H LITERS 




Objccti-v 


e 1990 


Object! v 


a 1990 


ANTELOPE 


3ti4.,fi60 


413,243 


9t),303 


41.538 


ELK 


73,4.15 


8-i. m 


59,195 


4a,sio 


MULE DEhK 


5)5,1*0 


5-12.7'j:- 


156,794 


86,145 


MQt?5E 


J L825 


12,7-i? 


1.679 


Iffli 


BtGHORK SHEEP 


8.39^ 


7.U69 


515 





The LWO population for amdopc, elk, mule deer and Diuoae exceed the oblcclive numbers while flic 
objective^ 19^0 hunters exceadud the actual number of hunters for the same species Tile EIS a devoid 
of any information calamine what the specilic population or hunter objectives arc for the planning urea 
which also means there is no indication of how [Ins "wUna"' >s going to be managed to reach those" 
objectives V\ e cannot be expected to guess what management is being planned for the area While the 
EIS refers W a WGif Strategic Planning doeumeni, that docmncnl does not identify the objectives for 
the plann.ng area Theroiwc, it is impossible to dciennms him the data found ui the EIS was arrived at. 

THE DRAFT EIS IS INACCURATE, INCOMPLETE AND INADEQUATE It NEEDS TO 8P 
WITHDRAWN AND MOONS 





367 



Bob Hobs 

BLH Team Leader 

P.O. Box 719 

Norland , WY 82401 

COMMENTS ON GRASS CRELK PETS 
Dear BLM Grass Creek EIS team: 

Pluase accept Lhe following considered opinions to liulp rorm 
you final management goals for thQ Grass Creek reaaurce area. Although I 
live in "urban" Cody, I spend a great deal of time in the Owi ccee* 
Mountain* iJu« to their unique qualities, and the Badlands of thu central 
Big Horn Basin in the Fifteen Mile basins are also personal favorites. 

BIG HORN SHFCP HABITAT: I Full well believe that upper DhI 
Creek (both forks), Cottonwood Creek, and otlier areas on the east slopes 
uf the high Absarnkax have supported much larger Biy Horn sheep pnpij- 
latiOfW in centuries past than rjun Ijhh seen today. My feeling is that 
abuses in the late 19th and early 20th centuries from domestic livestock 
qrazers all but eliminated the resident Biy Horn populations east of the 
Washakie Needles/ Twin Peeks, Because of" uncontrolled and unscientific 
grazing practices by the early explti iters, the entire range formula fot 
Big Horns was hopelessly skewed against them, an wh 1 1 as other big game 
species. The BLM Grass Creek plan should offer a more substantia goal 
of Sig Horn sheep recovery by reint reductions and habitaL improvements, 
even if that means a net loss of high country summer grazing AUMS. 

Still visible today in the Owl Creek Mountains are tha 
remains of pre-Columbian big horn sheep traps; converqjng lanes uf 
deadfall fences leading into capture areas. Therefore, Biq Horns once 
roamed over a larger area , and should be yivan the opportunity to da sa 
in the future, to a greater extent than any of the alternatives proposed 



1 Mi 



i» Mi. 



PREDATOR CUNIROL: I cons 
to control predator populations to bi 
yet I sue nut ui le wurd in the DEIS about predator 
nmnitl.pri tin piirpn-ie? Is it 
is hard to comment on someth 

My greatest cor 

mflnnnempnt. nl' Mountain Lit 

respect to deer herds and 



icern on the predutor iss 

populations in the Dwl Cci 

ie aforementioned fiiq Horn t 



ie is the sound 
;k Mountains with 
leep situation. 



OIL & GAS LEASING: In recent decades I have been disturbed 
t.n hhe point of outraqe over the BLM's indiscriminate issuance of oil 
leases in the Upper Dwl Creek urea. Abuses and/nr lank of enforcement of 
en ironmental st ipulations in the past should not be ullawed to become 
status quo policy. Please recall the high elevation F isher rig that s«t 
on top of the north fork of Rock Creek in thu S. Fk, of Owl Creek 
drainage in sight of the Washakie Needles in the early 19B0's; and the B- 
WAB rig which drilled an the North Fork of Owl Creek near Sunnr Loaf 
Mountain (on a State lease). Neither of those rigs should have been 
allowed surface occupancy f but for different reasons...) In the case of 



423 



367. 2_ 



DT.J5 Comments/ Page Z 
the former, the rig was allowed to "winter over" un \\j\e. rL^f^jBinivv 
11, £100 feet, and numerous environmental abuses went unreparteo, .such m 
Fuel spills, for lack oF supervision and enforcement- It was a half- 
baked ill concieved idea Lg allow the riy up there in the First place. 

Vhe B-WAB operation obviously violated Eagle Nest Hanch 
property riqhts when the oil company was allowed to Force a road thru 
trie middle of the ranch, thru tlin middle or the buildings even! across 
private land in order to reach the state lease via QLM roads and lands. 
IF there was ever un abuse of uil leasing overriding other LnfclNNNba* 
you need to look no Further than tagle Ni*sl HHnch, llw] Creek... 



I have a ver^ 
the oil companies recent' 
opportunities In the Gru 
dollars in tax revenues 
because of leasing rest 



hard time swallowing the argument stated by 
Lhat they are Liuiny -^hurt changed on leasing 
s Creek area, and that tens of millions of 
'ill be lost to local und county governments 
ictiuns- The "BIG PICTURE" of uil and gas 



leasing activity in recent years and the petroleum industry's past and 
present operations on at all level in all locations (including offshore 
and international ) make;; tht-ir arguments rather hollow and self" serving. 

The oil industry is lobbying hard to retain leasing oppor- 
tunities un every square millimeter uF lund everywhere in the Grass 
Creek area and elsewhere, even when they know Full well that exploration 
and development impacts other resources in a very negative way. The 
proposal to aJ low leasing on all Grass Creek lands apart from Wilderness 
Study Areas is abhorrent, period. 

For starters, the BLM needs to eliminate lease options near 
all areas uT Critical Environmental Concern (ACEC's) with appropriate 
buffer zones- Further, exploration should be denied in the upper tlwl 
Creek area foothills, highlends, and above timberline. Another real sore 
point is the waiving of No 5urfHc:e flccupancy (NSO) st ipulaL ions in the 
past. Any NSO's should be inviolable once issued, and should be issued 
lather liberully with regard to other resuurCBs. There are simply BOM 
locations that should nrver have drilling rigs allowed under any circum- 
stances. There is still plenty of leasing acreage left for the oil 
companies elsewhere in the Grass Creek resource area without creeping 
into the mountains, towards crucial wildlife winter range and other 
areas of high intrinsic value. 

GRAZING AND RANGELANOS: The Grass Creek plan needs to be 
very sensitive about gracing along riparian zonae; unrl the overall yuul 
should be managment to improve range conditions which are presently 
degraded or unbalanced. Given the extreme difficulty of educating 
ranchers, the BLM should nevertheless attempt just that. The "old wHy" 
of banding herds and flocks won't work anymore. Cowboys and herders need 
to stay with their stock on a Z4-hour basis 7 days a week and keep them 
moving at all times, working them to the best advantage of the land, and 
treating riparian areas like luxurious Beverly Hills restaurants instead 
uf free-for-alls;. Rnnge conditions need to be improved in almost every 
Hrna of the Grass Creek resource area that I have ever visited. One 
excellent tool for this goal is the steadfast use of a 50-year burn 
cycle on areas where vegetation communities have been altered due tu 
past fire suppression. I would hope that the Fll H could find a w«y i\; 
streamline Lhc Environmental Assessment f'rocess and up-Tront puperwurk 
intertiH to allow range cons and ranchers to actively pursue effective 
controlled burns. 

-le management 



tools 
plan to see that, paper* 



becomes real work 



st-tr 



367.3 



GRASS CREEK DEI5/ Pag« 5 
Grazing and range land*/ cont'd: I generally applaud fjt)i^ S-W'-S^ 
proposal in the DEIS to reduce grazing allotment levels to moi K leajisiie 
qui.ii.Hs that better reflect actual AUM useages. It is a step in the right 
direction towards reorienting the entire grazing program to fit tightly 
the carrying capacity oF the lands. I would hope that the BLM ha:> unuugh 
personnel and resource to actively immi tnr grazers and herds throughout 
the forage season to ensure compliance with dynamic goals. The thought 
had also occured tn nip that the local gracing advisory boards which have 
some degree of control and a great deal of input over decisions regarding 
rHnge allotments should «y a matter of |iulicy include at least one 
member who is not from the graying/ rRnching community. [ believe it is 
important that all resource users have direct management input in 
multiple use areas. Non-extract iv« resources and nun-income producing 
resources should have active representation on advisory boards and thru 
the BLM hierarchy. Wild! i f'e, recreation, and cultural resources deserve 
a role in discussions determining range allotments. 

One last comment on gracing; Don' t give into the temptation 
to adopt the Alan Savory "holistic" gracing approach wholeheartedly . 
Savory's techniques should be treated skeptical ly. The premise that yuu 
can place larger number of cHttle on grazing tracts and rotate them thru 
a cycle which actually improve;. rHncje carrying capacity and outs more 
weight on cows is one of those "tou good to be 1 rue" orrerings. Tf it 
didn't work in South Africa, what is he doing in America? The Savory 
"holistic" approach is largely smoke. 



GFNFRAI COMMENTS: The Grass Cret 
lands which are uniquw in many ways, and are 
predated outside the immediate area. Spectacu 
with a good mi x of historic and scenic value: 
the area are its greatest strength 



resource area contains 

arqeiy unknown or unnap 

ir geology and landForms 

plus the "openness" of 

rely hope that the BLM 



recognizes values other than rial lars when weighing alternatives to 

mana^nent actions. There is entirely too much political pressure being 
applied from local (county) and state (Rnvprnar's office) levels to 
develop any and all extrectable resources, soutTer rather than later. 1 
strongly believe that wildlife, cultural, and non-dollar intrinsic 
values get compromised when corporations coming demanding oil and 
1. imber and mininq leases; and more AUM's Tor their berely-profi table 
yrtui'iy programs. As I have indicated, I believe oil A gas are better 
developed elsewhere than sensitive 0w3 Creek/Absaruka foothills regions; 
livestock const i lute exotic alien spec ies und slmu id not be given so 
much "clout" in alluculing limited resources; and rangeland "repair" in 
urder to invest in the future makes more sense presently than high 
sustained yields of QrUA and a general degradation of the overall 
carrying capacity and alteration of vegetative communities uwuv From 
natal Original plant communities. 

I cannot overs La t^ the need to revisit criteria For Fostering 
Dig Horn sheep popultions, and working on the deer herds as well. Also, 
the day is not Far oFF when Grizzlies will be Found in the upper Owl 
Creeks and Absaroka front.. Not one word in the DEIS about that very real 
contingency, yet there will be "bear problems" an soon as this year. And 
we need to get realistic alxiut the place of the Mountain Lion in the 
ecosystem. Finally, I need to emphasize that greater consideration be 
given to setting aside more primitive/non-motorized ureas. 

Of the limited choices offered in the DEIS, your Alternative 
C most closely fits my concepts of the best management plan. 

Thanks for the opportunity to have some input 



I 



ayy 




368 



I'JEEAU OF UND KMJAGEW* 1 , 

'■"""•Lja )>., ^ d::r. ^ss 

Grace Creak ?-rs« D:*.L- Sli 
P.O 3cx 119 

War-land Wy 824C1-0U9 
Fax !307) 34": -5195 

r object. _ i. a she si^nifli 



individuals (ud ^usecuentlv co C hi c« blsef ^ , ff S :?J **? B '- 



- appreciate th 
Grass Creek Are 
comments be] ow. 



oppcT-tu^ity to cor.tribuxy to th 
itevlronmeiical liasact Statement. . 



Y I ^icort an r. 
aa« ftr.d my 



I object co the redueeior 
Alternatives , Rsal 

management decisions cr. each iljocffiea" 
established and stated. 

r ocjert Co the 



02 Grazing A'JMs proposed in Che 

cer.fi sciantizic data should be uaed co make 
Targets should he clearly 



e^arision uf "Wild Horac HaBagemenc " areas 
ORMHQd ellminacir-c ail -Wild Horso tonaqeire?.- ■■ areae ir.'th« 
Return all wild anintai maangeirenC co th 
'- return all managed wiaal prcduccta 



Oraaa Creek area rm? 
State Game ar.c Fish. a_*. 
tfle Frivate sector. 



Eton to 



a .r.c va-.i. co_.ect.un prcc^dur-s cited .or k^\ 

and suitability, rfcia snould be completely 



" ofcioct to che 

nrxpanaion , 



imcur.t cf Land cnr.s_ 



redone . 

rsd ;or luteurban 



IJtZiZZ* " lc l 7* c " »"«««WB about impacts to the valuj 
private, nati and county lands bv the vancus alta-a-i 
Specially those itcbedded with the am Adminiaterec- Undf 



ct to raotrictiona time hamper Che cuzzvr.z pr.nu-/ buaineaaafi 
oee federally adminietered land, T t c ,re 
r caiirrunicies Chrough "axes. 



generate ir.come and suppc 

objecr. co the severe a;:d undue numbe 



a 2- 3urfac u w «ur&MflB -in all or the altemativee. ' Mot JnouS 
«m»s^ haa been placed on new cechnology and new •nfoSitSS fe 
ra_Ci;ja»8 a---d reclaim ar.y impacts. 



bias ffw* recrestion dxatMroance 

, grazinc; and recreation. 



I object -o cha 



d - he bias 
w(s_-e*cion, 

aket reetrietionji cencaxned in cff-Raad 



368.2 



-■itm-Kt, a; ? , ■:..»' ioe- ^nux-^l : 'it<i'itr^etff',^SL 



se^J'r^^ 



A2A 



RECEIVED 



HW-8BGS 



3ii 



Linda Reynolds 



May 5, 1995 



Mr 



Rons, 



I am writing to comment on the Or a* s Crettk R»»oure« Area 
Resource Management Plan Draft EIS. 

My main nnnoern with tha document is that the entire Resource 
Area is to rum* in upen Tor 04C leasing. I have had peritonei 
experience with the Bffioftey of NSOs and other stipulations on the 
North Fork of Owl Creek. As soon as an oil company wanted to dri U 
m wildcat well in a particular spot, tha NSO on the situ wuu waived 
by BLM decree and the stl pu la Lions meant to protect the aoc«BS 
route were large I y ignored. Thus, al though the current dODUDCnt 
appears to he protecting sensitive areas with restrictive language, 
T am now fully aware that all it takes ix a stroke or the pen to 
remove these stipulations and allow unimpeded access to Industrial 
deve lopment. . 

Likewise, where the E1S appears to be proposing seasonal 
restrictions on certain ureas to protect wildlife habitat, the 
small print reads that these restrictions are Tor exploration only 
and would nut. apply to a production scenario. 

What is this Federal mandate l.u open all public land to O&CJ 
leasing"? I would sincerely appreciate a copy nf such a document for 
my files. Please send it. to me if you Qttn. In any case, you state 
in the introduction to the E1S that "public lands would remain open 
and available for mineral exploitation and development , unless 
doing otherwise is clearly in the national interest." The BIS 
identifies several important sites within the resource area, 
including Wilderness Study Areas, ACECs and NNLs. If these areas 
are of sufficient merit to justify these special designations, then 
it seems clear to me that it is in t.he national interest to protect 
them from industrial development. I have learned that withdrawing 
lands from leasing is the only course of action that will actually 
accomplish this. And from the point of view of an oil company, this 
aeems only fair. They pay good money for those leases, which ought 
to entitle them to access and the right to explore and develop. 
Removing the must sensitive lands from leasing would make the whole 
system much more straightforward. Even if all available land in the 
Resource Areu is already leased to 0&.G , it hardly seems premature 
tn set an objective to withdraw these sensitive areas as the 
current leases expire. 

A common objection by industry to this type of action is that 
these lands will "forever" be "looked up" and closed to extraction, 
development, etc . The important point tn rememher is that closure, 
even something as concrete us wilderness designation, is by nature 
temporary. Tn a national orisi s Congress can certai n I y revoke 
wilderness designation in favor of resource development. Right wing 
elements in society today are even proposing opening National Parks 
to •xtTwotiva industries. Political climates change with the wind. 
what doesn't change so easily, especial I y here in the arid West, is 



369.2 



the face of u 1 andscape that has been subjected to industrial 
development. Roads can be blocked off, but how many hundreds of 
years will it be, even if the land is recontoured, before the scars 
are no longer visible? It takes generations for trees to grow, 
riparian areas to heal, mineral pollutants to dissipate, erosion to 
stabi Use, Protecting f ragi le lands is simply a common sense 
conservative approach . Let future generations make their own 
decisions, based on their own economic imperatives. Lets leave them 
some al ternativee ■ 

To summarize, I suggest that the WSAs , NNLs and ACECs , as 
designated in t.he preferred alternative, be withdrawn from any 
future oil and gas and mineral leasing. Barring that, T support the 
more extensive NSO designations recommended in Alternative C. 

It was unclear to me what designation the BLM would ascribe to 
the WSAs in the event they failed to pass Congress. I think they 
should be protected by the most stringent restrictions available 
under the new plan, and in any event should be accorded roadless 
status . 

I support the proposal to require paleontological surveys in 
areas of known or suspected fossil deposi ts , These are a national 
resource, and this part of Wyoming is world famous for its fossil 
beds . 

L was concerned wi th how little protection was accorded the 
two pctroglyph sites. These are Native American sacred sites, and 
tha sac redness extends beyond the rock faces on which the 
petrog lypha are inscri bed , The whole area is sacred. The 
surrounding land is sacred, the vistas are sacred, the vegetation, 
the water and the fauna are sacred. Of course there are existing 
roads, fences, gravel pits, oil wells, etc in near proximity to the 
sites. That can't be helped. But I think these holy spots deserve 
more than a quarter or ha I f-mi 1 e buffer zone from future 
incursions . I hope you will make every effort to engage the 
Shoshone and the Crow peopl e in any decision making process 
involving these and any other aacred areas . Again I take the 
conservative stance: protect it today so that there remains the 
possibility of more informed decisions in the future. 

As far as land use and access, I generally support Alternative 
C. I think it iB important to designate significant areas of ROW 
avoidance, as well as designating ROW corridors, X also think that 
as far as public access ROWs are concerned, greater emphasis should 
be placed on securing non -motor! zed accesses i n preference to 
motorized ones . Private landowners have a lot more trouble with 
vehicles crossing their property than with riders or hikers. 

Alternative C also had a better proposal for dealing with land 
exchanges than the Preferred Alternative. I don't believe that 
public land should be sold. I think it should only be exchanged for 
land of equal value. But Alternative C goes one step further and 
requires that there be no net loss of crucial wildlife habitat. T 
support this concept , though I would like to see more specific 
wording than "crucial wildlife habitat". I would include wetlands 
and exceptional scenic areas as types of land that should remain in 
t.he public domain. 

Finally, T would !1kft tn make one additional general comment. 
I would like to see road-building and its impacts analyzed 



369.3 



separately in thi s type of planning document . Oil and gas and 
mineral exploration, public access logging, and other activities 
often result in road building or upgrading. Even if on attempt to 
reclaim the road is made, the visual scars and erosion and 

vegetation changes endure for decades. Often a request is submitted 
by landowners tu retain the road. Usually unce the thing is built 
it continues to be driven on. In a lot of the resource area all it 
takes is a few trips wi th a pickup and you have a two -track, 
resulting from boII compression and vegetst ion di 8 t urbane* , that 
becomes an invitation for the next driver to follow the snme route. 
Upgrading a two- track into a reasonably passable road brings more 
people to drive on it. 

The chain of events is as follows: Stage 1- No road- pristine 
1 and scape , game and stock trails . Stage 2- A '1 -wheel drive road 
leads up into the mountains, accessing cow camps and hunting camps, 
with unrestricted public access. Stage 3- An oil company decides to 
try a wildcat well on their BLM lease and upgrades the road. Stage 

4- Landowners , enraged at the oi 1 company , the BLM, and the 
increased public traffic on their road, put up a locked gate. Stage 

5- The public can no longer access B1.M and National Forest lands, 
is St loggerheads wl th the landowners , and the fight is on . 

Tli is is precisely what happened on both the South Fork and 
North I-'ork of Owl Creek, upper Cottonwood Creek, and in innume ruble 
other places . Meanwh i.le the BLM has been unwi 11 ing to take 
responsibi lity for the pivotal role that it plays in so many of 
these scenari ns . Ro ad building in probab ly the s ing le itioa t 
destructive acti vi ty that 



akes place 



iiesmj 



compromises everything from scenic values, soils, watershed and 
wildlife habitat to human relations and traditional land use 
patterns. And yet nowhere in this EIS or any other that I have read 
is it given even a paragraph on its own. 

Road-building and upgrading shciuld he analyzed on both a case- 
by-case basis and cumulatively, The domino effect of increased 
human access should be evaluated arid disclosed as part of t.he 
public process. The Resource Area should have goals in relation to 
roads on public lands. No net increase of roads might be a 
realistic objective. Different approaches to O&.Cl exploration could 
he considered, such as allowing access to certain sites only during 
winter with a snowpack and frozen ground. The Unimat system, which 
was used on niy property on the North Pork of Owl Creek, also has 
certain things to recommend it when it is taken up in a timely 
fashion. There are other access solutions besides building ruada , 
They may seem expensive in the short term, but in the long term 
future generations will thank you for them. 

I hope my comments will be of interest to you and help you in 
preparing the final BIS. 



""' 'M^-yU-'^ 



370 



BLM 

Bob Ross, RMP Team Leader 

P. 0. Box 119 

Worland, WY 82401-0119 

RE: Grass Creek Management Plan 

Gentiemen: 

1 appreciate the opportunity to contribute to this very important issue of Environmental 

Impact in the Grass Creek area. 

It is generally agreed that safe-guards of the environment, land values, history and other 

aspects need to be considered and protected. However, I feel this is currently being done by 

the BLM through its Standard Lease Agreement Section 6, the State DEQ, and other 

agencies through normal rigorous permitting processes. Additional blanket restrictions, such 

as those proposed in the current draft, are harmful and unwarranted and unnccded. 1 must 

object to the apparent lack of consideration given to the impact these restrictions could have 

on the oil and gas, livestock and timber industries. These businesses contribute a great deal 

to the tax base of many cities, towns and counties in the NW comer of Wyoming. 1 would 

hope 

Ipage 2 1 

the BLM would not want to be responsible for a loss of these industries. 

1 would recommend that a new preferred alternative be created with input from 

knowledgeable community members and representatives from livestock, grazing, oil and gas 

and minerals, limber and local and state governments. 

Thank you for this opportunity to respond 

Sincerely 

/s/ Carl L. Bassett 

XXJtXXXJtXXJtXXX 
XXX XXX XXXXX X XX X X 



425 



371! 



XXXXJLXXXXXXXXXX 
XXXXXXXXXXXKXXXXXXRAXX 

xxxxxxxxx 

May 3, 1995 

Worland BLM 

Bob Ross, Team Leader 

Box 119 

Worland, WY 82401-01 19 

Dear Mr. Ross, 

I am very concerned about the Draft Management Plan for the Grass Creek Resource 
Area of the Big Hom Basin. I think that the Plan should be completely rewritten. There are 
several reasons for this. Under the current Plan, there is little concern for the livelihood of a 
great many people. In additional, the reduction of the lax base of Washakie County, Park 
County, Big Hom County 
[page 2] 

and Hot Springs County would be severe. It doesn't seem fair to write off the 46,900 people 
who live in those counties. 

But even if the people are not considered, the current Plan should be rewritten because 
as il stands now, the strength of the United States is being reduced. This country is great 
because of its resources and its people who are willing to sacrifice for the good of the 
country. By limiting access to the country's resources, wc become ever more dependent on 
some one else to take care of us. 

Please rewrite the Draft Management Plan for the Grass Creek Resource Area. The 
resources of this area may be needed, and the people of this area which to continue 1o make 
a living without unnecessary interference. Sincerely, 

fat Ruth Ann Gardner 



HW-8B96 

Sob Roes 

3LM Tea-. Leaier | BJHOUi OFlANOJIHAGEv; 

l-C Box 11? 

Worland, .'.'¥ SS^SI 



372 



Pater Lcvuech 
PC Box a 06 
Drigge, ID 33422 



7 an writing about the Graas Greek ftetiourcc Area. 
I find your agency's plan for this area to be unacceptable. 
This ares neads more protection at this crucial time. 
Your prorosal to open WSAe Owl CreeW, Sheep Mountain, 'Aed 
Butte, and Bobcat Draw to minerals mining, motor vehicles, 
and other damaging or extractive industries is shortsighted 
and needs to lac terminated HOW. These areas need to be 
managed to retain their »J 1-dernees character. Regardless 
of the whims of Congress, YOU need to protect thece vital 

Furthermore, you need to designate mere of Grass 
creek as Semi-Primitive, Non-mo-.oriz^d, Demand for these 
tyj.es of areas la on the rise and will continue to rise. 
Don't fall prey to industry and politicians cries for 
more land to exploit. The public needs wild, unroaded 
lands as much ac the animals that live there do. We need 
to preserve as much of this fjreat national heriVigfl as wo 
can. Ths people and the critters that follow depend on it. 

I b;e in support of the wildlife prescriptions in 
AT tern ative C. I urge you to folio* this alternative or 
one that gives more protection to the wildlife and wildlar.ds 
in Gr&ss Creek. The other Alternatives anc the one that 
you recommend, are a disar-tar. You arc mandated to provide 
■multiple use'. On reviewing your plans, one thing cams 
to mind: •'multiple ABUSE' ! Please change the course of 
this 111 fated mansion. The future of GrariK Creek and all 
of Wyoming depends on you leadership. 



&P4tcu-~x^ 




"""'""'"* Wyoming State 
Grazing Board 



central COMMITTEE 



Mr. Ron Rtss Tewm Leader 
Grass Crsslt RM? 'Draft ETS 
FOB 119 
worland. wyo. 8;i01 



\ 



o ■ o 



These comments ar = in addition to the comments I presented at the 
Hearing held in Worland last month on this document. 

With respect to ;he information in the document on page 132 on 
acres of riparian habitat m "functioning condition", or not, my 
comment is that I can find no support outside of th* hlm in the 
range science technical community Cor the checklist approach to 
determine whether or not a riparian area is "functioning" oi not. 

In addition. I have dismissed this Item with a number of rirass 
Creek permittees. Very few remember being asked by the Worland 
BLM to participate in the evaluation of this item in their 

allotm»nt(e) . 

Foi these reasons, I ask that you withdraw the information in 
this BIS/RMP on riparian functioning condition until such time as 
the BLM agrees to use a technical method accepted by the 
consensus of the range science community. 

With respect to the Table on pagf 133 nn Desired Plant 
communities. It is presently BLM policy to require documentation 
that e proposed desired plant community is, in tact r possible to 
achiove or. a aite prior to it being proposed for that site. 

This HMP proposes a nurobei- of desired plant communities Without 
providing any support documentation that they are technically 
possible to achieve. Pleast flitho] withdraw the proposed desir&d 
plant communities in the RMP, or provide the support, informal ion 

a Final a«p that the proposed desired plant communities are 

act technically feasible. 

Also,, a number of permittees with Whom I have discussed this 
it-siiri do not recall having been consulted with prior to the 
publication of the Draft RMP on this subject. If they were not 
jrcOpsrly consulted or, this matter, the proposed dasired plant 
opmmimit ififl have been developed by the bi.m m violation of the 
letter A spirit of the Public Rangelands Improvement Act of. 1978. 
/ 



373.2 



The inventory on which the Information on range condition is 
based 15 inadequate for this purpose. The data on which these 
assumptions of range condition are based la too old to be 

considered current for the Grass Creek Resource Area. This "data" 
should be removed from the Final RMP because it can not be 
confirmed that the conditions stated tor each allotment are 
correct for the early 1990 period. 

in addition, the ea,rly 19B0 period sviM procedure used on the 
crass creek R.A, only took actual field data on plant composition 
by weight from 20% of the sample areas identified in the pre- 
planning stage of the inventory. It is :nappropriate to try and 
extrapolate plant composition data into the other 80% of the 
sample sites for the purposes of estimating range condition in 
this Area. For these reasons, all references to range condition 
should be removed from the Final RMP. 

The information on "suitability" was developed by BLM staff as an 
office procedure in the early 1980's period. The information in 
this Draft rmp has no support from the range science community, 
is based on an invalid technology, and should be withdrawn from 
the Final RMP. 

With respect to the utilization standards in this Draft RMP, I 
can find no support in the published literature to confirm that 
management of rangelands under these standards will accomplish 
any of the stated land management objectives. They should be 
withdrawn in the Final rmp and replaced with objectives based on 
a state of the art technology accepted by the profession. 

A number of the definitions provided in the GLOSSARY do not 
confirm with the definitions published by the Society For Range 
Management. Please remove, and/or change, those definitions that 
are not consistent with the srm publication on this subject. 
Attached is a copy of the cover of the most current, srm 
publication for your information and reference should you wish to 
obtain a copy from the Society. 

Thank you for considering these additional comments . 



KX 



Dick Loper, Consultant to hsgb 



426 







373.3 




A Glossary of 

Terms Used in 

Range Management 






Third Edition 
Compiled and Edited by 

Glossary Revision Special Committee, Publications Committee 
Society for Range Management 

Peter W. Jacoby, Chairman 

Published by 

Society for Range Management 

1839 York Street 

Denver, Colorado 80206 





HAY - 8 I 



MIKAU OFI LMO IIMAGEBEKT 



374 



Wilt jam J. Barmore, .lr 




May 5, 1995 



Bob Ross, Team I.cader 
Bureau of Land Management 
P.O.Box 119 
Wurhmd, Wyoming 82401-01 19 

Dear Mr. Ross: 

Thank you fur sending me a copy of the Grass Creek Resource Area 
Resource Management Plan and Draft Environmental lim>act Statement {DPEIS). 
I wrote the following page specific comments, suggestions, and recommendations 
as I progressively worked my way through the document, thus some duplication 
probably occurs, for which 1 apologize. In addition, in the interest of brevity 
(!).I have not commented on those extensive portions of the DPEIS which arc 
well done and with which I agree, but rather f concentrate on what 1 believe to be 
shortcomings in the document; on analyses, interpretations, and management 
recommendations with which 1 disagree; and on suggesting changes in the 
preferred alternative that I believe would better provide for the public interest 
over the long term. Clearly, the BUM staff has applied a lot of professional 
knowledge and talent in preparing the document. A wealth of important 
information is clearly presented. 

GENERAL COMMENTS AND MAJOR RECOMMENDATIONS 

A. I believe the preferred alternative should he modified, as I describe in my 
page specific comments below. io include more aspects of Alternative C, 
and some features that arc not included in any of the alternatives. 

B. The wilderness and roadless character of the wilderness study areas should 
be retained whether or not Congress decides to add these areas to the 
National Wilderness Preservation System, ll is imperative that these areas 
be closed to oil and gas leasing and mineral entry. 

C. Proposed National Natural landmarks should be closed to oil and gas 
leasing and mineral entry and motorized travel should be restricted to 

1. 



374.2 



designated roads (no travel on trails). 

D. The plan should include more explicit goals and a more aggressive 
program for achieving desired plant community objectives and acceptable 
ecological condition classes where degradation ts attributable to past or 
current livestock grazing, especially for riparian lands. 

E. The plan should include stronger provisions for protecting and enhancing 
the bighorn sheep population and its current and potential range from 
conflicts with livestock, particularly domestic sheep. 

F. Travel by motorized vehicles other than on designated roads and trails 
should be prohibited except for the proposed play area near Worland. 

G. The proposed Areas of Critical Environmental Concern should be 
withdrawn from oil and gas leasing and from applicability of the General 
Mining l.aws. 

H. The ecological significance and maintenance of adequate old growth forest 
should receive greater emphasis than is provided In the DPEIS and the 
preferred alternative. 

I. Bcner documentation to support statements of policy, regulations, 

interpretations, and conclusions, study results, etc. should be included in the 
Grass Creek Resource Area. Resource Management Plan and Final 
Environmental Impact Statement (FPEIS) along with full citations in the 
References section. 

PAGE SPECIFIC COMMENTS AND RECOMMENDATIONS FOR 
MODIFICATION OF THE PREFERRED ALTERNATIVE 

1 . Page 9, Withdrawals and classifications — -The (FPEIS) which is finally 
adopted should refer readers to Map 9 and Appendix 2 for more detailed 
information on which lands arc currently withdrawn or classified and why 
they were so withdrawn or classified. The FPEIS should more clearly 
indicate the justification for terminating the withdrawals and classifications. 
These lands should not be opened up to operation of the General Mining 
Laws until the these archaic laws arc revised. That such revision is 
anticipated is acknowledged elsewhere in the DPEIS. 

2. Page 14. Elimination of Gas and Oil Leasing — It is indeed unfortunate that 
nearly the entire resource area is currently covered by federal gas and oil 



374.3 



leases and that the terms for all these leases apparently will extend through 
the year 2005. Is this true? Clarify. If so, this reflects poor land use 
decisions and commitment of other resources and values, The situation 
seems to preclude withdrawing key areas (which 1 describe in my page 
specific comments) from oil and gas leasing when current leases expire. 
Every effort should be made to eliminate leases in these key areas by 
negotiation with the leasees, by exchanging such leases for leases in less 
sensitive areas, or perhaps in some exceptionally critical cases, by buying 
out leases. I believe that closing some of the key areas to mineral 
exploration and development can certainly he demonstrated to be in the 
national interest. The specific BLM policies that require opening all public 
lands for mineral exploration and development except for Congressional 
withdrawals should be quoted and referenced here or in Appendix 4. 
Appendix 4 should include a list of existing leases, initiation dales, 
expiration dales, and otfier pertinent information to support the statement 
that nearly all of the resource area will remain under lease until after the 
year 2005. 

Page 19. Cultural, PalcontologicaL and Natural History Resources 
Management , item 2 — Either here or under the Natural History section 
on pages 107 108 and in Table 16. or on page 189, the management 
activities thai will ensure the maintenance or enhancement of the special 
values of the proposed National Natural landmarks should be described. 
This should include withdrawal of these areas from oil and gas leasing and 
applicability of the general mining laws and closure to motorized travel 
except on designated roads (no travel on trails). 

Page 24. Foreslhuid Management, Management Objective — Apparently 
there are only 14,000 acres of BLM-administered forestland capable of 
sustaining forest production in the Grass Creek Resource Area. Some of 
this acreage occurs in the Owl Creek Wilderness Study Areas which are 
contiguous with designated wilderness in the Shoshone National Forest. In 
addition, the acreage of forestland south of Cottonwood Creek is 
contiguous with larger areas of forestland in the Shoshone National Forest 
(Management Area 3A) that are to be managed with emphasis on 
semiprimitive nonmolorized recreation. Management of forestland on 
BLM lands south of Cottonwood Creek also should emphasize 
semiprimitive nonmolorized recreation and noncommodity resources, us 
proposed in Alternative C. Management of BLM forestland north of 
Cottonwood Creek should be compatible with management of the 
contiguous USFS land. Basically, wildlife, recreation, maintenance of high 
visual quality, and minimal roading should be emphasized over timber 



427 



374.4 



harvest in all BLM forcstland. 



5. Patm 25, Forestland Management. .last item on (he page — -15 years is loo 
long to wait for clearcuts to be regenerated by natural or artificial means. 
Cutover areas should be regenerated within 5-7 years, as is required on the 
adjacent Shoshone National Forest. 

6. Page 26, Forestland Management, first item on the page -— Fencing aspen 
stands to preserve them from excessive browsing by ungulate and livestock 
cannot be justified ecologically, and especially for economic reasons. 
Natural or prescribed fire, used extensively, along with acceptable levels of 
browsing and grazing by wild and domestic ungulates is the only practical 
program for maintaining and increasing aspen stands. 

7. Page 29, Lands and Realty Management, Access. Management Actions — 
Emphasis should be on attaining public use easements on existing roads that 
are closed to public use where the roads cross private land. It appears to 
me that, if such access across private lands is attained, there is no need to 
construct more roads in the Grass Creek Resource Area to improve public 
access. 

What is the need for improved public access in the upper Grass Creek area? 
Is this a matter of obtaining access across private lands or constructing new 
roads'? Clarify. 

8. Page 30, Lands and Realty Management. Access, item 3 — -What is meant 
by "limited motorized vehicle access"? Access across private lands? 
Clarify. 

9. Page 30. Lands and Realty management. Access — Again, docs this refer to 
pursuing public access easements on existing roads across private lands? 
Clarify. Will improving access lead to more vandalism in the area? 

10. Page 32, Lands and Realty Management, Land Ownership Adjustments, 
item 1 — -The criteria in Appendix 2 should specifically state that the 
environmental analyses required for proposed land adjustments will include 
public involvement or other interested parlies. 

1 1. Pa ge 32, l,ands and Realty Management, I.and Ownership Adjustments, 
item 2 — The FPEIS should explain why these lands should be considered 
for deposition by means other than purchase by the BLM. 



374.5 



Page 32, Lands and Realty Management, I .and Ownership Adjustments, 
item 3 — This should clarify that the exchanges would be for the purpose of 
acquiring private lands in these areas. 

Page 33, Rights-of-Wav. item 1 — The FPEIS should be specific about the 
conflicts and sensitive areas referred to. 

Page 33, Rights-of-Wav, item 2 —It is unclear from Map 7 as to whether 
or not the two right-of-way corridors would be in addition to or in place of 
the right-of-way concentration areas. What is the difference between right- 
of-way corridors and right-of way concentration areas? These are not 
defined in the glossary. 

Page 34, Rights-of-Wav. items 1 and 3 — -The preferred alternative does 
not adequately provide for protecting scenic values along these travel 
routes. Alternative A and C should be followed, including the Right-of- 
way avoidance areas shown for Alternative C (Map 8). 

Page 35, Withdrawals, item 1 — These withdrawn lands should not be 
returned to operation of the General Mining Laws until these archaic laws 
are revised. 

Page 35. Withdrawals, item 4 — The proposed mineral withdrawals are 
appropriate and should be retained in the FPEIS. 

Page 35. Livestock Grazing Management — Since 53% of the allotments 
are in the "Improve" category where 'The objective is to improve resource 
conditions and productivity to enhance overall multiple use opportunities." 
(Appendix 3), the EIS and the alternative that is ultimately implemented 
should more explicitly include measures for expeditiously improving 
unsatisfactory conditions attributable to livestock grazing on allotments in 
the Improvement category. The preferred alternative is too vague in this 
regard. 

Page 40. Livestock Grazing Management, item 1 — -None of the forage in 
occupied or potential bighorn sheep range should be allocated to domestic 
livestock, especially on bighorn sheep winter range. Bighorn sheep habitat 
should be closed to domestic livestock grazing. 

Page 40. Livestock Grazing Management, item 2 — -There should be no use 
of occupied or historic bighorn sheep habitat by domestic sheep, due to the 
scientifically documented conflicts (disease and forage competition) 



374.6 



between bighorn sheep and domestic sheep. Removal of domestic sheep 
from these areas should he accomplished immediately. There is no way 
that mitigation — except complete separation of the two species— is relevant 
to this situation. The buffer zone of 2 miles is insufficient to safely 
eliminate the risk to bighorn sheep. What does '"Domestic sheep grazing 
would be restricted . . . ." (my emphasis) mean? No such grazing? Clarify. 

21 . Page 40, Livestock Grazing Management, items 3. 4. and 5 — Combined 
utilization of key grasses should be limited on all elk winter range and 
crucial winter range. All grass utilization should be allocated to elk on 
crucial elk winter range. Where domestic livestock grazing is to be allowed 
on elk winter range other than crucial winter range, a high proportion, 
probably 15% of the limited grazing utilization should be allocated for elk 
use during winter. The EIS should more explicitly indicate what 
proportions of the limited combined utilization will be allocated to elk and 
to livestock. Apparently 195,000 acres are considered to be winter and 
crucial winter range for elk. Elk should have high priority over livestock 
on all elk winter range. 

22. Page 41, Livestock Grazing Management, item 1 - — Again, what does 
"restricted" mean? Clarify. 

23. Pa ge 41, Livestock Grazing Management, item. 2 - — All woody forage in 
the apparently very limited acreage of moose winter range should be 
allocated to moose. 

24. Pa ge 41, Livestock Grazing Management, item 4 ----Be explicit about the 
meaning of "restricted" domestic sheep grazing. Apparently 490,000 acres 
are considered to be winter and crucial winter range for antelope. Does 
the 121.000 acres represent all the crucial antelope winter range? 



25. Page 41. Livestock Grazing Management, item 5 - 
about the meaning of "restricted." 



-Again, be explicit 



Page 42, Minerals Management — The proposal to open all public lands in 
the resource management area to leasing for oil, gas, geothermal, and other 
leasable minerals is irresponsible and unacceptable. All the wilderness 
study areas should be withdrawn from leasing, the Genera! Mining Laws. 
exploitation of salable minerals, and geophysical exploration until Congress 
decides whether or not to add these areas to the National Wilderness 
Preservation System. Even if Congress does not do so. these unique areas 
should be retained in a roadless stale and managed to retain their wilderness 
6 



27. 



374.7 



character. 



Page 44, Minerals Management. Gas and Oil, item 2 -The controlled- 
surfacc use stipulations should be described in detail in the text or in the 
Glossary. With regards to the no surface occupancy, controlled-surface use 
and timing stipulations, the FPEIS should summarize the history of the 
extent that these stipulations have been included in leases and the extent, if 
any, that such stipulations have been waived when exploration or 
development occurred and the reasons for any waivers. At least on U. S. 
Forest Service lands stipulations seem to waived all too easily and 
frequently. How would control led -surface use and timing restrictions be 
implemented once gas or oil development occurs as regards the 
maintenance and service requirements of developed wells? Clarify. 

28. Page 47. Off-Road Vehicle Management, item 3 ----Thesc areas should be 
identified as wilderness study areas in this table and, as is apparently the 
case under current management (Alternative A) should remain closed to 
motorized vehicle use even if Congress does not add these areas to the 
National Wilderness Preservation System. 

29. Page 47, items 4-6 and Page 48, item 1, Off-Road Vehicle Management — 
The proposal to limit vehicle use to designated roads and trails, except for 
the "play area" near Worland is commendable. Random off-road and off- 
trail use of motorized vehicles is unacceptable due to adverse impacts on 
natural resources. However, the FPEIS should more explicitly indicate in 
text and maps the extent of the existing and planned trail system and the 
extent that roads and trails would be open to motorized vehicle use. It is 
imperative that sufficient areas in appropriate environments, in addition to 
the wilderness study areas, be designated for non-motorized recreation use. 
This is particularly important in the foothills and peaks of the Absaroka 
Range. The majority of trails in the Absaroka Foothills should be closed to 
motorized vehicle use. 

30. Page 49, Off-Road Vehicle Management, item 2 — Restriction of over-the- 
snow vehicles to designated roads and trails until activity planning 
addresses their use is appropriate. In developing such plans consideration 
should be given to designating one or more areas accessible by plowed 
roads for non-motorized over-thc-snow travel (skis, snowshocs). 

31. Page 49. Recreation Management. Management Objective — -There appears 
to be a contradiction here. The Glossary states that "primitive" 
recreational opportunities do not exist in the resource area (also see page 

7. 



428 



374.8 



120). Such opportunities, by definition, should exist in the wilderness 
study areas, and should tx; retained there even if Congress docs not include 
these areas in the National Wilderness Preservation System. The FPEIS 
should explain why Ihe wilderness study areas are not considered to 
provide primitive recreational opportunities. 1 endorse the idea of 
managing more of the resource area for primitive recreational use. But 
here again, does "primitive." really mean "scmi-primitivc non-motorized" 
and "semi-primitive motorized"? 1 assume that it docs, but this should be 
clarified in the FEJS. 

32. Pa ge 49, Recreation Management, Management Actions, item 1 — The 
FPEIS should describe the management and use of SRMAs and ERMAs and 
the differences between the two kinds of areas. 

33. Pa ge 51, Recreation Management, item 3 — The general location of this 
road should be mapped in the FPEIS. If such a scenic road is developed, it 
should not detract from retaining the wilderness character and the quality 
of a primitive recreational experience in the wilderness study areas, 
whether or not Congress adds these areas to the National Wilderness 
Preservation System. 

34. Pa ge 51, Recreation Management, item 5 — -The locations of the Wardel 
and Harrington reservoirs should be shown on the maps. 

35. Pape 52. Recreation Management, item 1 — -Again, trails should be shown 
on a map. The action implies that the trails served by these (railheads 
would be closed to motorized vehicles. This should be clarified in the 
FPEIS. Again, the FPEIS should map designated trails that are to be open 
to motorized vehicles. In developing trail head facilities, particularly the 
size of parking areas, consideration should be given to the levels of use that 
are desired for the environments served by the facilities. 

36. Page 52. Recreation Management, item 2 — -See comment 35. Again, does 
"primitive" really mean "semi-primitive? Clarify. 

37. Page 57. Vegetation Management, DPC Objectives for Forestiands - 
Development of old growth forest requires long time periods, but natural 
or man-caused fire can wipe out extensive areas of old growth forest in a 
short time. Thus, to ensure an appropriate representation of old growth 
forest over the long term, a much higher proportion of the forestiands in 
the resource area should be maintained in old growth, both for ecological 
and esthetic reasons. 



40. 



374.9 



38, Page 62, Visual Resource Management, item 6 -The stronger restrictions 
under Alternatives A and C should be included in the final alternative that 
is implemented. It is imperative that the visual quality oj these corridors 
be maintained and, where possible, enhanced. 

39. Page 66, Wild Horse Management — -I do not believe that maintaining a 
wild horse herd is can be justified in terms of either the impacts on natura! 
resources or the management costs involved. At a minimum the wilderness 
study area currently included in the herd area should he excluded from any 
herd area that is ultimately established. 



Page 69. Wild Horse Mana gement, item 1 -— Additional water sources 
should not be developed in the wilderness study area regardless of whether 
or not Congress includes the area in the National Wilderness Preservation 
System. Wild horses should be excluded from the study area. 

Pa ge. 69, Wild Horse management, item Z — -Arty such development of 
enhanced opportunities for the public to view wild horses, especially road 
construction, should not occur within wilderness study areas or detract 
from maintaining their wilderness character, regardless of whether 
Congress includes the areas within the National Wilderness Preservation 
System. 

Page 72. Wildlife and Fish Habitat Management. Wildlife Habitat, item 3 — 
-Since the public lands belong to the national public, the FPEIS should 
indicate that ''affected public land users" includes the general public or 
other interested parties, not just commodity users in the resource area. 



Pa ge 74,. Wildlife and Fish Habitat management. Fish Habitat, items \ and 
2 — Establishing minimum pools for reservoirs should be a high priority 
for the agencies involved. 



Pages 74-77. Special Management Areas — -The establishment of the 3 
Areas of Critical Environment Concern is commendable, but the 
management of these areas should be strengthened by withdrawing them 
from oil and gas leasing and development and from applicability of the 
General Mining I^aws. The provision for no-surfacc occupancy of the 
Upper Owl Creek Area does not provide sufficient protection given the 
susceptibility of such restrictions to being waived. 



45 . Page 111. Livestock Grazing - 



-Eilhcr here or in Appendix 3 detail 

9 



374.10 



related to the development, implementation, and administration of 
allotments and allotment management plans should be provided (e.g., 
number of years for which a plan and grazing permit is valid, provisions 
for revising allotment management plans, how often such plans should be 
updated, etc.). 

46. Page 120, Recreational Opportunities. Semiprimitivc Motorized and 
Roaded Natural — These sections should more explicitly indicate how much 
of the acreage is currently restricted to travel on designated roads and trails 
and how much is open to random ase off of designated roads and trails. Or 
a separate section should indicate how much of the resource area Is 
currently open to random, off-road and off-trail motorized vehicles. 

47. Page 1 26, , Tabic 8, Livestock Grazing — The duration of soil loss due to 
grazing is stated as being temporary. Footnote 2 indicates that temporary 
impacts last for fewer than 5 years. Does this mean that all accelerated 
erosion due to grazing will be eliminated in 5 years? Or that accelerated 
erosion for any given spot is only temporary? Docs it mean that the 53% 
of the allotments in the Improvement category (where, I assume, some 
accelerated erosion occurs) will be improved within 5 years so that such 
erosion does not occur? Clarify - 

48. Page 1 31, Woodlands — The causes for the encroachment of woodlands on 
to nonwoodland vegetation types and the relative contributions of the eauses 
should be discussed. Due to climatic changes? Overgrazing? Fire 

suppression? 

49. Page 132. Factors Affecting Forestland Condition, General Factors — With 
an ecosystem approach to managing the forestland, which should include 
maintaining part of the forestland as old growth (where stagnation, insect 
disease, and old age are inherent), "production up to capability" should not 
be the overriding management goal. The FPEIS should acknowledge this. 



50. Page 135, Vegetation Inventory and Ecological Range Condition and Table 
12 — The FPEIS should indicate and discuss the desired and ecologically 
acceptable proportions of the 4 ecological condition classes for each plant 
community range site. What would good ecosystem management call for? 
Il is not enough to just list the current proportions in the various ecological 
condition classes. And what is the relationship between the current 
proportions and the impacts of livestock grazing and to the 53 % of the 
grazing allotments that are in the Improve category? 



374.11 



The column subtotals on the 1st and 2nd pages of Table 12 are misaligned. 

51. Page 139, Wild Horses, 4th paragraph -— The wild horses as well as the 
domestic sheep grazing should be managed to achieve desired range 
conditions and to reverse downward trends that can be attributed to 
grazing. Also the first part of comment 50 also applies here, 

52. Page 142, Bighorn Sheep — Here or elsewhere in the affected environment 
section, the current situation regarding the proximity of domestic sheep 
grazing to current, historic, or potential bighorn sheep range should be 
discussed. My cursory examination tsf grazing allotments in Table 3-3 and 
Map B indicate that all allotments within several miles of bighorn sheep 
winter range (as shown on Map 31) are for cattle. This is as il should be 
and should be pointed out in the FPEIS. 

53. P a g es 151-152. Proposed Areas of Critical Environmental Concern -- --The 
purposes for establishing these areas and the management actions that will 
be taken to accomplish the purposes should be described. This should 
include withdrawing them from oil and gas leasing and development and 
from applicability of the General Mining Laws. 



54. Page 152, Proposed Areas of Environmental. Conce r n, Upper Owl (.reck 
Area — The management objectives for this area should be stated. 



55. Pages 189-190. Livestock Grazing and Tabic 17 — The FPEIS should 
describe the degrees that the alternatives would correct undesirable 
vegetation and watershed conditions that are attributable to livestock 
grazing and management practices. The alternative that is finally 
implemented should be designed--and the reductions in livestock AUMs 
should ensure—that such undesirable conditions are corrected or are at least 
set on an improving trend. 

56. Page 192, Locatahlc Minerals, 5th paragraph — -The FPEIS should discuss 
the reasons for Lhc current closure of the coal and phosphate classifications 
and the justification for re-opening them under the preferred alternative, 
This could be partially accomplished by referring to Table 2 I. 

57. Pages 195. Forestland Vegetation, last paragraph — The statement "Before 
the planning area was settled, the forestiands maintained an open 
understory of grasses and scattered shrubs because of frequent low intensity 
fires" is too general and inclusive and if retained in the FPEIS should 
include supporting documentation. The statement is probably loo broad 

11. 



429 



374.12 



and inclusive. Forestlands ai higher elevations and on northern exposures 
would have most likely been dense old gTowth spruce-fir and mixed conifer 
forests lhal may have been returned to an early succcssional slate in patches 
of varying size by very infrequent (several hundred year intervals) stand- 
destroying fires. Bui the unbumed old growth stands then would have been 
similar to old growth stands now — dense stands of large trees; moderate to 
dense undergrowth of trees, shrubs and herbaceous vegetation; generally 
high moisture in the vegetation and soils; abundant woody material in 
various stages of decay in the overstory and on the ground, etc. The 
extensive current acreage of spruce-fir and mixed conifer forestlands 
cannot by a long shot be attributed to 100 years of fire exclusion. 

58. Page 196. Forcstland Vegetation — The FPEIS should define and describe 
"mature", "overmature", and "old growth" forestlands. 1 believe the 
DPEIS incorrectly downgrades the ecological significance of old growth 
forest and is incorrect in stating thai wildlife habitat and hiological 
diversity would decline over the planning period due to the remaining high 
acreage of older mature and old growth forests. If this interpretation is 
retained in ihe FPEIS, it should be documented. While an individual old 
growth stands may have lower biological diversity than some individual 
younger forest stands (this conclusion should be documented), old growth 
foresl contributes its own set of plant and animal species to the cumulative 
biological diversity of the forestlands and, thus, to the cumulative 
biological diversity of the resource area. The DPEIS gives too much 
emphasis to managing forestlands for maximum production of wood 
products. 

59. Page 196, Rangeland Vegetation. 3rd paragraph — It is appropriate to 
recognize prescribed fire as the preferred method of sagebrush control. 
Bui reference to prescribed fire should more specifically refer to 
prescribed natural fire and prescribed management- induced fire, and these 
terms should be defined in the text or Glossary. 1 suspect that fire would 
be effective in controlling the extent lhal juniper invades non-woodland 
vegetation if grass-forb fine fuels had not been reduced by past or current 
heavy grazing by livestock. 

60. Page 1%, Rangeland Vegetation, last 2 paragraphs -— The FPEIS should 
give the acreage for the 75 allotments that were in static condition in 1990. 
The FPEIS should also compare the number of allotments and acreages in 
the various ecological condition classes in 1990 with the anticipated 
acreages in 2005. 

12, 



374.13 



61- Pa^c 197. Ri parian Function and Tabic 21 - — Due to the extremely limited 
occurrence of riparian lands and their disproportionate contribution and 
importance to biological diversity, wildlife, and recreational activities, 
greater emphasis than is provided under the preferred alternative should be 
put on advancing the areas in a downward trend and the areas in ihe non 
functioning condition to the properly functioning or fundi on ing-nt- risk 
with an upward trend Condition classes, as is provided for in Alternative C. 

62. Pane 198, Wildlife habitat, 2nd paragraph - Coniferous forest that 
provides effective hiding cover for big game, especially elk. is extremely 
important to maintaining the size and distribution of herd segments. Loss 
of 1.900 acres of hiding cover due to timber harvest seems excessive, 
particularly considering the low acreage of coniferous forest in the 
resource area and the likelihood of increased human activity, particularly 
during the hunting season, resulting from the planned improvement in road 
access or from the forecasted increased recreational use with or without 
improved road access. 

63. Page. 1.99, Wildlife Habitat left column. 7th paragraph -— Due to the 
potential adverse impact of domestic sheep on bighorn sheep (disease 
transmission and competition for limited forage, particularly on bighorn 
sheep winter range), the buffer zone should be greater than 2 miles, and 
this seems to currently be the case based on the Information in Table 3 3, 
Map B, and Map 3 indicate that this may currently be the case. This 
paragraph could also mention that keeping domesric sheep grazing well 
away from bighorn sheep range, particularly winter range, would also 
preclude competition between the two species for forage. All forage on 
bighorn sheep range., especially their winter range should be allocated to 
bighorn sheep and other big game species, such as elk which often utilize 
bighorn sheep winter range. 

64. Page 199, Wildlife and Fish, right column. 2nd and 3rd paragraphs -— 
There seems to be a contradiction here. The 2nd paragraph states that 
controlled surface-use restrictions would allow the application of seasonal 
limitations on new gas and oil production on critical winter ranges and 
birthing habitat for elk, moose, and bighorn sheep. But the 3rd paragraph 
states Lhal seasonal restrictions would not be applied to new production . 
Why the difference? How can such restrictions be effectively applied to 
producing gas and oil wells and fields in light of their maintenance and 
service needs? Clarify. 



65. Page 200. Table 22 - 



-The emphasis in Ihe Preferred Alternative to 
13. 



374.14 



improve ihe status of bighorn sheep winter range is commendable and 
should be increased if ecologically and economically feasible, including 
rcinlroduction oF bighorn sheep into historic or potential range that is 
currently unoccupied. 

66. Page 202, Preferred Alternative Summary — Council on Environmental 
Quality Regulations (§ 1502.16) require discussions of (1) adverse 
environmental effects which cannot be avoided, (2) the relationship 
between short-term uses of man's environment and the maintenance of 
long-term productivity, and (3) of any irreversible or irretrievable 
commitment of resources which would be involved. The DPEIS lacks these 
required discussions. Why? 

67. Pagc 215, Wildlife Habitat , left column. 5th paragraph — This paragraph 
seems to imply that potential bighorn sheep range extends far beyond the 
currently occupied range. Appropriate management of bighorn sheep and 
their habitat will hopefully result in the expansion of bighorn sheep into ihe 
currently unoccupied but potential habitat. Thus, an adequate buffer zone 
between bighorn sheep and domestic sheep (which should be greater than 
the proposed 2 miles) should, at a minimum, be a moving zone that always 
extends well beyond any progressive expansion of bighorn sheep into their 
potential habitat. The buffer zone should not be a static one relative to Ihe 
current distribution of bighorn sheep. Ideally, the buffer zone would be 
established beyond the limits of the potential, bighorn sheep range, '['he 
nature and exlent of the buffer zone relative to these points should be 
discussed in the FPEIS. Regardless, complete separation of the two species 
must be ensured. 

68. Page 215. Alternative C Summary, 2nd paragraph — Again, this 
interpretation of the ecological significance of old growth forest to the 
biological diversity of the resource area seems flawed. Here or elsewhere 
this point requires more discussion and documentation from Ihe scientific 

literature. 

69- Page 230. Possible I window nership Adjustments, Review Process --This 
should explicitly provide for public involvement in the review process. 

70. Pa ges 231-271. Appendix 3_ livestock Grazing Management — -Somewhere 
in an existing or new table of all the grazing allotments, more complete 
information should be provided on which allolmenls operate under an 
allotment management plan, when the plans were developed and 
implemented, if they have been revised.and when they have been or should 
14. 



374.15 



be updated, etc. 



71 ■ Page 235, Cum pone ills of the livestock Grazing Management Program. 

item 2 — -The term "affected interest" should be defined and should provide 
for the involvement of the public at large not just publics with a vested 
economic interest in the program. This could be clarified by using the 
term "affected and interested parties," as is done on page 259. 

72. Page 255, Utilization, riuht column. 3rd paragraph — -Specific references 
should be given to support the statement that the indicated levels of 
utilization are appropriate for the precipitation zones and vegetation types 
and to support the stale-meal thai several studies indicate undcruse in wet 
years will compensate for overuse in dry years. 

73. Page 262. Table 3-8 — the acronym C.RMP should be defined in the list ol' 
abbreviations on page 3. 

All but the first page of Table 3-8 is mislabeled Table 8. 

I appreciate the opportunity to comment on ihe DPEIS. Please send me a 
copy of the FPEIS and the record of decision when they become available. 

Sincerely yours. 



William J. Rarmore, Jt. 



430 



WMM&mWBBUmBBaamBB^BSmBHaa^^mBBIUBBUffl 



MAY - 8 1995 



375 



Bl.M TtBnh Ross 

Grass Creek Area Draft EIS 

P.O. Box 1 19 

Wnrland , WY B2401-0119 

Dear Mr. Ross: 

I object to the s ignif icant financial impacts to bus i nesses , 
individuals (and consequent ly to the tax base), and the effected 
counties and coramunit ins due to restrictions proposed within all 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
indi v i dual s and represent at ives from gracing, re or eat ion , oil and 
gas and minerals industry, timer and local and state governments. 

I appreciate the opportunity to contribute to the very important 
Grabs Creek Area Environmental Impact Statement. Please find my 
rommeii ts be'. ow . 

I object to the reduction of Gracing AUK ' e proposed In the 
Al ternatives. Real, Current, scientific data should be used to 
make management decisions on each allotment. Targets should be 
clearly established and stated. 

1 object to the expansion of "Wild Horse Management" areas. t 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek Area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

I object to the data col lection procedures cited for AUM 
Utilization, and suitability. This should be completely redone. 

I object to the sma 1 | amount of land considered for suburban 
expansion. 

I object to the lack of discussion about impacts tn the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary 
businesses and individuals who use federally administered lands 
to generate income and support our communities through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance ill all of the alternatives. Not. enough 
emphasis has bean placed on new technology and new information to 
mitigate and reclaim any impacts. 



375.2 



1 object to the bias for recreation disturbance and the hjais 
ngainst minerals, grazing and recreation. 

t object to the proposed blanket restrictions contained in 
Off-Road Vehicle Management. 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of 
businesses should olso Ijh factored in. 

I object the lack o! detailed descriptions for restrictions. 

I object to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsuhstanl iated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

I believe in the multiple use concept, in that this La public 
land it should be used for all the public not just a chosen few. 
Public land should be used not only tor recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of the land should he sold into the private sector 
and put on the lav rolls. If not this then put, the control to 
the state level where local people have a say instead of Ihe 
'Great White Father" in Washington who doesn't understand local 
problems . 










nay 3, 1991 




RECEIVED \ O ^eO 




'" I O/D 

MAY - 8 1995 


EU 


EAU OF UHD MANAGER;.! 


B1.M IBob BohS 
GraBs Creek Ar 
P.O. Box 119 
War land, WY 2 


-a Draft KTS 
1)1-01 19 


Dear Mr. Ross: 


I object to the significant financial impacts to businesses, 
individuals 'and consequently to the tux base), and the effected 
counties and communities due to restrictions proposed within all 
ot the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and state governments. 


I appreciate I.Iim opportunity to contribute to the very important, 
Grass Crock Area Rnv i ronmental Impact Statement . Pleane find my 
comments below. 


I object to the reduction of Grazing A1JM ' a proposed in the 
Alternative*. Real, Currant scientific data should be used to 
make management, decisions on each allotment. Targets should be 
cleariy established and stated. 


1 object to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek Area RMP. Return all wild animal management to the 
State Same and Fish, and return all managed animal production to 
the Private sector. 


1 object to the data collection procedures cited for AUM 
utilization, and suitability. This Bhould bo completely redone. 


I object to the small amount of land considered for suburban 
expansion. 


I object to the lack o.f discussion about Impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the ULM Administered lands. 


I object to restrictions that hamper the current primary 
businesses and individuals who use federally administered lands 
lo generate income and support our communities through taxea. 


I object lo the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives, Not enough 
emphasis has been placed on now t echnulogy and new information to 
mitigate and reclaim any impacts. 



376.2 



I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

T object to the proposed blanket restrict 1 oris contained in 
Off-Road Vehicle Management.. 

I object, to the small consideration given to the economic impacts 
to businesses and also tax bases. Henef i cial impacts of 
businesses should also be factored in. 

T object the lack of detailed descriptions for restrictions. 

I cbjeL-t to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wo If inferences, and prairie dog-bl ack footed ferret inferences . 

I believe in the multiple use concept, in that this is public 
land it should ba used for all the public not just a chosen few. 
Pub I ic land should be used not only for recreation, but for 
grazing, harvesting ot timber, extraction of minerals as well. 

1 believe most of the land should be sold into the private sector 
and put on the tax rolls. If not this then put the control to 
the state level where local people have a say instead of the 
"Great White Pother" In Washington who doesn't understand local 
problems , 



&*A/-e^ 



c 



?ri0K 



3 



431 



wr - 8 1995 



BLM %Bob ROBS 

nrusii Creek Area Draft EIS 

P.O. Box 119 

Worland, WY 82401-0119 



377 



Mr- 



Mr. Boss 



1 Object to the significant financial impacts fco businesses, 
individuals (and nanaeijiisntly to the tax base), and the effected 
counties and communities due to restrictions proposed within all 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
Individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and state governments. 

I appreciate 1 he opportunity to contribute lo the very important 
Giabb Creek Area Environmental Impact Statement. Please find my 
comment s be I nw, 

I object to the reduction of Grazing AUM's proposed in the 
Alternatives. Real, Current scientific data should be used to 
make management decisions on each allotment. Targets should be 
clearly established and stated. 

I object to the expansion of 'Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek Area P.MP. Return all wild animal management to the 
State Game and Fish, and return all managed nnima! production to 
the Private sector. 



I object to the data collecti 
utilization, and suitability. 



ocedurea cited for AUM 

9 should be completely redone. 



small amount of land considered fnr suburbs 



I object to the lack of discussion about impacts to the value 
private, state and county lands by the various alternatives. 
Espaci&Uy those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary 
businesses and individuals who u B e federally administered Ian 
In generate income and support our communities through taxes. 



I object to the severe and undue number and !i 

on Surface Disturbance in all of the alternat. ., 

emphasis has been placed on new technology and new information lo 

mitigate and reclaim any Impacts. 



f restriction 
Not enough 



377.2 



1 object to the bins [c 
agai nst minerals , grnzi 



recreation disturbanc 
g and recreation. 



and the bias 



1 object to the proposed blanket restrictions contt 
Off-Road Vehicle Management. 



ed 



iderat inn given 

bases . Benef ic 
factored in. 



the economi g 
impacts of 



mpacts 



I object to the smal 
to businesses and al 
businesses should ti 1 

I object the lack ol detailed descriptions for restrictions. 

I object to the discussion of threatened, endangered and 

candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

I believe in the multiple use concept, in that this is public 
land it should bo used for all the public not just a chosen few 
Public land should be used not only for recreation, but tor 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of the land should be sold into the private sector 
and put on the tax rolls. If not this then put the control to 
the state level where local people hav« a say instead of the 

Great White Father' 1 in Washington who doesn't understand local 
problems . 






RECEIVED 

■81995 

| BURtAU QF_LANO_HA*AGUEN! 

BLM %Bob Ross 

Grass Creek Area Draft BI8 

P.O. Box 119 

Worland, WY 62401-01 1 9 

Dear Mr. Rons : 

1 object to the significant financi 
individual s (and 



378 



Counties and communities due to 



. .impacts to businesses, 
lequently to the tax base), and the effected 

.,, ~^ies due to restriction* proposed within all 

<ji the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil an 
gas and minerals industry, timer and local and state governments 

I appreciate the opportunity to contribute to the very important 
Brans Creek Area Environmental Impact statement. Please find my 

comments be i ow. 

I objectto the reduction of Grating AUM's proposed in the 
Alternative*. Benl , Current scientific data should be used to 
make management decisions on each allotment. Targets should be 
clearly established and stated, 

I object to the expansion of ''Wild Horse Management" areas, I 
recommend eliminating all "Wild Horse Management" areas in the 
BreSS Creek Area RMP. Return all wild animal Management to the 

State Oame and Fish, and return all managed animal production to 
the Private sector. 



I object to the 
ut i iizat i on , an 



procedures cited tor AUM 
This should be completely redone 



T object to the small amount uf land considered for suburban 



ipacts to the value 
ti ves . 



I object to the lack of discussion ab 

private, state and county lands by the various altemativ 

Especially those imbedded with the BLM Administered lands 

I object to restrictions that hamper the current primary 
businesses and individuals who use federally administered I ande 
to generate income and support our communities through taxes. 

1 object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternative*. Not enough 
emphasis has been placed on new technology and new information lo 
mitigate «nd reclaim any impacts. 



378.2 



I object to the bins for recreation disturbance and the bias 
agalnal minerals, grazing arid recreation. 

I abject to the proposed blanket restrictions contained in 
Off-Road Vehicle Management. 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of 
businesses should also be factored in. 



lack of detailed de 



criptions fur restrictio 



I object to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

I believe in the multiple u»e concept, in that this is public 
land it should be used for all the public not just a chosen few. 
Public land should be used not only for recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of the land should be sold into the private secto 
and put on the tax rolls. If not this then put The control to 
the state level where local people have a say instead ol the 

Great whjt.0 Father" in Washington who doesn't understand loral 
prool ems . 



432 





u t. v tiM - 






MAY- 81995 




HWUUOFUnORAMGrM 


Utf 



^ > // ~z^' 



FILM £B<nb Ross 

Grass Creek Area Dr-uit EIS 

P.O. Box 119 

Worlaiid, WY H2*i0l-ono 



Pear Mr. 



Ho 



I object to the significant financial impacts to bus i no sees , 
individuals (and consequent ly to the tax base), And the effected 
counties and communities due to restrictions proposed within all 
tif the alternatives, and recommend that a new preferred 
alternative he created wit.li I he help ol knowledgeable community 
indi vidua I B and re pre sen tat ives from grar.i ng , recreation, oi L and 
gas and minerals industry, timer and local and state governments. 

I appreciate tt>e opportunity to contribute to the very Important 
Grass Creek Area Environmental Impact Statement . Please find my 
comments be 1 ow. 

l object to the reduction of Grilling AUM's propound in the 
A] ternot iveh. Heal, Current scientific data should be used to 
makfc management decisions on each allotment. Targets should be 
clearly established and stated- 

I object to the expansion of "Wild Horse Management" ureas. I 
recommend eliminating all "Wild Horse Management" areas in t lift 
Grass Creek Area RMP. Return all wild animal management to the 
Slate fiame and Fish, and return all managed animal production to 
the Private sector. 



I object to the data coll 
Utilization, and suit.abLl 



fCti 



P» 



edurea cited for AUtt 
should be completely redone 



ii C land considered for 



I object to the lack of discussion obout impacts to the value of 

private , state and county lands by the various al ternat i ves . 
Especially those imbedded with the ELM Administered lands. 

I object to restrict ions that hamper the current primary 
businesses and individuals who use federally administered lands 
to generate income and support our comaiun i t iefi through taxes. 

I object, to the severe and undue number and leve J of restri ctioilB 
on Surface fil s turbunce in all of the alternative*. Not enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impactfi. 



379.2 



I object to the bias for recreation disturbance and the bias 
againsi mineral s , grazing and recreation. 

t object to the proposed blanket rwKl.r i ctions contained i n 
Urt-Hoad Vehicle Management. 

I ohjpet to the small consideration given to the economic impacts 
tn businesses and also tax bases. Beneficial impacts of 
businesses should also be factored in. 

I object the lack of detailed descriptions for restrictions, 

I object to the di sous si on of threatened , endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wo I f inferences , and prairie dog-bl nek footed ferret inference*. 

I believe In the multiple use concept, in that this is public 
land it should be used for all the pilhllc not just a chosen few. 
Public land should be used not only for recreation, hut for 
grazing, harvesting of t imber , . extract ion of minerals as well. 

I believe most of the land should he sold into the private sector 
and put. on the tax rolls. If not this then put the control to 
the state leve I where loca 1 people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 
problems . 








RECUSED 
1 1 




J-lay 3, 1993 


MAY -31995 1 


3fi 


BUREAU OF LAND MANAGFIL1ENT 




Bl.M JBofl Hoss 

Grass Creek Area Drutt f:iS 

P.O. Box 1 1 9 

Wor lurid, WY 02401-0119 


Dear Mr. Ross : 


I object to the significant financial impact s to bus i ne sees , 
Individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grating, recreation, oil and 
gas and minerals industry, timer and local and state governments, 


I appreciate the opportunity t.O contribute to the very important 
6r»ftt Creak Area Environmental Impact Statement. Please find my 






! object to t 
Alternatives. 

make manngpme 
c lear ly estar 


\e reduction of Giafcing At.JM'6 proposed in the 

Real, Current scientific data should he used to 
nt decisions on each allotment. Targets should ba 

llahftd and stated, 


I object to I 
recommend eli 
Grass Creek A 


he expansion of "Wi 
niinatirig all "Wi Id 
rea RMP. Return al 


Id Horse Management" areas. 1 
Horse Management" areas in the 
1 wild animal management to the 



State Game and Pish, and 
the Private sector. 


re tun 


all managed animal p 


roducti o 


n to 


I object 
uti lizat 


to the data col 1 
on, and suitabtl 


ectioi 

ity. 


procedures cited for 
This should be compl e 


AUM 
t«ly red 


one. 


[ object 


to the sma 1 1 a mo 


ant of 


land consl dered for 


suburban 




expansion 












I object 
private, 
Ekpeci ul 


to the lack of 6 
state and countj 
y those Imbedded 


Undi 

with 


ion about impacts to 

by the various alter 
the BLM Administered 


the valu 
natives, 
lands. 


B OT 


I object to restrictions 
businesses and indi vidua 
Lo generate income and si 


thai hamper the current primary 

& who use f ederal ly admin i stored 1 a 

ppor t nnr communiti us through taxes 


nds 


on Surface Disturbance in all of th«: alternatives. 

emphasis has been placed on new technology and new 
mitigate and reclaim any impacts. 


Not enou 

nf ormati 


tions 
gl' 

on to 



380.2 



[ object to the bias tor recreation disturbance and the bios 

against minerals, graz i ng and recreation. 

I object to the proposed blanket restrictions contained in 
Off-Road Vehicle Management. 

I object to the small consideration given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of 

businesbes should also be factored in. 

T object the lack of detailed descriptions for restrictions, 

r object to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wo I i inferences , and prairie dog-black footed ferret inferences . 

I believe in the multiple use concept, in that this Is public 
land it should be used for all the public not just a chosen few. 
Public land should he used not only for recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of the land should he sold into the private sector 
and put on the tux rolls. It not this then put the control to 
the state level where local people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 



nbl 



^V\<v-uv^ cp^MAui 



433 



RECEIVED 



MAY - 8 1995 



381 



Bi.M %Hob Ross 

Grass Creek Area Draft. 

P.O. Box 1 19 

Worland, WV 32401 -0119 



Dear Mr 



Rosb 



1 object to the significant Financial impacts to businesses. 
individuals Cand consequently to the tax base), and the effected 
CO«nti9B and communities due to restrict' ohm proposed within all 
at the alternatives, and recommend that a now preferred 
alternative ha created with the help of knowledgeable community 
Individual* and representatives troin grazing, recreation, oil nnri 
gat and mineral* industry, timer And local and sti 



i appreciate the 
Grass Cr-n^k Area 
comment s bal nw . 



Ity to contribute to 1. 
entai Impact Statement 



vernment s . 



very imparl ant 
Please find my 



1 object to the reduction of Grazing AUM's proposed in the 
Alternatives, Real, Current scientific data should be vised to 
make management decisions on each allotment. 
cl early est abi is hen and stated. 



Targets 



I object to (he expai 

recommend eliminatiri; 
Grass Creek Area RHP. Set 
State Game and Pi sh, and rot 
the Private saclor. 



on nt "Wild Horse Management' areas. I 
11 'Wild Horse Management" areas in the 
wild animal management to thB 
11 managed animal production to 



I abject to the data 
utilization, and aui 



I object 

expansion 



nl le 



1 1 Ity 

mount of 1 



n procedures cited for AUM 
This should be completely 



considered tor 
mpaeta 



I object, to the lack of discussion about 

private, state and county lands by the various ernatives 

Especially those imbedded with the H1.M Administered lands. 

I object to restriction* that hampei the current primary 
businesses and individual* who use federally administered land* 
to generate Income and support our communities through taxes. 



I object lo the B 
on Surface Qlt*( ut 
amphasis has. been 
mi i i gate and ran I 



-e and undue number and level of restrictions 
:e In all ot the alternatives. Not enough 
iced on new technology and nan information to 
any Impacts . 



381.2 



I object to the bias [or recreation disturbance and the bias 
against minerals, graving and recreation. 

T object to the proposed blenXet restrictions contained in 

Off -Road Vehicle Management., 

I object to thn small consideration given to the economic imparts 
to businesses and also tax bases. Beneficial imoarts of 
businesses should also be factored in. 



lack ot detai le 



script ions for restr 



I object t 
candidate 
Wolf infer 



the diauussion of threatened, endangered and 
lldlifn species, specifically unsubstantiated Gray 
ices, and prairie dog-black footed ferret inferences 



I believe in th* multiple use concept, irt that this is public 
land It should be used for all the public not just a chosen few. 
Public land should be used not only for recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

1 believe most of the land should he sold into the private sector 
and put on the tax rolls. If not this then put the contro' to 
!« ■!*£?, i"* 1 wt ""'* 1 "™ 1 P«P!« l^ v e a say instead of the 

great Mute Patner" in Washington who doesn't understand loca' 
prnbl ems . 



*&. 



- Jffoy 



n^-t 



iU< 



M*-8B95 



382 



BU EAUOFLAhD.Whstil'- ''1 ] 

DLM %flob Ross 

Cro)»« Creek Area Draft EIS 

P.O. Box l 19 

Norland, WY 0241)1-011=! 

Hear Mr,- Ross: 

I object to the significant financial impacts to businesses, 
individual!; (and consequently to the tox base), and the effect 
Counties and communities due to restrictions proposed within a 
ot the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable eommunit 
individuals and representatives from grazing, recreation oil 
gas and minerals industry, timer and local and state governmen 

I appreciate ths opportunity to contribute to the very imports 

Grasr, Creek Area Environmental Impact Statement. Please find 
comment s bel ow . 

I object to the reduction of Grazing AUM's proposed i„ the 
Alternatives. Heal, Current scientific data should be used to 
make management decisions on each allotment 
clearly established and stated. 

1 object to the expansion ot "Wild Haraa Management" eras. I 
recommend eliminating all "Wild HorRfl Management'' areas in the 
Grass Creek Area RHP. Return all wild animal management to the 
State Game and Fish, and return all. managed animal production to 
1Kb Private sector. 

I object to the data collection procedures cited for AUM 
Utilisation, and suitability. This should be completely redone. 

u bur ban 
mpacta to the vuluw of 



Targets should be 



1 object to the smaH Amount of land 
expansion. 

I object to the lack of discussion al 

private, state and county lands by the various alter 
Especially those imbedded with the Hl.M Administered lands. 

I object to restrictions that hamper the current primary 
buBineaaea and individuals who use federally administered lands 
to generate income and support unr communities through taxes. 



I object to the severe and undue number and 
on Surface Disturbance in all of the nlterti 
emphasis has been placed on new technology 
mitigate and reclaim any impact^. 



»\ of 



H t. r i ct U 

enough 



382.2 



eat ion disturbanr: 
recreat ion. 



find the hi as 



I object to the bins for 
agai nst minerals i grazin 

I object to the proposed blanket restrictions contained ir. 
Ore-Road Vehicle Management. 

1 object to the small oonsi derat i on given In the economic impacts 
to businesses and also tax bases. Beneficial impacts of 
businesses should also be factored in. 

I object the lack of detailed descriptions for restrictions. 



I object to the diocuse 
candidate wildlife spec 
Wolf inferences, and prairie dog-black footed J 



f threatened, endangered and 
pacifically unsubstantiated Gray 

t inferences , 



I believe in the multiple use concept., in that this is public 
land it should be used for all the public not just, a chosen few. 
Public land should be used not on ! v for recreation, but for 
grazing, harvesting ot timber, extraction of minerals as well. 

1 believe most of the land should be sold Into the private sector 
and put on the tax rolls. If not this then put the control to 
the state level where local people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 
probl ems . 




434 




383 



Dl.M %!lob Ross 

Grass Creek Area Draft BIS 

p.n. Box 119 

Woi-land, WY 82*01-0119 



Mr 



Rosa 



I object Lo the; significant financial impacts to businesses, 
individuals (and OQftaeciuently to the tax base), and the effected 
counties and communities due In rest rict ions proposed within al ! 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil arid 
g9<8 and minerals industry, timer and local and state government*. 



appr 



aciafce the opportunity to contribute to the very important 
E*ra*tB Creek Arna Envl mmtiental Impact Statement. Please find my 
comments below. 

I object to ttie redaction of Grazing AUH's proposed in the 
Alternatives. Seal, Current scientific data should be used to 
make management decisions on each allotment- Targets should be 
clearly established and stated. 

I object to the expansion of "Wild Horse Management " areas. I 
recommend eliminating ull "Wild Morse Management" ureas in the 
Grass Creek Area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 

I object to the data col.leotl.au procedures cited for aUM 
utilization, and suitability, This should be completely redone. 



the amal 1 amount of la 



nsldered for suburban 



I object t 
■xpans ion . 

1 object to the lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object to restrictions that hamper the current primary 
businesses and indi vidua! s who use f eriera 1 ]y admini stereri I ends 
to generate income and support our common) ties through taxes . 

1 object io the severe and undue number arid level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
emphasis lifts b«#>n placed on new technology and new information to 
mitigate and reclaim any impacts. 



383.2 



I object 1 o i. 
agai nst miner 



i as tor recreation diet urbane 
grazing and recreation. 



T object to the proposed blanket, restrictions contained in 
ott-Road Vehicle Management. 

I object tn the small consideration given to the economic impact 
to bus iiiKHBHK and al so tax bases . Beneficial Impacts of 
businesses should also be factored In, 

1 object the lack of derailed descriptions for restrictions. 

I object to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf Infere-TWee, and prairie dog~black footed ferret inferences. 

I believe in the multiple use concept, in that this is public 
land it should be used for all the public not just a chuson few. 
Public land should bo used not only for recreation, but for 
grazing, harvesting of timber, extraction o£ minerals as well. 

1 believe most of the land should be sold into the private secto 
and put on the tax rolls. If not this then put the control to 
the state level where local people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 



pr 



ble 




&P" 



384 



MAY -8 1995 i 

I BURIaU Of LAND MANAGEMENT 
1 woRLW w rcmwc 1 

BLM Iflob Ross 

Grass Creek Area Draft tflS 

P . Q . Bo x 119 

Worland, wy 82*01-011.9 

Hear Mr. Ross: 

I object to t he significant financial impacts to businesses , 
individuals (and consequently tn the tax base), and the effected 
counties and communities due to restrictions proposed within all 
of i he alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and state governmGn1.fi. 



T Appre 

Grass Creek An 
comments below 



■the 



Spportuivi ty to ROHtri bute to th 
Envl ronmental Impact Statement . 



mpc 



I object ta the reduction of Grazing AUM's proposed in the 
Alternef ivea. Real, Current scientific data should be used to 
make management decisions on each allotment. Targets should be 
clearly establinhed and stated. 

T object to the expansion of "Wild Horse Management" areas, I 
recommend eliminating fill "Wild Horse Management" areas in the 
Grass Creek Area RMP. Return al! wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private sector. 



T object to the data 
UtiliZflt ion , and sui 



1 object to the 



ollection procedures cited for AUM 
bility. This should be completely 



d«r«d for suburban 



1 object to the lack of discussion about Impacts lo the value of 
private, StSte and couriiy lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object to restrict ions that hamper the current primary 
businesses and iudi vidua 1 s who use federal ly administered lands 
to generate income and support Our communities through taxes. 

I object to the Severe and undue number and level of restrictions 
on Surface Disturbance Jn fill of the alternative*. Not. enough 
emphasis has been placed on new technology and new information to 
mitigate and reclaim any impacts. 



384.2 



I object to Lilt 



ecreati on dist urbane 
and recreation. 



I object to the proposed blanket restrictions contained in 
Off-Road Vehicle Management. 

I object to the sma 1 1 consideration given to the economic impacts 
to businesses and also ten; bases. Beneficial impacts of 
bus i nee Be h shou I d also be factored in. 

1 object the lack of detailed descriptions for restrictions, 

I object to the di scussion of threatened , and align red and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

I believe in the multiple use concept, in that this is public 
land it should be used for all the public not just a chosen few. 
Public land should be used not only for recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe moat nf I be land should be sold into the private sector 

and put on the tax rolls. If nol thlfl then put the control to 
the state level where local people have u say instead of the 
"Groat White Father" in Washington who doesn't understand local 



VfjU&Ul v. &i*A«J 



435 











RECEIVED 


^O w 




MAY - 8 BBS | 


May 3, J 995 




■ 




BUREAU OF LAND MANAGE ' 








BLH tflob Ross 






Brass Creek Area Draft EXS 


P.O. Box 119 


Worland, WY A2AC1-01 19 


Dear Mr. Ross : 


1 object-, to the significant financial impacts to businesses, 


individuals t«nd consequently to the tax base), and tha effected 


counties and communities due to restrictions proponed within all 


of the a 1 ternati ves , and recommend tha t a new preferred 


alternative be created with the help of knowledgeable community 


Individuals and representatives from grazing, recreation, oi t and 


gas and minerals industry, timer and local and state governments. 


I appreciate t h« opportunity to contribute to the very important 


Grass Crunk Area Environmental Impact; Statement. Please find my 


comments below. 


1 object to the reduction of Grazing AUM's proposed in the 


Alternatives. Real, Current scientific data should be used to 


make management decisions on each allotment. Targets should be 


Clearly establ ished and stated . 


) object, to the expansion of "Wild Horse Management" areas. I 


recommend eliminating all "Wild Horse Management" areas in the 


Gra&s Creek Area RMP. Return all wild animal management to the 


State Game and Fish, and return till managed animal production to 


Hie Private sector. 


T object to the data collection procedures cited for AUM 


utilization, and Suitability. This should be completely redone. 


I object to the small amount of land considered for suburban 


expansion. 


I object, to the lack ot discussion about impacts to the value of 


private, state and county lands by the various alternatives. 


Especially those imbedded with the BI.M Administered lands. 


I object to restrictions that hamper the current primary 


businesses and Individuals who use federally administered lands 


to generate Income and support our communities through taxes, 


I object to the severe and undue number and level ot restrictions 


on Surface Disturbance in all of the alternatives. Not enough 


emphasis has been placed on new technology and new information to 


mitigate and reclaim any impacts. 



385.2 



I object to the bias for 
against miner a 1 a , grazing 



reation disturbanc 
d recreation. 



I object to the proposed blanket restriction 
Off-Road Vehicle Management, 

I object to the small consideration given to 
tu businesses and also tax bases. Beneticia 
businesses should also be factored in. 



contai ned in 



J object the lack of 



riptions for restr 



T object, to the di sense i on of threatened, endangered and 
candidate wildtite species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

I bal ieve in the mil Iti pi e use concept , in that this is public 
land it should be used for all the public not just a chosen few. 
Public land should be used not only for recreation, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of tha land should be sold into the private Bector 
arid put on the tax rolls. If not this then put the control to 
the state level where local people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 








1 


386 


J RECEIVED 


May 3, 1 

BI.M %Bnh 
Grass V.r 
P.O. Box 

Worland, 


1 WSY 3 1995 
95 | | J 


1 


UUU 


i uiu.AU Of IANOU&NAGEMIK' 


Boss 

ek Area Draft F.TS 

119 

WY B2401-U1 1 v 


Dear Mr. 


Ross J 






I object to the significant financial impacts 
individuals [arid consequently to the tax base 
counties and communities due to restrictions 
of the a 1 ternati ves , and recommend that a new 
alternative be created with the help ot know 1 
indi vidual s and representatives from gracing, 
gas and minerals industry, timer arid local an 


to husine&ses, 
) , and the effected 
proposed within all 

preferred 
ndgeabl e community 

recreati on , oil and 
d state governments . 


I appreciate the opportunity to 
Grass r:reek Area Environmental 
comments bel ow . 


contribute tc 
inpact Stateme 


the very important 
ni . Please find my 


I object to the reduction of Gracing AUM ' 8 pi 
Al te-rial tvfifi. Hefl 1 , Current scientific data 
make management decisions on each allotment, 
clearly established ^nd stated. 


Opused in the 
should be used to 
Targets should be 


J nbjf:(:t tu tlie expansion of "W 
recommend eliminating all "Wild 
Grass Creek Area RMP. Return a 
State Game and Fi^h, and return 
the Private sector. 


Id Horte Mana 
Horse Managei 
1 wild anima 1 
al 1 managed e 


ent" areas in the 

management to the 
nima 1 production to 


I object' 

utilUst 


to the data collection procedures C 
on, and au ; tabi I i ty . This should he 


ted for AUM 
compl etely redone. 


I object 


to the sm«] 1 amount of 


land consider 


ed for suburban 


I object 
private, 

Etspeci al 


to the lack of di BCUSS 
utate and county lands 
y those imbedded with 


on about impa 
by the variou 
the BLM Admini 


cts to the value si 
s alternatives, 
stered lands . 


T object 
bus i ness 
to goner 


to restrictions that hamper the cur: 
-^ and individuals who use federally 
ate i rifiCme and support our communi tit 


ent primary 
admini stered lands 
s through taxes. 


1 object 
on Surfa 
y Dip ha si s 

mi t i gate 


to the severe and undu 
-.tt Disturbance in al 1 o 
has been placed on new 
and reclaim any impact 


i number and 1 
r the iilternat 
technology ai 

3 . 


eve! of restrictions. 

ive*. Not enough 

il new information to 



386.2 



to the bias tor recreation disturbance and the bias 
Minerals, grazing and recreation. 



1 object to the proposed bl a like t rest riot 
Off-Road Vehicle Management. 

I object to the small consideration given 
to businesses and also tax buses. Benefi 
bus i nes ses shou 1 d a 1 so lie factored in. 



conta i ned 



I object I he lack of detailed descriptions for restrictions. 

I object to the discussion ot threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences. 

1 believe in the multiple use concept, in that this is publir 
land it .should ba used for all the public not just a chosen few. 
Public land should be used not only for recreation, but tor 
grazing, harvesting ot timber, extraction of miners 1b as well. 

I believe most of the land should be sold into the private sector 
and put cm the tax ro 1 1 a . If not this then put the control to 
the state level where local people have a say instead of the 
'Great White Father" Ln Washington who doesn't understand local 
prnbl ems . 



J? 






W 



436 



MAY - 8 1995 



387 



BI.M %Bob Hosb 

Gross Creek Area Draft EI8 

p.n. Box i n 

Wnrland, WY 82401-01 IT 

Dear Mr-. Roes! 

I object to the significant financial impacts 10 businesses, 
individuals (and consequently to the tax base), and the effected 
counties and eommuni t ies due to restrictions proposed within alt 
of the al ternati ves , and recommend thai a new preferred 
alternative be created with the help of knowledgeable community 
i nd i vidua Is and representatives from graz ing , recreation , nil and 
gas and minerals industry, timer and local and state governments. 

I appreciate t he op port un i I y to contribute to the very important 
Gra»6 Creek Area Environmental Impact Statement. Please find my 
comment fi below. 

1 object to the reduction of Crazing AUM's proposed in the 
Alternatives. Real, Current scientific data should be used to 
make managemer, t deci s i on a on each all otment . Target e should be 
clearly established and stated. 

J object tn the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek Area RMP. Return all wild animal management to the 
Stale Game and Fish, and return all managed animal production to 
the Private sector. 



1 obje 
utiliz 



t.o the data collect i 
ion, and uuiubl 1 Ity. 



edures cited for AUM 

should be completely redone. 



1 object to the email amount ot land considered tor suburban 

expansion . 

I object to the lack or discussion about impacts to ttaa value of 

private, state and county lands by the various alternatives. 
Especially those imbedded with I be BI.M Administered lands. 

I object to restri ctions that hamper I he current primary 
businesses and individuals who use federally administered lande 
to generate income and support our communities through taxes. 

I object to the severe and undue number and level of restrictions 
on Surface Disturbance in all of the alternatives. Not enough 
nmphaeie bos been placed on new technology and new information to 
mitigate and reclaim any impacts. 



387.2 



I object to the bias for recreation disturbance and the bias 
against minerals, grazing and recreation. 

I object to the proposed blanket restrictions contained in 
Off-Road Vehicle Management. 

I object to the small consideration given to I he economic impa 
to businesses and also tax bases. Beneficial impacts of 
businesses should also be factored in. 



ack of dotal led de 



ript i ons for re a tr i cti ons . 



I Object t.o the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolt inferences, and prairie dog-black footed ferret inferences. 

I believe in the multiple use concept, in that this is public 
land it should be used for al! the public not just a chosen few. 
Public land should be used not only for recreation, but tor 

grazing, harvesting of timber, extraction of minerals as well. 

r believe mo&t ot the land should be sold into the private sector 
and put on the tax rolls. H not this then put. the control to 
the state level where local people have a say instead of the 
"Great White Father" in Washington who doesn't understand local 
probl ems . 



ffw**, j^^^S^A 



MAY - 8 IMS 



BUREAU OF UHD MANAGEMENT 



388 



DI.M IRoh Rose 

Grass Creek Area Dcift RTfi 

P.O. Box 1 1 9 

Worland. WY 82'.01-01 19 



■•'.: 



I object to 1. lie s i gni t leant f inane, i a I impacts t o bus 3 uesses , 
individuals [and consequent ly to the te» hasp), end the effected 
cyimlie* and communl Hen dun In restrictions proposed within all 
of the alternatives, nnd recommend Mint a new preEerred 
alternative ha created with the help nf know 1 r-rlgoah I e .-..minimi I y 
i ndt vi dual s and represent Al ives ft' urn gr.iv. i rig . rcturea 1 Ion, oil and 
gut, ami mi n r:*-.-, is Industry, timer and local and stain gnvommen t. s , 



ccmlribute 



I appreci a I e t tie opportunity td 

Grass Creek Area Rnvi eonmenta 1 impact SI ateir 



very Important 
Please find mv 



object lo tlie reduction of Gr 
tfirnatives. Heal, Cnrrnnt sc 
ke management: dec I si oris on ea 
early established and stated. 



ft ing 



should be 

Targetr; q 



ieri to 
>uid bi 



1 object to the expansion of "Wild Horse Management" areas- i 
recommend eliminating all "Wild Morse Nanagr-mpnt" areas in the 
Grass Creek Area RMP. Return all wild animal management to the 
Statu Came and Fish, and return all managed animal production to 
the Private sector, 

I Object to the date collection procedures cited for AUM 
utilization, and suitability. This should be completely redone. 

I object to the smn I 1 amount of laud considered for suburban 



I object to the lack nf discussion about impacts to the 
private, state and county lands by the various alternati 
Especially those imbedded with '' 



BI.M Administered lands 



I object to restrictions that hamper the current primary 
bu si ii esses and individuals who use federally administered I 
to gene rat e income and support our eommuni ties through taxe 

I object tc the severe and undue number and level of restri 



on Surface Disturbance i 
emphasis has " 
m i t ig.it e and 



ter.liimlogy ami 



388.2 



I object to the bias for r 
against minerals, grazing 



T object to the proposed blanket restrict J 
or f-Road Vehicle Management ■ 

I object to the amal I consideration given 
to businesses and also tax bases. Benefic 
businesses sliuu Id S I so be factored in. 



re at ion din t. urban cc and the hi a 
d recreation. 



e economic impacts 
mpnets of 



I object the lack of detailed descriptions for restrictions. 

I object to the discussion of threatened , endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wol f inferences , and prairie dog-bl ack footed ferret inferences . 

I believe in the multiple use concept., in that this is public 
land it should be used for all the public not just a chosen few. 
Pub I ic land should be used not only for recreot ion , but for 
graz i ng, harvest ing of t imber , ext r act ion ot mineral s as wr<1 1 . 

I believe most ot the land should be sold into the private sector 
and put on the tax rolls. If not this then put the control to 
the state level where local people hove a say instead of the 
"Great White Father" in Washington who doesn't understand local 
problems. 



v _ oxX-a*-*— 



437 



L !U 



MAY - 8 1995 



kEAUOF LAND SiiittObUE«! 



389 



iSLM %Hob Kohr 

Grass Creek Area Draft EIS 

P.O. Box llv 

Wnrland, WY 83401*0119 



rieat- 



Roi; 



1 object to the significant financial impacts to businesses. 
individuals tond consequently to the Lax base), and the effected 
counties and communities due to restrict ions proposed within all 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer «nd local and state governments. 

1 appreciate the opportunity to contribute to the very important 
Gr«ss Creek Area Envi ronmanta 1 lmpn.it Statement. Please find my 

common ts bei uw . 

I object 1o the reduction of Grazing AUM's proposed in the 
Alternatives. Real, Current scientific data should he used to 
make management decisions on each allotment. Targets should he 
clearly established and stated. 

I object to the expansion o 1 "Wild Horse Management" areas, I 
recommend eliminating oil "Wild Horse Management" areas in the 
Groan Creek Area RMP. Return all wild animal management to the 
State Game and Fish, and return all managed animal production to 
the Private Rector. 

1 object to the data collection procedures cited for AIJM 
utilization, and suitability. This should he completely redone. 



I object tu the smal I 



onsidered for suburban 



I object to tht lack of discussion about impacts to the value of 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered lands. 

I object tu restrictions that hamper the current primary 
businesses end Individuals who use federally administered lands 
to generate income and support our communities through taxes. 

I object to the severe and undue numher and level of restrictions 
on.Kurfi.ee Disturbance Id all of the alternatives. Not enough 
emphasis has been placed on new technology and new information to 



389.2 



and the bi 



l abj»ct to the bias for recreation diatur 
agfiinst *i ««(•«'*, gracing and recrcat i an. 

I objeot to t ho proposed blanket restrict; 
Orr-Rnad Vehicle Management. 

I object to the oma1 I consideration givnn in kha economic iir.pa-t 
lu btiHitit)*»t»i and also tax banea. Beneficial impacts of 
buslnaaeftfl should alco bo factored in. 

1 object the lack or detailed descriptions for rastrlMians. 

I Object to the diocyiiwion ol *hreaten«rl , endangered and 
candidate wlldlite species, specifically unsuUstonlia ted Bray 
WoJf inferences, and prniri*> ring-Mark fnntod r#rr-l in(»rfnces. 

I believe in the multiple use concept, lfl that tins •» public 
land it should he u««/1 for all the public not just rt chosen few 
Public land at.ai.ld be used not only [ V1[ recreation, hut for 
grazing, harvesting ot timber, extraction r f minerals as wall. 

1 believe .m.st of the land should be sold into the private secto 
and put on the tax rolls. If not this ther. put the cent™ I to 
the itate l ftV *1 where Meal people have n ea y instead of M.p 
Oraet White Father'' in Washington *hn doesn't understand local 

probl ems. 



^oJ^Jr AJlf ^ 



r r e c e i v h~ — 


I 


390 


MAY - 3 BQ5 

May S, J 99.1 | | ™ | 


I 


vwv 




! 




BLM %Bob Ross 

Grass Creek Area Draft EIS 

P.O. Box 119 

Borland, WY B2401-01J9 






fle.ir Mr. Ross: 






I objacl to the significant financial impacts to businesses 
Individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all 
of the alternative*, and recommend that a new preferred 
alternative he eraatad with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and state governments. 


I appreciate 1 he opportunity to 
Grass Creek Area Envi ronment til 
comment's be 1 ow. 


contribute to the very import 
inpact Statement. Please find 


Hit 


1 object to the reduction of Grazing AUM's proposed It, tfca 
Alternatives. Real, Currant scientific data should be used t 
make management decisions on each allotment. Targets should 
clearly established and stated. 


>t! 


J object to the expansion of "W 
recommend eliminating oil "Wild 
Grass Creek Area RMP. Return a 
State Game and Fish, and return 
the Prlvfttif sector. 


Id Horse Management" areas. I 
Horse Management" areas in the 
1 wild animal management to the 
ol! managed animal production to 


I object t.o the data collection procedures cited for AUM 
utilization, and suitability, Thin should be completely rody 


ie. 


I object to the small amount of 
expansion, 


land considered for suburban 




I object to the lock of discussion about impacts to the value 
private, state and county lands by the various alternatives. 
Especially those imbedded with the BLM Administered land*. 


of 


I object In restriction* that hamper tho current primary 
businesses and individuals who use federally administered lands 
to generate income and support our communities through taxes. 


I object to the severe and undue number and level ot restriction* 
on Surface Disturbance in all ot the alternatives. N'ot enough 
emphasis has been placed on new Leehnotngy and now information to 
mitigate and reclaim any impacts. 



390.2 



I object to the bfas tor rucrsation dtaUrbt 
against minerals, grazing «nd recreation. 

I object to the proponed blanket restriction 
Off-Rood Vehicle Management. 

I object to the small con*id«r«jt ion givnn U 

to businesses and also rax bases. Benefioin 
businesses should tilsri he factored in. 



lie fconnmtc imp 
imports ot 



I nhjert I he Uck of detailed descriptions for res trlcl I (Jim. 

I objeii to the dievuHviutt o! Ihreatanod, nndangarad and 
oandldata wildlife opaclA*, specifically utunibaUntUtid Gray 
Wolf inferences, and pri.tr J* dog-hloek footed ferret inferences. 

1 believe in the multiple use concept, in that this is publi<- 
land it should b», used Tor all the public not just a chosen few. 
Public land should he used not only for recreation, but for 
grazing, harvesting of timber, extrHution of minerals as we.lt, 

1 believe most of the Utid should he sold into the private sec tn 
and put nn the tax rolls. If not this Then put the control to 
the state level where locnl people havo a say instead of the 

t.reat White Father" in Washington who doesn't understand loca^ 
problems. 




438 



RECEIVED 



MAY - 8 1995 



391 



lUBEAUOFLMDHMrtfr'E!.;. 



BLM Itiob Hoss 

Grass Creek Area Draft EIS 

P.O.. Box J19 

Wor 1 . arid, WY 82401-0119 

near Mr. Ross: 

I object to the significant financial impacts to businesses, 
individuals (and consequent ly to the tax bu.se), and the effected 
counties and communities due to restrictions proponed within at I 
of the alternatives., and recommend that a new preferred 

alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and state government*. 

I appreciate the opportunity to contribute to the very important 
Orosa Creek Area Environmental Impact Statement. Please find my 
comment s below. 

] object In The reduction of Grazing AllM's proposed In the 

Alternatives. Real, Eurrfilll scientific del a should be used to 
make management decisions on each allotment. Targets should be 
clearly established and stated. 

I object to the expansion ot "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas In the 
Grass Creek Area RMP. Return all wild animal management to the 
State Came and Fish, end return all managed animal production to 
the Private sector. 

I object to the data collection procedures cited for AUM 
utilization, and suitability. This should be complete ly redone . 



I object to the smal I amount of land 



idered for 



1 object to the lack ol discussion about impacts to the value of 
private, slnls and county lands by the various, a Iternatives . 
Especially those imbedded with the BLM Administered lands. 

I object to restrict ions that hamper the current primary 
businesses and Individuals who use federally administered lends 
to generate income nnd support our communities through taxes. 



1 object, to the severe and undue- number and 1 

on Surface Disturbance In all of the alternat 

emphasis has been placed on new technology and new In format! 

Mitigate and reclaim nny impacts. 



1 or restriction* 
nough 



391.2 



I objc 
ana Ins 



ins tor recreation disturhanc 
grazing ami recreation. 



ind the bias 



I object to the proposed blanket restriction* contained 
Off-Boad Vehicle Management. 



economic imparts 



I ubjaet. to the small consideration given tn 
to businesses and also tax bases. Beneficia 
businesses should also be factored in. 

I object the lack of detailed descriptions tor restrictions. 

I object to the discuc&ion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-black footed ferret inferences 

I believe in the multiple use concept, in that this is public 
land it should be used for all the public not just: a chosen few 
Public land should be used not only for recreation, hut for 
grazing, harvesting of timber, extraction of minerals as well. 



I believe mnst of the land should be sold into the private sector 
and put on the tax rolls. If not this then put the nnntrol to 

a] people have a say instead of the 

ut White Father" in Washington who doesn't understand local 



the state level when* 
"Oreo 

prnbl 



~rU& 



<*<u 






RECEIVED 



3S2 



BUREAU OF lAHDSlAMAGtUEHI 



BLM XBob Ro 

Grass Creek 

P.O. Box 119 

Norland, WY 62^01-0 1 1 Q 



Draft BIS 



De 



Mr. fcos* 



1 object to the s i grii f i cant financial impacts fco businesses, 
individuals (and consequently to the tax base), and the effected 
counties and communities due to restrictions proposed within all 
of the alternatives, and recommend that a new preferred 
alternative be created with the help of knowledgeable community 
individuals and representatives from grazing, recreation, oil and 
gas and minerals industry, timer and local and stote governments. 



ry important. 



T appreciate the opportunity to contribute to th 

Gj-nbH Creak Area Environmental Impact Statement. Please find my 

comments below. 

I object lei the reduction of Grazing AUM's proposed in the 
Alternet Ives. Real, Current scientific data should be used to 
make management decisions on each allotment. Targets, should be 
clearly established and stated. 

T nbjfll t to the expansion of "Wild Horse Management" areas. I 
recommend eliminating all "Wild Horse Management" areas in the 
Grass Creek Area RMP. Return all wild animal management to the 
Slate Game and Fish, and return .ill managed animal production to 



i b, 



vatn 



T object to the 
ut: 1 i r.ation, and 



abil ity 

amouri t of land 



procedures cited for AUM 
This should be completely 



idered for 



r nbjert to the 
expansion. 

I object to the tank of discussion about impacts to the valu 

privnte, state and county lands by the various alternatives. 

Especially those imbedded with the BLM Administered lands. 

I object, to restrict inns that hamper the current primary 

businesses, ond individuals who use federally administered lu 

to generate income and support our communities through taxes 



i's and undue number and lev 
oh in al 1 of the alternativ 
aced on new technology and 
any impac Is . 



t enough 
nrmntion to 



392.2 



I object to the bias for recreation di sT.urbonce and the 



T ohject to the proposed bT onket restrict ionn cant a i ned in 
Off-Road Vehicle Management. 

I object to the urn a 11 cons i derail on given to the economic impacts 
to businesses and also tax bases. Beneficial impacts of 
businesses should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of threilened, endangered and 
candidate wildlife species, specifically unsubstantiated Gray 
Wolf inferences, and prairie dog-block footed ferret inferences. 

I believe in the multiple use concept, in that this is public 
land it should be used for all the public not just a chosen few. 
Publ i c I and should be used not only for retreat ion, but for 
grazing, harvesting of timber, extraction of minerals as well. 

I believe most of the land should be sold into the private sector 
and put on the tax rolls. 11 not this then put the control to 
the state level where local people have a say Instead ot the 
"Great White Father" in Washington who doesn't understand local 
prnbl W ms. 



(J 



y °J?ry 



439 



RECEIVED 



(W-8B85 



MUM OF USDHAMSIl 



m 



393 



American Wildlands 

i-0 Fas! Ma:r S^refiT, Suite 2. Bamrr-an. MT 59715 
(406; 536 8- 75. FAX (4061 586 6?*? 



Bob Ross 

BLM Team Leader 

P.O.Box 119 

Worland, Wyoming 82401-01 19 

May 5, 1995 

Dear Mr, Ross, 

Thanh you for the opportunity to comment on the Grass Creek Management 
Plan. American Wildiands (AWL) sees portions of the Analysis Area as important 
components of the functioning greater ecosystem of the northern Rockies. In these 
times of extreme political pressure we are encouraged by some of the proposals within 
your plan including; the continued protection for the Owl Creek, Sheep Mountain, Red 
Butte and Bobcat Draw Badlands Wilderness Study Areas, lie recognition of valid needs 
for non-motorized semi- primitive recreation areas, the proposal for three Areas of 
Critical Environmental Concern (ACliC) and the withdrawal of public lands along the 
Bighorn River, the Legend Rock Petroglyph Site, parts of the Meeteetse Draw Rock Art 
ACEC and the Upper Owl Creek ACEC from mineral development. We urge you to go 
further in protecting such resources as the South Fork of Owl Creek, all riparian lands, 
critical habitat for plants, fish and wildlife, roadless and primitive country, grazing lands, 
candidate National Natural Landmarks, additional ACECs and opportunities for genuine 
'multiple use". 

American Wildlands believes that Owl Creek, Sheep Mountain. Red Butte, and 
Bobcat Draw Badlands should be managed to retain their wilderness character. We 
think that the heavy emphasis within the proposed management plan on provision of 
motorized recreation is unacceptable. Opportunities for recreation in unloaded and 
primitive settings within the resource area are severely limited already. Unique and 
valuable scenic resources and candidate and potential National Natural Landmarks 
should be granted protection under visual management classification of "VRM 11." 

We support the proposal to establish the Fifteenmile Creek, Meeteetse Draw and 
Upper Owl ACECs but we think they should also be withdrawn from potential leasing 
for oil and gas and minerals development. The extraordinary value of the natural and 
recreational resources of the Fifteenmile Creek Watershed Area should be recognized 
and protected. We think that the South Fork of Owl Creek does in actuality meet the 
criteria for classification as a Wild and Scenic River and that it should be protected from 
oil and gas and minerals development and road construction. 



393.2 



AWL supports the proposal to remove lands along the Bighorn River, the 
proposed Owl Creek ACEC, parts of the proposed Mecteese Draw Rock Art ACEC and 
the Legend Rock Petroglyph Site from mineral entry. Please consider extending the 
proposed withdrawal to the four Wilderness Study Areas in this resource area. 

Thank you for the opportunity to comment on this important management 
proposal. 

Sincerely, 



Robert Hitchcock 
Resource Specialist 



/ULhiiUU 



MAY -8 1995 | 



394 



May 4. 1995 

Sherman T. Mast 
215 W. 8lh 
Casper, WY 82601 

Mr. Bob Ross 
RMP Team Leader 

P.O. Box I 19 

101 S. 23rd St. 

Worland, Wyoming 82401 



■0119 



Dear Mr. Ross: 

Over a period of" several weeks. I had an opporruniry to examine 
the draft Grass Creek Resource Area Management Plan in 
considerable detail. Indeed, outside the BLM, 1 probably know as 
much about this document as anyone. I am also familiar with the 
country, T have tramped across public lands in the Bighorn Basin 
for the better part of 30 years. 

First, allow me to make a few comments about the process. I know- 
many people who adhere, in one hue or another, to the so-called 
"wise use" philosophy in your area and throughout the state. Many 
arc good, well-meaning souls who want to improve relations 
between users of public lands and the agency personnel who 
manage them. Some ranchers in particular are real 
conservationists. 

A few disciples, however, are merely blow-hards looking to pick a 
fight, or to line their pockets. Worse, they are ignorant blow-hards 
who don't like anything sharp, like facts, pricking their dull 
impulses. 

The BLM has no responsibility to make decisions simply to placate 
a gaggle of this ilk. I think you know the difference, and I trust you 



will keep the distinction in mind as the planning process goes 
forward. 

Moreover, keep in mind that I own the same 1 /260,000.000th 
interest in the Grass Creek Resource Area as any rancher, miner, 
hunter, or hiker in Worland. Grcybull. or any citizen of Newark. 
N.J., or Honolulu, Hawaii. I spend much of my Lime on public 
lands, sometimes with a 4x5 field camera on my shoulder. Camera 
or not, the simple delight of such places is reward enough. Thai's 
my "custom and culture. " It's called public access, now and in 
perpetuity. 

Deal with lacts and science, not supposition and hysteria. Do what 
is right by the resource, because the resource will outlast us all. 
Your principal responsibility is to protect it for future generations. 
On the plan's details. I would offer the following comments: 
First, I do not think the fate of the state's oil and gas industry 
hinges on a single strip of kind approximately 2.5 miles by 10 miles 
in size. Withdraw the Upper Owl Creek area from leasing 
consideration entirely. If Upper Owl Creek is worth protecting, 
then protect it. Don't simply make a show. Don't leave the door 
open for future drilling exemptions. 

It is not holy writ that oil and gas activity shall be pre-eminent, at 
all times and under all circumstances. Some objections have even 
heen raised to timing stipulations, as if allowing antelope an 
opportunity to give birth infringes upon a "right" to drill public 
land at will. 

Of course, this is nonsense. If multiple use means anything, then oil 
and gas must be regulated in a manner that is consistent with other 
values. Timing stipulations, and even outright prohibitions in some 
cases, are no more than predictable consequences of true multiple 
use management. 

Many people are amazed to learn there are wild horses northwest 
of Worland. But knowing ihey exist doesn't make them any easier 
to find. A good dirt road to at least a portion of ihe range would 
help. And more visibility means a larger constituency, as 
experience on the Pryor Mountain Range suggests. 
In terms of economic impacts, there may be a few AUMs lost to 
cattle or sheep if the horse herd management area is formally 



394.2 



440 



394.3 



enlarged. But any economic loss would be minuscule compared to 

potential economic benefits. 

Outings organized by the BLM, or by volunteers, could help slow 

the tourist swarms to and from Yellowstone. Properly promoted. 

many people would surely spend an extra day in the basin if they 

had a reasonable hope of seeing some REAL wild horses. How 

many tourists are likely to stop with assurances of seeing REAL 

cows? 

Keep in mind people worldwide are looking for interesting travel 

experiences. Gene Bryan, state tourism director, says dude ranches 

and things with an authentic Old West flavor are good bets for 

travel development. Put the horses on the Internet. They could 

become famous. 

Some environmentalists are troubled by the presence of cattle and 

sheep on public lands. Frankly, it never occurred to me that they 

shouldn't be there. 

I will say you did yourself no favor by the manner in which grazing 

was described in the draft plan. I'm sure no one knows better than 

you how difficult it is to reassure people a 25 percent cut in AUMs 

is actually not a change. 

And your Fiftecnmile Watershed ACEC got caught up in the 

brouhaha. Many people don't trust ACECs. They suspect an ACEC 

is simply wilderness by another name. 

1 know "ACEC" is merely another way of saying mere are special 

concerns about an area. But it really doesn't matter what you call 

it. Designate it the "Joe Johnson Historic Hereford Preserve," if 

that Is more acceptable. What matters is how you manage, and 

whether the resource is enhanced or diminished. 

You might simply want to proclaim that grazing will remain 

generally at current levels Changes to protect the resource will be 

made according to the condition of individual allotments- In the 

Fifteenmile area, solemnly announce that no ACLC will be 

designated according to the wishes of the people — but prudent 

steps will be taken to reduce sedimentation and to protect the 

watershed. Which, of course, it about what the plan seeks to do 

anyway. 

And speaking of ACLCs, how about that Meeteetse Draw 



394.4 



petroglyph area? Now we're really talking "custom and culture." 

People should be able to enjoy the petroglyphs. But that doesn't 

mean access should be easy. Vandalism is less likely ro be inflicted 

by a person who must work to reach the site than by a goof 

casually cruising past with a six-pack on the seat and a 30.06 in 

hand. 

Perhaps there should be a locked gate at Meeteetse Draw, like 

there is at Legend Rock. A key could be checked out at the BLM 

office or at Hot Springs State Park. Organized tours and 

continuing education projects also are good ideas. 

This approach may address concerns expressed by the Eastern 

Shoshones, Speaking of the tribes, the Eastern Shoshones and 

Crows must be full partners in deciding the fate of both Legend 

Rock and Meeteetse Draw. It's their heritage you're talkjng about, 

after all. Who would presume to manage the Sistine Chapel without 

consulting the Catholics? 

I know that wilderness is beyond the scope of this document, but I 

cannot imagine, whether in wilderness or not, a higher use for the 

painted badlands than to leave them alone. These truly belong to 

the ages. 

Please enter my comments into the official record for the draft 

Environmental Impact Statement of the revised Grass Creek 

Resource Area Management Plan. 



Sincerely. 



>4^^nr 



Sherman T. Mast 



395 



Steve Jones Cheryl Eisenmann 
xxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx 
xxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx 

Page Spahr 
xxxxxxxxx 
xxxxxxxxxxxxxxxxx 



Bob Ross 

BLM Team Leader 

P.O.Box 119 

Worland, WY 82401-0119 

Re: Grass Creek Management Plan 



Dear Mr. Ross: 

I am writing to express rny concern over the Grass Creek Management Plan. It seems 
to me your plan manages (or encourages) use by industry, but not recreatiorusts. Wildlife 
and wilderness considerations are largely ignored. I urge you to rewrite the plan to achieve 
some balance. Specifically, I suggest you do the following: 

1. Close all wilderness study areas to oil & gas leasing, hard rock mining, and 
motorized vehicle use. 

2. Maintain all roadless areas over 5,000 acres as primitive backcountry areas. 
Manage these areas to promote solitude and backcountry use. 

3. D_q No_t Allow gjflj more roads Ja fee built. Roads affect wildlife more seriously 
than any other types of construction, because the 

[page 2] 

access is so greatly increased that hunting pressure increases geometrically. 

4. Ban any natural resource development in Areas of Critical Environmental Concern. 
If they are of critical concern, why let oil & gas or mining companies muck it up? 

5. Allow no more than 50% of the acres to be leased to oil & gas development and/or 
mining combined. 

For those of us living in Wyoming, we want to be able to enjoy the public lands in our 
state. We can only do this if you save some acres for enjoying the land undis turb ed, in its 
natural state. 

Please amend your plan accordingly. 



I%l Page Spahr 

/$/ Cheryl Eisenmann 



Sincerely, 

Is/ Steve Jones 




396 



Amoco Production Company 



3aa-[i3QirHo 



May 5. I9"5 

Me. Bob Ross, Team Leader 
Bureau of Land Managerr-eni 
P.O Box 119 
Worland, Wyoming 82101-0119 

Grass Crock R esource Are a Resource Man ngcrr.cn; Plan 
Draft Ennronmcnt.il Impact Statement 

Amocti Production Company (Amoco), a subsidiary of Amoco Corporation, is incorporated for the 
purpose of exploring for and developing oil mid ijas resources throughout die United Slates 
Amoco has extensive federal Icaseholdings throughout [he western U S., and a continuing interest 
in the federal land planning process Amoco has conducted and plans to continue to conduct 
operations throughout Wyoming, therefore, management policies Outlined in this draft EIS could 
have an impact on Amoco's interests in the area We appreciate ihc opportunity to C< 
this draft EIS. 



The Preferred Ahernauvc in the DEIS/RMP doubles the use of restrictive lease stipulations in 
Grass Creek Resource Area . This is not backed by data that support the sigmficani increases 
restrictions on future oil and gas c^plgraricni and development, It is BUM's obligation to 
demonstrate that less restrictive measures were considered but found insufficient to protect the 
resources identified A general statement that there "'appears (□ be sensitive or conflicting 
values'" docs not justify' the need to expand resmcuons An examination of the less restrictive 
measures il critical to the analysts in the Draft EIS 

The Draft EIS indicates histonc resources in ten oil and gas fields would lie managed for scientific 
and public use. Inn purpose of the program would be to improve knowledge of ijic historic 
significance of the fields and facilitate the approval of future development and reclamation 
activities PAW posed several questions regarding this approach that, to our knowledge, have not 
yet been answered Tncsc questions were 

I) How docs Bl.M justify this reallocation of time and resources when areas such as southwest 
Wyoming arc in desperate need of archeological surveys for APDs. rights-of-way, etc ? 

7.) BxplllJI the need to examine these fields for listing 

3) Clarify the benefits derived from listing these fields Would then; be uny incentives to spur 
Opoi ator participation" How would designations affect post-production abandonment procedures' 1 



441 



396.2 



4) How does BLM plan to handle the National Histonc Preservation AcL (NHPA) Section 106 
consultation requirements to consider possible effects of undertaking & on listed districts, sites, 
building, structures or objects, especially when the proposed new operation is the same or similar 
in scope to pnor activities and operations' 1 Specifically, will BLM impose restrictions that inhibit 
an operator's ability to replace or update old equipment or to pursue new technology which might 
extend production? 

.Amoco cannot support this program without the answers to these questions 

If the Preferred Alternative is adopted, BLM would impose a limit on total surface disturbance to 
less than 20% in sage grouse habitat. Clarification is needed as to whether other multiple-use 
activities (in addition to energy and mineral activities) would be subject to no surface occupancy 
constraints, In general, we favor a case-by-case analysis that takes into account site-specific 
opportunities for mitigation of adverse effects on sage grouse rather than the impact threshold 
approach 

Many of the proposed ACBQ have significant potential for oil and gas exploration and 
development. I lowrver, it is unclear how such designations will affect opportunities to explore for 
and develop oil and gas BLM Manual 1 61 3 requires ACECs to have specific relevance and 
importance in order lo qualify for designation. It is unclear how these proposed designations meet 
the importance criteria. 

In conclusion, Amoco hclicves dial extraction of oil and gas can be accomplished in an 
environmentally responsible manner without unreasonable restrictions and stipulations. With this 
in mind, we believe these concerns can and should be addressed in the Final Environmental Impact 
Statement. Again, we appreciate the Opportunity to comment. 



}. R Rutty 
Environmental Specialist 



■■■■■.:-' f>-;.' ij 



5/3/95 



1 am writing in regard to your Grass Creek Resource Area Management Plan. I 
disapprove of your Preferred alternative. It is slanted away from multiple use and the 
Historic uses of Oil & Gas, Grazing. The cconomys of the Locals will be greatly affected 
by a reduction A.U.M.s. and restrictive Oil & Gas Leases. 

I object to createing Wilderness, and Manageing Like Wilderness without Congressional 
aproveal . 

There also seem Like your office has broken many Acts of Congress in makeing of 
your Pi an. 

71 % of alternatives are the same (Nepa) also 1 believe you arc in violation of 
Wilderness Act, Multipal Use sustain Veiled act.; Americans with disabilities act, 

I would Like you to turn more to commodity USE and Motorized ReCreation. 
Thank you 
Michael Tokarczyk / s / Michael Tokarczyk 

xxxxxxxxxxxx 
xxxxxxxxxxxxxxxx 



RECEIVED 


j m- 


8B95 


BUMSUOF U 


Nf> (Maufimn 



398 



May 6, 1995 

Tom Easterly 
132 N 5th St 
Greybul 1 . WY 8242b 



Boh Ross, Team leader 
Wor land District . BLM 
PO Box 1 19 
Worlanrj. WY B2407-01 19 



am wr i t in 
laws are m 
rganizat io 



• concerned citizen of the Bishorn Basin. My 
alone and do not represent that of any 
agency. 



1 would like to commend the BLM on ch 
Are* Management Plan. It does eunsid 
not go for enough to protecting the v 



BKfi Creek Resource 
ultiple use, but do 
at ion and wi Id] ife 



Livestock grazing will need to be more closely monitored to 
ensure enough for«Ke is left for wildlife, ac-il and water 
protection, and health of the vegetation. 

Oil and gas exploration/development does have lib place in the 
area, but timing restrictions should be in place on wintering 
and parturition areas for big game. Well densities should not 
exceed a level that will discourage use of the area by 

wildlife. There should be some areas (e.g. ACECs) set aside 
where no development could occur. 

Wild horse numbers should be lightly eontrolled. Too many 
horses can cau.su damage to vegetation and soils, just like too 
many cattle or too many deer, Wild horses should be given 
lowest priority In alt areas, after all species of wildlife and 
(1 hate to say it) livestock. 



nt plan should be 
cd every year. Thi 



Soma road closures or a vehicle ms 
d«vts loped . More roads are being f 
needs to Of stopped. 

Again, 1 would like to commend you on a good job. Do not I 
the anti-government, wise abuse movement sway this plan (or 
something more resource friendly) from being carried out. 




WYO-BEN, INC. 



399 



Mr Bob Ross 
RPM Team Leader 
Bureau of Land Management 
Pom Office Box 119 
Wuriand. VVY 82401-01 1 9 

RJi. (Bran Cnrk Resource Area Draft SIS 



Dear Mr Ross. 

Wye-Ren. Inc interests in the Meetectsc Draw area lie not only with our mineral claims. 
bul also with the preservation of the rock an adjacent to the claims We would like io emphasize 
from the beginning that Wyo-Ben supports ilie evolution of a conservation plan for the unique 
petroglypb sites, especially a plan thai includes public viewing and access Wc may, in fact, be 
able to assist ingress and egress through a variety of beneficial, U'unreiated, activities associaied 
with our mineral access, and would not rule out other forms of assistance wherever possible 

However. Wyo-Ben could not sanction the proposed Meeteeisc Draw ACEC withoui 
reasonable assurance that the designation would have a negligible economic affect on us 
Particularly, we could noi accept any resolution to exclude or impede our ability to explore, 
conduct mining operations, or further establish viable mineral claims. 

We are also concerned about the perception of the general public when day excavation 
begins in this area, wc are already an award- winning reclamation organization and will continue to 
maintain our philosophy of environmental excellence. Despite this, there are those who will 
object to our mere presence regardless of any vested economic interest Wyo-Ben might have 

We are convinced that a variety of solutions exist Particularly, the EIS would be 
enhanced by language that accepts bentonite mi rung U an inevitable use of the land The F.IS 
could also provide a mote flexible definition of "Immediate Vicinity," to allow tor the assessment 
of site specific: impact from mining 

We also require clai iucalion of the requirements for conducting exploration work in the 
ACEC The 3809 regulations do not provide for a notice in an ACEC. only casual use or a plan. 
We are nul prepared foi the additional bonding or permitting requirements lhat might be created' 
as a consequence of a new designation 



442 



399.2 



The His contains Information designating diKufbancs (Table 8) associated with bentonite 

mining Supporting documental ion describing the specific disturbance and erosion would be 
appreciated 

Isolation Of the Mecicctsc Draw A.CEC to those sandstone outcrops where the :ock art 
cvists eliminates any interpretation of mining viability, unless "adjacency" becomes an issue 
Please consider limiting the boundary lo the exact location, lithology, and lopojjraphy of the 
petroglyphs without imparting a buffer /.one 

Lastly. Wvo-Ben's participation in the development ot'a Management Plgn is essential 
Agam. WB may be able to offer help in several ways, and the knowledge we gain would allow for 
the coordination of mining activity with the augmentation of the rock an sites In such fashion, 
we can also minimize any impact, perceived or real, to the area surrounding these exciting and 
important discoveries 



Ifv 



a assist in any way., please do not hesitate to contact us Thank you 



Very Truly Yours. 
WYO-BEN, INC 



Rick Magstadt 
General Manager 



[Wyoming State Legislature Letterheadj 



400 

[State Seal] 



SENATOR CARROLL S. MILLER 
Senate District 19 
BiQ Horn/Park Counties 
219S Beaver Creek Road 
Shell. Wyoming 82441 

Committees: 
Corporations. Elections and 
Political Subdivisions, Chairman 
Judiciary 

Team leader, Grass Creek Management Plan 
Bureau of Land Management 
Worland, Wy, 82407 

Dear Sir: 

I am writing to voice deep concern and opposition to many elements and the general thrust of 
the Grass Creek Resource Management Plan. 

There is a definite dilution of the multiple-use concepts with significant impacts being felt by 
all users. I sense an attempt in the document to reflect certain politically correct positions 
that on closer examination are injurious to both the national and the local interest. For 
instance, why a reduction in the ability to access potentially valuable oil and gas deposits at a 
time when our negative trade balance of payments, much of which is the result of increasing 
oil imports, is threatening our very financial structure? Why the attempt to reduce grazing 
instead of maximizing use of that renewable resource? Why not serious efforts of the 
alternative of holistic management of grazing which has worked well in my immediate area? 
Please change the direction of your document to maximizing use of this marvelous area, 
which is, in truth, woefully under-used, as evidenced I'm 
[page 2] 

sure by the fact that many of your respondents have never been in or about the area or 
actually know its location. And that brings up a concern about the apparent equal weight 
factor given to any communication whether the writer has the slightest knowledge of the land 
or not, and the total implications of what is being proposed. 

I would ask your complete reconsideration of the draft and the major problems that the 
citizenry has with it. 

Sincerely yours. 

Is/ Carroll S. Miller 




401 



May 2, 1995 



Bureau of Land Management 
Grass Creek Area Draff. BIS 
F.O Sox 119 
Worland Wy 82401 0119 

Attention: Sob Ross 

Fax [3071 347-6195 



I object CO the significant financial impacts to businesses, 
individuals land consequently to the tax base) ,and the effected 
counties and communities due to restrictions proposed within all of 
the alternatives, and recommend that a r.ew preferred alternative be 
created with the help of knowledgeable community individuals and 
representatives from grazing, recreation, oil and gas and minerals 
industry, timber and local and State governments. 

T appreciate the opportunity to contribute to the very important 
Grass Creek Area Environmental Impact Statement. Please find my 
conmer.ts below: 

i; I abject t.o the reduction of Grazing Aims proposed in the 
Alternatives. Real, current scientific data should be 
used to make management decisions on each allotment:. 
Targets should be clearly established and sv.at.ed. 

2! 1 object to the expansion of "Wild Worse Management" 
areas. I recommend eliminating all "Wild Horse 
Management" Areas in Lhe Grass Creek area RAMP, Return 
all wild animal management to the State Carte and Fish, 
and return all managed animal production to the Private 
sector. 

2) T object to the data collection procedures cited for A.1K 
utilization, and suitability. Thie should be completely 
redone. 

4| T object to the email amount of land considered for 
suburban expansion. 

5) T object to the lack of discussion about impacts to the 
value of private, 3tate and county lands by the various 
alternatives. Especially those imbedded with the BLM 
Mminiaterud lands. 

5) I object to restrictions that hamper the current, primary 
businesses and individuals who use federally administered 
lands to generate income and support our communities 
through r.^xes . 



401.2 



7 ) I obj ect co the severe and undue number and level of. 
restrictions on Surface Disturbance in all of the 
alternatives. Not enough emphasis has been placed on nsw 
technology and new information to mitigate and reclaim 
any impacts . 

S) I object to the bias for recreation disturbance and the 
bias against minerals, grazing and recreation. 

9) I object to the proposed blanket restrictions contained 
in Off-Road Vehicle Management. 

L0) I abject to the small consideration given to the economic 
impacts to businesses and also tax baaea. Beneficial 
impacts of businesses should also be factored in. 

:i) I object to 
restrictions. 



the lack of detailed descriptions for 



I object to the discussion of threatened, endangered and 
candidate wildlife species, specifically unsubstantiated 
Gray Wolf inferences, and Prairie dog, aiaclt-Footed 
Ferret inferences . 




443 



40 4 



SUA 

C/0 Bob Ross 
PO Box 1 19 
Worland WY 82401 



0119 



Dear Mr. Ross, 

Thank you for the opportunity to make my comments on the Grass Creek HIS. 

I have been following some of the issues, and it appears to me that the individuals an groups 
which use the land to drive the local economy arc being short-changed. Restrictions such as 
surface occupancy additions will only hurt the grazing, oil and gas, and timber industries. 
These are what are most imponnt: the groups which provide jobs. We simply can't afford to 
have a land mangement program in place which does things like expanding Wild Horse 
Management areas. 

Sincerely, 

/$/ Robert Winland 

XXXXXXAXXXAXXXXXX 
XXXXXXXXX XXX XXX 



to businesses, 
she effected 



NfV ^£1956'-"'! i C/O sob Ross 

SriasJCreaJt Area Dract KIS 

new w_ lamd uutAKEtfL e :X ll5 

WBJUO.W.^ .v. ■■■ ._:-..: 

Rx (327) 347-B195 

I cfaject co che sicjii fica.it: ;".ir.ar.cial irr.pacts 

individuals (and conaequencly co che tax base) , ; 

couacies and cemmurueias due to restrictions proposed v 

ci« alternatives, and recommend that a new preferred alternative ba 

crasced with che help of kr.owIedojiaoLs con-muni, ty individuals and 

representatives! from gracing, recreation, oil and gas and minerals 

Industry, timber and local and state goveEWRWits . 

7 appreciate the opportunity tz contribute to the very imporcanc 
Gra^s Creek Area Environmental Impact Statement. ?lease find my 
comment!: below. 

I object to tha reduction of Crazing AUMs orooossd in the 
Alucmativas , Real, current scientific data should fca used CO make 
inar.agefr.ent decisions on each allattnei&t.. Tdrge-s should be clearly 
established and stated. 

1 cbject to the expansion c; "Wild Horse Management" areas. 1 
recoranenc eliminating ail "Wild Horse Management" a-2as in the 

Grass Creek area RKP. Return all wild animal management to the 
State Game and Fish, and return all manac/ed animal production tc 
the Private sector. 

I cbject to the data collection procedures cited for mjm 
utilization, and suitability. This should be cemplssely redor.e. 



403 



amount oi 



land cons idered 



? object to che la^!< of discussion about impacts to the value o; 
private, state and county lands by the various alternatives . 
Especially those imbedded with the SLM Administered lands. 

I object to restrictions that hamper the currant primary businesses 
and individuals who use federally administered lands to are 
gefiaxs.ee income and support our communities through taxes. 

" c"c;ect to the severe ar.d undue number and level of restrictions 
on Surface Disturbance ir. all of the alternatives Met enough 
emphasis has bean placed on new technology and new information ta 
mitigate and reclaim anv impacts. 



_ object co th-s proposed blanks; : 
Vehicle Management . 






403.2 



I object co the STiall consideration given to the economic impacts 
to businesses and also tax bases . Beneficial impacts of businesses 

should also be factored in. 

I object the lack of detailed descriptions for restrictions. 

I object to the discussion of Threatened, endangered and candidate 
wildlife species, specifically unsubstantiated Gray Wolf 
inferences, and prairie dec/- Black-footed ferret inferences. 



jZ^a ^f r . JL./C- 



RECEIVEC 

wr- 



^ 



8&C<% 



'f> 



404 



T E E T S E 



WYOMING 






IRADLtrCAUFFMAN 



V O 80*3ia- vtncCTSi mC".' 



»] «6frv:(,j . pmOnF <30*1 M-2 



April 18. 1995 



Boa Ross. Team 1-eader 
SLM 

Worland District Office 

PO Box 1 iy 

Worland. WY S2401-01 iy 

Dear Mr. Ross: 

RIL: Grass Creek Resource Area Draft Environment Impact Statement 

All entities within Ihs Grass Creek Resource Area will inherit ihe consequences of the proposed 
decisions of the Grass Creek Resource Area DEIS which become policy for all io live with, The 
grave impacts and the process should be questioned. 

Every school district within the boundaries of the Grass Creek Resource Areas's nearly million 
acres should have been informed and involved with the formation of this bureaucratic process 
burden of proof. As members of the Board uf Trustees of Park Co'jntv School District gl6, we 
publish meeting dates, so die democrat:: process oi public involvement can continue in our 
community. Shouldn't a policy-making document as significant as this have had input in the 
beginning, rather than reactionary comments at the end? Without due process, .school districts 
are being superseded by the iron rod of "some persons" within a federal agency It appears as 
if this process should be changed. 



: for our well- 

the efforts of 

When U-.ese 



School districts, just like federal agencies, are totally dependent upon the tax 
being. Like you, we do not generate money. That lax base is derived r 
private enterprise. In good times or had. we are the benefit of the reiou 
private enterprises become over-regulated, evervone loses. 

Let's look at the economics of grazing, for instance. This plan calls for an unscientific and 
unsubstantiated cut of 56,000 AUM's. which according to Dr. f-'letcher from the University of 
Wyoming, are worth $77. SO each to the local economy. , That is a loss of $4.juo, 000.00 
annually to the local economics this "resource" area. The oil and gas proposals, such as time 



444 



404.2 



Bob Ross - BLM 



Page 2 



limitations, are hostile to Park County School District #16. because it is 86% dependent upon 
the oil and gas taxable revenues. We have already "riffed" on our staff. Our district cannot 
afford a penny's loss. 

Schools are primary to the custom find culture in each of the small communities within the Grass 
Creek Resource Area. The school is the focal point of community activities and the source of 
pnde for individual, team, and community accomplishments. The proposed cuts and lossci .set 
forth in the Grass Creek DHLS of the current revenue and taxes derived from oil and gas 
production and grazing of federal lands will jeopardize schools and their programs for Uic most 
valuable resource, our children. 

What a few folks at the BLM office to Worland feel is right, will adversely impact this entire 
area. Due to the economic and the custom-and culture devastation to Park County School 
District #16, we implore you to withdraw the Grass Creek Resource Area Draft Environmental 
Impact Statement of which we have had no input. 



Yours truly, 

John Hogg 

Chairman of The Board 



Don Miller 
Treasurer 



Congresswoman Barbara Cubin 

Senator Craig Thomas 
Senator Al Simpson 
Governor Jim Geringer 
State Senator Hank Coe 
State Representative Peg Shreve 
Darrell Barnes 
Joe Vessels 



//;• 



<^£ 



,4*- 



Mervin I-arscn 
Clerk 



Charles Raper 
Vice-Chairman 



Bill Schlenker 
Board Tnisiec 



RECEIVED 



MAY - 8 B95 

ujkuuofUNDUM&abn 



First Xatioxai Baku 

AFFILIATE OF PINNACLE BAM CORP 



PO 9o> i36y 
i Ot?TlBfl*-5S58 • Fm i30?i asi-iirot. 



405 



May 5. IWS 



United States Department of the tntertot 

Bureau of Land Management 

Worland District Office 

PO Box 119 

Wot land. WY 82401-0119 

Attention Joseph I. Vessels 

Grass Creek Area Manager 



QrlM Creek Ri 



Management Plan 



Dear Mr. Vessels 



Enclosed please find OUT comments on the Grass Creek Resource Management Plnn Please 
review them at your convenience 



Sincerely. 



" Branch President' 



JLS/lu 
Enclosures 



jr 



405-2 



First Xatio.\ajl Baxk 

AFFILIATE OF PINNACLE BANCORP 



P.O. Box 1369 
Therm opens Wyoming 82443 
Phono: (307) B64<8S5J • hax (30'') 36. 



'10 WHOM IT MAY CONCRRN 

R£ COMMENTS ON THE GRASS CREEK 

RESOURCE MANAGEMENT PLAN 
ENVIRONMENTAL STATEMENT BY 
JERRY L. SLAGLE AND STEVE COUGHLIN 
FIRST NATIONAL BANK - THERMOPOL1S 

It is very difficult to summarize in a few pages the comments concerning a study thai has been 
yoing on for years and contains as much information as'this plan has 

In trying to breaking it down, it appears that it has roughly three (3) areas of purpose for this 
study and plan, which EN 

(1) Vegetation management 

(2) Special management area designations 

(3) The recourse accessibility and manageability. 

It in lacking in three ways. 

( 1 ) The economical impact effecting the residents of the recourse area 

(2) No solution offered to the residents to increase their economic productivity 
within the resource area. ' , 

O) We Fail to see thai this document gives any support or encourage any multi-use of 
public land. 

Everything we r<jad within this proposal will restrict or- reduce animal units for the ranchers and 
restrict mineral exploration and extraction practices 

The multi-use description in the Grass Creek Plan will restrict ranch families and oil field workers 
in their activities, not only in numbers, but restrict their ability to cover the ground. You should 
be aware, that these are the people that supervise and are the stewards of the land, such 
restrictions on their travel and their function will certainly have an impact on being up-to-date on 
condition of the area. True multi-use ground is used for ranch:r.g. oil production, hunting, site 
seeing, wild life habitat and wet lands. Comments within this study show that this is not the inlent 
of the multi-use. but is to restrict many of these activities or uses 



MAY- 81995 



UtiAU OF LAND MAMAGEMltn 



406 



WORLAND DISTRICT BLM 

BOB ROSS, HMP TEAM LEADER 

BOX 119 

WORLAND, WY S2401-G119 



DEAR SIR 

I AM WRITING REGARDING THE GRASS CREEK LAND USE PLAN. I OPPOSE THE 
PLAN BECAUSR I DO NOT BELIEVE THE INFORMATION USED IN THTS PLAN HAS 
BEEN RESEARCHED ENOUGH . THE DEFINITION OF BXCESSIVE SOIL EROSION, 
POOH VEGETATION AND OTHER CONDITIONS ON PAGE 3 7 OF TABLE 2 NEED 
CLARIFICATION . 

THERF, ARE NO NUMBERS OF WILD LIFE AND WILD HORSES IN YOUR PREFERRED 
PLAN. THERE IS NO DIFFERENCE IN PREFERRED PLAN AND R,B,&C TN 
GRAZING STRATEGIES ON ELK WINTERING RANGES. I OPPOSE- THE BOUNDARIES 
OP THP. ELK WINTERING RANGE. 

I THINK NO SURFACE OCCUPANCY IN THE OWL CHEEK AREA WOULD RE 
DETRIMENTAL TO ANY GAS AND OIL PRODUCTION AND IS UNNECESSARY 

THE REDUCTION IN AUM'S TN YOUR PLAN HAS NOT BEEN EXPLAINED. THERE 
IS NO REASONING BEHIND THESE CUTS. MDST OF THE OBJECTIVES ARE NOT 
ACHIEVABLE IN THIS PLAN, SO I OPPOSE THE ENTIRE DRAFT. 

ED SHAFFER 



cs Mju 



H O RANCH, MANAGER 



445 




Hot Springs (hardy 
Sportsman's A ssociation 

THESMOPOUS, WYOMING 



U.S. ^tijt. of Jiitorior 
Bureau of i*nd Kanaptncnt 
Krone, Croek Ueaouras Ar^^ 
uorJand, rv 3»i01 



l ml i IfW 



■■•-■■ 



tun Lender 



The main concern ef our Hot Springs County Sportsman's Association is to 
oonmunt on recreational use, particularly in regards to access- '["he two main 
arena wc would like improved public accese are the Kcd Canyon ;md Owl Crwtk/ 
Ruck Creek mm, 

Tim liert Canyon needs (iceees from the north t>nd for rich's now with a Biptnsd 
^rkinp; axa&i Low impact opportunity by foot or horseback only would be 
M.ccept^blB ami nininlsa damage to this sensitive anvtroamtiU. in tnt- future 
access through the ned Crock valley mi^hl be obtained through landowner (MttlwiQi! 
or cooperative agrecsienta. 

Access to the South Fork of 0*i Creek and Rock Creek up the existing rtswl Lb 
vital to the interest of aportsutas and recreational users in Slot Springs C' 
This area provides an important access corridor for hunting and fishing 
opportunity to the Vashakie Wilrerne66 arna. 

XOVX continued Interest in public access ifl greatly appreciated. 



ty. 




Bob Ross 

As a former resident of Wyo. and still a land owner in the area that will be affected by 
the Grass Creek Resource Area. I would like to state my objeiion to the Plan. 

AH BLM lands should be abel to be used to its full potential. Not set a side for a few 
selfccntcred environ men talest. Who do not have to worry about trying to make a live off of 
the land. 

Further more it is acts like this that are makeing peopel in the west mad. The 
government should stand up and take notice or the people in the west are liable to stand up 
for there rights. 

Thank you 

($/ Lewis Mc Sharry 




409 



ftStCMt, Suite 2&0i 



• Denver, COR0203--1313 

Telephone 303/860-0099 

FAX 303/860-0310 



Mr. Bob Ross, Team Leader 
Bureau of Land Management 
P. 0- Box 119 
Worland, WY 82401-0119 

Dear Mr, Ross: 

On behalf of the Rocky Mountain Oil and Gas Association {RMOGA), following arc 
comments on the Draft Environmental Impact Statement (DEIS) and Resource 
Management Plan IRMP) for the Grass Creek Resource Area (GCRA). RMOGA is a trade 
association with hundreds of members, both small and large, who account for more than 
90 percent of The oil and gas exploration and development activities in the Rocky 
Mountain-West. As such, RMOGA's members have a vested interest in how BLM intends 
to manage its lands, specifically with regard to oil and gas activities. 

RMOGA Is strongly opposed to the Preferred Alternative contained in the DEIS/RMP 
because it would arbitrarily do uble the use of restrictive lease stipulations in the GCRA. 
This management proposal is especially troubling since BLM failed to present data in the 
DEIS which furnish a basis for the severe increase in restrictions on future oil and gas 
exploration and development activities. Bureau policy, restated in the DEIS, requires 
NEPA and planning documents to conclusively demonstrate the need for constraints and 
that less restrictive measures were considered but found inodequote to protect the 
resource identified as requiring special protection. This has not been done. 

A general remark in the DEIS That there are sensitive or conflicting resource values Of uses 
in an area certainly does not meet analysis or policy requirements. Vague assertions do 
not constitute justification for expanding lease or operational restrictions. Discussion of 
specific resources to be safeguarded, along with a discussion of perceived conflicts 
between it and oil and gas activities, must be given. Furthermore, an examination of the 
less restrictive measures which could have been utilized must be a fundamental element 
of the analysis discussed in the DEIS. BLM has not fulfilled these requirements and has, 
Therefore, failed to comply with NEPA analysis standards or BLM Manual 1624 
Supplemental Program Guidance for Fluid Minerals. 

The DEIS also tails to include a discussion of mitigation measures, operating standards, 
or guidelines in the DEIS. Section 1502 of the Council on Environmental Quality 



Mr. Bob Ross, Tean 
May 8, 1995 



Page 2 



409.2 



Regulations on the National Environmental Policy Act directs that mitigation measures 
which could be employed to reduce or entirely avoid impacts to other resource values 
must be identified in the EIS. While this could be construed to mean that only lease 
stipulations need to be identified, it is crucial to discuss mitigation which may be utilized 
bt the time of oil and gas drilling, both exploration and development, such as area-wide 
standards and guidelines for oil and gas operations. This information is of fundamental 
importance because it illustrates that with appropriate mitigation, oil and gas activities are 
compatible with other resource uses, including those in sensitive areas. 

Throughout the last decade, it has been Wyoming BLM policy to include in the DEIS/RMP 
an appendix which describes tease stipulations and the parameters for their usage. A 
similar appendix is also furnished on permit conditions of approval tCQA). The DEIS does 
not provide these essential details. Nor does it address provisions for waiver, exception 
or modification (WEM) of stipulations or prescribed mitigation measures. WEM's could 
be granted if site-specific project analysis shows they are unnecessary because the 
conditions which originally warranted a restriction no longer exist or the location of the 
proposed activity is moved to avoid such conditions. 

We categorically oppose the creation of a CSU stipulation which would place seasonal 
limitations on the oporation and maintenance of oil and gas producing facilities in newly 
discovered fields. BLM indicates this new stipulation would be used on 61,000 acres of 
winter ranges, birthing areas and migration corridors. No justification other than additional 
security would be provided for big game species and their predators is discussed in the 
DEIS. While added security for big game may be desirable, it is an inadequate reason for 
such a harsh requirement, particularly when other less stringent measures are routinely 
used to minimize adverse effects, 

Many other means available have been successfully used to mitigate such wildlife 
concerns, e.g., submersible pumps, automated facilities, and controls on roaded access, 
without resorting to a seasonal cessation of operations. Imposition of seasonal 
restrictions on production would be irresponsible in light of the technical and economic 
hardships they would cause, not to mention escalated safety concerns. BLM must 
recognize the notable advancements in oil and gas technology that have been made before 
advancing such an onerous proposal. Furthermore, there is no documentation offered to 
confirm such restrictions would result in any additional benefits TO wildlife, 

The Shoshone National Forest in its DEIS on Oil and Gas Leasing rejected a similar 
proposal from environmental groups and the Wyoming Game and Fish Department to 
impose timing limitations on production activities. Specifically, it is stated on page IV-31 
of the Shoshone Leasing DEIS; 

"Timing limitations applied through production could have adverse impacts 
on oil and gas production. Shutting down production can damage reservoirs 



446 



Mr. Bob Ross, Team Leader 
May 8, 1995 



Page 3 



409.3 



to trie point that recoverable reserves decrease, and swabbing, stimulation 
and workovgr costs could be required. Elimination of secondary and tertiary 
recovery opportunities would be possible. Delays could increase project life 
with no financial benefit, increase project risk, increase capital costs, 
increase operating and transportation cost, and decrease Net Present Value 
and Rate of Return. There could be staffing problems associated with 
temporary field operation and increased costs to keep facilities in warm shut- 
down conditions. Lifting problems could require beam pumps instead of 
submersible pumps and long project life could increase equipment costs 
because of increased corrosion problems. Transportation costs could 
increase due to difficulty in obtaining seasonal Transportation and possible 
elimination of transportation options such as pipelines. Production would be 
less, which would decrease tax and royalty payments, limit employment in 
the field, and increase dependency on unemployment benefits." 

References cited In the DEIS for the above include BLM and Conoco, Inc., 4/92. There 
are no grounds offered in the DEIS for the Grass Creek Resource Area to revise existing 
Bureau- wide policy not to require timing restrictions on production activities. BLM should 
abandon this severe proposal in the FEIS. 

The DEIS announces historic resources in ten oil and gas fields would be managed for 
scientific and public use. The purported purpose of the program would be to improve 
knowledge of the historic significance of the fields and facilitate the approval of future 
development and reclamation activities. The fields involved are Hamilton Dome, Grass 
Creek, Little Buffalo Basin, Walker Dome, Enos Creek, Golden Eagle, Gooseberry, Hidden 
Dome, Little Grass Creek and Gebo. In July, 1994, the Petroleum Association of 
Wyoming (PAWI posed several questions regarding this program. Specifically: 

1 1 How does BLM justify this reallocation of time and resources when areas such as 
southwest Wyoming are in desperate need of arch surveys. for APDs, rlghts-of 
ways, etc.? 

2) Explain the "need" to examine these fields for listing. 

3] Clarify the benefits derived from listing these fields. Would there be any incentives 
to spur operator participation? How would designations affect post-production 
abandonment procedures? 

4) How does BLM plan to handle the National Historic Preservation Act (NHPA) 
Section 1 06 consultation requirements to consider possible effects of undertakings 

on listed districts, sites, buildings, structures or objects, especially when the 
proposed new operation is the same or similar in scope to prior activities and 
operations? Specifically, will BLM impose restrictions that inhibit an operator's 



Mr. Bob Ross, Team Leader 
MayS, 1995 



409.4 



ability to replace or update old equipment or to pursue new technology which might 
extend production? 

It is impossible for industry to support this program without first being given an 
opportunity to evaluate it in conjunction with the concerns described in the Questions 
above. Therefore, we are using this occasion to once again request answers to the above 
questions before the FEIS Is published. 

BLM indicates under the Preferred Alternative it would limit total surface disturbance to 
less than 20 percent in sage grouse habitat. Evidently, the 20% objective would include 
habitat affected by direct surface disturbance as well as areas affected by indirect, human 
presence activities. An example of protecting the area from indirect disturbance would 
be to impose a CSU stipulation within 1/8 of a mile on each side of a road or a quarter 
mile around a gas well. There is no basis offered in the DEIS for such potentially 
burdensome mitigation. 

Specifically, BLM does not discuss the current condition of sage grouse habitat or the 
reason for declining sage grouse populations. Moreover, It is unclear whether other 
multiple-use activities would be subject to such constraints or whether only oil and gas 
activities would have to bear the full impact of such a constraint. We oppose this impact 
threshold concept and favor a case-by-case analysis which takes into account site-specific 
opportunities tor mitigating adverse effects on sage grouse. In addition, implementation 
of this restriction in pre-existing fields is unfair because the level of activity may be 
reaching or have already reached the threshold. There must be more management 
flexibility afforded older fields. 

Many of the proposed ACEC's have significant potential for oil and gas exploration and 
development, However, it is unclear as to how such designations will affect opportunities 
to explore for and develop oil and gas. Moreover, the BLM has failed to document in the 
DEIS that the proposed ACEC's meet the designation criteria described in BLM Manual 
Section 1613. These criteria require potential ACEC's to have specific relevance and 
importance in order to qualify for designation. While these areas may be relevant in terms 
of resource values, the BLM has not illustrated their importance. 

BLM needs to update the geologic information usod to develop the reasonably foreseeable 
development scenario contained in the DEIS. The Information used in the analysis does 
not reflect recent industry focus on gas development. New information is needed before 
decisions affecting opportunities to explore for and develop oil and gas resources are 
made. 

We support the preferred alternative approach to right-of-way {ROW] management along 
routes to Yellowstone National Park in that they will not be designated "avoidance" areas. 



Mr. Bob Ross. Team Leader 
MayS, 1995 



409.5 



However, these ROW'S also must not be subject to increased restrictions to protect scenic 
values. 

BLM must address how the updated GCRA RMP will affect existing lease rights. BLM 
policy provides that existing lease rights cannot be changed by a new plan. Voluntary 
compliance to the new plan should be sought from lessees if activities are initiated. 
Nevertheless. BLM needs to specify in the planning documents if and how valid existing 
lease rights could be impacted by the new leasing decisions. Specifically, potential 
conditions of approval for operations and other changes should be identified. 

While the DEIS contains limited socio-economic data relating to oil and gas development, 
It is obvious this information was not a significant factor in the development of the BLM's 
preferred alternative. A comprehensive analysis of the socio-economic benefits of oil and 
gas development activities in the area must be a major component of the decision-making 
process. We recommend the BLM show in the analysis a comparison of the cost of 
administering the minerals program and industry's financial contributions to local, state 
and federal treasuries. The study must also include a risk assessment and cost/benefit 
analysis to determine whether the benefits outweigh the risks of allowing less restricted 
oil and gas development in the area. 

Visual Resource Management {VRM) requirements are applied on public lands or to BLM- 
approved mineral development on split-estate land. It is our understanding that surface 
uses on split-estate lands are determined by the surface owner and not The federal 
government. BLM needs to clarify its policy on this issue in the Final EIS. 

Again, wc appreciate this opportunity to provide you with our comments. If you have any 
questions regarding our views, please do not hesitate to contact me. 



fa 



iQi , ~57^W'< 



Claire M. Moseley 

Director, Public Lands Division 



If 



Bob Armstrong, Assistant Secretary for Land and Minerals 

Micheal Dombeck, BLM Director 

W. Hord Tipton, AD Resource Use and Protection 

Alan Pierson, Wyoming BLM State Director 

Petroleum Association of Wyoming 



RECEIVED 



410 



IRtAUOFUHDHAKAeElftEH 

WLtx n Tiwfeb R OSS ' 

BLM Team Leader 

PO Box 1 1 9 

Worlanri. WY R?40V0119 !>-5-9S 

Dear Mr, Ross, 

1 lived in Wyoming for many years and am familiar with the Grass Creek Resource Area 
(GCllA). I applaud some of your considerations but am encical ol others. My comments 
on the Draft Management Plan follow 

1 . Too much emphasis on oH and gas leasing and not enough emphasis on 
wildlife and fisheries, scenic values, historic and cultural sites and 
water quality. Opening up all acres ol the GCRA to Oil and gas leasing is extreme and 
would violate your Multiple Use Mandate Please don't forget that multiple- use includes 
n on -extractive uses such as; 

•protecting and managing wildlife habitat 

-maintaining healthy and functioning fisheries 

-protecting water quality and watersheds 

-providing opportunities for education and scientific research, recreation and 
aesthetic values 

-preserving important historic and cultural resources 
Many of the non-extractive uses would be jeopardized, and/or ruined if oil and gas 
leasing were allowed on every inch of the GCRA. Please follow yoiir mandate more 
thoroughly. 

2 You should manage more of the resource for Semi-private, Non 

Motorized Recreation Activities. Your Plan puts too much emphasis on allowing 
motorized recreation activities. Even though you prodlct a significant rise in "semt- 
prlmitivG non-motorized" use. only 8% of me resource would be managed For hiking, 
Bunting and fishing, wildlife watching, and opportunities for solitude solely. I strongly 
encourage you to manage all the wilderness Study Areas for unroaded semi-primrrive 
non-motorized even if Congress does not designate the WSAs as Wilderness, as weH as 
adding more areas to this designation. 

3. The Wilderness Study Areas should be closed to Hard Rock Mining, 

Motorized Use and Oil; and fias Development I urge you to manage the four WSAs 
to retain their wilderness character even if Congress does not designate them as such. 
These spectacular areas should be placed off limits to ort and gas leasing, mineral 

extraction and motorized use. 

4. More Attention Needs to be Given to Improving tho Condition ol 

Riparian Areas and Hangeland In our arid West riparian areas are of paramount 
importance. Please focus more attention on riparian restoration and Identifying and 
preventing sources of riparian damage 

Please be more aggressive in improving the ecosystem health of rangeland by using 
coordinated range management techniques. 

5. Greater Protection for the Potential National Natural Landmarks from 
OP and Gas leasing and Hard Hock Mining. Please protect Gooseberry Badlands, 
East Ridge- Fifteen Creek Badlands and 1 atman Mountain From oil and gas leasing and 

hard rock mining. Please give these sites the visual resource management classification 
Of VRM II. 



447 



S. Oil and Gas Leasing and Hard Rock Mining Should Be Prohibited in Areas Of Critical 

Environmental Concern (ACfcC). I strongly support the establishment of the 

Fifteenmilc Creek. Meetcetsc Draw and Upper Owl Creek ACECs but feel oil and gas 

leasing and hard rock mining should not be allowed in these areas. Please acknowledge 

and protect the recreational and natural resource values of the Fifteen Mile Watershed 

Area, 

7 The South Fork of Owl Creek Does Indeed Meet the Criteria for Wild and 
Scenic River Designation. Please reconsider your decision not to include Owl Creek 
for NWSR designation, it js 9 beautiful and pristine stretch and deserving of 
preservation. And in all events, do not allow oil and gas leasing, mineral development, 
and roads in the river corridor. 

a. More Emphasis Should Be Place on Managing Wildlife and Fish Habitat. 
Please use stronger language in the Plan's section on fish and wildlife habitat and be 
generally more committed to the idea. Only the wildlife prescriptions in Alternative C 
would meet the Wy. G3me and Fish Dept.'s objective. I want adequate protection tor all 
big game wintering grounds and expansion of fish and wildlife habitat throughout the 
Grass Creek Resource Area. 

9. Hard Rock Mineral Withdrawals are Important and Should Be Extended 
to the Wilderness Study Areas. I applaud your proposal to dose a few areas of GCRA 
to hard rack mineral development but strongly encourage you to add the Wilderness 
Study Areas. 

Please keep me informed about the Management Plan process. 

And please help preserve some of our public lands in the Grass Creek Resource Area in 
pristine form for generations to come. Once an area is mined or a river corridor 
impacted, the damage is forever. 

Sincerely, 3? j-* 

Lisa Johnson Hammond 



y.^il^j 




'Citizen Petition Opposing The Grasi Crt-ck MfllUfftCtWM Plan 
Petition NiLmhcr ] 



411-430 



BuHEAUOF uWlUWSCSftn | 
■■ Th i ? foffK Sf&flSKliUiit p .ftsk'iii Plan would sevwaih unpaci fa im basr of fbuj counties Bik Hc-ru. Hot Spring 1 :, Park 
and Washnloc — IIWHtftn 00 opod purpose is Mrvwj and .u.ur. In is mo. .its Mid resident!, stand io loose iheu livelihoods 
wjiii ii'torfoivi of uccwti 'Qierewcv, I&U! plan spouM be ■uaL'P.'d sn«ipl«riy. m kvoi oi' LUC Ba aBfl fi^tmum fljftfl whit-h 
the KutfaiijjJJjiui! ^danasfiQBSJUfiUi'fli admit; hpp w^lyi ?$ ygp However, the ,,'n.icd Suneg and Wyoming 
Ccosthuiioui enture *bn nates (hould bt idnwiwru^ Uitu i*wn naic tnoda. 

Name Address Tcicphew 




5 /J etOt. ' SMAUr* 

io S~.; 'TriiJa.. , 



: ^rY 7 m ^<— 








R I C E I V S 



n Opposing The Crass Creek Marmpcmcw Pl«i 
i-etttlon Number! 



431-450 



' E^AUOF LAND MANAGUA!!,. I 

The QttU Creek Maoasmwnl PVlU Wuld wvnafl) impHci tin Ui>: b*W of four cotlUUm Big Hem. Hoi Spnnp.i. Pari, 
and Wjishabe — iboiiBli DO good purprtw w Mrved. and many bUBoWMfi nod mxuienti stand to loose itieir livelihoods 
asd (harden) efuwws Therefor!iihii^«iiibr^!ilt£_s«apped ccuattorii., tn tivj?f/tfjii*_r.tt'««i' "pcrnticr.pJw! which 

(bLBUEMlLQJ J_riiid M;iii;ii3t..iM{ii, iRIAlj. admits .las^octed. <Htl 9*fl. Howl-vci. lbe United !4UtM and Wyoming 

iom ensure the irtaieii nhwiM tr adouBisumn^ tiiuu own .sunt lttti.li., 




^JJrw; 



Telephone 



5. Am&±* Zftfajff^j 









Men Pennon opposing Tile Cnu Civok M«ugrai«t Plar 
Petition Number i 



451-470 



lb Utt« Qrt Maa^aoM pi,„ u „ uU „„..„, „„«, ,„ ra i... „, flHlr am , m Bif R<ni Ho , s paiV 

jiu wuuue - itnitb go ,-c.j rsarrat „ nrvH. md ajoijv lumnan md muknii stiwd ... lo,« ,i,., iswu^j, 

to Biw i aof ia mlMw iiii m i rol iULMl i.lnnntmMtM on »,u Hpjww. :h« Umnd Sum ,w u v.,™ r 

L .sEMtltuliMU '-Tisuit ujl- sidle. siK.ulJ be jslniinj.ilpnun ll^u si^u .lni. lAudd 








s. - 




L^_ 



■ c/ ^^ 



448 



«iciw«5_ 471-481 

Citucr. I'clilinr, Opposing The Grs... Creek Mima£tmLT.I Plan 
Petition Number A 



■ 3LIRLAJ CF UNO MANAGEMENT | 

iae Gnu CreetMSJwme.il Plan wold .„v,,.,IK ,„,,„„ j* a. x „„, f f „, „, mllcs BlE Hont |)o| Sp[ilBS PafJ . 
and '.'. utstta . tbaigti no pKd purr.v, t „ anal ^, ,,„,. Hkiubtoi and ren.lenr. Hand m km lira ti«-bj«»d s 
ai»! frnatan 01 Keen. HasikEJ!,, .jjm, i-uld Sijcanped i-jaslnelj jrjtor c! luuEtwilaiuiinuaushiijliK" 
ihcBaeiiLi-LLajid Mjyjiwcuieni LfiUyll, Ndpu!,.lia, wodfMfltf *ejl lloue.*. ujh Ijn.ied stni e , and UVoniijifl 
croarlBUUCfOa ensure die slate. ,boul J be ajiinui iteruihj Uieir uwii .late lands 



6. If^f^i-- ^V^rZ 



'^^ 1\\^ 



M«V - 3 1995 



ten Petition Oppusinr. The Grass Creek Minagemrnl Plan 
Prtilion Number 5 



482-493 



Tire GraTs Creel Mjraie.eioe.il Man would aewnLri uopaci the .ax be* ol four craimie. Ha, Horn. Hoi Spnraa Put 
ml "utvkK - .Iwwb !»• ciuo purpuse, II nerve.!, and uia.r. bu.me.mi and reairimK naud lo lc.se their Iiviafc.o.ts 
a,,,:m*»1..mo, access a»dllljHMll«lUtattfc^ 

ujeBnnanjjLLuj»l..iami;aniji' .HLMl. a.J.oiaiJ,M;.-.oHc4i,uL»eJl llrwrar, Hit United Suncs ,nd iVviuuiia 
1 urislitiiiioDs ensure die states should he adnonisienno Lhe.r cam so.it lands 



1 ttmy~> \*prU&l— 



Irlephont 




Mav7. 1995 



RECEIVED 



W-8BB 



494 



Bob Ross 

Team Leader 
POBox 115 
Worlar.d. WY 82401-0119 

Dear Mr Ross, 

This is intended as an overall comment on the proposed Grass Creek Resource Area 
Resource Management Plan. It appears to me to be too wide and sweeping for any 
problems that are currently affecting the area "Hobby collection of invertebrate animals 
would be allowed in specified areas", is this a change from current policy? What areas 
and what size will be available? Recreation appears to be strongly promoted. Are you 
proposing to set up two acre plots for tourists to pick for fossils? Is there a problem with 
this sort of thing now'' So much of the plan seems to mandate control over situations 
which you already control The preferred alternative on grazing management seems to be 
primarily a proposal to cut AL'Ms regardless of management changes, range improvement 
or any other extenuating circumstances. In my experience the BLM already ha.i the 
authority to adjust permits to conditions. If there is a problem why not solve it Currently 
I would assume that grazing and Oil and Gas exploration are important to the socio- 
economic structure of several Counties and many individuals und should be encouraged 
when conducted m a responsible manner I am dubious aboui your proposals regarding 
Wild Horses. I am concerned about predator control, and noxious weed control on these 
1.485.700 acres 

Ptease give careful consideration to this proposal and thought to modification. 
Sine* 

(a, 



Altamont 

GAS TRANSMISSION COMPANY 
P. 0. Box 2511 
HoDtlun.TMa. 77ZS2 



RECEIVED 
MAY - 8 B95 



tti^^ujoiT^abri 



495 



Bob Rosi, Team I winter, Grass Creek HIS 
Worland BLM District 
Bureau of Land Management 
101 South 23rd Street 
Worland. WY 82401 

VIA FEDERAI. EXPRESS 

Re: Grans Creek Resource Management Plan Draft Environmental Impact Statement 

Dear Mi. Ross: 

AJuiiutn.t Gas Transmission Company CAItamoat") submits comments on Ihc Grass Creek Resource 
Management Plan fRMP) Draft Environmental Impact Statement (DEIS). 

The DEIS [page 1 1 1) acknowledges .Altamont as a proposed project. However. Altamont is far beyond 
simply the proposal stage. Altamont has already received certification from the Federal h.nergy 
Regulatory Commission (FERC) on 1 August 1991. and the Bureau of Land Management (BLM) was a 
party to that process. Furthermore. BLM issued a Record of Decision for the Altamont project on 
29 July 1994. 

Altamont wishes to ensure that its preexisting DUthon7AIion, and the conditions under which the pipeline 
will be installed and operated, are not compromised by the RMP. Altamont is committed to constructing 
and operating its pipeline in an environmentally responsible manner, and considerable adjustments to 
accommodate environmental concerns have already been made during the planning process. The FERC 
Certificate imposes stringent environmental guidelines and mitigauon measures, and ihe BLM Plan of 
Development (POD), currently being formulated in conjunction with BLM staff, will also be 
comprehensive and thorough. However, Altamont is concerned that measures proposed in the DEIS will 
affect the measures already in place and those currently being developed, The specific comments that 
follow (sec attached table) reflect thai ci 



Therefore. Altamont requests that the Final Env iron menial Impact Statement for the Grass Creek RMP 
acknowledge Altamont as a preexisting project governed by the conditions of the FERC certificate and 
the BLM Plan of Development, and not governed by any new conditions of the RMP. 



Robert A. Honig 
Environmental Manager 
(713)757-3709 



449 



Page 



Paragraph /Map /Table 



'',Vi(t!l'lti Resources 



Wildlilo Resoiir 



Wildlife ReSOUIC 



Wildlife Resources 



Wilolile Resources 



Ahanont Gai Co. - Gra=3 Cree. F:5 



Undof Preferred Alternative, discussion of timing 
restricimns include 10 surface-disturbance or 
disruptive activities within 0.5 mile of raptor 
nests or within viow of nests, whichever is closer. 
Preface "raotor nests" with toe word "active", as 
numerous r-esis exisl withir Ih s resource area and 
aiong the Altamoni ROW, It would be entirely too 
restrictive to place activity restrictions on every 
nest observed. Altarront also suggests that the NSO 
restrictions for raptors identify (he -aptor species [as 
designated by special federal 01 state stati.s recognition) 
which tall Into thase restrictive categories. 



Alternative B would bo the leasi -astrictive opt.on 
impacting A|tan-ont, Milgulion stipulations outlined 
in the POD would reflect the site-specific analyses 
required for Ihcso actions, The Preferred Alternative 
&M Alternative C d rcctiy impact Al'amont, resirii 
corsmicrion and/or creating costly ROW adjusimerus 



ng 



Table 3 
Para. 1 



The Preferred Alternative for surface distu'bance of 
other Jaks appears more flexible than Alternative C, which 
prohibits any surface d^stu'bance. 

AlternativoA would impactAltainont, despite site-specific 
onvironmont.nl nnnlynes being conducted. This paragraph 
is contusing in light of pagu 61's discussion of lek 
distLibancc. Porhaps this paragraph should be included 
on page 81 unoer Alternative A. 

"Sunace-disiurbing activities wrjUd be prohibited within 
0.5 mile of the Bighorn River (1,200 acres I " Altamoni 
would be impeded if it required access to the rivor 



o 






IDENTIFICATION OF ISSUES IN THE GRASS CREEK RESOURCE AREA 

RESOURCE MANAGEMENT PLAN AND DRAFT EIS 

POTENTIALLY AFFECTING THE ALTAMONT PIPELINE ROUTE 



Page Paragraph /Map /Tab Is 



ALTERNATIVES* 



Lands and Realty Management 



Minerals Management 



43-44 Taole 2 



Ofl-Road Vehicle Management 49 Table 2 

pure. 1 



'Assume the issue is applicable to all alternatives unless othcrv 



Under the Preferred Alternative and Alternative B most 
of the planning area would be open for nghtS'of-wav 
development. Two right-of-way coirido't; would be 
designated as seen on Map 7, pg. 88. Alternative A 
discusses righls-ol-way without designating specific 
corr dors; rather it designates 'concentration areas" as 
the prefcrrod locations 'or future rights of ways. 
Altornativo C is the same as Al-.emutive A according to 
the Table. However, on Map 8 (identified as Rigfrts-of- 
Avoidance Areas} Alternative C excludes occupancy in 
the proposed ATamont ROW, identifying thai area as 
a ROW Avolcance Area, thereby impacting Allemo-it. 
The table s confusing 10 read. 



UndertheGasandOildiscussinnnlA tnrnalives.su-face 
disturbance restrictions wu.ild he paced on areas jp to 
1 44,400 acres, depend ng on alternatives. Altamoot is 
concerned with no surface occupancy and surface 
disturbance stipulations requirements 'or the oil and gas 
industry. Would NSO stipulations apply to a sjbsurface 
pipeline? 

Restrictions prohibit ufl-road veniclc use lor wot sois 
and an slopes greater then 25% ir" unrieiiessa-y damage 
to vegetation, soils, or water qualiiy would result. 
Would this apply to construction equipment? If so, a 
"necessary tasks'' work exemption should he applied. 







Subject 


Page 


Paragraph/Map /Table j Issue 




Wildlife Resources 82 continued through public land 




niflnts-of-Wsy Avoidance Areas B9 Mop 8 This nmp daSrwRtes Highway 16/20, which Aliamont 

parallels with us ROW, as being an Avoidance Area. This 
directly and significantly mpacts Aliamont, Tne Altamoni 
ROW should be acknowledged on this map as a pre 
Blasting facility. 




imi-.s on Surface Disturbance 92-95 Maps 1114 All Alternatives bjt AfterrwdveBwouldimpactArtamom's 

proposed ROW due 10 delineated areas of No Surface 
Occupancy and Timing Restrictions. Alternative B is the 
least restrictive. The A tamonT HOW should be 
acknowledged on this map as a pre-existing facility. 


Activities Affecting Sois & Est mated 

Acres and Durations of Distu-batcc I 76 Table 8 Under the Lands and Realty section, a pipeline has boen 

estimated to have 2 acres ol disturbance pei mile and 
24 tons of soil loss per acre per yea- with a permanent 
impact d urnlion. This soil loss estimate, footnoted in the 
table, has been based on "...rerrovfil of ...soil ...caused 
by erosion or by direct hut nan activity such as road cor 
struc:ion...". Altamoni has olanned extensive 'eclamation 
procedures based upon 8LM Reclamation Standards. A 
reclaimed pipeline should not be compaied to an 
unreclaimed din road In terms of impacts and soil loss. 
The duration of ;he impact shoclc be labeled temporary, 
as BLM refers to the temporary nature of pipeline 
construct on in Table 16 (page 1761 where "... (olio wing 
reclamation of those areas {pipeline construction, surface 
mining,,..}, forage production would retuM to pre- 
disiurbiNtCK levels.", 

AtomoM riwiCe- -Gr«i Crack EIS 

CO 
JJ1 

on 



CO 

m 











| Subject 


Page 


Paragraph/Map/Table | Issue 




Vegetation Management 61 Tnblo ? DPC (Desired Plant Community Objectives for Saae 

Grouse Nostinq Habitat stnlirq "veoctation roqiiiri!men:<i 
sagebrush witnin two miles of sage grouso leks naeas 
lo cover 20-10% of the ground"., may impact placcrreni 
ofright ol way and.'orrevegetaiion planfor plant species 
other thai that Described in the POD. Altamont An 
form Ua ted seed mixtures for revegetation to match 
existing vegetation and thus shou dnot be subject to any 
additional guidelines. 

Watershed Management 55 Table 7 "To protect watershed values, driving would be prohibited 

on wet soils and on slopes greater than 25%,if 
unnecessary damage to vegetation, solJs, or water quetty 
wou Id result. "A "necessary las «" work exemption should 
be applied. 

Wildlife and Fish Haaiai 

Management 71 Table 2 Under Wildlife Habitat discussion for tie nrHlerrwf 

alternative, restrict ons suggested in the following 
oaragraph may impact the certi'icated ROW proposed 
by Altamoni. "Nest sites, roosta, cotlonwuod trcus. and 
other potential ciilica habitats releted lu hunting arte 
concentrolioi areas lor bale eagles would be orotected, 
especial y along the Bighorn and Greybull Rivers...". 


Miscellaneous Resources 78 Tab 3 Resvlciois placed on surface-disturbing act'vilies 

described in this p]nrag/nph nay affect Altamont. although 
Aliamont recognizes thai site specific environment a 
analysts will 1111 coikJucecO! on these activities. 

Arramom G*s Co.- C.l«i Creek EIS -2- 


CO 

en 



[Copy Faxed to BLM 
May 8, I995-BD.] 




S.'-Ol'i? OlOfl \Ml/\ 



496 



'{107) 777-6593 



" io^fftfiiss 2 ' 1 — ... 

RMP Team Leader 
"Borland niarricr HLM 
P.O. Box US 
Warland, WY B2401-0119 



commente on the SLW Draft Environmental 
e Grass Prftftk. planning -area. 

We are greatly concerned about Che crippling impacts Che 
proposed unwarranted reductions in AUKs will have upon the 
agriculture producers and economies oJ this rural area. 

In conversations with the citizens and officials living in 
this aruoi, i learned that little coordination with local resource 
users occurred In the preparation of this plan, and the DEIS 
suffers accordingly. I strongly encourage your close coordination 
with the people, governments, interests, and agencies who will be 
moat affected by this plan during r.hft preparation of the final SIS, 
These folks possess experience and knowledge that will makfi this 
plan wore practical, efficient, and useful. 

you propose reductions from thw current 157, 355 AUHs lo an 
preferred alternative AtJMs of aD4,€12, but you have not included 
specific monitoring evidence to justify this reduction. There is 
insufficient evidence of specific range and soil health CO justify 
your desired goal . Your erroneous and unwarranted conclusions 
shout for collaborating evidence, and they need to be in the BIS, 
or your decisions need to be modified accordingly. 

In Sect , F bel leva adequate monitoring of the area would 
justify managing the resource at the current level of 1.57,355 AUMs . 
Etortovax, the present increases in technology and coordination, 
that have been leading to Increased rangsland health on these and 
other BLM management areas in Wyoming, strongly bolster this view. 

I believe you must consider also the horrifying consequences 
of your proposed actions in the DEIS upon the continued existence 
of agriculture producers and rural economies in this area. 

Based upon inadequate Specific monitoring evidence, you intend 
to void 54,983 AUMS that in all likelihood will never be replaced. 
These represent a 35 percent reduction, aa you note on p. 177. 
These lost AUMo represent disabling impact!* on the agriculture 
croduc*ra who depend upon these AtJMs for their livelihoods. 



Mitnjflj. Oallti 



BUAK'J WtMHtHS 

HiQhtPttiftit idiymons 



496.2 



This loss is net adequately reflected in the DEIS. The lost 
AljMs represent an estimated decline in total economic activity 
greater than S5.S million, has»d on a conservative S10C generated 
by each A[JM. University c£ Wyoming estimates for similar areas 
indicate a total loss of S117 per eliminated AUM in total economic 
activity for an affected area. The area af fecr.&d by the Crass 
Creek RMA is purely rural ar.d simply can not withstand the loss of 
five-plus million dollars caused by the reductions in AUMs that you 
propose. In fact, the people in this area would have difficulty 
absorb i nq a million dollar loss represented by a 1C , 000 ADM 
reduction. This economic factor must be illustrated in the E1S and 
be considered in your decisions. 

Because these federal lands supply critical seasonal grazing 
ihac can not be replaced on private lands, the impact of the lest 
AUMs is far greater than the indicated 54,&85 AUKs . The corre- 
sponding economic ^mpacf upon Che lives of the folkn in this rural 
area is likewise magnified. 

The loss of agriculture producers also has terrifying impacts 
for the wildlife and other natural resources of z'r.et Grass Creek 
RMA. within the last decade, declining incomes have tarced the 
sale Of ranchns throughout western states, including Wyoming. 
Sales have often resulted in subdi visions and ranch's t tea, with a 
corresponding loss in open space, wi 1 dli fe habitat , wildlife 
migration, and an increased destruction of natural resources that 
the RKA is trying to protect . 7or this reason., I disagree 
vehemently with your conclusion that reduced livestock grazing will 
have beneficial effects on wildlife habitat. As I've noted, the 
likelihood is that reduced grazing possesses the potent Lai for 
profound destructive consequences. 



Bottom Line 5 severe reduction 
livelihoods and natural resources. 



Ln aums 



ill 



rably harm 



olio 



ing are comments upon 



CCif ic orftss . 



In the DEIS {p. 151), you propose to designate the Fifteenmile 
Creek watershed as an Area of Critical Environmental Concern. You 
implicate grazing as the culprit for increased sediment delivery 
with no collaboratir.Q evidence and without any reference to the 
natural erosion that is common to an area o£ naturally erodible 
aoils. In addition there is no collaborating data to support the 
claim that "hydrologio processes are nor functioning." 

Uesired Plant Community standards that are addressed on pps 
55-51 are extremely vagus and are better addressee at the allotment 
level with permittees and other involved interests. 



We believe the prescribed burning needs t 
offset years of fire suppressions, especially 
bruah/pme/junipcr areas. 



o be increased to 
in areas o£ oage- 



496.3 



On p. 72, you state that control measures directed toward 
coyotes and other predators would be evaluated by BLM, APHIS and 
affected public land users before implementation. I believe that 
your proposals also need to b*> coordinated with appropriate state 
officials. 

I want to thank you for the opportunity to comment, upon this 
DEIS, as it has major consequential , negative impacts) upon the 
people and the natural resources of the Grass Creek RMA. 

Sincerely, 



Q^^SKL- 



Hon Michel i 

Director of Agriculture 



Governor Geringpr 

Jim Magagna 

Board o£ Agriculture 




MOflPTKN OIL 






497 



warland, Wyoming =2401-0119 



i»», IW Team Uodn: 



Dear Mr. Rflii: 

I have conplatvd a rovim of the four oltorn«ul™B set forth In tha Oc«ib 
Crav* ,"<<■■ ii •jur-.-u Aroa RKT Drutt US. I bcLUv* you hav* corrtplatad an e*cellaat 
document: and concur with moat of trie praacrlptlona »t lortli in tha rrafarcad 
Altarnativa. Howavac, I would auggaat that: you ro-conaidar the. um of tha ko 
Gur 1 abb Ot.-.up.m-v (NSQ) and Cwnt rol lod Surfaoa IIh (CSD) stipulation* far oil 
and gao leases in tha pcafccrcd altarnatlv*. 

Over tha last IS yaarB, 1 hVI follovad with grant intercut the oil and gas 
activity ln the planning i;si. My axparlonca 1" that ouch pcovisiono am not 
necaaaajry aaeapt far protection of obvioua, al«B-~KpacLf ic raaoureaa such »■ 

takan to pr-otect tha raaoureaa euch atlpulations addrcuD and tnitigataa tha 
aame with tha ItuHt at the tin* a apoeLfle drilling and devclapmant plan in 
submitted Eor approval. 



•i»m • oparatlena minimise 
pacific tciitln, «tu.. at tha 



Tha fadaral oil and gaa leaae focn itiju, 

oivcrw Impacts to the envirnnjoanc . Thi 

page 191 of the Dealt IIS recognlzei thi 

peoponed dmvwlapment usually results in 

0n4«V tha currant plan, i:ha EI3 Indleataa that wildlife populations have 

ulowly incraaaad- So, why add unneeeoasry provisions before a ioano la 

production will not raach th« lavata rac forth in undoc the "retorted 



By ol lisinatlng theso stipulations, oparatora will be encouraged to *>pl»ca tha 
planntno oraa no.-c flolde will ba found wLth a graatar aocioecnnooile impact 
than tiuUmca in the Draft. With appropt Lata niitLyating mmium applied for 
each wall at the Bin's jurisdiction, the resulting reaponalDla mlt igatad 
devulopnmnv will not aoVcraely Impact historic and cultural reaourcaa, ganotlc 
and biologic dlveiraity and racraatlenal or othar uaara of tha public land. 



Think yon for 
Slncnrxly. 



ring th*< 



aSW^/^SW&aCB 



David K. Davcnpor' 



Post^fTiuNuie 7071 


I-H4-- 1 


n fi^ri P0« 


►>—£,£ p^je-fjpee-r 


— SlH 


& 


rus* 


™#B 


F«i sol-^^T-fcitS 





451 





DECEIVED 


— i 




m -em 




IUEJUI OF UWIUMEKM 



Mr. Bob Boss, Team Ueader 
Grass Creek Resource Area RMP 
Bureau of Land Management 
P.O.Box 119 
Worland, WY 82401-0119 



Dear Mr. Ross: 



^V ^7rl ; (-=0 



•n,. r~= a Creek Resource Area Resource Managemenl Plan, Draft 
cultural values. 

slate. 

Th ere shoufd be no further «*S^»,J^JSSWS 
,„r Wild horses. No one ^^J^JES/vou have to give 
destructive to the lands, anc hrnpact P»™' e « , „ wlll na ve 

private lands. 

-^s^=^'S^^ = P- 

the resource. 

y ou have received many ^^SST*S!SSA ESSE? 

SS.S5 on £^sf -KySiS KKSs w ° 



438.2 



furure of this resource area. You have regulations to work with to menage 
™™ £U of orailnq concern. You cannot even find agreement among the 
anTo KSStaoS criteria to judge the resource; theretore. you cannot glv, 
credence to groups that do not understand the resource. 
I have always been concerned about the numbers of wildlife allowed to 
lourlsh wftn their numbers being set by the Wyoming Game and Fish 
When elk Us introduced on Copper Mln., the Wyoming I Game and Bsh 
discussed the quota with ranchers and arrived at the figure of 75 as 
being a suHiclent number. In 1988, during a drouth, when w .deeded 
"o ease land elsewhere and rest our land on copper! «*V.««*9<*2 
counted 300 head of elk grazing our private lands. The BLM has 18% 
the lease, and the elk were all In the bas.n, not on the BLM slope. 

You have laws enacted by Congress, and regulations "HWfltafO" 

eliminating the commodity usors on «»» > benefit Wyoming 

Washington >h« conflicts wi.h the laws enacted by Congress. 
Thank you for the extension allowing more Input to the draft BS on the 
Grass Creek Resource Area RMP. 

Sincerely, 



9i4> - 

,Is G. Herbst 
General Partner, 
Herbst Lajy TV Cattle Co 



of the state of Wyoming. NF£PA '^"'™ slJpcrV i S ing the drilling of 
of the Grass Creek Resource Area. 



r" stc 



499 




SPEAK UP FOR WILDLIFE FOUNDATION 
Box 84O06 
PO Market Mall 
Calgary, Alberta 

Canada 
T3A5C4 



1 May 1995 



Surest! of Laud Management 
bob Ross, Team Leader 
Box 119 

Worland, WY 
U.S.A. 82401 



Dear Mr. Ross: 

RE: GRASS CREEK RESO URCE AREA MANAGEMENT PLAN AND DEIS 

Please send me a copy of the above plan. 

I am interested in any supporting biological opinions that may be available regarding the plan 
and issues related to it. 

Enclosed please find a copy of a draft document relating to habitat fragmentation by the oil 
and gas industry in Alberta. It is probably relevant to Wyoming. 1 trust you will address the 
issues raised in the attached document in the DEIS. 



Thank you for your prompt attention. 
Sincerely, 

Dr. Rrimi L. Hurejsi 
cc. WY Outdcor Council 



BLH/me 
tcluded with this teller 



the Habitat Fragmentation by the Oil and Gas Industry in 
'and British Columbia: It's Impact on Wildlife Draft by Brian L. Horejsi, Wildlife 
Scientist; Western Wildlife Environments Consulting Ltd., Calgary. Alberta, Canada T3A 
5C4, March 1995.] 



RECEIVE D 




WYOMING 



HM-9B95 j 

OUTDOOR *J C I ijgjglgggig 
COUNCIL iw-iefj 



500 



May 5, 1995 

Mr. Bob Ross 
RMP Team leader 
WbiUnd District BLM 
P.O.Box il9 
Worland, Wyoming 82401 

Re: Grass Creek Draft RMP/EtS 

Dear Bob: 

Thank you for inviting the Wyoming Outdoor Council (WOC) to review and 
comment on the adwJUSCy of the Grass Creek RflSOUTCK Area's Draft Resource 
Management Plan (RMP) and accompanying enviroiunftntal impact statement (EIS). 
Established in 1967, WOC is a non profit, grass-roots-based, statewide organization 
dedicated to the conservation of Wyoming's natural resources and protection of its 
em ironment As you develop the final KMP and SIS, please consider the following^ 

The writers and editors of the Draft 05 anc RMP deserve much credit for 
putting together a document that Is, for the most par;, understandable and dearly 
written. The format of the RMP. however, leaves a lot to be desired. Our biggest 

complaint is with Chapter Four, Environmental Consequences, This section should 

facilitate a comparison of alternatives, Instead, it facilitates contusion, and is difficult 
and Hme consuming to use. On page 153, Tables IS and 16 interrupt the discuMton of 
the environmental am sequences of the preferred alternative The narrative resumes or 
page 189 Can't these tables be placed somewhere else, tor example, at the beginning or 
end of a section. Also, the absence of tabs or some other form of identifier makes the 
environmental consequences discussion of one alternative difficult lo distinguish from 
another. Displaying the heading (e.g., "Alternative C ') more conspicuously, perhaps at 
the top of the page, would be helpful In addition, all maps and tables should be 
consolidate at one place in the document. 

Unfortunately, a readable document is not necessarily a legally adequate 
document, or one that WOC can support. Ihe draft KMP places far too much empnasis 
on Ihe production Of commodities such as Oil, gas. and timber, at the expense of other 
important values and resources such as semi-primitive recreation opportunities, 
wildlife habitat, ^n^i scenic values Although the document promises these resources 
and values will be provided for, the lack of specific allocations for them in the RMP 
make such promises difficult to fulfill For example, assuming for the sake of argument. 
If the energy industry decided to develop in the next 10 years every outstanding oil and 

25 years of Wyoming Conservation Action 

201 Main Lander, Wyoming 8ISI0 (307) 532-7031 



452 



500.2 



ukl KLM provide adequate wildlife habitat and a 



gas lease in the resource area, how 
mix uf recreational opportunities. 

The draft plan proposes oil and gas leasing on every single available- acre of 
public land within the resource area-including prime grizzlv bear habitat, crucial 
winter range for elk, moose, mule deer, antelope, and big horn sheep, areas of critical 
environmental concern, and undeveloped primitive recreation areas. The plan also fails 
to adequately address declining resource conditions caused by overgrazing, off -road 
vehicle use, and poor management practices. Instead, the plan reflects the BLM's 
traditional emphasis on the development and exploitation of natural resources: oil and 
natural gas production, hard rock minerals mining, Livestock grazing, and commercial 
timber harvesting. Other uses and values, recognized and supposedly protected by 
federal law, such as wildlife and fisheries, scenic values, historic and cultural sites, and 
water quality, continue to play "second fiddle," and suffer as a result. 

Multiple Use Management? 

By law, the BLM must manage for multiple use and sustained yield. Wo feel thus 
basic mandate is not being met when every alternative displayed m the EIS authorizes 
uil and gas leasing on every single acre of legally-available land in the Resource Area; 
when the BLM alleges commercial logging is necessary to "improve" forest health and 
offers a "range of alternatives" for this resource that is basically illusory; and when 
fewer than 8% of the resource area is available for semi -primitive recreation, and even 
less -about 1%» if Congress decides not to designate the WSAs as wilderness. 

The RMP indicates on page 14 that: 

nearly the entire planning area is covered by federal oil and gas leases, 
and portions of the area are developed. This situation would continue for 
the entire time this plan is in effect. Eliminating federal oil and gas 
leasing in the entire planning area would be overkill' because resource 
conflicts tend to be located in specific areas, not area wide (emphasis 
added), 

We have a few comments regarding this statement. First, we know of no group 
or individual that is advocating the elimination of oil and gas development in the Grass 
Creek Resource Area, and detailed consideration of such an alternative would clearly be 
unwarranted. However, WOC represents a large group of individuals who believe oil 
and gas leasing and development on public lands is not appropriate in certain areas, 
such as crucial big game winter range, calving grounds, and travel corridors, sensitive 
watersheds, habitat for threatened, endangered, and sensitive species, areas with 
unique scenic and aesthetic values, in areas that are spiritually significant In Native 
Americans, and in important primitive and semi-primitive recreation areas. Prohibiting 
oil and gas development in these areas clearly would not be "overkill." Far from it. 
Such action represents prudent stewardship and long-range thinking that is so often 
lacking in government decisionmaking. 



500.3 



Second, the italicized statement in the indented quote presupposes the outcome 
of this planning effort. Although the entire planning area may presently be covered by 
oil and gas leases, whether it is in the future is a decision that should follow -not 
precede- this planning effort. Uke all federal oil and gas leases, the leases covering the 
Grass Creek Resource Area are issued for a prescribed period of time, typically 10 years 
in the absence of production. Because the leases were issued at different times, they 
expire at different times. Thus, the fact that an area may be subject to a lease today- does 
not dictate that it must be forever. We think BLM owes the public an explanation as to 
why it ha s already decided t o lease the entire resou rce area before the planning process 
has been completed . 

So there is no understanding, you should also explain to the public that there is 
no law requiring you to lease public lands (the Mineral Leasing Act is discretionary); 
that you could decide to lease 3/4, 1/2, or 1/4 of the resource area (or any other amount 
less than the sum of the resource area) if you chose to; that an individual oil and gas 
lease is a few thousand acres {under 6,000) in size, and that offering one lease does not 
commit the government to commit to offering another; and that the issuance of a lease is 
an irretrievable and irreversible commitment of resources that all but eliminates the 
IJLM's ability to prohibit development on the lease. 

Third, the statement reveals the BLM's strong bias in favor of mineral 
production. There is no federal law that requires the BLM to lease every square foot of 
public lands under its jurisdiction, yet that is exactly what this plan says it will do. 

The BLM's traditional deference to :hc production ol commodities (not only here 
in Wyoming, but also Nationwide) has resulteo in Lhe significant loss of wildlife habitat 
and biodiversity, contributed to the desrruetion of nearly all of our virgin forest land 
(approximately 8% remains), caused. significant water quality degradation, accelerated 
the permanent loss of soils, assisted the destruction of cultural, historical, and Native 
American spiritual sites, and has significantly impaired recreational and scenic values 
nationwide. Unfortunately, ihe BLM'S traditional deference to the production oi 
commodities is reflected in the Grass Creek RMP 

With the exception of the WSAs, the proposed plan authorizes oil and gas 
development on every single acre of public land within the resource area, including 
areas of critical environmental concern, sensitive wildlife habitat, and undeveloped 
recreation lands. The RMP claims (page 14) the BLM has a mandate to lease everything, 
but curiously, is unable to point to any law demonstrating the basis for such a policy. A 
policy that leads to the widespread and extensive industrialization, of public lands does 
not meet the requirements of multiple use and sustained yield under which BLM must 
operate. By law, multiple use includes much more than just mining, grazing, timber 
cutting, and mineral development. As defined by Congress, multiple-use includes non- 
extractive uses Such as protecting and managing wildlife habitat, maintaining healthy 
and functioning fisheries, protecting water quality and watersheds, providing 



500.4 



opportunities for education and scientific research, recreation, and aesthetic values, and 
preserving important historic and cultural resources. 

This issue was the topic of two earlier letters submitted by WOC on the Crass 
Creek RMP, which are appended hereto for your information. We would like a written 
response to th e points raised in th e letter s-, since there is no indication thev were 
considered, in the EJSZJKMjl. 

Ecosystem Management and the Greater Yellowstone Ecosystem 

We find it interesting that although the BLM is now espousing "ecosystem 
management," the fact that a significant portion of the 1 -5 million acre Grass Creek 
Resource Area comprises an integral part of the Greater Yellowstone Ecosystem in 
Wyoming is barely noted m the EIS/RMP. Moreover, the map on page 2 docs not show 
the Wind River Indian Reservation, which lies immediately south of the Grass Creek 
Resource Area. Notwithstanding the rhetoric, it appears the BLM's thinking arid policy 
decisions are still very much oriented along and dictated by artificial political 
boundaries. We have included a map of the GYH lor your information. 

Management of Wilderness Study Areas 

The Grass Creek Resource Area contains four BT.M-designated wilderness study 
areas: Owl Creek, Sheep Mountain, Red BurtC, ar.d Bobcat Draw Badlands. These areas 
combined total only about 54,000 acres, less than 6% of all public lands in the resource 
area. For the most part, these small to moderately-sized WSAs are the only areas within 
the resource area able to provide a semi-primitive, unroaded barkcounrry experience. 
The RMP proposes to open these WSAs to oil and gas development, hard rock mineral 
mining, road development, and other conflicting uses if the Congress decides not to 
designate the WSAs as wilderness, WOC's members feel strongly that Owl Creek, 
Sheep Mountain, Red Butte, and Bobcat Draw Badlands wilderness study areas should 
be managed to retain their wilderness character even if Congress decides against 
wilderness designation. Under the proposed management plan, if Congress fails to 
designate the WSAs as Wilderness, those areas could be severely impacted by mineral 
development, off -road vehicle use, and oil and gas leasing and development. 
Regardless of whether they are ultimately designated wilderness, these spectacular 
areas should be placed off-limits to mineral extraction, oil and gas development, and 
use by motorized vehicles. Alternatives to the proposed management scenario must be 
considered in the HIS and made available for public comment. Consideration to the 
Citizens Wyoming Wilderness Proposal must also be given. 

Lack of Semi- Primitive Recreation Opportunities 

The RMP should make available more of the resource area for semi -primitive, 
nonmotorized recreation activities. The proposed resource management plan places 
unacceptable emphasis on providing motorized recreation activities. The Grass Creek 
Resource Area covers nearly 1 5 million acres, 968,000 acres of which are public lands. 



500.5 



Under the current proposal, only about 62,270 acres would be managed for "semi- 
primitive non-motori/.ed" recreational activities. Although demand for these kinds of 
recreation opportunities is predicted to rise significantly in the planning area, less than 
8% of the public lands within the resource area would be managed to provide for the 
kinds of activities you and 1 enjoy most, such as backcountry hunting and fishing, 
hiking, camping, wildliie watching, sightseeing, nature study, and opportunities for 
solitude in natural environments. A disproportionate amount of land, in excess of 
900,000 acres, would be managed for recreational uses which depend primarily on the 
automobile. Roads and "two tracks" already crisscross most of the entire planning area, 
but under the Draft RMP proposal, that situation would continue. Over 205,000 acres of 
public lands would be managed for "roaded natural" activities; approximately 97,000 
acres would be managed for "rural opportunities;' and the remainder, more than 
603,000 acres, would be managed to provide for semi-primitive motorized activities. 

What is most disturbing about the proposal is that the meager amount ot land 
managed for semi-primitive non-motorized use could drop to below 9,500 acres (less 
than 1% of the public lands within the planning area!) if Congress decides not to 
designate the WSAs as wilderness. Whv? Because the BLM considers the four existing 
WSAs in the resource area, which combined total 53,850 acres, as being managed for 
semi-primitive non-motorized activities. However, under the scenario outlined in the 
Draft RMP, if Congress at some point fails to designate the WSAs as wilderness, those 
areas which are currently off limits to vehicles would be available for mining, oil and 
gas leasing and development, roads, and other environmentally disturbing activities. 
Thus, only 9,130 acres of public lands in the resource area out of a total of 966/000 acres 
would be managed to provide unroaded recreational opportunities. WSAs should be 
managed for semi- primitive nonmotorized recreation opportunities even if Congress 
elects not to designate the WSAs as wilderness. 

Greater Protection Needed for Potential National Natural Landmarks 

The Grass Creek Resource Area contains several candidate National Natural 
Landmarks, or N'NLs. NNT.s are areas identified by the National Park Service as having 
nationally significant ecological and geological features. The potential NNLs within the 
resource area include Gooseberry Badlands, about 30,000 acres of rugged, colorful 
badland topography dominated by a variety of rock hoodoos, arches, castles, and 
mushrooms; East Ridge-Fifteen Creek Badlands. 69.000 acres of badlands described :n 
the LIS as "some of the most spectacular in the central Rocky Mountains; ' and Tatnian 
Mountain, a gravel-capped mesa where the Greybull River once flowed, which provides 
an excellent record of Rocky Mountain geologic history. To protect these areas, oil and 
gas leasing and devejopment and hard rock muting should be prohibited. Scenic 
resources in NISI I .s should he protected with a visual resource management 
classification of "VRM IT." Special management plans for these important areas should 
be developed in consultation with the National Park Service. 

More Protection is Needed for Special Recreation Management Areas 



453 



500.6 



The Draft RMP proposes to establish tour Special Recreation Management Areas: 
the Absaroka foothills, Badlands, Bighorn River, and Red Canyon Creek. WOC 
supports the establishment of these SRMAs but believes these areas should be put off 
limits to olJ and gas leasing and development to protect their unique and important 
values. 

The Upper Owl Creek ACEC and Meeteetse Draw Rock An Area Should be Off 
Limits to Oil and Gas Leasing and Development 

The Federal Land Policy and Management Act (FLPMA) requires the BLM to 
"give priority to the designation and protection of areas of critical environmental 
concern." Areas of critical environmental concern, or ACECs, are defined by law as 
'areas within the public lands where special management attention is required to 
protect and prevent irreparable damage to important historic, cultural, or scenic values, 
fish and wildlife resources or other natural systems or processes — " The draft plan 
proposes three ACECs: Fifteenmile Creek Watershed, Meeteetse Draw Rock Art Area, 
and Upper Owl Creek- WOC supports the proposal to establish the Fifteenmile Creek, 
Meeteetse Draw, and Upper Owl Creek ACECs, but encourages you to consider a 
management alternative that would prohibit oil and gas leasing and mineral 
development in the Meeteetse Draw Sock Art Area and the Upper Owl Creek. In 
addition, the recreational and natural resource values of the Fifteenmile Creek 
Watershed Area should be acknowledged and protected. 

The Fifteenmile Creek Watershed, comprising over one-quarter of the entire 
planning area, has been severely impacted by overgrazing, road development, poor 
management, and generations of neglect. According to the BLM, only about one-half of 
all streams and riparian areas within the watershed are functioning properly. Ln 
addition, many of the upland areas in the watershed arc in fair to poor ecologicaJ 
condition, and remain in a declining trend. Accelerating sediment levels in several 
streams have caused a significant decline in fish habitat in the Bighorn River, and 
Fifteenmile Creek has been identified as the largest contributor of sediment to that river- 
Excessive livestock grazing in riparian areas, more than any other use, is responsible for 
loss of streamside vegetation and degradation of fish and wildlife habitat. The objective 
of the proposed 274,300-acre ACF-C is to reverse the declining watershed conditions and 
improve water quality and fish and wildlife habitat by restoring native grass and shrub 
communities, closing and reclaiming heavily eroded and washed out roads, improving 
management of livestock and wild horses, and by better monitoring 

Although we support the proposed m ana gem en I objectives for all the ACECs, 
we are concerned that when management action, is taken to achieve the objective of the 
Fifteenmile Creek ACEC, damage could occur toother important values and resources 
in that ACEC. For example, constructing concrete barriers to control erosion and 
sedimentation could impact the area's naturalness. Consideration to this issue should 
be given. 



500.7 



The Meeteetse Draw Rock Art Area encompasses approximately 6,800 acres of 
public lands in the southern portion of the resource area near the confluence of the 
Bighorn River and South Fork of Owl Creek. The Meetoelse Draw area contains a very 
large number of medicine wheels, vision quest structures, stone circles, ancient 
perroglyphs, and other evidence of extended occupation of the area by aboriginal 
peoples Many of the sites within the rock art area have traditional cultural value and 
spiritual significance to Native Americans including the Northern Arapaho, Crow, and 
Shoshone tribes- Several sites have been determined eligible for listing on the National 
Register of Historic Places. The proposed ACEC. accompanied by mineral withdrawals 
and surface disturbance restrictions, would provide permanent protection for this 
unique resource. 

The proposed Upper Owl Creek ACEC covers some 17,100 acres of public lands 
in the southern Absaroka Mountain foothills- An important component of the Greater 
Yellowstone Ecosystem, the Upper Owl Creek borders the Shoshone National Eorest's 
Washakie Wilderness and the Owl Creek mountains. With elevations ranging from 
7,200 feet to over 11,300 feet above sea level, the Upper Owl Creek Area encompasses 
several different landscapes, and provides habitat for incredible array of plant and 
animal species. The area's inaccessibility, topography, and vegetative diversity make it 
ideal habitat for a number of sensitive plant and animal species. 

The South Fork of Owl Creek Should be Protected 

WOC does not agree with your determination that the South Fork ol Owl Creek 
is "not eligible" for inclusion in the National Wild and Scenic Rivers System. To the 
contrary, the South Fork of Owl Creek is an outstanding river resource undeniably 
entitled to legal protection as a Wild and Scenic River. We also recognize, however, that 
there are substantial political and logisticai barriers that impede such designation. But 
that does not mean the South Fork should not be protected. In this instance, the RI.M 
can and should implement through this planning process protective measures designed 
Co protect the South Fork from development threats. We recommend that the South 
H'ork of Owl Creek and its corridor (1/2 mile on either side) be placed off limits to water 
development and hydroelectric projects, oil and gas leasing, roads, and hard rock and 
leasable mineral development, This can be achieved without Congressional action 
through the planning process. 

Hard Rock Mineral Withdrawals Should be Sought 

Mosl of the Wast, including the Grass Creek Resource Area, is open to "hard 
rock" mineral development (e,g,, gold, silver, titanium, load, uranium, bentonite) under 
the Mining Law of 1872. This antiquated law allows anyone who has staked a mining 
claim and made a discovery of a valuable mineral to apply to the United States 
government for a patent, the equivalent of complete ownership of the land. H a 
claimant can demonstrate the existence of a locntable mineral in commercial quantities, 
the 1872 law requires the government to sell the public lands -and the minerals 
underneath -to tlie person or, more typically, multinational corporation, for no more 



500.8 



than S5.Q0 per acre. Because Congress failed at its most recent attempt to reform this 
law, it still applies on the majority of public lands in the West. 

The Draft RMP proposes closing a few areas in the Grass Creek Resource Area to 
mining and mineral entry under the Mining Law of 1872. Public lands along the 
Righorn River, the Legend Rock Perroglyph Site, parts of the proposed Meeteetse Draw 
Rock Art ACEC, and all of the proposed Upper Owl Creek ACEC would be closed to 
mineral development. WOC supports the proposal to remove these important areas 
from mineral entry, but also encourage the BLM to consider extending the proposed 
mineral withdrawal to the four existing BUM -designs ted Wilderness Study Areas in the 
planning area that will be without any protection if Congress decides against 
designation. 

The Wild Horse Management Plan is a Necessary Response to On-the-Ground 
Conditions 

WOC supports the proposal to expand the Fifteenmile Wild Horse Herd 
Management Area. Wild horses have roamed much of the resource area since the late 
1880s. With the passage of the Wild Horse and Burro Act of 1971, a portion of the 
natural range was established as a herd management area. Because wild horses (even 
well -behaving ones) do not recognize administrative boundaries, the preferred 
alternative proposes to expand the 83,000-acrc Fifteenmile Wild Horse Herd 
Management Area by about 31,000 acres. The boundary change simply reflects historic 
and actual use of the area by free-roaming wild horses. 

Riparian Areas and Rangeland Need Greater Protection 

More emphasis needs to be placed on restoring degraded wetland, riparian areas 
and rangeland. According to the EIS, only about one-half ol all riparian habitat within 
the resource area is considered "properly I unction i tig," and this situation is 
Unfortunately expected to remain relatively static during the entire 10-15 year planning 
period- Even under the "preferred alternative," the amounl of riparian habitat 
considered to be properly functioning would increase only slightly, from 1,140 acres to 
1,300 acres by the year 2005. The BLM should focus more attention and resources on 
riparian restoration and on identifying and preventing sources of riparian degradation. 

Similarly, a large portion of the rangeland In the resource area is degraded and 
unhealthy, damaged bv years of overgrazing and abuse. Although grazing practices 
and management have improved dramatically during the past few years, many grazing 
allotments remain in unsatisfactory condition. A more aggressive use of coordinated 
range management techniques coupled with time-controlled grazing practices would 
greatly improve ecosystem health and biodiversity. 

Greater Emphasis Should be Placed on Fish and Wildlife Habitat 



500.9 



The proposed resource plan would provide suitable habitat and forage required 
to support wildlife populations set by the Wyoming Game and Fish Department's 
strategic plan only "to the extent possible." In addition, the plan would maintain or 
enhance fish and wildlife habitat, promote species diversity, and allow the expansion of 
wildlife and fish only "where appropriate." These "weasel words" don't really mean 
much, so what is the point of using mem, other than to provide an escape hatch for the 
agency. The BLM is either going to provide tor wildlife Or not - you should not 
equivocate on such an important and valuable resource. 

WOC supports the wildlife prescriptions in Alternative C, the only alternative 
that would meet WCHJ wildlife objectives and "allow [s] the expansion of wildlife and 
fish into high potential habitats." Alternative C is also the only alternative that provides 
adequate protection for all big game winter range. The proposed plan only protects 
"crucial" winter range for elk, mule deer, moose, bighorn sheep, and antelope. 

The BLM Must Stop Thinking of Forests Merely as Tree Farms and Begin to 
Recognize and Manage for Their Intrinsic Value. 

The RMP makes the biologically-bankrupt statement on page 14 that "BLM- 
administered t'orestlrfnds - - need to be harvested over time to maintain a healthy, 
vigorous forest.' Really? The answer to improving forest health is to cut down the 
forest? The notion that active "vegetative treatment" is needed to maintain a healthy, 
functioning forest ecosystem is not only absurd, but is belied by both the facts and 
history. Forests thrived for thousands of years before the advent of chain saws. How 
did our forests manage to do so well without modern sivicultural practices? Today, 
there are fortunately thousands of acres of forest protected by wilderness designation. 
These forests are fully-functioning ecosystems supporting a tremendous array of plant 
and animal species, despite the lack of active management. And they are unhealthy? If 
BLM is proposing to develop a publicly-owned tree farm on the Grass Creek Resource 
Area, which does require active management, it should so inform the public. 

Despite the express recognition that the "preferred alternative" would accelerate 
fragmentation of elk and deer habitat in some areas, the plan proposes to maintain 
timber harvesting at historic high levels bv entering areas that have experienced 
rela lively little timber harvest activity. The draft plan proposes to cut about 6 million 
board feet of commercial timber from public lands, in addition to 30 million board feet 
from private and state lands in the planning area As much as 1,900 acres of public land 
would be impacted by timber harvest and other forest "treatments" during the planning 
period- The preferred alternative proposes at least 15 miles of new or upgraded roads, 
With each new mile reducing effective wildlife habitat by 320 acres, Under the proposal, 
harvesting of "old growth" would continue until only about 10% of the original forest 
remains unaltered. 

In order to meet sustained-yield objectives, far less timber should be cut from the 
public lands during the planning period. Because large amounts of timber are being cut 
Ofl private and state lands within the resource area, the BLM may have to reduce timber 



454 



500.10 



volumes even further in order to compensate fur the loss of wildlife habitat resulting 
rrorn private and state land sales. Thf RLM should prohibit commercial timber harvests 
in the Upper Owl Creek ACEC unless cutting can be pro ven to improve and enhance 
wildlife habitat. At least 30% of the forest should be managed as old growth in order to 
provide suitable habitat for old growth dopendem species, such as the northern 
goshawk, marten, and three-toed woodpecker. The BLM should adopt a "no net gain" 
policy for roads so that tor every new road created an equivalent amount is obliterated 
(not merely closed) and reclaimed, Roads should not be constructed on slopes in excess 
of 20%, in wetlands and riparian areas, or on erosive soils, and road closures need to be 
stricUy enforced. 

Additional Alternatives are Needed, and a Clarification of NEPA Responsibilities 

In order to comply with the National Environmental Policy Act ("NEPA"), new 
alternatives prohibiting oil and gas leasing and development in ACfiCs, W5As, and 
SRMAs needs to be developed. As it exists now, every alternative in the Draft Plan 
allows oil and gas leasing on every available acre of land in the resource area. 
Additional alternatives need to be developed lor the management of wilderness study 
areas that arc not designated by Congress, and for the management of visual and ioresl 
resources. 

At what point does BLM consider the "no action" alternative For individual oil 
and gas lease offerings on public lands, and how is the public involved in this decision? 
Although the RMP (page 14) indicates that "icJlosing the planning area to gas and oil 
leasing was considered to resolve conflicts with other resource uses[,]" such 
consideration ('i.e., on a planning level) does not satisfy your obligation under NPPA to 
consider the no action alternative for each lease decision. 

Environmental Consequences 

Discussion of environmental consequences is a basic requirement of NEPA This 
section should describe the environmental impacts likely to result from Implementation 
of the selected alternative. The discussion should also facilitate a comparison of the 
alternatives described in the EI$. In the case of the Grass Creek RMT, it does neither. 
Rather than describing environmental effects, the EIS's focus appears to be describing 
how measures taken to protect the environment (i.e., a no surface occupancy stipulation 
on a oil and gas lease) might interfere with management actions. 

Thank you for the opportunity to comment. Please let us know of any additional 
comment opportunities and the availability of the Final or supplemental Draft EISs. 

Sincerely, 



Danileilig 
Associate Director 



OSIMM YELLOWSTONE BC< 



500.11 





WY OMING 
OUTDOOR 
COUNCIL 



500.12 



April 14, 1993 

Joseph T. Vessels 

Grass Creek Area Manager 

P.O. Snx 119 

Wor 1 and , Wye-m 1 .ig 

RE: Grass Creelc Resource Area Resource Management Plan ■ 
Planning Criteria 



Dea 



Vessels: 



The following comments are provided on behalf of the 
Wyoming Outdoor Council (HOC) in response to your invitation for 
assistance In developing planning , criteria for the forthcoming 
Grass Creek Resource Management Plan (RMP) . 

WOC is a grass roots conservation organization dedicated to 
the protection and enhancement of Wyoming's environment. HOC 
achieves its mission by educating and involving it* members and 
the public in agency decisionmaking and by advocating 
environmentally sound public policies. 

I. ALTERNATIVES 

In your March 4, 1992 letter requesting assistance in 
developing planning criteria for the Grass Creek RMP, you state 
that the "[p]lanning criteria will be used to guide the 
formulation and evaluation of alternatives, including the 
analysis of the environmental consequences of the alternatives . " 

WOC previously transmitted comments tc you which addressed, 
among ether things, alternatives to oil and gas leasing on 
federal lands within the Grass Creek Area. S eo Letter from Dan 
Heilig, Associate Director, WOC, to Joseph Vessels, Grass Creek 
Area Manager, dated January 3, 1992. Those comments are 
responsive to the concerns you raise in the planning criteria 
letter and are therefore incorporated by reference herein. -In 
our previous comments, we expressed our concern about the manner 
in which the BLM perceives Its responsibilities under the Federal 
Land Policy and Management Act (FLPMA): namely, that the BLM 
appears to routinely elevate oil and gas development over Other 
resource values, such aa wildlife, recreation, scientific, and 
natural scenic values. To support that claim., we cited a number 
at RMPs in Wyoming which authorize oil and gas activities on all 
(or virtually all) of the lands legally available (e.g., lands 
outside WSAs) under the respective resource management plans. 
The Cody, Washakie, Great Divide, Lander. Plnedale, and' Kenmierer 
RMPs, for example, authorise oil and gas activities on nearly all 
legally available lands within their respective planning areas. 

201 Main Under, Wyoming; 82520 (3G7) 332-7031 



500.13 



The Congress has stated that "management [of the public 
lands] he on the basis of multiple use and sustained yield 
unless otherwise specified by law." FLPMA, 43 U.S.C. 1701(a)(7), 
1732(a). Multiple use does not mean oil and gas development at 
the expense of other resource values . Multiple use does mean "a 
combination of balanced and diverse resource uses that takes 
into account the long-term needs of future generations for 
renewable and nonrenewable resources, including, but not limited 
to, recreation, range, timber, minerals, watershed, wildlife and 
fish, and natural scenic, scientific and historical values . . 
.." See 43 D.5.C. 1702(c). The doctrine of multiple use 
contemplates "making the most judicious use of the land for some 
or all of these resources . . . . " Jfl . 



In accordance with the abov 
development of a wide range of 
reflect the multiple use policie 
possessing special or unique res- 
oil and gas development; other a 
by the use of stringent surface 
(Please see our January 3, 2992, 
recommendations! , The alternate 
development subject ta stands 1 
open to leasing subject tc re 
timing or seasonal use, areas op 
no -surf ace-occupancy stipulation. 
See BLM Supplemental Program flaii 
attachment illustrating Shoshone 
preliminary alternatives. 



strongly urge the 
Iternatives that accurately 
Of FLPMA. Certain areas 
rce values should be closed to 
reas may be adequately protected 
"isturbance restrictions. 
comments for specific 
ves should identify areas open to 
lease terms and conditions , areas 
ictive stipulations, such as 
en subject to 

s , and areas closed to leasing. 
.ar.ee (SPG) 1624 .21 and 
National Forest Oil and Gas EIS 



The consideration of alternatives 
environmental analysis under NEPA. Rag 



3 heart of 

ans developed by the 
the President's Council on Environmental Quality (CEQ) require 
all federal agencies preparing EISs to "rigorously explore and 
objectively evaluate all reasonable alternatives . . . and 
devote substantial treatment t« each alternative . . . ." See 40 
CFR 1507(2) (d). Indeed, the BLM's own planning regulations 
provide that " [a] 11 reasonable alternatives shal 1 be considered 
and several complete alternatives developed for detailed study. " 
See 43 CFR 1610.4-5. Alternatives that close areas within the 
Grass Creek Resource Area containing special and/or unique 
resource values are without question reasonable and must, 
therefore, be considered in the planning document. 



ENVIRONMENTAL CONSEQUENCES 



letter, you state that 



fs. In your March 4th planning criteria 
the "[e]ffacts of surf ace -disturbing land 



455 



500.14 



Vessels, Page 3 



uses and other human activ- 



es on air quality, cultural 



.-.sources, recreational opportunities, watershed, and wildlife 
resources" will be addressed in the analysis or environmental 
consequences in the Grass Creek RMP. why are a number of 
important resource values left out of the draft olanning criteria 
le.ter? As the Nation's principal conservation agency" WOC 
oelleves that the BLM must consider the following additional 
resource values in the environmental consequences section of the 
KMP: (1) scenic and visual resources, (2) fisheries (3) 
hazardous wastes. (4) geology, (5) soils, (6) vegetation, [71 
timber management, (8) wild horses, (9) wetlands and riparian 
areas. (101 water resources including groundwater (11) 
geothermal resources. (12) Native American Indian concerns, and 
,13) socio economic impacts. Indeed, the majority of these 
resource values are expressly considered in section 103 of FLPMA 
and all are explicitly analyzed in many other RM?'« in Wyoming 
See., e.g., Cody RHP/SIS at pp. 77-92. 

, b - Cumulative impacts. Given BLM ' s increasing reliance on 
-and use plans to support leasing and development decisions, we 
be 11 eve that the BLM must do a more thorough job of analyzing the 
cumulative impacts of the proposed action and alternatives In a 
recent report, the Genera! Accounting Office (GAO) -"ound that 
"Imlost BLM and Forest service land use Dians and related 
environmental studies for resource areas and forests with high 
oil and gas potential do not contain adequate information 
necessary to make informed decisions about the environmental 
impacts of oil and gas leasing and development." See General 
Accounting office. Federal Land Management i "Better _ 0il and Gas 
Information Needed to Support Land Use Decisions" (June 1990) at 
p. -34. The report identified five "key" elements reouired by 
NZPA and BLM regulations (including BLM ' s supnlenental program 
guidance (SPG)) as essential for the agencies to assess the 
environmental impacts of oil and gas development in resource 
areas with high oil and gas potential. The elements ar- (1) oil 
and gas potential, (2) reasonably foreseeable development 
scenarios, (3) Indirect impacts, (4) cumulative imoacts and, (s) 
lease stipulations. The GAO was especially critical of the BLM ' s 
failure to adequately analyze the cumulative impacts of oil and 
gas activities. For example, of the 40 RMPs reviewed by the SAO 
only 7 specifically referred to the term "cumulative impact." 

To comply with both NEPA and BLM ' s SPG, the RMP/EIS must 
analyze in detail the cumulative impacts of reasonable 
foreseeable development scenarios. Cumulative impact means "the 
impact on the environment which results from the incremental 
inpact of the action when added to other past, present, and 
reasonably foreseeable future actions regardless of what agency 
(Feoeral or non-Federal) or person undertakes such actions 



500.15 



over a period oH 



Vessels, Page 4 



Cumulative impacts can result from individually minor but 
collectively significant actions talcing Dlace 
time." See 40 CFR 150(3,7. 

Thank you for providing this opportunity to comment 
Please keep me informed of additional comment ODaortunities 
related to the Grass Creek RMP: WOC ' s members have expressed 
their interest in the development of this RMP, and a desire to 
see more or the Grass Creek ajrea protected from damaging oil and 
gas development activities. 

Sincerely, 



Dm Heilig 
Associate Director 




WYOMING 
OUTDOOR 
COUNCIL 



500.16 



January 3, 1592 

Joseph T. Vessels 

Grass Creek Area Manager 

Bureau of Land Management 

P.O. Box 119 

Woriand, Wyoming 82401 

RE: Scoping Notice - Grass Creek Resource Area Resource Management 

Dear Mr. Vessels; 

Thank you for inviting the Wyoming Outdoor Council to participate in the 
development of a resource management plan for the Bureau of Land Management's 
Grass Creek Resource Area. 

WOC appreciates the amount of effort and resources that the BLM must 
devote in the development of a resource management plan (RMP); therefore, we 
have attempted to address a few issues which merit careful consideration in the 
early stages of plan development. In addition, I discuss issues surrounding oil and 
gas leasing in some detail in an effort to be responsive to your request for comments 
concerning mineral leasing exploration, and development on the Grass Creek 
Resource Area. I hope you fine our comments useful, 

.Leasing 

We understand from your November 25, 1991 letter inviting comments that 
the alternatives to be considered in the RMP will be identified in the "planning 
criteria" stage of the planning process and that comments with respect to 
alternatives will be requested when the planning cnteria are developed We look 
forward to providing additional comments addressing this issue when a specific 
request is made. We would ask, however, that you begin thinking about 
considering in the Draft H1S/RMP alternatives for oil and gas leasing in the Grass 
Creek Resource Area that would come closer to satisfying the multiple use 
objectives mandated by the Federal Land Policy and Management Act (FLPMA), 43 



Under, Wyoming S252Q 



U.5.C. 1701 ct sc-q,, gnd the express requiremen 
Policy Act (NEPA) 42 U S C. 4321 el <pg 



500^17 

its uf the National Environmental 



a) Ihc-EXM is not meeting FLPMA's rmilHp i fi ma gqajfi The Congress has 
stated that "management [of (he public landsl be on the basis of multiple use and 
sustained yield unless otherwise specified by law," 43 U.S.C 1701(a)(7), 1732(a). 
Multiple use, as defined in FLPMA, 

means the management at the public lands and their various 
resource values so that they are utilized in the combination that 
will best meet the present and future needs of the American people; 
making the most jud-cious use of the land for some or aU of these 
resources or related services'ever areas large enough to provide 
sufficient latitude for periodic adjustments in use to conform to 
changing needs and conditions; the use of some land for less than 
a!] of the resources; a combination of balanced and diverse 
resources uses that takes into account the long-term needs of future 
generations for renewable and nonrenewable resources, including, 
but net limited to, recreation, range, timber, minerals, watershed, 
wildlife and fish, and natural scenic scientific and historical values; 
and harmonious and coordinated management of the various 
resources without permanent impairment of the productivity of the 
land and the quality of the environment with consideration being 
given to the relative values of the resources and not necessarily to 
the combination of uses that will give the greatest economic return 
or the greatest unit output. 

43 U.S.C. 1702(c). 

h is clear to us, however, that the BLM in Wyoming habitually violates 
FLPMA's multiple use objectives by placing undue emphasis on oil and gas 
development at the expense uf other legitimate multiple use activities on the public 
lands. For example, oil and gas leasing is authorized on ninety-nine per cent (99%) 
of the Washakie Resource Area with surface disturbing activities permitted on a full 
ninety-three percent (93%) of the federal mineral estate Washaki e Resource 
M a n agemen t K a iu En a l. EIS at 3. Similarly, the entire Great Divide Resource Area is 
available for oil and gas leasing. Great Divide Re sou rce Ares J& aaase^togamaat 
Plan Fi n al PI ? at 52, and all but one per cent (1%) of the 27 million acres of federal 
mineral estate within the Lander Resource Area is available for oil and gas teasing. 
L ander Baaouisa Arpfl Bflaausa Man a g gmejaLJaaa at 384 in the Washakie and 
Great Divide Resource Area RMPs, the BLM attempts to justify the inordinate 
amount of land available for oil and gas Icastng by citing FLPMA's multiple use 



456 



mandate. SftEL Eg..Jiceal..Diyid£-EfiSfi] 

RMP /Final E1S at 111. 



500^18 

i at 52 and Washakie 



WOC disagrees with the ELM's assertion that FLPMA mandates oil and gas 
leasing en all (or substantial portions of) BLM- administered lands. In fact, FLPMA 
dearly does not requir e oil and gas leasing on the public lands. The Act merely 
recognizes that mineral development is but one of many authorized uses of public 
lands and their resources. As quoted above, FLPMA requires "a combination of 
balanced and diverse resource uses" and "judicious use of the land for some or all of 
these resources" and finally, consideration of "the relative values of the resources 
and not necessarily to the combination of uses that will give the greatest economic 
return or the greatest unit output." Oil and gas ieasing and development on an 
entire resource area is certainly not balanced, nor can it reasonably be claimed to be a 
judicious use of public resources, given the detetenous impacts to the environment 
caused by this activity. Oil and gas leasing may provide the greatest economic 
return, but FLPMA directs agencies to consider the relative values of other 
resources, such as wildlife and fish, recreation, cultural and historic, air, water, 
ecological, scientific and scenic. 43 U.S.C 1702(c), 170 1(a)(8). Thus, while 
management for resource utilization is one major goal, the definition of multiple 
use clearly contemplates conservation -oriented management on appropriate areas 
of the public lands. We urge you to reconsider your obligations under FLPMA 
taking into account what has been said above. 

Accordingly, we ask that you carefully consider a range of alternatives in the 
forthcoming KMP/EIS which would propose withdrawals or deny oil and gas 
leasing for all (or a combination of) the following areas: 

* rare, threatened, endangered, and candidate species habitat 

* areas of critical environmental concern 

* wilderness study areas (including "citizens' proposal") 

* steep £15% gradient) and unstable slopes 

* crucial wildlife winter range areas 

' important wildlife winter range, calving and breeding areas, migration routes, 

and summer concentration areas 

' fioodplains, wetlands and riparian areas 

* high soil and water (induding groundwater) hazard areas 

* municipal watersheds 

' sage grouse leks and habitat 



500.19 



* fisheries 

* developed and dispersed camp sites 

* popular travel corridors, routes and trails 

* Native American spiritual sites 

* sites listed, or eligible for listing, under the National Historic Preservation Act 

* raptor concentration areas 

* sperial management areas 

' Class I and II visual resource management areas 

* other areas where oil and gas development would not be compatible with existing 
or foreseeable resource values and uses. 

b) The Rl.M must analyze a full range cf altemaflyes, The consideration of 
alternatives is the heart of environmental analysis under NEPA Section 102(2)(E) 
of NEPA requires agendes to "study, develop, and describe appropriate alternatives 
to recommended courses of action in any proposal which involves unresolved 
conflicts concerning alternative uses of available resources." See also. 40 CFR 
1507.2(d). in the alternatives section, the agency must "[rjigorously explore and 
objectively evaluate all reasonable alternatives . . . and (djevote substantial 
treatment to each alternative ..." Id 

The regulations promulgated by the Council on Environmental Quality 
(CEQJ implementing NEPA direct federal agencies "to identify and assess the 

reasonable alternatives to proposed actions that will avoid or minimize adverse 
effects of these actions upon the quality of the human environment." 40 CFR. 
1500.2(e), The discussion of alternatives in an environmental analysis document 
"should present the environmental impacts of the proposal and the alternatives in 
comparative form, thus sharply defining the issues and providing a clear basis for 
choice among options by the dedsionmaker and the public" 150114. In particular, 
wc encourage you to analyze and include a discussion of the "conservation potential 
of various alternatives and mitigation measures." 40 CFR 1502.16(e), 

In sum, WOC urges you to "rigorously explore and objectively evaluate all 
reasonable alternatives" with respect to oil and gas leasing on the Grass Creek 
Resource Area. This analysis must cleariy include alternatives that propose 
withdrawing and /or denying leasing for the areas enumerated above. 

II. Compliance w ith FLPMA 



500,20 

a ) The Rl.M can ac hieve FLPMA' s mu j;i plp use and sustained yield goals. 
Section 202 of FLPMA directs the Secretary to "use and observe the prinripals of 
multiple use and sustained yield" in the development of land use plans. 43 U.S.C 
1712(b)(1). We are deeply concerned that this mandate is not being met on much of 
the BLM- administered public lands in Wyoming. We hope that with the 
development of the Grass Creek Resource Area RMP, action can be taken to bring 
BLM management activity into conformance with the policy embodied in FLPMA 

The RMP must provide for "the achievement and maintenance in 
perpetuity" a high-level output of renewable resources of the public lands. It must 
meet the "present and future needs of the American people" and "take into account 
the long-term needs of future generations for renewable and nonrenewable 
resources." 1702(c). All to often, it seems, "the long-term needs of future 
generations" are ignored in the planning and management decisions for the public 
lands. 

We offer the following recommendations: 

1) The BLM can help achieve the multiple use objectives mandated by 
FLPMA by properly utilizing ACEC designations . ACHCs, or areas of critical 
environmental concern, are 

areas within the public lands where spedal management attention 
is required (when such areas are developed or used or where no 
development is required) to protect and prevent irreparable damage 
:o important historic, cultural, or scenic values, fish and wildlife 
resources or other natural systems or processes, or to protect life and 
safety from natural hazards. 

43 U.S.C 1702 (al 

FLPMA requires the Secretary, in the development of land use plans, to "give 
priority to the designation and protection of areas of critical environmental 
concern." 1712(c)(3). WOC encourages the use of the ACEC designation to further 
the multiple use mandates embodied in FLPMA and will support efforts to protect 
such areas. Proposed ACEC's should be identified in the Draft RMP and plans 
promptly developed "for the protection of public land areas of critical 
environmental concern" FLPMA, 43 U.SC 1701(a)(ll). 



500.21 



2) Section 202 of FLPMA directs the Secretary in the development of land use 
plans to "weigh long term, benefits to the public against short-term benefits." 43 
U.S.C 1712(c)(7), We ask that you consider and include in the Draft Grass Creek 
Resource Area RMP/EIS a discussion addressing this important requirement. A 
discussion of this issue necessarily entails consideration of "present and potential 
uses" of the public lands." 17l2(cXS). 

For example, while WOC members recognize that oil and gas leasing is a 
legitimate use of the public lands, few see any long-term benefits (other than 
revenue generation) to be derived from increased oil and gas exploration, 
development, and production activities on the public lands, particularly in sensitive 
areas. This is especially true when "full field" development takes place on or near 
areas that have special or unique values, such as habitat for endangered species, 
sensitive watersheds, important cultural or historic sites, to name a few. Typically, 
oil and gas development occurs at the expense of other values, some irreplaceable. 

We would be interested in hearing from the perspective of the BLM, what 
the long term benefits of oil and gas leasing are when development of that resource 
so often causes irreparable damage to wildlife and wildlife habitat, soil, air and water 
quality, visual and scenic resources, recreation opportunities, etc? Tne same 
question can (and probably should) be asked with respect to timbering, grazing, 
recreation, and other potentially damaging uses on BLM-administered public land. 

3) Section 102 of FLPMA the Congress declares it is the policy of the United 
States that 

the public lands be managed in a manner that will protect the 
quality of sdentific, scenic, historical, ecological, environmental, air 
and atmospheric, water resource, and archaeological values; that, 
where appropriate, will preserve and protect certain public lands in 
their natural condition; that will provide food and habitat for fish 
and wildlife and domestic domestic animals; and that will provide 
for outdoor recreation and human occupancy and use. 

43 U.S.C. 1701(a)(8). 

WOC urges you to develop a resource management plan which implements 
the policy set forth in section 102 of FLPMA. 



457 



4) Section 202(c)(6) of FLPMA directs the Secretary fo "consider the 
scarcity of the values involved and the availability of alternative means (including 
recycling) and sites for realization cf those values." 1712(c)(6). This section is related 
to NEPA requirement to "fi]denttfy methods and procedures required by sec 
102;2)(R) to insure that presently unquantified environmental amenities and values 
may be given appropriate consideration." 40 CFR 1507.2. 

WOC urges you to give thoughtful and appropriate consideration to 
"presently unqualified environmental amenities and values" on the Grass Creek 
Resource Area, including, but not limited to, scenic vistas, clean air and water, 
wildlife viewing, quiet solitude, semi-primitive recreational opportunities, non- 
designated "de facto" wilderness, and benefits derived therefrom, and lack of 
noticeable presence of man and his impacts. These amenities and values, many of 
which are scarce, are unique to the sparsely populated western states. These and 
other "presently unqualified environmental amenities and values" do exist 
outside of BLM designated wilderness areas and must be taken into account during 
the development and implementation of the Grass Creek RMP. 

The potential environmental impacts of current and foreseeable mineral 
development must be specifically and thoroughly addressed in the Grass Creek 
Resource Area RMF/EIS. 

The issuance of an ail and gas lease without a no-surface-occupancy 
stipulation (NSO) constitutes an irretrievable commitment of resources requiring 
the preparation of a detailed environmental impact statement. Sfifi, e.g., SjejiaXlilb 
v. fetcrspj, 717 F.2d 1409 (D.C. Circuit 19S3). This is so because the lease confers 
upon its holder an irrevocable right to explore, develop, and produce, by means 
involving surface disturbing activities, the mineral resource somewhere on the 
lease tract. With few exceptions (e.g, protection of endangered species under the 
Endangered Species Act), the government is powerless to prevent surface disturbing 
activities once a lease containing no NSO stipulations is issued. Therefore, a detailed 
environmental analysis must take place at the lease issuance stage to ensure "that 
environmental information is available to public officials and citizens before 
decisions are made and before actions arE taken." 40 CFR 1500.1(b). Detailed site- 
specific analysis conducted during activity planning is clearly not adequate to assess 
and prevent environmental damage. 



.22 



500.24 



State of Wyoming groundwater classifications (existing and potential) for 
aquifers underlying the Grass Creek Resource Area should be identified in the RMP 
and management activities conducted in accordance with applicable slate 
classifications. In addition, aquifer data should be included in the RMP. 



The RMP should include a discussion of the potential impacts on surface 
water resources as a result of various development scenarios prescribed by the RMP. 
Methods available to mitigate - and monitor - such impacts, and criteria used to 
select such methods, should be discussed. Current and potential surface water 
classifications (federal and state) should be identified and statutory and regulatory 
framework providing protection for Wyoming's surface water explained. Please 
include in the RMP a discussion of how water quality data is collected and analyzed. 



Proper and appropnate classification of visual resources en the Grass Creek 
Area is essential to carry out the multiple use mandate of FLPMA. WOC believes 
visual resources are extremely valuable and frequently underrated in BLM 
management of the public lands. In addition, our members have often found that 
efforts to mitigate impacts to visual resources on BLM-admintstcred lands, 
including Wyoming BLM Standard Oil and Gas Lease Stipulations and Dther 
mitigations developed during site-specific environmental analyses, are woefully 
inadequate. We hope the Draft RMP/ EI5 includes a discussion of the methods 
employed by the BLM to identify and evaluate visual resources. The rational for 
proposed VRM classifications should also be explained and supportable. 



VII. 



Sial.ut.es, Re gulat ions.^ Planning and Environmental A nalysis Documents 



Please include in the Grass Creek RMP/E1S a brief discussion of applicable 

laws, regulations, planning and environmental analyses documents that influence 
management direction and actions within the Grass Creek Area. Comments 
addressing this issue can assist the public in understanding the basis and need for 
certain activities on 3LM-adininistered public lands, 



500.23 



IV. 



.QAinulaHvc_lmpacts 



NEPA requires analysis of the cumulative impacts of actions (management 
goals and direction) prescribed by the RMP. "Cumulative impact is the impact on 
the environment which results from the incremental impact of the action when 
added to other past, present, and reasonably foreseeable future actions regardless of 
what agency (Federal or non-Federal) or person undertakes such other such 
actions." 40 CFR 1508.7 "Cumulative impacts can result from individually minor 
but collectively significant actions taking place over a period of time." Id 

Oil and gas leasing, exploration, and development, coal-bed methane 
development, hard rock mining utility rights-of-ways, recreation, timber and range 
management activities, livestock grazing and fire suppression are illustrative of the 
types of actions prescribed by BLM resource management plans. Tne Grass Creek 
RMP/EIS should assess the incremental environmental impacts of these and other 
"past, proposed, or reasonably foreseeable future actions" within the resource area. 

V. Water Resou rces 

a) Wetland s The RMP should indicate the location of wetlands in the 
resource area and identify the functions and values of wetlands potentially impacted 
by development scenarios under each of the alternatives. Wetland maps are 
available from the U.S. Fish and Wildlife Service as a result of that agency's 
National Wetland Inventory (NWD- 

The RMP should indicate that the discharge of fill material into wetlands and 
waters of the United States is regulated by Section 404 of the Clean Water Act, 33 
U.S.C 1344. The RMP should also note the existence of and compliance with 
Executive Order 11990. 

b) Gxaunclw a tejlj&s.aurcgs. Management actions, particularly hard rock 
mining coal mining and oil and gas development can have a harmful and 
irreparable impact on groundwater resources. The RMP should include a discussion 
of the potential impacts on groundwater resources (including disposal of produced 
water) of various development scenarios and methods available to mitigate - and 
monitor - such impacts, and criteria used to select such methods. 



500.25 



The Crass Creek Resource Area RMP should Include a discussion of the 
•n-.eans to mitigate adverse environmental impacts- (40 CFR 1502.16(h), 1502.14(0) 
and monitoring should be incorporated into the Record of Decision 40 CFR 1505 2 
15053. * 



IX. 



Ina3mpJeie_ar.JJnav,iilrihlt-JtifomialiQn 



We are disappointed that the BI.M "will conduct very little new inventory 
work for [the Crass Creek RMP) but will rely upon existing, available resource 
information and data/ ScopingJtoiice (November 25, 1991). We sincerely hope 
that you can "insure the professional integrity, including scientific integrity of the 
discussions and analyses" (40 CFR 150224 - Methodology and scientific accuracv) in 
the Grass Creek RMP/EIS without the benefit of additional inventory work and 
information. WOC would suggest a rewew of CEQ section 1502.22 ■ Incomplete or 
unavailable information - prior to the preparation of the Draft EIS. We also 
recommend consultation with the Wyoming Nature Conservancy, located here in 
Lander, and the Greater Yellowstone Coalition, in Bojeman, MT. 

You indicate that "existing available resource information and data" will be 
be relied upon. What information, specifically, will be used? Have you consulted 
other federal, state, and local agencies in an effort to obtain current and reliable 

information? 

X, Tiering ard_inccirp.oxaliori by Rsfaama 

Tiering (40 CFR 1502.20, 1508.28) and incorporation by reference (150221) may 
be used to reduce paperwork and eliminate repetitive discussions cf the same issues 
We encourage the use of these practices. 



in the environmental document 



WOC appreciates the opportunity to offer our comments. Please do not 
hesitate to call me if you have questions or thoughts on the issues discussed herein. 
I look forward to participating further in the development of the Grass Creek RMP. 

Sincerely, 



Dan Keiiig 
Associate Director 



458 



K 1 c e I v £ D 




MAY - 9 ( 

j BukxUOFLftNDUAHAtiUltHT ' 



!3ob Ross 

Rur«au of Lflnd Man 

Box 119 

Worland, WY 92101 



501 



Grass Creek Resource Management. Plan 



Deflr Hr. Ross. 

I belj.ev« the Urass Cre*k 8HP is a fairly sound document.. My only 
concerns aro the provisions on off road vehicle travel and whether 
the BLK will follow through with its plans fur grazing management 
in the Resource Area. 

The off road vehicle ban will be hard to enforce and «xcept in wet 
conditions , is not impacting "he Area at present levels . The 
retrieval of downed game animals should be allowed, at a minimum 

The grazing provisions in the old RMP were very good and were not 
followed. I hope the BLM will be able to follow this document 
better than the last one. The lower allotments in th« Basi are 
generally in worse shape and are getting less attention. These 
watersheds are Impacting the fisheries or. the Big Horn River and 
after years of personal involvement 1 have not seen much measurable 
improvement. 



Sruca Ostencar.ri 



MAY -9 1995 

j BUBEAU OF UND MANAGEMENT 1 

fid.! „•'■■■'■:. . „.' 



HOMESTEAD REALTY 




502 



535 Brcadway ■ Thermopolis. WY B2443 



Ph: 307-664-2343 ■ Pax 307-86*-238G 



UDfiand BLH 

Bob Ross, KMH learn Leader 

P. 0. Box 11? 

War lard WY 82401 

Bob: 

Please accept this letter as my comments concerning the 
'Grass Creel. Rusoiirte Arg* Hesource Management Plan Draft 
Ervireinmeiits: Impact Statement." I oppose the plan for the 
following r easons: 

1 ) it... i.3 nor needed time. . and . ffioneu h=>ve been maaLed 
cjevel0Bing_it_3nd_m0.ce.- will ____5._gD-t._d__ __________ Vou now h»v* 

the >-:noi_ ledge and re_iil_Hano to do iuh_t yay profess this 
dccurr.ent will al low you to do. In m-any capers it has and is now 
tipi ng dose. The thousands of hours spent