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
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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
GRASS
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*BM»«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 entirety.
Mailing addrcss;_
City, State & ZIP: _
Tl^ttas \J/£f ?#"*■<<-«
Bp^Z/t^BW
Q&ASS
20
Qr.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 0 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:_
7Mc
£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
fAntennaria aromatjea) and Wyoming tansymustard
(Descurainia torulosa) . 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 fPhysari?. 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 0
September 1993 Notice of Review-
The federal status Of two species in Table 11 is
incorrect. Persistent sepal yel lowcress fRorioaa
calvcina) is listed as a 2C candidate in the 1993
Notice of Review. William's waferparsnip (Cymapterus
will 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
(Oryzopsis contracta) 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
33f130 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 „.« Mu 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.nEe 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 „0r„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, ii1- 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 regavcl 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.™Bd to t, r,„.„ary »« |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 Lrdvel 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 rur
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
UPK% 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, ..W4itur. 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, L99r]
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 HOME 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., always 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 inadequacy 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
enforcement 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 25th 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. Water Quality Rules and
■i peculations 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 Quality 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' 0 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 Kas 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..iDr,,t.d .h fir.. ,,, CrUtiC.l
Environmental Concern becaw of Us soertaclv ^-„.,- Z
e«tn.»,,ly fr»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 change. 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 ,11 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 0
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 Conservationist1 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. IQU5
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 priority1
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'
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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 0 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 Grass 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 rjesipna\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 pjobjsrris of Qyergra/.inE in the resource area.
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, including 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
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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 0
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.
SptT'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 Conservationists1 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] LKnora» 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 Ksnaa.nant i™,, (RSMAs
--h.3s.lUnd. .-.MA bu such eKW.ns!,, fr.ei 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 = lte ,„,,!. -
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
— jcchlra 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 opposed 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 0 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 can, 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
ConQ»rning 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, ond 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, Brc provide a tloelins to accomplish those goals in tho noxt' fivo
Tha "It you for your attentlon.
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(
1kT
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 0 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 0 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 0 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 must1 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- sand "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 ver1?; 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 changes 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
:0T1'3 "
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 chuggES 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 0 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-Vr& '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 changes 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) Exotect 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 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 from 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 overgrazing 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:
0 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/ariElueJEtreiBely 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 , 0 . 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 a1? 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 devclpm
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 0
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 0 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 think 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&
Environmental 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
mM 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
*&&&$€:■ <5wt&&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»
MEMORANDUM
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*prjili-|-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 h3s takei
Tour years to preja're M.KF*. rjotUir^-.t aw v.e >sc<(\y«i ;jr fjrnt
draft in January afc 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?» Cr- 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 air1 l.
Btunomis berie'i: 'or our county*. ' Contfexris wc> -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 wjth 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
0
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 particular 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, noii:;. Leader
Bureau of :<at)d :iatafl^«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 $dz
uevs'o?fli8n'i;» etitJ waula Liite to ■safest tihut aov.e s
^lould be protected from this.
'Jiie .ibsGrckc !--'ooti:i J J.s ,
tuiJ p.ed '^nyon '.'reel! ",:.gcla'i
»rw.£ should be no vrcije'c-ed. ;.iio tii- ":',£^i.-j ndd :;,;:..;
ciiould be aa ,\ren ci' flrltioti] wvisomiictrtai .'oncar/j
(:; ■'.:■'; tje-eaaaa of ox-irentijiy frK&iie soij.? an:! racUy
iy,?cct0Mifii7 trenerv. T r^-o believe that Bll e.rer.e
iuciuaeti la the reader vs. tioni.-ta1 ..Iterratr.': to 'ti'ie
Bi::'i '.'IMarneK- froj>orRl iaclailes l&uck out. ids
'ilelsrotrsi, "tudy ^reae elioii^i be protected freia oiJ
1 1 wculi'l f.ist.' E'jqci wIj^ t;cj i?T07lfle i:.cre ie£inS"Ss
jOi-la tg B'iireur the pwljieiafe oC overgrftsiajs in tiie
resource rrcr , inclu-.l i.n;; & ircjrieiuv.e or definite tlffif*
bo Rocompiiari tii-e-a s ja-a.le in ihc next fiv-e vgem:.
.■■.iii'nou^b j hiive never visited '-'VtMuiai, 1 iiwva re«d
su-clj tbout its jp^c it. i. b*feyties:, '* book by John :;al'b&*>
b.in.^ cue oX 'the most itttereEtiti.-i. I have been in o*lWp
nrsi :; oi' the n&t*t where the t.*!a.$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 Tearn 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
urge1 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 0
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, Wv 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
aLay5\eerVi\-Lr'0t * *»»«*«• ?»« pinions, which has
££**;!• »2 -"--- - 5 nay' but l!: is a c°^°^^ With stron3
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 LL.Af!D Sal*«"CNT
Hob Ross
Bt.M Traam Leader
P 0 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 Leader
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 uplifted 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, I99ri
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*\
Andy 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 RESOURCE 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 hard 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. 0
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 people 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.
,r261
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
WMvvuj, &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 AUM1
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 "Yellowstone EcQsyflejn?'' 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
hearts (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 , 0 , 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 and 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 ieaaear 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-
RECEIVED
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
WARRANTED 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
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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/a11 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 ■Je
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 SQ3C 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 0 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 alan.
I believe the BLM has performed a good jnb in developing the EIE
There wili 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 0f
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 gr5Zing 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.
The 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'
0
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.
7Jlease advise me with respect to further developments in reaard
to the management plan.
Jack Van Baal en
389
MAY- 3885
»™ll^&^kB£ea0Draft 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; 1Jf^lrf 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%helP 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 maM9ed animal production to
LjfKff to jhe Jda," 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 hS"r?aCh Dlh3turb>"== 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°?ie.-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^eft,t°. the si9^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 """""Vaa-laak 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 stopped! 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 Off-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 BOX 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 ranainR 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! nsl 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 recognise 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^thac will help indicate what the desired,
future condition" should be for the area in Question. Base specific standards
on what Is necessary. to achieve tha dosirea1 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 consideration 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 natura 1 ly . " - y$l
Moderate sensitivity: Allow no -more than 25<k .streajrbank-dlsturbance above' ' '^~u
what occurs naturally. . """* ' ~~;
Low sensitivity: ■ Allow no mora than frO» atrearobank disturbance above, what
occurs naturally.
STUBBLE HEIGHT: The height of standing herbaesoua vegetation remaining v^bQH- «r
the flood plain at the end of the livestock (trajOaB ■e.nnr* "r rwtF season. ;
wbiohayer 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 sensitivity: 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 Improvement
ia the condition of woody vegetation, and ponr condition 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 rendition 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 any an? -of r>1» ">"""■ ■"•tfnT^ \j, reached. Hormal.ly, one of the above
criteria will -surface, na. the determining factor for allowable use in each'
pasture or allotment,.
factors mc -utilize
-Che 5BBT
:'be attained 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 towards- "ofejacclves, ■ you 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!. ■ _.,- /
*fE.;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 0 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 ur 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 econotrii332ct2
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 ilJ
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
forage production, and biological 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 impri
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?
Spring 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
iUed :
%^..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*rl0t«,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 administered 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 vcn- 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 0 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»gu« 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'7Sfa7b34r
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 lw""»gjaD.saMt»""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 altamaLive 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.veiop!r£nt:a. M indlMtJ rSST^S if "he
SautZ S4ctB="S^cIiiSon^p01' llvesto<* «*«*«■ -« tta
a ='"=>-(- on cne local economy, we suqqest the Bun ye
S'u".^^10™ "* not decrsKe the S-* 3"aS5iS us.
Sincerely,
SiS3y 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
MaV 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.
Terrestrial 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 able1
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
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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 Natural History Resources
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- - Rights-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 Ne s ting Habitat
Page 61 - DPC Objectives 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 Management Areas
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 Resources
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.
vegetation, 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 273 - 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.
page 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.
Page 2 9 9 - Ref e rences
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 WYOMING59,8
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
5r^££r."uss ftttsartasl,s
dp.troteUmUrAssCo°or.e"o"10onf %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 Strategic Plan lor Wyoming's Aon cultural Industry 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'f1, 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 restncted 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 are 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 feed 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 multiple 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. fencing 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 SlMtWC r|;ir. IW U vnmm.;':. Agricultural 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, pafie 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,sh 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 moiK 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 Chi 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 l7* 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
0 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
a2-3urfacu 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 . Road building in probably 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 tactr 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. Page 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. Page 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. Page 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. Page 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. Page 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. Page 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 Management, 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.
Page. 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.
Page 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. Pages 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. Concern, 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. Riparian 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. Pagc215, 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. Pages 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 0 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 uBe 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^ve 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 wrcmwc 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 lftV*1 where Meal people have n eay instead of M.p
Oraet White Father'' in Washington *hn doesn't understand local
probl ems.
^oJ^JrAJlf ^
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 sectn
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
Wor1. 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 Wms.
(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 undisturbed, 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 Resource Area Resource Manngcrr.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 double 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
WLtxn Tiwfeb ROSS '
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 |
■■ Thi? foffKSf&flSKliUiitp.ftsk'iii Plan would sevwaih unpaci fa im basr of fbuj counties Bik Hc-ru. Hot Spring1:, 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 BaaBfl 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.. ,
:^rY7m^<—
R I C E I V S 0
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,
toBiwiaofiamlMwiiiimirol 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 „„, 0f f0„, „,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«»ds
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 stnie, 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 0 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^fftfiiss2'1— ...
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.
There 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 nave
private lands.
-^s^=^'S^^ = P-
the resource.
you 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 '^"'™ slJpcrViSing 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 RESOURCE 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 has already decided to lease the entire resource 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 the points raised in the letters-, 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 proven 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
WYOMING
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. Seo 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 stands1
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) socioeconomic 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 rmilHpifi 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 Washakie Resource
Management KaiuEnal. EIS at 3. Similarly, the entire Great Divide Resource Area is
available for oil and gas leasing. Great Divide Resource Ares J&aaase^togamaat
Plan Final 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.
Lander Baaouisa Arpfl Bflaausa ManaggmejaLJaaa 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 require 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 with FLPMA
500,20
a ) The Rl.M can achieve FLPMA' s muj;iplp 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, Regulations.^ Planning and Environmental Analysis 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 Resources
a) Wetlands 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 0 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 unt mrj this plan cnul d
n*ve and sr.ould havs been spent out un the ground actually rto^ng
thinqs to iifiprDvc the r_»nyt» and '.lean up the environment. Then
look rit the man hours _-a_t_d by the ELM staff sp-nt fging to
justify the 3B0 pages uf da-a and all the time spent by all of
the public trying to decipher _.'i_.t it rea 1 1 ij =i.ays and what you
are really trying to accomp i ish . No doubt at ter it is final ued
wo uiill eOflttnua to fight and _s_t_ time ana other rMOurcM
trying to determine i_n_U it says and if it is legal.
2) Ihe_IMyltiple_yse_Cgntgpt^._.gf_gubli^
trashed by this dacLiment^ The commDCity users of the land are net
given anywhere near ecual footinc mi Hi other user-:;, i.e.
wildlife, recreation o;- just no use. Priority use*> ha-ze boon
established BucH b-s "Wild Horse Areac", "Critical elk wintering
range*, "Area of Critical EnvironmRntal Concern", 'Hioarian
i!abit_t". "Nc Ro*d Areas' and others. These oriority uses «re not
acequ^itely defined or proven to C-e justified but if su designated
i t moans commoditi£s_rtigve_oy5r_oi- oli t . Bei ng in the Re„l Eotavt?
and retail business as well as. ranching in Hot Springs County I
kntMu uur economy js very fraqile. Minor economic impact as is
expressed In the plan may turn out to not be minor. Many smell
business *■¥■• ,iust barely in the black, just a ^ma] 1 decrease in
gt"08B rw venues puts them in the red and oven tu_tl ly out of
_UStln»»*. Tho ripple effect then starts and more and more
businesses r*] 3 by the- ways i de»« Then ta^ base and jobs are los t .
"any ranches such as mine cannot continue to operate if your goal
cf 25X -.-eduction in nrari-g use is yven partially attained,
unreasonable restrictions on the Oil and Gas industry will cause
unnecessary economic nardsrip m the *> counties and tSe state.
502.2
3) WildI^fe_and_livestock_haye_cg-eKist— _-----— We
do not need to eliminate one to promote the other. There ia more
game in the Owl Creek Area than at anytime during the 47 years I
have lived here. Much of the increase can be contributed to
increased feed production on the ranchers private 1-ands. When the
Game and Fish personnel came to the landowners and permittees
with the idea of reintroducing Mountain Sheep we were assured
that there would be no conflict with livestocV grazing, but now
we hear a different tune. NO SHEEP and REDUCED UTILIZATION BV
CATTLE. It's, not honest it's not fair and it's not necessary.
Mountain Sheep can flourish with cattle and domestic ^heep.
**' tJH^H— °t_*tig__l_ta .used *" the document has questionable
accur acy_and_i n t er p_r gt s£i.orj . Ex amp 1 es : Table 3-5 appen d i X 3 has
calculations of suitable AUM's that were not allowed in previous
resource management plans. Table 3-3 appendix 3 dealing with
actual livestock grazing use has many errors as well as
indicating that the only reason for previous non-use is because
the range would not support the permitted use. Table 3-2
categorization is arbitrary and in many cases inaccurate. Map A
vegetation t page 2371 i<; not accurate.
BCMllfclMl a Justification for almost any decision made can be
found somewhere in the plan. In ttie wrong manager's hands, very
general goals combined with less than factual data sure looks
like disaster for the commodity users of the public land's.
Last but surely not least in my mind is the control of my
private land's being lost through tighter and more inflexible
plans and administration of my grazing permits. Even though
federal land use only accounts for 207. to 237. of allotted grazing
use 10GHE control is imposed by the agency in the name of
conservation and the public good. This has been the direction
taken in all plans and changes made for 30 some gears. I really
believe my vote and opinion, because of my 40 years of ranching
and range management experience plus 727. to 807. ownership of my
grazing permiLi, should be more heavily weighted than the opinion
of some J-hn Dn- from KokDmo that has very limited knowledge of
the situation but that wants to be a do gooder.
u.jnmi -- CcuaflxuMi
MAY - 9 1996
503
C.A. BtBHNEfi 3ANCH
BOX 336
MEETEETSE, WYOMING 62433
Mr. Bob Ross, Team Leader
Bureau of Land Management
worland District Office
P.O. Box 119
Worland, Wyoming 82401-0119
RE:
Grass Creek Resource Area Management Plan DEIS comments
As s permittee in the Grass Creek Resource Area., I wish to make
the following comments on the DEIS and in effort to impress upon
you the fact that you have not provided, viable alternatives under
the grazing management section and do not provide adequate
just if .cation lor the alternatives. Much of the text is vague and
therefore left open to interpretation. This is dangerous.
For example , on page 37 under Livestock Grazing Management you
state: "Authorized livestock grazing preference may be reduced m
«reas with excessive soil erosion, poor vegetative condition, or as
necessary to provide forage for wildlife and wild horses, or tc
improve the visual quality cf lands with high recreational value."
What is excessive erosion? What is "poor" vegetative condition?
How much wildlife and how many wild horses? Grazing is taking
second seat to recreational value - this is not acceptable. Why
are you closing land tracts along the Bighorn River to livestock
grazing?
The proposed ac_u for the Fi_te*nmllfl Creek watershed is creating
defacto wildernass; areas that severely limits commodity use. Why?
Have you dona a cost/benetit ratio on this proposal? If appears Lo
us that you believe that you can play "God" with the proposed
alternatives. The geological make-up of the soils in this area are
such that the natural erosion that Will take place cannot be
stopped. It may be slewed down; but, in lealxLy, this area will
never be a grassland- even if you. eliminated every cow qrazinq on
the allotments, why are you so interested in protecting the "wild
horses", when they are not truly wild horses? How many acres to
they need and at what cost to our local economy?
The conditions for fire management need to be defined. It appears
the present plan is based on a 1600 year burn cycle, a fifty year
cycle would be much more appropriate. Wa are already 100 years
into the cycle. For example, the critical oik habitat aroa on
Rnost^r CreRk is completely overrun with large sagebrush and shrubs
and needs to be burned now.
459
(2)
503.2
On page 264 oi the PETS in reference to Che 0C626 Timber Creek
al lotmsnt you state "the permittee toolt a 59 percent reduction in
grazing preference" . This is correct, we die the permittee, and
the fact is that the reduction was taken under d'jress and we still
do not agree with these terms.
we disagree with taking "1990" as the base year. A much better
approach would have been to take a ten year average to establish
the base. What is so special about 1990?
You have not ident if led th« benef i ts of 1 ivestock grazing on the
public land in the DEIS. Cutting AUMs on uncertain quantitative
data outlined in the DEIS will not benefit the custom and culture
and economic base of the area. ¥ou allow no flexibility in
managing thocc areas . This is not. a black and white issue - you
muat look at the long range on an individual basis, taking into
account the climate (which is not controllable even by the 3LM) in
a particular year.
Throughout the document you are placing a greater emphasis on
recreation and wildlife than grazing, How much income do these
uses bring to the federal government? w« are not against wildlife
and recreation but there needs to be a balance. The BLM does not
recognize Lhe split estate that the permittees have in the
allotments even though the IRS has seen it appropr iate to assess
•state taxes on them. When you reduce AUMs you are reducing our
ability to make a living and this is a taking of our property and
civil rights without just compensation.
Sincerely,
Chris Banner. Vice President
C.A. Renner Ranch
RECEIVED
MAY - 9 I
504
BUREAU OF UNO IWNflGCMEHr ;
GOULD RANCH COMPANY
123 PITCHFORK ROAD
MEETEETSE, WYOMING 82-*>33
MAY 5, 1995
Mr . Bob Ross
Team i eader
P.G. Pox 119
worland. Wyoming 82401 -Oil*?
RE: GRASS CREEK RESOURCE AREA RESOURCE MANAGEMENT PLAN
DRAFT ENVIRONMENTAL IMPACT STATEMENT
C0MM6NT8 CONCERNING ALLCTIMEKTS 0564, 2*10, AND 2511
hap A: wgi reeweet that all three of the above aJ lotments be
removed from full suppress! an urea.
Map 11 : Limits on Surface Di st urbane©
fiOuld Bench Company requests that no timing limitation be
placed on this three allotments .
Map lb; Off Road vehicle Management
we request ORV use be waved for the on-going ranch
nar.age1r.2nt needs.
Mas 22: Precipitation Zones
■ he thres allotments must be included i
precipitation zone, because actual data
the 10-M
clearly shows this
'able.' 3 p. Lgfe; Activities Affecting Soils Estimated Acres
and Durations of Disturbance
Goulo Ranch Co. takes exception with ,3 ton of soil Joss per
acre due M J J ven racK grazing. We strongly assert, tnat
planned biological livestock grazing builds soil ratner than
causing scil erosion.
.-[■:-■
127: soil Productivity, paragraph ? states,
iCUltural soils, there are few opportunities to
"Unlike
imo-ove the oroductivity of rangeland soils through
Lof ] fertilizers. "
Ihis is •> blatantly false and unprnven statement . Livestock
fed a commercially preoarcd free choice salection of
minerals will consumes minerals which are deficient in the
soil and plant*. Through urination and dunging, 50* of the
iac-King minerals consumed are deposited. Balancing
herbivore*' mineral needs, the sail becomes renewed and
balanced, Holisticelly, all resources will benefit from a
vigorous mineral cycle.
Table 10 p, j.29:.
L-lassif ication o
There's a
Iron CreeK
■adtctlon between The dec's
tn« Wyoming Game and F- 1st-
504.2
classification of Iron Creek. Wyoming Gams and Pish
classification of Iron Creek being a class s is more
accurate than the class 2 stated by DEQ.
Ra nge land Veqeta t i p n . p , 152 : The term preferred species
("Key species') should not be used in the CSrass Creek
Resource Area's management decisions. All manage me re-
direction must bra through the DPC concept obtained by a
well-thought out goal with the DPC having the ability to
propagate the site specific area through on-ground evidence.
Reference to Ecoloqica 1 Condition Classes
Throughout the document . ecologies J condition classes should
be omitted due to current scientific evidence from the
University of Wyomi ng , among many, which negates the
Clamant Ian theory. Therefore, Table 12 anoula be removed.
wild Morses p. 159
Because of the undes irable effect from wild horses upon the*
resource area, the wild horse herd should be removed from
this area. There is-, a true wild horse herd descendant from
the Spanish horse living in the Prior Mountains, which will
satisfy the public view for actual wild horses.
wild Lite Big Game p. 139
In this first paragraph, the 'limiting factor" is not more
haoi tat , but the proper management of the species . 1 ndsed.
The most valuable and unnamed habi tat for wildlife is
private property, where wildlife find abundant water and a
more palatable forage.
Map 31: Big Horn Sheep & Pron<ihoni Antelope Habitat
Allotments 0564, 2510. & 2511 must be removed from the
Pronghorn Crucial winter range, because they simple do not
winter- i n these a 1 lotments .
fao 32; £lk Habitat
Cr ucial winter range- designated In Township <J8. Range 100
West should be removed, because it in not crucial .
Mup „T.tf; Mule Deer habitat
tiori of Allotments 056-3 & 2310 as c
Tt mule deer must fie removed, t\ecau
this Brett at any time of thet ysftr.
eftMr/" don ' t
Habitat & Co
l-.ap 55 ; Sage G
Gould Ranch Co. would be "willing to work with the 3lM to
enhance the strutting grounds and the breeding and nesting
habitat designated in t-is R10QW .
Northern RocKy Mountain Gr^yWoIt p. ] £-Q
Why csn r one bureaucracy communica te. fftc.tr. with enother?
It behoov&s us thst the Grey Wolf mxfetS in the Grass: Cree
ffpscurce nrea upon the evidence of this document, while
504.3
.inather frdrr#l agpney spends mi J J J one "reintroducing " the
Grey Wolf. This is highly frustrating to taxpayers with a
novernme-nt in Chapter u condition. To rut> our fnc.es in jC,
the document states how the. wildlife is QOSn® to hs food for
the Grey Wolf.
Pro&oaed Ar«?as of critical Environmental concer
151
We strongly object to the Fifteen Mile watershed proposed
ACEC. If a problem exists, it should be handled through
Public _«w 566 and Wyoming Statutes pertaining to watershed
management .
r?a rwe I a nd Veget a t ion p . 196
Gould Ranch Co. suggests different classes of livestock be a
viable option in control 1 ing noxious weeds .
Soc iue
.1.93
it s ludicrous that such a tiny portion of this document is
devoted to the social and economical factors. The poop le
who live here depend upon the economic out-put from the
federal lands for their well-being. For- example, the
MOOteetse Area i s S6% dependent upon the oil and gas
production. Clearly, if this 'management plan" is
i mo 1 erne n tec , our custom and culture will be destroyed .
Great chunks of the agricultural and oil * gas industries
will be gone along with thai- tax bases which support
nearly everything conceivaoLe in our area.
. 1 v.
ck Grazing p ,. J. 89
L imi ti ng f i re due to sage grouse is backward, si nee sage
grouse don" t care for old , decadent sage. Strong evidence
i ndi cares that the major decline of sage grouse in the West
is due to the massivn increase of old, decedent sage brush
communities. Limiting fire or other brush control methods
h1 i mi nates a necessary tool to enhance sage grouse habi tat .
Sage grouse chicks eat succulent, young and tender forbs and
grasses . therefore burning can i ncrease and improve sage
grouse nabi ts t .
Appendix 3 o. 23 S : Components of the Livestock Grazi ng
Management Program
Section 3 of PuhJic Ranc/s-Jand Impr
iricl ud£>d in this seatioh.
vem&nt act
fable 3-2 p. 25S:
Allotment
Authorised Gr
i n<j Use Information b-/
Active preference AUM's on Little Buffalo Basin Allotment
0564 should oe raised to incl ude the 63 suspended AUM's.
which were suspended for oil and gas activity. Observation
through the years has demonstrated that a wel I site or road
has created significantly more forage than the natural
community might have Produced. "nis, is, due to the fact of
water run-off and more heat from the wel 1 si te or roao
enabl i ng border i ng koch ia and ether highly product i we
460
504.4
species Co produce large amounts of high ly pa I a tab 1 e and
nutritious foraqe. ("he disturbance of the oil and gas
'ields, has increased the pounds of production way beyond the
suspended 6S AUM's.
• ,-i i-.- ; e
_l^:.j^
J ■'■■:--'
Allotment" 7r:.10: The r>eleccive Management Category in thio
al lotment should be changed f rom I to M category , because ©
the large quanti ty and qual i ty of establ ished range
improvements, the planned biological grazing program
Utilized by Gould Ranch Co . , and future planned
improvements. intensive monitoring obviously reveals that,
trend and other indicators of range health prove that this
allotment no longer belongs i r> I category .
Table 3-3 Appendix A
Ave-rnqe qr. rrua 1 fia^i ng Use by Al lotment Season of Use for
Al lotment OS 64 needs to be open to better suit planned
biological gazi tig and wea Cher conditions.
The col ijinri desf gnati ng actus 1 use for the 5 -year per iod of
1987-91 le of no value, because we experienced the most
severe drought ever recorded for this area. The same reaso
is. true for the next two columns.
1 abi e 3-3 Average Actual Gaz i ng Use by All oinant
Al lotment: 07 SI Or T he season of use should ">e open due to
Gould Ranch Co. '3 planned biological grazing and weather
condi ti one .
Average actual use for the five year period from 198 7-9.1 wa
the the most severe drought recorded for this ares. The
same reason applies to the following two columns.
The footnote at the bottom of this table indicates the ELM
haul no data to support any numbers, therefore there should
be no numbers in any of the deaiynatea column*.
table 5— q Appendix 3 Eco logical Condi tior Class and Ac
■i^:
of Public Land by Allotment
Al lotment 05&4: Data presented in this table is inaccurate.
The reading by the BLM of the east trend transect in 1,992
showed the majority of the pasture to be in "excel lent"
condition,, which iff. not reflected in the table, that 1 istsi
the condition as "good".
A] ] otnient a.la.10; The most recent, readi ng of the al lotment I n
1992 shows, the Grass Creek Resource Area document is
erroneous from the actual data col lee ted by the BLM _
Table 3- a Comparison of Stocki rig Levels . Actual Use, and
SuitaOi lity by Al lotment
A 1 i d ment Liioi : Recommendec stock: ng levels as presented in
column C is faulty because the data used to arrive at the
504.5
conclusion is not the most recent arid accurate data
available (1992). The 1992 data clearly indicates this
allotment is capable of supporting the grazing preference of
6 25 AUM "ti . This document ' s data, which ceased in 1990 Of
before is contrary to the 1992 data.
Table 8 Status Report of Completed allotment Flan
Implementation Allotment:-. Qjo-1 * 2blG
An AMP was. signed by Gould Ranch Co. in 1985, but an updated
evaluation of that was signed in 1992, which contains new
management methods as well as new goais. The Grass Creek
C)£ IS states the trends were upward in some, but not all
areas. A clearer statement should be that the trends are
upward in the majority of these allotments, but in the
remaining places the trends are static due to climax sage
brush domi. hated communities. This condi t ion was predicted
by a technology team from the U. of Wyo. and the BLM in
1935. That report is on file with the- BLM.
Gould Ranch Co. requests the final Grass Creek ftrftS
Management Plan state the suspended and voluntary non-use
ftUH*9 be restored to the allotments referred to in this
letter.
sincerely,
James F. Gould
Secretary
cc; Wyoming Congressional Delegation
Governor Geringer
Park County Legislative Delegation
Park County Commissioners
505
TO ELM C/0 Dob Ross
Grass Creek Area Draft ETS
?.0 Box 119
Worland Wy 82401-0119
Fax (307) 347-6195
I object to the significant financial impacLs 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
comment s be lew .
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.
1 object to the expansion of "Wild Horse Management" areas. I
recoTmend 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.
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 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 lc 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 in all of the alternatives . Not enough
emphasis has bean placed on new technology and new information to
mitigate and reclaim any impacts.
I objec!
against
to the hi as for recreation di.
minerals, grazing and recreation.
turbance and the bias
I object to the proposed blanket restrictions contained in Off -Road
Vehicle Management .
505.2
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.
Z 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.
461
Mr. Bub HOSSi Team' Leader
BlltTMU of Land Management
worland District office
P.O. Box 119
Worland, wy 82401-0119
- 9 1995
soe
RE:
creek Flea
Fit Plan-DEIS
Dear Mr. Ross:
The Graas Creek Resource Area Management Plan Draft Enviromenta.1
Impact Statement is a very unique and interesting document . I
wonder haw many people and hours went into developing this
document - It is also interesting to read such statement.':.
as the Acting State Director, Robert A. Eennet made in his
Opening letter, "This Draft Environmental Impact Statement
for the Grass Creek. Resource Management Plan outlines four
alternatives for managing the public lands and resources in
the Grass Creek Resource Area of the Bureau o± Land Management."
"Thess alternatives are designed to resolve resource management
issues that were identified with public involvement during
the planning process. This document al«a describes the anticipated
environmental consequences of implementing each alternative. "
I aeknoweledge that the mission of the document is to maintain,
enhance and give direction to the multiple uses of federal
lands in the resource area.
I find it somewhat difficult to support the proposed plan
when there is so much of it that appears to be very biased
toward one facet of multiple use and that is wildlife. Specific
concerns have been discussed on a number oE occasions with
you and your staff and at Che various public meetings and
hearings , however I would like to 'add the following:
1. Acting Director sennet states there are four alternatives
when in fact there is about 71% of the alternatives that
read "Same 'as Preferred." This does not in fact provide
and alternative if everything is the same!
2. The document provides only minimal information of the
economic impact that the Preferred Alternatives vill have
one. the entire resource area. It does not provide information
of how many livestock users will be. put out cf business
by the reductions proposed of 25%- 35%.
3. The number of contradictory statements that the document
contains is very discerning, such' as "No coal is currently
mined or leased on BLM-adniniat,ered public lands in the
planning area.," (page 114) and yet "Coal production totaled
100,000 short tons in 1990, raising the area's economic
activity by over $1.74 million that year. It also supported
about eleven full time area jobs. BLM-admini stored mineral
estate lands accounted for approximately one-half of this'
coal .production and the resulting economic impact." {page
123). When in fact tha only, producing coal min» in th*
ares at that time was a privately owned mine on private
lands.
506.2
"In gen
plannni
and wil
alone a
trend -
would
lands,
rate d
as acti
page 19
sums, p
130,926
sums .
the amp
livest
eral , reaour
ng area, in
"life habit
d are not
hat they c
arrant elim
(page 13)
ring the an
vity plans
i indicate
eferred al
**um3, 2 2
To me thi
ck
in a
nnot
ina ti
Graz
aly3i
are i
the
erna
llotm
infer
the n
azing .
iditions on p
ig range vege
I not the res
itate of such
!« maintained
in of livesto
.ng use would
: period, rea
lplemented. " {
total author
;ive 117,762
;nta without
lation certai
>xt U years
iblic lands in the
;ation, watershed,
ilt of livestock g
poor conditon. or
or enhanced or th
:k grazing on the
be adjusted at a
:hing anticipated
>agel60) . Table 1
.zed gracing og 15
lums, actual use
.nventory data 15
ily indicates that
.s to reduce and e
olic
nstant
990
392
4. The oil & gas industry provides the majority of revenues
to this resource area and the pro^oaed No Surface Occupancy
or Controlled Surface Uses will have a significant economic
impact to the communities and individuals within the area.
It seems to mc that these designations are not necessary
when you cover these issues in your present lease agreements.
There must be flexibility or there willnotbe further development
the
ea .
5. The wild horse land expansion proposals should be removed.
Why is the herd being expanded from the 1989 levels? It
appears that you are taking the easy way out for managing
the herd and that is by expanding the herd area. The problem
identified in th EIS are similar to those of the present
livestock permittee and they do not have the option of
expanding their land area to accomodate their livestock.
The horses can be managed without the expansion if the
effort is put forth. It is not of a cost benefit to build
a road into that area for the limited viewing that would
take place and there would in fact be a greater expense
and potential for land abuse if the entire road was not
fencad and monitered to ensure there was no off road travel
taking Dlace - The area as described is an area of critical
environmental concern and has soils that are highly erodibJe.
Consideration should be given to remove the horses from
this atea to an area that already has roadways available
such as the McCullogh Peaks.
6 Comments regarding the Northern Rocky Mountain Grey
Wolf should be eliminated from the plan as this area ha.s
notbeen designated a part of the wolf recovery area. In
fact there should be a predator control plan written and
included -in the EIS that not only considers the wolf but
all other predators as well .
7 It is recommended that your fire limitations of 500
acres per year be reviewed and expanded as this is one
of the best range treatment tools available for not only
livestock grazing- but for wildlife and range conditions.
506.3
6- The timber management plan needs extensive revision
and consideration for the timbering og the 86% mature foresL
be harvested rather than just letting the timber rot or
develop itself for a major fire and destruction of the
usable timber. Selective cutting will provide the removal
of usable trees and wildlife habitat.
9. Off Redd Vehicle management needs more clearly defined
designations along with a specific program for enforcemenr
of violations. The areas of the Ab3aroka Foot hi 1 Is appear
to need additional limitations for the use of off road
v seniles ■ particular ily the " 4 wheelers . "
10. I cannot determin from the EIS why there is such a
need to declare so much of the resource area as an Area
of Critical Environmental Concer n . This seems to cake
on the connotation of expanding nr developing more wilderness
me that the EIS does not provide a
o the multiple users, the governmental
e3 in the resource area and the public
re there are a number of changes that
ed and incorporated into this BIS prior
ed for final approval, I believe you
recommendations , particular ily from
commissions in the resource area, individual
n or the Worland State Gracing Board ,
11 provide a more balanced and acceptable
plan for all concerned. Please accept these comments for
consideration into a modified plan for th resource area .
i t appears to
ed approach t
es, communiti
hole , theref o
o be consider
being submitt
eceived many
nous county
tees, chairma
f accepted wi
es E Hillberry
ividually and tor
MAY - 9 1995
507
John R. Cuhbon
■itAUOf UHnMANAGFi;;:
bureau of Ijind Management
C/0 Mr. Rob Ross
Worland. WY S24Q1
Dear Mr Ross;
I have reviewed the Grass Creek Area Resource Management Plan Draft Environmental Impact
Statement and have the following concerns and suggestions for your consideration.
1. I am strongly opposed lo expanding the "wild horse" management areas. In fact, these
"wild horses" are not native species to Wyoming and should not be treated as though they
need protection. In contrast, (he current "wild horse" {or more correctly; "offspring uf once
tame horses") management area should be totally eliminated.
. 2, I am strongly opposed to further restriction to surface me on these lands. Current
environmental laws, historic preservation laws, game laws, etc, already adequately protect the
lands. Further and redundant regulations are not needed.
3. The value that is placed on recreation is much too high in the Draft EIS. The people of the
State of Wyoming depend on those lands not only for recreation, but for ta livelihood as well.
1 should remind you that the BLM is only the sreward (or administrator) of these lands and
should view the opinions of the people who live near these lands and who depend on them for
their livelihood as more important dian of those who live in other pans of the country and do
not have to deal on a daily basis with the regulations that are put on these lands.
4. Timber Harvesting, Mineral Extraction, and Ranching are not given fair consideration in die
Draft EIS. These industries provide much of die tax base in Wyoming and the economic
imptici to these industries have not been given ample consideration.
5. 1 strongly object to the use of my tax dollars to build "interpretive sites" and "Nature Trails".
This type of development on these lands will not attract additional tourism in this area. These
types of projects arc "nice" in some areas but are not need in the Grass Creek Area.
462
507.2
In summary, it appears that the BLM is trying to force the radical environmental ist view of how
these lands should be managed (or not managed) on the people of Wyoming without, regard or
concern for the impact that further regulation of these lands will have on our economy,
livelihood, and lifestyle. Instead, the BLM should work with the people of Wyoming to alleviate
unnecessary regulatory burdens and to promote development of our natural resources in a
reasonable and responsible manner. I personally enjoy the use of BLM administered lands and
am grateful that these lands arc open to the use of all Americans. However. I do believe that the
radical threats to the lifestyle of the people of Wyoming that are outlined in the Draft EIS will
strengthen the "states rights" movement and will result in the eventual administration of these
lands by the state (of which I would strongly support).
I strorjgly encourage you to meet with the Timber, Mineral and Mining, Ranching, and
Wyoming Tourism industries prior to implementing any new restrictions on this area. Please
remember, the commission of the BLM is to manage the land under it's administration, not to
dictate and recommend how it should be used; that job must be left up to the state.
Sincerely,
e
John R. Cubbon
cc: Governor Gerringcr
County Commissioners
r£ceived"
I MAY -9 1995
508
May 2, 1995
BLM
C/0 Bob Ross
Grass Creek Area Draft EiS
P.O. BOX 119
Worland, WY 82401-0119
Fax (307) 347-5195
Mr. Ross:
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
gas and minerals industry, timber and local and state governments.
I appreciate the opportunity to contribute to the 'jery 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 "Wile 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 to the data collection procedures cited for AUM utilization, and
suitability, This should be completely redone.
I object Lo 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. Especial 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 generate income and
support our communities through taxes.
508.2
Mr. Bob Ross
May 2, 199S
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, grazing 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 businesses should also
be factored in.
I object to the lack of detailed descriptions For restrictions.
] object to the discussion of threatened, endangered and candidate wildlife
species, specifically unsubstantiated Gray Wolf inferences, and Prairie dog,
Black-Footed Ferret inferences.
RE C E I V E D
MAY -9 1995 I
BWtAU m LAND vfiffiSw. •
509
Richard D, Ro sencrans
May3^^95
BLM C/0 Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy B2401-0119
I appreciate the opportunity to contribute to the v&ry important
Grass Creek Area Environmental Impact Statement. Please find my
comments below.
I object to the BLM's noncompliance with its own rules on the DEIS
process with regards to accepting form letter comments.
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 individualsand
representatives from grazing, -ecreation, oil and gas and minerals
industry, timber and local and state governments. Beneficial impacts
of businesses should also De considered,
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.
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 of restrictions on Surface
Disturbance in all of the alternatives. Not enough emphasis has been
placed on new technology, successes and cooperation of various industry
groups, and new methods of mitigating and reclaiming any impacts.
1 object to the bias for recreation disturbance and the bias
against minerals and grazing.
1 object to the proposed blanket restrictions contained in Off-Road
Vehicle Management. I object to the higher standards to which specific
industry groups are held compared to government and the general public.
463
Monica L. Rosencrans
RECEIVED
~~n
MAY - 9 1995
WJ«W(J OP tANB H#fH!rP(
sm
BLH C/O Bob Ross
Grass Creek Area Draft FIS
P.O Box 319
WorUnd Wy 82401-0119
I appreciate the opportunity to contribute to the very important
Grass Creek Area Frwironmental Impact Statement. Please find my
comments below.
I object to the BLM's noncompliance with Its own rules on the DEIS
process with regards to accepting form letter comments.
1 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 cummunity individuals and
representatives from grazing, recreation, ail and gas and minerals
industry, timber and local and state governments. Beneficial impacts
of businesses should also be considered.
1 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 BLH 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 of restrictions on Surface
Disturbance in all of the alternatives. Not enough emphasis has been
placed on new technology, successes and cooperation of various industry
groups, and new methods of mitigating and reclaiming 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 Off-Road
Vehicle Management. I object to the higher standards to which specific
industry groups are held compared to government and the general public.
Sincerely,
n *'i ■
Monica L. Rosencrans
fwsW-—fc*»-*-
RECEIVED
MAY - 9 1995
^UUf UNO HANAfiEUFH
rn
William P. Zogg
May 2, 1995
Bureau of Land Management;
c/o Mr. sob Ross
Grass Creek Area Draft BIS
P.O. box 119
Worland, Wyoming 82401-0119
Dear Mr. Ross :
I have reviewed the draft EIS recently prepared for the Grass Crock
Area and am troubled by a number of proposed changes included in
the document. 0£>vi ausly I have read certain portions more
carefully than others but the following should summarize my
concerns and objections to the document in its present form.
cause significant
individuals alike,
e undo hardship on
to provide needed
police protection,
alternatives and
created with input
sentativas of the
gas and minerals
1 ) All of the proposed al ternatives will
detrimental financial impact to businesses and
This in turn will erode the tax base and caus
communities and counties already hard pressed
services (education, social services, fire and
etc. ) . Therefore, I object to the current
recommend that a new preferred alternative be
f torn knowledgeable citizens as well as repre
affected groups (grazing, recreation, oil/
industry, timber and local governments) .
2} I recommend eliminating all "Wild Horse Management" areas in the
Grass Creek area RMI1, not the expansion of such areas, wild animal
management should be controlled by the State Game and Fish and
managed animal production by the private sector. Feral horses were
not part of the original wild animal population and thus should not
be treated as a protected element. While there may be room for
some wild horses, the herds should be. severely restricted.
3) The current document does not discuss or take into consideration
the impacts to the value of private, state and county lands
adjacent to or embedded within blm administered lands. This, in
effect, results in a "takings" which must not be allowed.
4 ) fill of the alternatives propos
restrictions on surface di sturbance.
been placed on new technology and ne-
and reclaiming any impacts . There i
bias for recreation disturbance vei
forms of economic activity.
unduly severe levels of
insufficient emphasis has
ew information for mitigating
is also a clear and definite
us minerals, grazing and other
Thank .you,
william D.-Zogcj
RECEIVED
512
Matthew J. Kintzele
May 2, 1995
blm c/O Bob Robs
Grass Creek Area Draft EIS
F.O Box 119
Worland Wy 92403-0119
Fax (307] 347-6195
I appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement . I hope someone
has the opportunity to read and consider my comments below in
detail .
I would first like to object to the significant financial impacts
to businesses, individuals (and the resulting negative effect on
the tax base) , and the effected counties and communities due Lo
restrictions proposed within all of the current alternatives, and
recommend that a new preferred alternative be created with the help
at knowledgeable community individuals and representatives from
grazing, recreation, oil and gas and minerals industry, timber and
local and state governments . These entities have been all but left
out of the procesB and should be included due to the enormous
impact this statement could have on the industry and communities
(due to possible substantial tax base losses) .
I also find it hard to agree with the expansion of "Wild Horse
Management" areas. I recommend eliminating all "Wild Horse
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 the Private sector. The Federal
Government has proved time and again its inability to manage
effectively and efficiently.
I also disagree to the reduction of Crazing A'JMs proposed in the
Alternatives. Real, current scientific data should be used to make
management decisions on all allotments. Targets should be clearly
established and stated. The data collection procedures cited for
AUM utilization, and suitability should be redone entirely.
Proposed restrictions hamper Lhe current, primary businesses and
individuals who use federally administered lands to generate income
and support our communities through taxes. These restrictions are
not necessary and only show the true character of the radical
attitudes that were expressed in the study.
i object to the severe and undue number and leve!
on Surface Disturbance in all of the alternati^
emphasis has been placed on new technology and new information to
restrictions
Not enough
512.2
mitigate and reclaim any impacts.
I object to Lhe bias for recreation disturbance and the bias
against minerals, grazing and recreation. The statement must have
beer, written by radical environmentalist that have no understanding
of effecto on the surrounding communities. Other voices must be
allowed to have input on the statement . Industry is willing uo
work out possible problems and come to reasonable compromises .
Governmental agencies and environmentalist need to understand that
they must work with industry to come to reasonable solutions, not
work against industry and development at all costs.
I object to che proposed blanket restrictions contained in Cff-Rcad
Vehicle Management and to the small amount of land considered for
suburban expansion and 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 BT..M Administered
lands .
I object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog. Black -Footed Ferret inferences.
Radical environmentalist have wasted enough of our hard earned tax
dollars, and cause huge unmeasurable industry losses to save
species that are not truly endangered, or a species that can and
have adapted to changes in their environment. More value should be
given to the human race ■
In conclusion I would like to once again object to the small
consideration given to the economic impacts to businesses and alao
tax bases . Beneficial impacts of businesses should be factored
into Lhe study. Thank you for thie opportunity for input on this
subject .
464
RECEIVED
HW-
513
crass CreeK Area Draft SIS
?.0 Box 119
norland wy 82101-0119
Fax (307) 317 S195
I object Co the significant financial impacts to businesses,,
individuals {and consequently Lo Lhe Lax base) , and the effected
counties and communities due to restrictions proposed within all of
the alternatives, and recommend that a new preferred alternative bo
created with the help of know] edgeable community individuals and
representatives from grazing, recreation, oil and gaa and minerals
industry, timber and local and state governments.
I aupreciate 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 AiJMs proposed in the
Alternatives. Real, current scientific data should be ueed to make
management decisions on each allotment. TargetB should be clearly
established and stated.
l object to the expansion of "Wild Horse Management" areas. I
recommend eliminating all "Wild Horse Management" areas in the
Grass Creek ares RMP, Return all wild animal management to the
State Game and Fish, and return all managed animal production to
the Private sector.
the
data col 1 action procedures cited for AUM
itability. This should be completely redone.
to the small
nt of land considered for suburban
I object
expansion.
I abject to the lack of discussion about impacts to Che value of
private, state and county lands by the various alternatives .
Especially those imbedded with the 3LM 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.
T 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 impactB.
I object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
I object to the proposed blanket restrictions i
Vehicle Management.
ed in Off-Road
513.2
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 is,
I object to the lack of detailed deccriptions for restrictions.
T object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wclf
inferences, and Prairie dog, Black-Footed Ferret inferences.
RECEIVED
BUBUU OF LAND MANAGEMENT
514
To 31*1 C/o Rob Rosa
Grass Creek Area Draft EI,
P.O Box 119
worland 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 F.nvi.ronmental 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 ilorse 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.
1 object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
the small amount, of land considered for suburban
I object i
expansion.
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 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 in all of the alternatives. Not enough
emphasis lias 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.
514.2
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 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.
^Ad
465
RECEIVED
MAY - 9 1995 1
1
IAUDI LAND MANAGED'
515
To BLM C/o Rob Ross
Grass Creek Area Draft SIS
F . 0 Box 119
Kcrland 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.
T appreciate the opportunity to contribute to the very imco-tar."
Grass Creek Area Environmental Impact Statement. Please fird my
comments below. '
I object to the reduction of Grazing AUMs oropoaed in the
Alternatives. Heal, current scientific data should be used to make
management decisions on each allotment. Targets should be clearlv
established and stated. y
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
Sta-e Game and Fish, and return all managed animal production to
tne Private sector.
: 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 [.hose imbedded with the RLM Administered lands.
t 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
empnasis 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 biaB
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in Off -Road
vehicle Management .
515.2
I object to the small consideration given to the economic impacts
'^l1",3"3 ^ al'3° ?M bases- Beneficial impacts of businesses
should also ne factored in.
I object to the lack of detailed descriptions for restrictions.
I'?5'ia? to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated
inferences, and Prairie dog, Black-Foot< '
Gray
Ferret inferences
^X^ti-rA^.
MAY - 9 1995
miKAUOFUIHllKliAOIllEKl
TOU«irffln«
516
To BLM C/O Bob Ross
Grass Creek Area Draft E
P.O Box 119
Worland Wy 824C1-0119
Fax (307) 347-6195
I object to the significant financial impacts to businesses,
individuals (and consequently to the tax baseband 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 =as and minerals
moustry, timber and local and state governments. minerals
1 appreciate the opportunity to contribute to the verv important
Grass Cree/. Area Environmental Impact Statement . please find mv
comment s Del ow . J
I object to the reduction of Grazing AUMs Drcuosed 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 Lhe expansion of "Wild Horse Management" areas I
recommend eliminating ail "Wild Horse Management" areas in' the
Grass Creek area RMP. Return all wild animal management to the
S-ate Game and Fish, and return all managed animal production to
the Private 3ector.
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
c;:pa^si on .
T object to the lack of discussion about impacts to the value of
private, state and county lands by the various alternatives,
^specially those imbedded with the BLM Administered lands.
: object to restrictions that hamper the current primary businesses
and individuals who use federally administered "lands to generate
income anc 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 Lo the bias for recreation disturbance
against minerals, grazing and recreation.
nd the bias
I object to the proposed blanket restrictions contained in off "oad
Vehicle Management .
516.2
I object to the small consideration given to the economic impacts
-£™,?Sir1S3e3 "f Sl3° I8? base3- Beneficial impacts of businesses
should also oe faccored in.
I object to the lack of detailed descriptions for restrictions.
LftfcS co the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences
466
RECEIVED
MAY - 9 1995
3LK C/0 Bob Ross | SUSEAU 0F_LAN OJIAKAGEMEH 1
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy 82401-0119
Fax {3071 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-
very important
Please find my
I appreciate the opportunity to contribute to the
Grass Creek Area Environmental Impact Statement,
comments below.
I object to the reduction of Grazing auks proposed in the
Alternatives. Real, current scientific data should be used to make
management decisions on each allotment. Targets should he clnnrly
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 aninal production to
the Private sector.
I object to the data collection procedures cited for Aim
utilization, and suitability. This should be completely redone.
of land con:
idered for suburban
I object to the smal 1 air
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 generate
income and support our communities through taxes.
I object to the severe and undue number and level of restrictions
or. 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.
517.2
T 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 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.
7k~. .-VXq -U£>cijj.V<
or,
MAY - 9 1995
518
BUREAU OF LAND Hih'AGEVP
To SIM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland 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 AUKs proposed in the
Alternatives, Real, current scientific data should be used to make
management decisions on each allotment. Targets should be clearly
established and 3tated.
1 object to the expansion of -Wild Horse Management" areas . I
recommend eliminating all "Wild Horse Management" areas in the
Grass Creek area RKP. 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 data collection procedures cited for ATJM
utilization, and suitability. This should be completely redone.
I object to the
expansion .
small amount of land considered to
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 3LM 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.
T 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 Ori-Road
Vehicle Management.
518.2
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.
1 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.
K jfl&d^
467
MAY - 9 1995
519
SUREAJ OF UNO MANACEUEN:
To BLM C/O Bob Rosa
Grass Creek Area Draft EIS
?.0 Box 119
worland Wy R2401-0119
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 qas and minerals
industry, timber and local and state governments .
1 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.
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 Game and Fish, and return all managed animal production to
the Private sector.
Z object to the data collection procedures cited for AVJM
utilization, and suitability. This should be completely redone.
2 object tu the small amount of land considered for suburban
expans i on .
T 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.
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 restrictions contained in Off-Road
Vehicle Management.
519.2
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 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.
JjECBivia
To 3LM C/O Bob Ross
Grass Creek Area Draft EIS ! BU«*inSnM3toAJj27=LT
p.o box 119 ' — Baa&eSEr"*!
Worland Wy 82401-0119
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 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 v^ry important
Grass Creek Area environmental Impact Statement. Please find mv
comments below. J
1 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
State Game and Fieh,
the Private sector.
mo
Return all wild animal management to the
id return all managed animal production to
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.
I object to restrictions that hamper the current primary businesses
ana individuals who use federally administered lands ;o Generate
income and support our communities through taxes.
T object to the severe and undue number and level o^ restrictions
on Surface Disturbance in all of the alternatives. Not enouqh
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 .
520.2
I object to the small consideration given to the economic imoacts
to Businesses and also tax bases. Beneficial ixoacts of besj-esses
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
468
RECEIVED
521
To BLM C/0 Bob Ross
Grass Creek Area Draft BIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-G195
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 Tiha 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. 1
recommend eliminating all "Wild Horse Management" areas in the
Grass Creek area RMP. Return all wild animal management to the
State Game and Fi3h, 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.
r 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.
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 ir. Off -Road
Vehicle Management .
521.2
T 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 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.
^
!»■ U~~/<
RECriVEO
522
To BLM C/O Bob ROSS
Grass Creek Area Draft EIS
P.O Box 119
Norland Wy 82401-0119
Fax (307) 347-6l9b
I object to the significant financial impacts to businesses,
individuals (and consequently to the tax base) ,and the effected
counties and communities due to rastrictioilB 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.
2 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.
1 object to the expansion of "Wild Horse Management" areas. I
recommend el iminat ing all " Wi Id 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,
. 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 RLM 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.
T object to the severe and undue number and level of restrictions
on Surface Disturbance in all of the alternatives . Not enough
emphasis has been nlaced on new technology and new information to
mitigate and reclaim any impacts.
1 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 .
522.2
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.
1 object to the lack of detailed descriptions for restrictions.
I object to the discussion of threatened, endangered and candidate
w.i ldlif e species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
IS Cuii£ai
469
BLM C/0 Sob Ross
Grass Creek Area Draft Els
P.O Box 119
Norland Wy 824D1-0119
Fax (307) 347-6195
HAY - 9 1995
WSLAU OF LAW WHWatȣt!
[.-"' ' ">' L':
Q"3ect 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
tho 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 mv
comments below. J
1 object to the reduction of Grazing AUMs proDosed in the
Alternatives. Real, current scientific data should be used to make
management decisions on each allotment. Targets should be clearlv
established and stated. ' y
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 manacred animal production to
t.ie Private sector.
I object to the data collection procedures cited for AUM
utilisation, and suitability. This should be completely redone.
I object to the small amount of land considered Cor suburbar
expansion. UWWiU*'
I object to the lack of discussion about impacts to the value o'
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
anc 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 in all of the alternatives. Not enouqh
emphasis has seen placed on new technology and new info-nation 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 .
523.2
I object co the small consideration given to the economic impacts
to Businesses and also Lax bases . Beneficial impacts of businesses
should also be factored in.
I object to the lack of detailed descriptions for restrictions.
1 °h.'it:r:t c° the discussion of threatened, endangered and eandida-e
wilclne species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences
524
To BLM c/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-G19S
r object to the significant financial impacts to busi nesses,
individuals (and consequently to the tax base) , and the effected
counties and communities due to restrictions proposed within ail of
the alternatives, and recommend that a new preferred alternative be
created with Lhe help of knowledgeable community individual's and
representatives from grazing, recreation, oil and oas 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.
ob j ect
Alternatives.
the reduction of Grazing AUMs nrooosed in the
Real, current scientific data should be used to make
management decisions on each allotment. Targets should be clearly
established and stated.
i oo-ect to the expansion of "Wild Horse Management" areas I
recommend eliminating all "Wild Horse Management" areas in the
~rass creek area j^p, Re-urri aU wild ^^j manaaement to the
5-ate Game and Fish, and return all managed animal production to
amount of land considered for suburban
1 object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
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,
aspeciaiiy c.iosc imbedded with the BLM Administered lands.
I object to restrictions chat hamper the current primary businesses
and individuals who use federally administered lands to generate
income and support our communities through taxes
objecL
the
■ severe and undue number and level of restrictions
«* Surface Disturbance in all of the alternatives. Not enouqh
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.
524.2
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 to the lack of detailed descriptions for restrictions.
LSS?? L° the disoussion of threatened, endangered and candidate
Wlldlne species, specifically unsubstantiated Gray Wol"
inferences, and Prairi.e dog, Black-Footed Ferret inferences
XVV^cx-
Ju.
*A=)
470
MAY - 9 B95
E2B
To 3LH C/O Bob Roes
Grass Creek Area Draft.
?.0 Box 119
Norland Wy S2401-0119
Fax (307) 347-619B
I object to Che significant financial impacts to businesses,
individuals (and consequently to the tax base), and Che 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 CO the very important
Grass Creek Area Environmental Impact Statement. Please find my
comments below,
I object tc the reduction of Grazing aums proposed in the
Alternatives. Real, current scientific data should be used to make
management decisions on each allotment. Tarcets should be clearly
established and stated.
I object Co the expansion of "Wild Horse Management" areas. I
recommend eliminating all "Wild Horse Management" areas in Che
Grass Crock 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 AOm
utilization, and suitability. This should be completely redone.
T object to the small amount of land considered for suburban
expans ion .
I object to the lack of discussion about impacts to the value of
private, scate 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 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.
525.2
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 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.
MAY - 9 1995
SUEEAUOf LAND MANAGEMENT
526
To BLM C/O Bob Ross
Grass Creek Area Draft ETS
P.O Box 119
Norland Wy B2401-01I9 '
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.
T object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
1 object to the small amount of land considered for suburban
expansion.
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 individuals who U3e 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 in all of the alternatives. Not enough
i^mpliasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
I object to the bias for recreation di
against minerals, grazing and recreation
I object to the proposed blanket res
Vehicle Management.
bance and the bias
ictior.K contained in Off-Road
526.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
ahould also be factored in.
I object to the lack of detailed descriptions for restrictions.
I object to Che discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Slack-Footed Ferret inferences.
471
To BLM C/0 Bob Ross
Grass Creek Area Draft EIS
P. a Box 119
Worland 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 coinmunities due to restrictions protiosed 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 Lo the very important
Grass Creek Area Environmental Impact Statement. Please f^nd mv
consents below. J
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
recomnmd eliminating all "Wild Horse Management" areas in the
Grass Creek area rmp. Return all wild animal manaaement to the
State Game and Fish, and return all managed animal production to
tae Private sector.
I object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
527
I object to the small amount
expansion.
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.
I object to restrictions that hamper the current primary businesses
and mcividuals 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 in all of the alternatives. Not enouqh
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,
527.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
sboula also be factored in.
I object to the lack of detailed descriptions for restrictions.
r.°^ect to the discussion of threatened, endangered and candidafe
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
gCC-jj- s,<
RECEIVED
MAY - 9 1995
1
BUREAU OF LAND MAHAGEKENT
To BLM c/0 Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland 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.
a very important
Please find my
528
I appreciate the opportunity to contribute to th
Grass Creek Area Environmental Impact Statement .
comments below.
I cbj ect to the reduction of Grazing AUMs proposed i n the
Alternatives. Real, current scientific data should be used to make
management decisions on each allotment. Targets should be elearlv
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 ail 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 abject 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.
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 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.
T object to the proposed blanket restrictions contained in Ofi-Road
Vehicle Management .
528.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
shoula also ne factored in.
I object to the lack of detailed descriptions for restrictions.
1 °5j?.t to che,dl=cu33ion °£ threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black- footed Ferret inferences
472
MAY - 9 1995
529
BUREAU Of LAND MftMtMfitT I
To BLM C/O Bob Ross
Crass Creek Area Draft EIS
P.O 3ox 119
Worland Wy H2401-0119 ~J
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.
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 Game and Pish, and return all managed animal production to
the Private sector.
I object to the data collection procedures cited for AtJM
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.
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 in all of the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts,
1 object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
T object to the proposed blanket restrictions contained in Off Road
Vehicle Management .
529.2
T 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 to the lack of detailed descripti
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.
$sklj£0£
530
To B1W C/O Bob Ross
Grass creek Area Draft EIS
P.O Box 119
Worland 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.
: object to the reduction of Grazing AUMs 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 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 collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
ransidered tor suburban
1 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 vari ous 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 in all of the alternatives. Nol 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 cbje::t to the proposed blanket restrictions contained in Off-Road
Vehicle Management .
530.2
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 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.
&
Vx f{ fC
473
531
To ELM C/0 Sob Ross
Grass Creek Area Draft EI
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-6195
I object Lo the significant financial impacts to businesses,
individuals (and consequently to the tax base) , and the effected
counties and communities due to restrictions proposed within pi), 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 cas and minerals
industry, Limber and local and state governments.
I appreciate the opportunity to contribute to the verv important
Grass Creek Area Environmental Impact Statement. Please find my
comments below.
; 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.
established and stated.
Targets should be clearly
: 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 t
utilization,
i the data collection procedures cited for AUM
and suitability. This should be completely redone.
I object
expansion,
to the 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.
T object to restrictions that hamper the current primary businesses
and individuals who use federally administered lands to cencrate
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
•aphasia 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 bia3
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in oft-Road
Vehicle Management.
531.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
should alao be factored in.
I object to the lack of detailed descriptions for restrictions.
[object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
MAY - 9 TO I
532
flUSffAJCF L.M, ft '(..',:"
To BIM C/O 3ob ROSS
Grass Creek Area Draft B
P.O Box 119
Worland Wy 82401 0119
Fax (307) 347-619&
I object to the signi fficant 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 Che reduction of Grazing AUM3 prooosed in the
Alternatives. Real, current scientific data should be used to make
management decisions on each allotment. Targe ls 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 Lo the
State Game and Fish, and return all managed animal Droduction 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 .
T object to the lack ot discussion about imoacts 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.
t object to the severe and undue number and level ot restrictions
on Surface Disturbance in all of the alternatives. Not enough
empnasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
I abject to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
1 object to the proposed blanket rcstricti
vehicle Management .
ns contained j
532.2
I object co the small consideration given Co the economic imoacts
CO businesses and also tax bases. 3eneficial imoaocs of businesses
should also be faccored in.
I object to the lack of detailed descriptions for rest
notions.
I object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences
^£cy rr< 3ZuL&~
474
MW-9B95
533
BUBEMIOFLAHDKAHAGEKEKi
To BLM C/0 Sob Ross
Grass Creek Area Draft EIS
P.O Box LIS
Norland Wy 82401-0119
Fax (307) 347-6195
I object: tc the significant financial impacts to businesses,
individuals (and consequently to the tax base), and Che 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 ga3 and minerals
industry, timber and local and 3Late 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 reduoL ion 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 BMP. Return all wild animal management Co the
State Game and Fish, and return all managed animal production to
the Private sector.
I object to the data collection procedures cited Cor AUM
utilization, and suitability. This should be completely redone.
1 object to the small amount of land considered
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 Chat hamper Lhe 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 in all of the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
1 object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
for suburban
1 object to the proposed blanket restrict.!
Vehicle Management.
ns contained :
533.2
I object to the small consideration given to the economic impacts
to businesses and also Lax bases. 3eneficial impacts of businesses
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, Biack-Fccted Ferret inferences.
o&a
a* ^^g.
MAY - 9 t
534
BUREAU OF LAND MANAGED
To BLM C/O Bob Rosa
Grass Creek Area Draft ETS
P.O Box 119
Norland Wy 82401-0115
Fax (307) 347-619S
I object to the aignif icant 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.
T 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 dat_a 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 al 1 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 rerinn« .
to the small amount of land considered for suburban
1 object
expansion .
I object to the lack of discussion abouL impacts to the value of
private, state and county lands by the various alternatives.
Especially those imbedded with the BLM Administered lands.
I object CO restrictions that hamper the current primary businesses
and individuals who use federally administered lands to generate
income and support our1 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 objecr. to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
I object to Che proposed blanket restrictions contained in Oil-Road
Vehicle Managemenc .
534.2
I object to Che small consideracion given co the economic impacts
to businesses and also tax base3 . Beneficial impacCs of businesses
should also be factored in.
1 object co Che lack of decailed 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.
475
RECEIVED
b K i
To BLM C/0 Bob Roes
Grass Creek Area DrafC EIS
P.O Box 119
Worland Wy 82401-0119
Pax (307) 347-6195
I object Co Lhe significant financial impacts to businesses,
individuals (and consequently to the tax base) , and the effected
counties and communities due to restrictions Droposed 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,
established and stated.
Targets should be clearly
L 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
S-ate Game and Fish, and return all managed animal oroduction to
the Private Bector.
r object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
I obj ect to the smal 1 amount of land considered for suburban
expansion.
I object to Lhe lack of discussion about impacts to the value of
private, state and county lands by the various alternatives.
Especially those imbedded with the BLK 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 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.
535.2
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 to the lack of detailed descriptions for restrictions.
I object to the discussion of threatened, endangered and candidate
wildlire species, specifically unsubstantiated Gray wolf
inferences, and Prairie dog, Black-Footed Ferret inferences
MAY - 9 1595
To BLM C/0 Bob Ross
Grass Creek Area Draft EIS
P.O Box US
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 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
ina.ust.ry, 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.
536
I object to
Alternatives .
the reduction of Grazing AUMs proposed in the
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 che
State Game and Fisn, and return all managed animal production to
the. Private sector.
: 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,
T object to the lack of discussion about impacts to the value of
private, state and county land3 by the various alternatives
Especially those imbedded with the BIW Administered lands.
I object to restrictions that hamper the current primary businesses
and individuals who use federally administered lands to generaLe
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
enphasis 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 biaa
against minerals, grazing and recreation.
I object to the proposed blanket, restrictions contained in 0££-Road
Vehicle Management.
536.2
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 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
Ui&L
^X
476
RECEIVED
I MAY -9 (996
L
•'.'ftAUOFUHDIUIIMEUEHr
To BLM C/O bob Ross
Grass Creek Area Draft EIS
P.O 3ox 119
Worland My 82401-0119
Fax {307) 347-6195
T object to the significant financial impacts to businesses,
individuals [and consequently to the tax base), and tbe effected
counties and communities due to restrictions prooosed 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.
T appreciate the opportunity to contribute to the very important-
Grass Creek Area Environmental Impact Statement. Please find my
comments below .
T object to the reduction o* Grazing AUKs proposed in Lhc
Alternatives. 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 . 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 manaqed 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 smal 1 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.
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 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 Che bias for recreation disturbance and the bias
against minerals, grazing and recreation.
: object to the proposed blanket restrict.!
Vehicle Management.
. contained
537.2
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 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.
m-j-QX
RECEIVED
MflY - 9 1995
EU
EflU Of UUtDIMfUflr*
-»'
538
To BLM C/O Bob ROSS
Grass Creek Area Draft SIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-619S
I object Lo 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.
r object to the expansion of "Wild Horse Management" areaa. 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 to the data collection procedures cited tor AUM
utilization, and suitability. This should be completely redone.
I object to the small amount of land considered for suburban
expansion.
T object to the lack of discussion about impact* 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 primary businesses
and individuals who use federally administered lands to generate
income and support our communities through taxes.
I object to the severe and undun number and level of restrictions
or. 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.
3 object to the proposed blanket restrictions contained in Cft'-Road
Vehicle Management.
538.2
I object to Lhe small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
should also be factored in.
I object to the lack of detailed descriptions for restrictions.
I object to the discussion cf threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black -Footed Ferret inferences,
477
RECEIVED
MAY -9 1995
§3S
BUREAU OF UND HAfJAGf"
To BLM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-5195
I object to che significant financial impacts to husinessec,
individuals (and consequently to the tax base) , and the effected
counties and comrm.inj.ties 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 arid
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 Lo 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 b*= clearly
established and stated.
I object to Lhe expansion of "Wild Horse Management" areas. jc
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 o^oduction to
the Private sector.
I object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
I object
expansion.
T 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 primarv 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
or Surface Disturbance in ail 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 Lo the proposed blanket restrictions contained in Off -Road
Vehn.de Management.
the small amount of land considered for suburban
539.2
I orgect to the small consideration given to trie economic impacts
to businesses and also tax basc3 . SffiBSfiicial impacts of businesses
should also be factored in.
I object to the lack of detailed descriptions for restrictions.
I object to the discussion at threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
6
RECEIVED
HAY - 9 1995
BU
?KAU OF LAND MANAGE!
willlll.Nr. itinvj.,.-
ENT
54<Q
To BLM c/O Bob Floss
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy 02401-0119
Fax (307) 347-S19S
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.
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 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. Thi3 3hould 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.
I abject 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
p.mphasi s 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 .
540.2
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 to the lack of detailed descri
ns for restrictions.
I object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, arid Prairie dog, Black-Footed Ferret inferences.
478
RECEIVED
I WAY - 9 (
t
IWUu Of uIlD IMMEIIIIT
541
To BLM C/C Bob Ross
Grass Creek Area Draft E
?.0 Box 119
Worland Wy 82401-0119
Fax (307) 247-619S
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 cemmuni fcy individuals and
representatives from grazing, recreation, oil and gas and minerals
industry, timber and local and state governments.
r 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 AUWs 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.
T object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
I object to
expansion .
j 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.
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 biaa for recreation disturbance and the bias
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in Off Road
Vehicle Management.
the small amount of land considered for suburban
541.2
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 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.
MAY - 9 1995
542
3UHLAU0F UNDMAJUGFUENT
TO BLM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 11.9
worlar-d wy 82401-0119
Fax (307) 347-6195
1 object to the significant financial impacts to businesses,
individuals (and consequently to the tax baea),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.
[ aooreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement. Please find my
comments below.
T abject 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 Korse Management" areas. I
recommend eliminating all "Wild Korse Management " areas in the
Grass Creek area kMP. 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, ana suitability. This should cc completely redone.
1 object to the small amount of land considered for suburban
expansion.
l 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 resttrictior.s
en 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 .
542.2
T object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
should also be facLored 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.
L AJf.
479
543
To BIK C/O Bob Roes
Grass Creek Area Draft EIS
P.O Box 119
Norland Wy 82401-OU9
Fax (307) 347-6195
7 ob jeer, 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 eras 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 try
comments below.
T object to the reduction of Grazing AUMs proposed in the
Alternatives. Real , current scientific data should be used to make
management decisions or. 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 Manaaement" 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 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.
I object to restrictions that hamper the current crimary busineBses
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 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, grazing and recreation.
I object to the proposed blanket restrictions contained in Off-Road
Vehicle Maiiaqement .
543.2
I object to the snail consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
Should aiso be factored in.
l abject the lack of detailed descriptions for restrictions.
I object to the discussion of Threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
nferences, and prairie dog- Black- footed ferret inferences
BLM C/0 Bob Ross
Grass Creek Area Draft SIS
P.O Box 119
Borland wy 82401-0119
Fax (307) 347-S195
RECEIVFD
MAY - 9 1995
544
DUSEAU OF LAND JHAIMGEHIEN1
businesses,
effected
I object to the significant tinancial impacts t>
individuals (and consequently to the tax base) , and the effected
counties and communities due to restrictions proposed within all o*
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 loea.1 ^nH -ar-afe Hnukwm.nr-.
md local and state governments
represen. v,
industry, timber
I appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement. Pleaae rind mv
comments below. '
I object to the reduction of Grazing AUYs prooosed in the
Alternatives. Real, currant scientific data should be used to make
management decisions on each allotment. Targets shou"d be clear lv
established and stated.
I object to the expansion of "Wild Horse Management" areas 1
recommend eliminating all "Wild Hor3e 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 collection procedures cited tor AUM
utilization, and suitability. This should be completely redone.
I object to the small amount of land considered Cor suburban
expansion.
I object to the lack of discussion about impacts to -he value of
private, state and county landB by the various alternatives
Especially those imbedded with the BL^I Administered lands.
I object to restrictions that hamper the current pnma-y busiresses
anc individuals who use federally administered lands to are
generate income and support our communities through taxes.
necicna
Not enough
ion to
I ooject Co the severe and undue number and level o
or. Surface Disturbance in ail of the alternatives
emphasis has been placed on new technology and new irforma
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 blanker: restrictions contained in Off -Road
Vehicle Management.
544.2
I object to the small consideration given to the economic i— acts
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 Candida- e
Wildlife species, specifically unsubstantiated Cray Wolf
inferences, and prairie dog- Black-footed ferret infe-ences
480
RECEIVED
HAY - 9 1995
BUMAUOFUNDUANAGtUEMT
mt
To 3LM C/O Bob Ross
Grass Creek Area Draft EIS
P.O 3ox 119
Norland Wy 82401-0119
Fax (307) 347-619S
I object to the significant financial impacts to businesses,
individuals (and consequently to the cax base) , and the effected
counties and communities due to restrictions proposed within all of
tha 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 Knvi ronmental 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
Szate Game and Fish, and return all managed animal production to
rhe Private sector.
I object to the data collection procedures cited for AUM
utilization, and suitability. Thin should be completely redone.
1 object to the small amount of land considered for suburban
expar.sicn .
J object to the lack of diflcuaaion about impacts to the value of
private , state and county lands by the various alternatives .
Especially those imbedded with the BLM Administered lands.
T 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
en Surface Uist-jrbar.ee in all o£ the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitiga-e and reclaim any impacts.
7 object to rhe hi a a for recreation disturbance and the bias
against minerals, grazing and recreation.
T object to the proposed blanket restrictions contained in Off-Road
Vehicle Management .
545.2
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.
RECEIVED
MAY - 9 [995
BUHEAUOFLANDMANAGEMEN!
546
To BLM C/O Bob Roas
Grass Creek Area Draft EIS
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 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.
I appreciate the opportunity to contribute to zhe very important
Grass Creek Area Environmental Impact Statement. Please find my
comments below.
I object to the reduction of Grazing ACMs 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 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 Lhe 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 in all of the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
1 object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
I object to the proposed blanket restrictions concained in Off -Road
Vehicle Management .
546.2
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.
3 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.
li^UJLsa^L
481
RECEIVED
MAY - 9 1995
547
BUREAU OF LAND MANAGE^1
To 3121 C/O Bob Ross
Grass Creek Area Draft SIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-6195
I object to Lhe significant financial impacts to businesses,
individuals (and consequently to the tax base) , and. Che effected
comities and OORtBUnitiW 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
incustry, timber and local and state governments.
1 appreciate the opportunity to contribute to the very Important
Grass Creek Area Environmental Impact Statement. Please find my
comments below. J
1 ob j »ct to the reduct 1 on of Grazing AUWs 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" area3 . I
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
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 generate
income and support our communities through taxes.
I object to the severe and undue number and level of restrictions
on Surface Disturbance in ail of the alternatives. Not enough
empnasis ha3 been placed on new technology and new information to
mitigate and reclaim any impacLs .
I object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
T object to the proposed blanket restrictions contained in Off -Road
Vehicle Management.
.and considered for suburban
547.2
I object to the email consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
shoula also be factored in.
1 object to the lack of detailed descriptions for restrictions.
I°^?^c Co the diacussion of threatened, endangered and candidate
wilcuirc species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed "
Gray
Ferret inferences.
~L*t222£Z&i 2^
'*tL4-t?Ld££fl
BLM C/O Bob Ross
Crass Creek Area Dr«£t EIS
P.O Box 119
Worland Wy B2401-0119
Fax {307) 347-619S
MAY - 9 1995
BU EAU OF LAND MANAGEMENT
548
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.
: appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement. oi^aP find my
comments below. x
l Object to the reduction of Grazing ATJMs 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 Fish, and return all managed animal production to
the Private sector.
1 object to the data collection procedures cited for AEJM
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.
Z 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.
l object to the severe and undue number and level of restrictions
on Surface Disturbance in all of the alternatives. Nnt enough
enpnasi-s has been placed on new technology and new information to
mitigate and reclaim any impacts.
1 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.
548.2
I Object to the email consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
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.
MlA^lXH^
482
RECEIVED
MAY - 9 I99S
549
[ BURtAUOf LAlMKAfiM."
TO 3LK C/O Bob Koss
Grass Creek Area Draft EIS
P.O Box 119
Norland 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 9 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
3rass Creek Area Environmental Impact Statement. Please find my
comments below.
I object to the reduction of Grazing aijms 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 Management11 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 ail managed animal production to
the 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 amoui
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 tha 31M Administered lands.
I object to restrictions that hamper the current primary businesses
and individuals who use federally administered lands tc 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 disturbar.ee and the bia3
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in Off-Road
Vehicle Management .
of land considered for suburban
549.2
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.
: 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.
RECEIVED
■ i MAY - 9 1955
To BI*I C/0 Bob Ross [
Crass Creek Area Draft ElS j suaWufuiiDMAiiMEBEKi
P.O Sox 119 I mwLWf wmw
Norland Wy 82401-0119
Fax [307) 347-6195
1 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.
1 appreciate the opportunity tc contribute to the very important
Grass Creek Area Environmental Impact Statement . Please find my
comments below.
I object to the reduction cf Grazing AUKs 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 to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
I and considered for suburban
I object to the smal 1 amoun
expansion.
I object to the lack oE 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.
I object to the severe and undue number and level of restrictions
on Surface Disturbance in al 1 of the alternatives . Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
I object
against
to the bias for recreation disturbance and the bias
inerals, grazing and recreation.
I object to the proposed blanket restrictions cor.Lair.ed in Off -Road
Vehicle Management .
550.2
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 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.
jiuA&a jL fi/La-T^~ — ■
483
I MAY - 9 1995 i > w
To BLM C/O Eob Ross | j
Grass Creek Area Draft EIS BUREAU OF LAND MANAGEMENT j
P.O Box 119 L- wmwmowwc J
Worland Wy B2401-D119
Pax (307) 347-6195
I object to the sign! £ leant 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 ana gma 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 Stetnagement " areas. X
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 collection procedures cited for AUK
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.
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.
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 restrictions contained in Off -Road
Vehicle Management .
551.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases, neneficial impacts of businesses
should also be factored in.
I object to the lack of detailed descripti
restrictions .
T object to r.he discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed ferret inferences.
Qtlluuo. 0-C.oU.
RECEIVED
MAY - 9 I9S5 !
BU
WUOFIAH0MANAGIKEN1
wtmm. wvdhm
552
To BLM C/O Bob Ross
Grass Creek Area Draft ElS
P.O 3ox 119
Worland 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 to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
small amount of land considered for suburban
; 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 altarnati ves .
Especially those imbedded with the ELM Administered lands,
I object to restrictions that hamper the Current primary businesses
and individuals who use fade-rally administered "lands to generate
income and support our communities through taxes.
T object to the severe and undue number and level of restrictions
on Surface Disturbance in all of the alternatives. Mot 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.
552.2
I object to the small consideration given to the economic impacts
to businesses and also tax bases. 3eneficial impacts of businesses
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.
'/LJMM^SMM^ri
484
RECEIVED
MAV-91995 '
BUREAU On ANIUVVj:,:
553
To BLK C/O Bob Rosa
Grass Creek Area Draft EIS
P.O Box 119
Mbrland Wy 82401-0119
Fax (307) 347-6195
1 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. Pieace find my
comments below.
I object to the reduction of Grazing ASMS proposed in the
Alternatives. Real, current scientific data should be used t.o make
management decisions on each allotment. Targets should be clearly
established and stated.
I object to the expansion of "Wild Horse Management*1 areas. I
recommend eliminating all "Wild Horse 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
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 Biw 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 in all of the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
[ 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 .
553.2
I object to the email consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
should also be factored in.
I object to the lack of detailed descriptions for restrictions .
1 object, to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
RECEIVED
BS4
TO BLM C/0 3ob Ross
Grass Creek Area Draft SIS
P.O Box 119
Worland Wy 82401-01L9
Fax (307) 347-6195
T 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
cor.Tier.ts below.
7 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.
1 object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
1 object to the small amount of land considered for suburban
expansion.
: 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.
1 object to the severe and undue number and level of restrictions
or. Surface Disturbance in all of the alternatives. Not enough
ompnaaie has been placed on new technology and new information to
mitigate and reclaim any impacts.
I object to the
against minerals,
lias for recreation dij
grazing and recreation.
turbancc and the bias
I object to the proposed blanket restrictions contained in Of F Road
Vehicle Management.
554.2
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 to 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.
■HA;.L\(\&am^~
485
BBS
Targets should be clearly
the
To BLM C/0 Bob Rosa
Grass Creek Area Draft ET
P.O Box 119
Wariand Wy 82401-0119
Pax {307) 347-6195
I object to the significant; financial impacts to businesses,
individuals (and consequen c ly to the tax base) , and the ettected
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.
- appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact. Statement. Please find my
comments below.
7 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,
established and stated.
I object to the expansion of "Wild Horse Management" areas,
recommend eliminating all "Wild Horse Management" areas in t
Grass Creek area RMP. Return all wild animal management to the
State Game and Fish, and return all managed animal production Lo
ihe 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 3LM Administered lands.
I object to restrictions that hamper the current primary businesses
and maividuale who use federally administered lands ;o generate
income and support our communities through taxes.
I object to the severe and undue number and level of restriction*
on Surface Disturbance in all of the alternatives. Not enouqh
emphasis has been placed on new technology and new information to
talugfttm and reclaim any impacts.
I object to the bias for recreation disturbance and the biaB
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in Cff-Road
ver.icle Management .
555.2
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 to the lack of detailed descriptions for restrictions.
l object co the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Cray Wolf
inferences, and Prairie dog. Black Footed Ferret inferences.
RECEIVED
MAY - 9 1995
556
BUREAU OF UKD IMMflEKUIJ
TO BLM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Worland Wy 32401-0119
Fax (307) 347-6195
I object to the significant financial impacts co businesses,
individuals (and consequently to the tax base), and the effected
countieB 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.
: 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 orocosed m 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 to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
1 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.
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 in ail of the alternatives. Not enough
emphasis has been placed on new technology and new information to
mitigate and reclaim any impacts.
1 object to the bias for recreation disturbance and the bias
against minerals, grazing and recreation.
I object to the proposed blanket restrictions contain
Vehicle Management.
: in Off-Road
556.2
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 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, 31ack-Footed Ferret inferences.
.ftybASi^ ^
486
RECEIVED
HAY - 9 1995
557
BUREAU OF LAhD MANAGE'.!:*'
To 3LM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Woriand Wy 82401-0119
Pax (307) 347-6195
I object to the significant financial impacts Lo businesses,
individuals (and consequently to the tax base), and the ejected
counties and communities due lo rcstriccions 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 Tmpact Statement. Please find my
comments below.
I object to the reduction of Grazing AUMo 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 Pish, and rafcum 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
f object b
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 BZJ4 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.
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 Cff-Road
Vehicle Management .
557.2
I object to the small consideration given to the economic: imnacts
to businesses and also tax bases. Beneficial impacts of businesses
should also be factored in.
I object to the lack of detailed descriptions lor restrictions.
I abject to the discussion cf threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
558
TO HliM C/o Bob Rose
Grass Creek Area Draft EIS
P.O Box 119
woriand wy 82401-0119
Fax (307) 347-C195
1 object to the significant financial impacts to businesses,
individuals (and consequently to the Lax base) , and the effected
countieo and communities due to restrictions proposed within all of
the alternatives, and recommend that a new preferred alternative be
created with the help of knowjedgeable community individuals and
representatives from grazing, recreation, oil and gas and minerals
industry, timber and local and state governments.
7 appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement. Please find my
comments below.
1 object Lo the reduction of Grazing A'JMs 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 Korse Management" area3 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.
object to the data collection procedures cited for AUM
tilization, and suitability. Thic should be completely redone.
to the small amount of land considered for suburban
I object
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 CO 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.
T 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 .
558.2
1 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 to the lack of detailed descriptions for restrictions.
1 object to the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences.
487
RECEIVED
MAY - 9 1995
BUREAU Of LAND IMMSENENl
To BLM C/O Bob Ross
Grass Creek Area Draft EIS
P.O Box 119
Norland Wy B2401-0119
Fax (307) 347-6195
I object co the significant financial impacts to businesses
individuals (and consequently to the tax baseband the effected
counties and communities due la restrictions proncsed within all of
tne alternatives, and recommend that a now 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 ve-y <mportart
Grass Creek Area Environmental Impact Statement. please find mv
comments below. '
1 object to the reduction of Grazing AUMs oroposed 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" a*-eas I
recommend eliminating all "Wild Horse Management" areas in' the
Grass Creek area RMP. Return ail wild animal management Co the
State Game and Pish, and return all managed animal production to
tne Private sector.
I object to the data collection procedures cited for AUM
utilization, and suitability. This should be completely redone.
: object to the small amount of land considered for suburban
expansion.
I object to the lack of discussion about impacts Co Che value of
private state and county lands by the various alternatives
Especially those imbedded with the BLK Administered lands.
1 object to restrictions that hamper the currant primary businesses
and individuals who use federally administered lands to oene^ate
income and support our communities through taxes.
I object to the severe and undue number and level of restrictions
™^J<CfCK Disturt»noe "•. «U 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
agains„ minerals, grazing and recreation.
ventcre'^anageme^05^ ""^ **""*«*«• — «■*— t» °«-Road
559
559.2
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 to the lack of detailed descriptions for restrictions.
Im51°«C r'° the discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-footed Ferret inferences
■jCE:
^
RECEIVED
MAY -9 1995 j
BU
tAUU, L AND M4MC. *.;v
560
To BLM c/0 Bob Ross
Grass Creek Area Draft SIS
P.O Box 119
Worland Wy 82401-0119
Fax (307) 347-6195
Lj&te,'0, Chf sJ-Shificanc financial impacts to businesses,
ndividuals (and consequently to the tax base) , and the effected
counties and communities due to restrictions proposed within all of
tne alternatives, and recommend that a new preferred alternative be
r»n-™„r\ Che help of knowledgeable community individuals and
Sg^^ives from grazing recreation, oil and gas and minerals
mdus-ry, Clmber and loca_ and stace governments.
SJS5rSiS*.£" °PP?rtuait-y « contribute to the very important
cSSmanS Slc^" Envlro"™"":L Iraf*ct Statement. Please find my
I object to the reduction of Grazing A0MS proposed in the
A—ema-ives. Reai, current scientific data should be used to make
management decisions on each allotmenc. Targets should be clearly
established and stated.
I object to the expansion of "Wild Horse Management" areas
recommend eliminating all "Wild Horse Management" areas in the
jrass Creek area MP. Return all wild animal management to the
s a„e Game and Fish, and return all managed animal production to
the Private sector.
: object BO the data collection procedures cited for AUM
utilisation, and suitability. This should be completely redone.
1 object to the small amcu
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
w;Vfa:S "h° USe federallV administered "iands^to generate
income and support our communities through taxes.
I object to the severe and undue number and level of restrictions
2Lk aCu Dtst-lirbanoe in all of the alternatives. Not enough
emphasis has been placed on new technology and new information to
m-tigate and reclaim any impacts.
: object to the biaa for recreation disturbance and the bias
against minerals, grazing and recreation.
of land considered for suburban
560.2
I object to the lack of detailed descriptions for restrictions .
ii?Hl?5; C° the .discussion of threatened, endangered and candidate
wildlife species, specifically unsubstantiated Oravwvvr
inferences, and Prairie dog, Black-Footed W«« inferences. ^
488
MAY - 9 1996
BUKUU OF UNO SANAGEHUNT
561
To 3LM C/C BOb R033
Grass Creek Area. Draft St!
JP.O Box 119
Worland Wy 82401-0119
Pax (307) 347-6195
I ob j ect to the signi ficant 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 r.o contribute to the very important
Grass Creek Area Environmental impact Statement. Please find my
comments below.
l 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 Korse Management" areas. I
rftcommend el iminat ing al 1 "Wild Horse Management " areas in the
Grass Creek area RMP. Return oil wild anirnal management to the
State Game and Fish, and return all managed animal production to
the Private sector.
I obj«ct 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 Lhe DLM Administered lands.
. object to restrictions that hamper the current primary businesses
and individuals who use federally administered "laada 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
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.
561.2
I object to the small consideration given to the economic impacts
to businesee3 and also tax bases. Beneficial impacts of businesses
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.
Cu. £ AJ ,/Z,
562
3LM C/0 Bob Ross
Grass Creek Area Draft Els
P.C Box 119
norland wy 82401-0119
Fax (307) 347-6195
Dear Mr Ross,
I have re-wriLten moat, of my comments from individual looseleaf
pages into the nraft EIS document with the hepe that it would
expedite the process of cross analysis. It appeared that it would
be faster to review if the comment D were at least more easily
referenced. Due to the time requirement, did not etch a comment by
each subject if it was repeated throughout the document. Instead
1 would hope the comment would be used for the topic in all
locations it is discussed.
I have been asked to continue to contribute input thru the county
commissioners for Big Horn County and Park County and through them
have additional detailed information for you on Oi. and Gas. If you
have quesiton9 or would like to talk about any of the subjects,
don't hesitate to contact me.
Mart in Dobson
-vUOt
[Because of the format and volume of Mr. Dobson's comments, they are not being printed in
this document. Interested persons are invited to peruse these comments at the Worland
District Office during normal business hours. -ED.)
RECEIVED
Ktf-91995
563
1501 Stampede Avenue
Codv, WY B24 14-4721
TolapHotif 307/867-4961
Bureau of I and Management
Bob Ross, Team Leader
P. 0. Box 119
Worland, WY 82407-0119
Dear Bob.
Marathon Oil Company appreciates the opportunity to provide additional
comments on the Bureau of Land Management's (BLH) Grass Creek Resource
Management Plan {RMP) Draft Environmental Impact, Statement (EIS) that
was released in January, 1995. Previous official comments for
Marathon were presented by E. M. Dauernhcim, Marathon's Exploitation
Manager, at the BLM's public hearing on May 3, 1995, as well as my
comments at the open house in Heuiefit.SB, Wyoming.
As the number one liquid hydrocarbon producer in bo'.h Wyoming and Lhe
Grass Creek Resource Area (RA) as well as being active in Grass Creek
for over eighty years, our company has a strong Interest in the
outcome, of this EIS. We do disagree with the preferred alternative in
this Draft EIS in that it proposes a restrictive management scenario
that will result in minimal, if any, exploration opportunities for our
industry. Marathon would recomend the use of Alternative B or a new
alternative that would allow our industry reasonable access.
The proposed management for Doth our industry and the livestock
industry will in turn result in providing even more economic stresses
on both the four counties in the RA and Wyoming that benefit Trow the
revenues generated in the Grass Creek Resource Area. While the
hydrocarbon production from this RA is only a small part of the
nation's production from federal lands, it is ironic that the BLM's
National Performance Review efforts are proposing incentives for our
industry to find new reserves on federal lands while, in turn, the
proposals for management of Grass Creek are to restrict access to
those same lands, lhe BLM must work with the commodity industries and
the local government officials in order for the management of the
federal lands to support the economy of the communities.
As we have stated over the past few months, Marathon is willing to
work with the BLH and the counties to develop a Grass Creek Resource
Area management recommendation which will allow our industry
opportunities to explore for hydrocarbons; continue to provide
revenues to the communities; and minimize impact on environmentally
sensitive areas.
i\ suDSidiilry a: JHX Corpora
489
563.2
Bureau of Land Management
Bob Ross, Team Leader
May 8. 1995
Page 2
The following comments are suggested changes to the Draft EIS and
additional support information to be considered in the document.
Produced Water
In Wyoming, produced water from our industry has been surface
discharged or reinjected through various permit mechanisms for many
years. Host of that produced water is of a quality that it can be
beneficially used by others. Several years ago, the EPA and the
Wyoming OEQ developed new water quality standards covering our surface
discharge permits. Testimony from industry and individuals during
that time provided insight into the value of the produced water.
Attached are copies of pertinent testimony and public statements (red
covered, bound book) about the produced water. In particular, my
testimony should provide the BLM a basis for determining the economic
value cf the water throuyh irrigation use.
I would suggest that the Worland BLM contact the Cody BLM and obtain
a copy of the USFWS's study of Lake Loch Katrine in Marathon's Oregon
Basin field. This study was the first detailed study, to my
knowledge, of the affects of produced water on waterfowl. Reading the
study, not the abstract, supports the fact that little or no affect to
the birds results from the water.
The previous information should be incorporated in this EIS, possibly
Dn pages 64, 69, and 195. As stated (located in front of red book) 6y
Hr. Enright, previous Cody Resource Manager for the BLM, the produced
water is an important benefit to management of the public land.
Visual
On page 62, possible screening of incustry operations is suggested for
visual management. As noted in the previous section, our industry
started before Wyoming was a state. Because of our historical
significance, it is suggested that enhancement rather than screening
be used for this for management. It appears hypocritical to recogni?e
our historical significance in the EIS and then suggest visual
restrictions. Maintenance of our operations is supported in order to
show a clean, neat operation; however, screening is not recommended.
the economic value of a seismic line is
A typical 3D project is approximately 10
As stated in the EIS
approximately S8,000/mi
miles square with 70 miles of source and receiver lines' and "ao^to 30
miles of 2D seismic lines. Utilizing the economic value in the EIS
a 3D project would have a value of about S700.00Q or J800 OOo'
Statistically, approximately ten 3D projects would result in' one
discovery field; therefore, the economic value of these projects for
a new field would be approximately seven to eight million dollars.
Wildlife Restrictions
In general, we believe that the federal agencies do not provide
sufficient justification for surface access restrictions on our
industry in order to prevent any possible impact on wildlife. It is
our opinion there are many studies on other sources that can
negatively influence wi Idl i fe survival more so than our industry. For
instance, published articles indicate that predators create
significant impact on wildlife. Recent articles in the monthly
publications of "Ducks Unlimited" and "The North American Pronghorn
Foundation" are but two sources of studies of the affect of predators
Those articles can be provided to the BLM. Also, droughts reportedly
have an impact on the wi 1 dl i fe. The agenc i es need to start
considering these impacts also in conjunction with our possible
impacts.
563.3
Bureau of Land Management
Bob Ross, Team Leader
Hay 8, 1995
Page 3
Soil Loss
On pages 126 & 127, a study of soil losses from various land uses is
included. For my industry, the soil losses appear excessive. Since
it was stated that the study was a computer model, I would suggest
that compaction and stabilization cover be incorporated in the study
should result in more reasonable data.
which, in turn,
Northern Rocky mountain Gray Wolf
On page 201, the discussion of the wolf should be deleted The
USFWS's Final EIS on the grey wolf specifically excluded any
protection outside Yellowstone Park. The species is considered to be
"experimental" and not to be protected.
Seismic Operations
Three-D seismic is a modern oil field exploration tool used to locate
new fields. Shooting a 3D seismic survey involves bringing
specialized people, equipment, etc. to a location and conducting the
survey over a period of several days. The local economic benefit from
such a survey would be expenses associated with motels, meals, local
purchases, and equipment, repairs. It is estimated that a typical 3D
seismic survey would result in local expenditures of S5.00D to
5 1 [) , 000 .
563.4
Bureau of Land Management
Bob Ross, Team Leader
May 8, 1995
Page A
No Surface Occupancy fNSO^ Restrictions
Our industry objects to the ACLC proposal and the proposed NSO
management for the upper Owl Creek area. Reasonable NSO restrictions,
such as the Legend Rock Petroglyph Site, provide protection of
sensitive areas and still allows access for the commodity industry.
Blanket NSO management, such as the 10 mi 1 e by 2.5 mile "ACEC" area,
is not reasonable. While there are locations in this area that should
be avoided, corridors of access for exploration should be incorporated
in the surface management for approval on a case by case basis.
Should reserves be discovered, the operator can design a development
scheme with the BLM that would minimize surface impacts.
Controlled Surface Use (CSU1 Restrictions
Marathon would recommend that the CSU management including the ceasing
of maintenance and production operations be dropped. Many cases in
our industry, in recent times, have incorporated automation techniques
to minimize the necessity of continual access to active wells. Arco's
Sheep Mountain project that is attached is one of those cases. As
mentioned in the Wildlife Restriction comments, the need for any CSU
restrictions should be justified. As with the NSO proposal, each
industry proposal should be developed on a case by case basis, rather
than used blanket restrictions.
Operations In Sensitive Areas
Our industry has explored and developed hydrocarbons in sensitive
areas for many years and throughout the world. In 1992, I used a
literature search to obtain copies of various articles concerning
operating in sensitive areas and submitted them to the Shoshone
National Forest personnel for consideration in their leasing FIS.
Copies of those thirty-one articles are attached for your
consideration in this FIS.
Existing Fields
While the Draft EIS does not propose restrictions for the existing
fields, the areal limits of no .restrictions appear to be the field or
unit boundaries. Marathon recommends that the areal limits for no
restrictions be two miles past the boundaries of the fields. The
563.5
Bureau of Land Management
Bob Ross, Team Leader
May 8, 1995
Page 5
reason: Marathon has discovered that three structural or
stratigraphic traps utilizing 3D seismic extended past the boundaries
of fields that we currently operate in the Big Horn Basin.
Production Response From The Management For The Four Alternatives
Marathon has not completed their analysis of this data but will
provide the data soon.
Socioeconomics
As Mr. Dauernheim stated in his testimony, the various alternatives
will lead to dramatically different exploration and development
scenarios that would, in turn, result in different hydrocarbon
production in the future. After Marathon and others provide the
support data, it is recommended that the University of Wyoming develop
tables showing the economics impact, including tax and royalty
revenues, of the four alternatives in the EIS. We would recommend
that the Worland BLM obtain a copy of the Expanded Moxa Arch Area
Draft EIS to use as a guide for the socioeconomic section. This
document can be obtained from Bill McMahan of the BLH's Rock Sprinos
District Office.
Cultural and Archeological Issues
Marathon realizes that cultural and archeological issues are covered
under existing federal regulations; However, it is recommended that
the Worland BLM make every effort to streamline the permitting
process. As mentioned on paqe 153 in the EIS, our Industry's actions
have resulted in the majority of the cultural finds. Since our
industry has been diligent in reporting any finds, even in cleared
permitted areas, Marathon believes that an effort to reduce the cost
to our industry will not reduce the discovery of any cultural finds.
A reduction in costs of the permitting would, in turn, result in more
incentives to increased activities by our industry.
Summary
Marathon recommends that the BLM carefully consider our proposals. We
are willing to provide additional information, if necessary. Should
you have any questions concerning this letter, please let me know.
490
563.6
Bureau of Land Management
Bob Ross, Team Leader
Hay 8, 1995
Page 6
Sincerely,
MARATHON OIL COMPANY
Pat Guilders
Government Affairs Coordinator
Rnr.fcy Mountain Region
:CPC (3151-12)
Enclosures
xc: L. M. Mueller
G. M. Lewis
Petroleum Association of Wyoming
Rocky Mountain Oil and Gas Association
RECEIVED
WW BMBSvlerkity Associates
P.Q Box 6C32. Litaml.:. Wy 82070 I3C7: 712-79/8 tax 7«-7989
564
K«»i«i«nMycaEI|TJ
Bob Ross, Team Leader
Grass Creek RMP
Worland Distiict, Bureau of Land Management
PO Box 119
Worland, WY S24O1-0119
Dear Bob
The following constitute our commenis on the Crass Creek Resource Area Re<
Management Plan Draft Environmental Impact Statement (DEIS], Please include them in
the public record and respond to them in subsequent environmental documents.
Biodiversity Associates is a 501(c)(3) non-profit conservation organization, based in
Laramie, Wyoming, which works :o protect and restore native species and their habitats.
Introduction and General Commenis
We realize thut producing a comprehensive, long-term management plan is a
challenging task, as is analyzing the impacts of various aliemative plans However, we find
the DEIS extremely difficult to read And it has been virtually impossible for us to determine
the basic differences between, and relative impacts of the various alternatives. The tables
which atterr.pt to describe the alternatives, assumptions, mitigation measures, and
environmental effects are confounding at best In addition to clarification and reformatting,
the tables also need, at a minimum, some sort of numbering scheme so that specific items
can be referenced, The DEIS also appears to confuse alternatives, assumptions, and effects,
and activities and resources We wit. cite specific examples of these problems below.
The BLM has an obligation to manage public lanes under the multiple use concept in a
manner that protects the publics resources This includes wildlife, plants, and recreation
opportunities. Yet the DEIS and preferred alternative appear to be nothing more than
extractive industry development plans. The greatest emphasis is on oil and gas development
and livestock grazing All other uses seem to he lumped into the "other" category and are
subordinate to mineral development and grazing by domestic livestock. This is nol
acceptable and is contrary to law.
For example, the preferred alternative makes the entire 1,171,000 acres (100% of the
BLM mineral estate) of the planning area open to oil and gas leasing and applies No Surface
Occupancy (NSO) stipulations to ?. mere I 7% of the planning area, In fact, every
alternative analyzed In the DELS mskps every acre open to leasing. Only the leasing
stipulations are different. This is not a reasonable range of alternatives under the CEQ
regulations. Furthermore, many areas important for wildlife, primitive recreation, and other
values that should have been withdrawn horn mineral entry were not, And, given how little
ol the nation's land Is in an undeveloped state, the few remaining undeveloped tracts in the
Grass Creek Resource Area (RA) should be protected from development In particular, we
believe that the Owl Creek. Sheep Mountain. Red Butt*, and Bobcat Draw Badlands
564.2
~ j:i,^Ay;cs:*. ■ ■"
M) 3n Grssi Crert W DElS
Wilderness Study Areas should be preserved in an undeveloped slate and protected as
Wilderness. These make up only 6% of the public lands in the RA and their protection
cannot be construed as an unreasonable measure. In the event that Congress does not
designate the WSAs as Wilderness, we urge that the areas be protected from development
as ACECs We also supporl the larger acreages for the WSAs as presented in Wilderness At
Risk: Citizen 's Wilderness Proposal for Wyoming BLM Lands {prepared by the. Wyoming
Wilderness Coalition). Even if these lands were nor noteworthy because of geological
features, 'wildlife and plants, and cultural sites, they are unique and of special importance
merely because they are undeveloped and should be protected from mineral development
of any kind and from ORV and automobile use.
The WSAs are also worthy nf protection because uiimotorized recreation is given so
little emphasis in thfi preferred alternative. In general, development and motorized
recreation are the focus of the RMP, while virtually no areas are reserved for non-mortorized
activities. This can hardly be considered multiple use. Regardless of eventual designation as
Wilderness, more than 6% ot the areas should be reserved for undeveloped, unroaded
recreation. We urge BLM to provide more opportunities for semi-primitive, non-motorized
recreation — well beyond that in the preferred alternative
Another example of the short shrift given to all but extractive activities is the lack of
up-to-date vegetation data, Whik> the DEIS slates that one of the three principal planning
issues to be addressee tn the RMP EIS is vegetation management (DEIS at 11), the entire
analysis appears to depend upon vegetation surveys conducted nearly two decades ago,
between 1977 and 1979 [DEIS at 135}, A greater time has passed since the vegetation was
assessed than the proposed RMP will likely be In effect. Furthermore, the DEIS defines
ecological condition as the currant vegetative composition compared to the potential natural
community (DEIS at 135). Eighteen year old data cannot be used to specify the current
condition Using such old data is a lalal flaw and is a violation of 43 CFR § 1610.4-3.
in general, we support strong environmental protection measures and the protection of
resources in short supply in the RA and nationally. This means prohibiting development in
undeveloped areas and protection of unique wildlife and plant resources, waterways, and
the like We believe resource extraction should not get the emphasis is has goiien from
BLM While alternative C goes farther than the preferred alternative to protect some of the
narural values, ii does not go nearly far enough. There is no alternative offered in the DEIS
which protects the wildlife, plant, and natural values to the extent we believe is necessary to
protect the public interest and meet the requirements of law.
National Natural Landmarks and ACECs
In general, we support the designation o: Fifteenmile Creek. Meeteetse Draw, and
Upper Owl Creek ACECs. We also support the designation of Gooseberry Badlands, East
Ridge- Fifteen mile Creek Badlands, and Taxman Mountains as National Natural Landmarks
(NNLs). We urge BLM to withdraw the ACECs and NNLs, as well as the WSAs. from oi!
and gas leasing and from hard rock mining
Specific Commenis
Pace 5.T 1 We do not agree with the statement that "each [alternative] represents a
complete and reasonable resource management plan" because each alternative makes
the entire RA open for oil and gas leasing. For this reason, we believe that none of the
HWIveraity Auodafcs • Comntems <:n lirass Zmnt RM= DsiS
alternatives is reasonable and that the entire process is contrary to multiple use as
defined in 43 CFR 6 1601.0-5(f).
Page 7: Selection of Preferred Alternative The second statement in this section, that
''Before restricting development, was the potential for occurrence of energy and
mineral resources considered'" implies mat protection measures were more likely
applied to areas without potential for development. This is backwards. Protective
measures should be applied to areas tha: require protection, regardless of the activity
which might be envisioned
Page 8. 91 2 The phrase 'conserve their richness o.' plant and animal species" should be
changed to reflect native plant and animal species
Page 8, SI 3 Assessing biological diversity by assessing habitat has many shortfalls and
generally does not take into account a number of factors such as habitat effectiveness,
spatial considerations, and population status. Actual, on-the-ground, quantitative
measurements of plant and wild.ife populations are required.
Page 8. Development of Mitigation Needs This is the first discussion in the DEIS regarding
protective measures and it is unclear, throughout the document, exactly what
mitigation, stipulations, and other measures will be used to protect the environment.
The first paragraph states that each alternative included mitigations to protect or reduce
adverse effects to resources. We could not find a list of specific mitigation requirements
in either the DEIS or the other information prepared by BLM1. Is the DEIS referring to
the differences between alternatives listed in Table. 2 and Table 3? If nol, where are
these measures spelled out? We believe that concrete measures should be applied to
activities, regardless of alternative, which would protect environmental values, wildlife,
and plants. II a giver, activity would have negative environmental impacts, strong
protective and mitigating measures should be applied (if the activity Is approved),
regardless of alternative. Do measures required to protect the environment and comply
with environmental protection laws and policy really depend upon which alternative
RMP is under consideration?
Page 9. Wilderness As mentioned above, the WSAs, if not designated Wilderness by
Congress, should be protected by designation as ACEC or other administrative action.
564.3
Pago]
Page 9. Wild and Sci
I .1- M ■
We disagree that no public lands were found to meet the
eligibility criteria We believe that the South Fork of Owl Creek meets the criteria and
should be designated a Wild and Scenic River. Regardless of designation, the river/nver
corridor should be protected from oil and gas exploration, leasing, and development as
well as oilier mineral entry The nver and corridor should also be protected from roads,
impoundments, hydroelectnc facilities, and other developments. We urge BLM to
pursue a withdrawal from entry under the 1872 mining act.
Paoe 11. Access We believe that there are already enough, or even too many, roads on
these public lands. No new roads are needed in the RA arid we urge BLM to construct
no new roads and to eliminate those roads that are not needed or are contributing to
resource damage such as sedimentation, wildlife impacts, etc. ___^___
1 Wo received t fleewment flnfflJtd Wyoming BLM Stendtud Mitigation (3 uidetinos for Surf Qce-Ditfrubing Activities
but tfiift contained only boiler plate language and generic statements. In addition, most of tha boiler-plate included
caveats such as "exception, waiver, of modification a; mis BrrritaWn may be approvod in writing.. " This is hardly
Strong protection.
491
564.4
Page 13. Developing Alternative Please see the comment above for Page 5,1 1.
Page 14. Elimination of Timber Harvesting The rationale in the DEIS for not
considering the elimination of timber harvesting is preposterous, incorrect, and
unsupportable. We coLild not disagree more with the "cut it down to save it"
philosophy embodied in the DEIS. Disease, insects, and fire are completely natural and
are in fact essential components oi forest ecosystems. The key to forest health is
maintenance of natural processes, including fires, insects, and dead and dying trees.
There is a large body of information supporting these principles. On the other hand,
logging and roads are not natural processes and are not necessary for forest health.
Human disturbance and fire repression — not fire or insects — remain the greatest threat
to forest ecosystem integrity. The public's forested lands should not be created by BLM
as industrial tree farms. Custodial management, including a let bum policy for
lightening-caused fires, is the appropriate approach. Furthermore, the impacts on
native wildlife of forest fragmentation caused by clearcutting, group selection cutting,
and roads are measurable but have not been taken into account in the DEIS.
Subsequent environmental documents (supplemental DEIS) should include a
quantitative analysis oi the effects ol forest fragmentation on forest species, especially
those dependent upon interior forest, and show how these effects will be mitigated.
Finally, we know of no refereed scientific papers in the literature which show that
"harvesting of forest products helps sustain the ecological processes that maintain the
healthy condition of the forest" and we believe this is simply arm-waving on the part of
BLM. If you have any documents which show that timber harvest is better than fire
and other natural disturbances, please send them to us and include appropriate
references to these papers in subsequent environmental documents. We urge BLM to
eliminate commercial Limber harvest from the selected alternative.
The following communis on Table 2 refer in general to the preferred alternative.
Page 15. Table 2 As mentioned previously, some sort of numbering scheme should be
added to Tables 2, 3, 15, and 16 so that specific portions o: the tables can be easily
referenced. Also mentioned previously, the information in Table 2 should be
reformatted for easier reading and so that the differences berween the alternatives can
be more easily discerned Those features, actions, etc., which are the same across all
alternatives should not be listed in the table showing the differences between
alternatives. Those items in common should be shown separately and should be
described only once For example, some of the items listed in Table 2 appear to be
similar to mitigation measures or stipulations and many apply lo all alternatives
analyzed. If these are indeed protective measures, they should be presented as such in
a different table.
Page 20-23. Table 2 Fire management appears to be identical in all alternatives. A range of
alternative fire management approaches should have been included in the alternative
management plans, in addition, the impacts of the fire policy on the various
resources — including economic analysis are not discussed anywhere in the
Environmental Consequences chapter. These are fatal flaws in the DEIS.
In general, we believe naturally occurring fires should be allowed to bum unless there
is a threat to human health or safety or species of special concern. In undeveloped
Biortveisfr AsjosialoJ - CoTTcne -;n lira:; U>l'> KM"Nt.;
564.5
areas such as the WSAs, naturally occurring fires should not be suppressed. If for some
reason fires are fought in undeveloped areas, only non mechanized equipment should
be used.
Regarding the use of prescribed fire on page 23: It is ludicrous to "rehabilitate old
timber sale areas" by prescribed fire when allowing natural fires to burn, without having
environmentally damaging timber sales, would obviate the need for such prescribed
fires.
We are wholeheartedly opposed to the use of prescribed fire or mechanical treatments
to increase forage for domestic livestock. The removal of sagebrush, juniper, and
Umber pine for the sole purpose of increasing forage is unwarranted. Privately owned
domestic animals should not be given preference over natural processes and wildlife on
the public lands.
Page 25. Table 2 As mentioned previously, forest health is not a reason to cut down the
forests on public lands Mistletoe and mountain pine beetle are components of the
natural forest and are not an adequaie reason for industrial cutting. There is no
compelling reason to have commercial harvesting on these lands, and we oppose
commercial timber activities on the few forested areas of the RA. The language in the
Management Actions part of the Forestland Management section of the table reflects
an industrial forestry perspective, not an ecologically informed one; this is directly
contrary to the principles of ecosystem management, which seeks to work with natural
processes, not against them.
The 15 year restocking standard is absolutely inadequate and unsupported and should
be 5 years as a maximum We oppose any clearcutting on the public lands, and we
oppose any road building, especially i: il is for the purposes of timber sales If there is
any scientific basis for wildlife needing industrial cutting (and we believe there is not),
please make it available to us and include i: (or references to it) in subsequent
documents.
Page 35. Table 2 The Right ot Way avoidance areas in Alternative C should be applied
to the preferred alternative These imponar.t wildlife areas should not be subject to
rights-of-way under any circumstances.
Page 38. Table 2 In situations where resource damage is occurring from livestock
grazing, livestock should be removed from the public range. If for some reason
livestock are not removed, any fences, construction, etc. undertaken to prevent
damage should be paid (or by the owner of the livestock The public should not have
to pay to prevent damage to public lands from domestic livestock owned by private,
for-profit extractive operations
Page 41, Table 2 What does it mean that "livestock grazing would be managed to
enhance riparian stream habitat..." ? Grazing cannot be used to fix the problems that it
most likely caused.
Page 43. Table 2 As mentioned previously, it is neither acceptable nor in compliance
with law and regulation to make the entire RA open to oil and gas leasing. In addition,
( CommMtt wiC-nssCrwrHMPOfJS
564.6
the range of surface occupancy stipulations presented is inadequate to provide a
reasonable range ol alternatives or to meet the multiple use mandate
Pace 47. Table 2 We support the off-road vehicle restrictions in the preferred alternative
and urge the BLM to restrict ORV use in the entire RA to designated roads and traits.
We also support increased funding for enforcement of ORV restrictions as well as
prompt and severe penaities for those found to be in violation of such restrictions,
.Page 49. Table 2 If the management objective for recreation is to enhance opportunities
for primitive recreation (as is stated on p. 49), all remaining undeveloped areas should
remain undeveloped. We support this concept and urge protection of unroaded areas
as Wilderness and ACF.Cs. Trie oil and gas, timber, and grazing activities in the
preferred alternative would not allow for enhanced primitive recreation opportunities
and are therelore in conflict with the management objective for recreation.
Page 51. Table 2 We do not support Lie construction of any additional roads, even for
recreation.
Page 53. Table 2 The wording of the vegetation management objective makes it clear
that the emphasis of BLM is on timber production and livestock. We oppose this
approach and believe that the public is besl served if wildlife, rare plants, and
undeveloped area protechon are given the greatest emphasis.
Page 53. Table 2 The actions under the preferred alternative for Candidate and T&E
sp«ci«s are not adequaie 10 protect valuable public resources and are not in
compliance wiih applicable BLM Manual requirements. The manual at 6810.06 (C)(1)
requires that BLM "Determine the distribution, abundance, reasons for current
status, and habitat needs for candidate species... and evaluate the significance of
the lands administered by BLM or actions in maintaining those species."
(emphasis added;. We could not find anything in the DEIS or supporting
documentation that indicates Bl M met the requirements of this provision,
Because the required evaluations of significance mentioned above were not performed,
it is likely that all of the alternatives analyzed, including the preferred alternative, are
not in compliance with BLM Manual 6840.06 (C)(2) (b) through (d). These provisions
require management plans for candidate species, specific habitat and population
management objectives designed for recovery, strategies necessary to meet those
objectives, and monitoring of populations and habitats to determine whether
management objectives are being met
Page 57,, Tabje 2 As mentioned above, the approach to forestland vegetation presented
in the DEIS which works against rather limn with natural processes- -is not consistent
with ecosystem management pnnciples
The DEIS fails' to offer the scientific basis BLM is relying on ior 10% old growth
management'-1 What exactly does "Ten percent of the forestlands would be managed
for old growth" mean? Dues it mean that 10% will be reserved in an old growth
condition and designated as protected? This needs to be clarified in later documents.
Page 63. Table 2 We support efforts to improve water quality and increase the
percentage ol properly functioning riparian areas. The preferred alternative does not go
in (kiss Cram. RMPGEiS
564.7
far enough to halt damage, however. We advocate complete removal of domestic
livestock from impaired areas— particularly riparian areas. We also support additional
funding for enforcement of protection provisions, stocking levels, etc.
Regarding the use of vehicles, we believe all motorized vehicles should be restricted to
designated roads and trails. Dues the prohibition against driving on wet soil or slopes
greater than 25% apply lo roads and trails, everything, or just off-road? This needs to
be clanfied.
Page 69. Table 2 The population and species references under the Wildlife and Fish
Habitat Management Objective should emphasize native species only. Diversity for the
sake of diversity is not the point. Maintaining viable populations of native species is the
point.
Page 70, Table 2 The caveat "To the extent possible" is not acceptable if the wildlife
population objectives of the Wyoming Game and Fish are based on scientific
information such as ecological carrying capacity, etc. Who defines what rs "possible"?
As mentioned above, the DEIS alternatives do not meet the requirements of the BLM
manual fur Candidate T&E species
Page 72. Table 2 A lull analysts of the ecological impacts of predator control activities Is
necessary before any predator control activities take place. No lethal predator control
should be allowed on public lands.
Paqe 74. Tab.e g Native species should be emphasized in riparian areas Exotic fish
should not be introduced.
Page 75 Table 2 Rehabilitation efions on Kifieenmile Creek watershed should be paid
for by the parties responsible for the degradation wherever possible. If it can be
determined that particular permittees are responsible, they should be charged for
reclamation costs II structures need to be removed to meet environmental goals, those
who placed the Structures should pay for the removal
Page 79, Table 3 We support Alternative C Wildlife Resources constraints. Under the
preferred alternative, the constraints begin with the phrase "Unless site-specific
environmental analyses demonstrate thai adverse effects can be mitigated or
avoided . . " If this caveat is to be retained, a large-scale, cumulative impacts analysts
should be required in the sile-specilic environmental analysis.
Page 132, first *?. The statements about forestland production show a clear extractive,
commodity bias end have nothing to do with the ecological condition of the forested
lands To reiterate from above, this is not a commercial tree farm and it should not be
managed as such, Cutting a forest merely because it is old is inappropriate.
Page 153 and Table IS This table is actually a description of the alternatives, not a list
of assumptions. Much of the information here should have been presented in other
chap:ers
Page 160. Table 15 The range ol alternatives lor active preference grazing is unreasonable
and inadequate to meet the legal and regulatory requirements.
492
Biodiwnity AuscaMs Omrnwits or f.r.js "nwk RM» DElS
564.8
Page 193. Socioeconomics We find the economic analysis totally unsupported and, at face
value, simply preposterous. Subsequent documentation should clearly explain the
figures and th?. methodology, assumptions, etc..
Page 198. Wildlife Habitat The issues of fragmentation of wildlife habitat must be
addressed and quantified, especially "hose from roads and timber harvest.
Page 202. Preferred Alternative Summary The description o! forest structural diversity is
unsubstantiated and erroneous. It does not accurately porrray the value to wildlife of
older forests This again is a fatal flaw
Thank you for considering these comments.
Jeff Kessler
for Biodiversity Associates
BUDD-FAi,EN LAW OFFICES, P.C.
RECEIVED
565
MAY t 0 1995
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May a, 299^
QS&T I F IED /RETURN RECEIPT
g Z 091 063 721
Mr. Bob Rose
P.O. Box 119
Norland, WY B2401-0119
Re: Comments far Grass Creek Resource Area Plan
Dear Sir:
On behalf of Hillberry Cattle Company and Tim Hart, this
letter contains comments to Lhe Bureau of Land Management (BLM)
Grass Creek Draft Environmcr.tal Impact statement (DEIS) and
proposed Rcaource Management Plan (proposed RM? or Plan) .
Hillberry Cattle Company is the owner of a ranch in the Gracs Creek
Resource Area . Tim Hart , who has leased the ranch for
approximately ten years, is tha BLM permittee on the Suifalo Creek
and Coal Creek allotments and is one of the permittees on the
Pi'otiptect Common allotment. The Hillberry Ranch consists of private
property, private water rights, state leased lands and grazing
preference to 1,896 Animal Unit Months (AtlMs) of livestock grazing
on federal lands in the Buffalo and Coal Craek allotments. In
addition, they have preference co AUMs in the Prospect Commons
alloLment .
565.2
This Plan directly and severely impacts the land owner and
permittee by (!) proposing a reduction in the number of livestock
they can graze on their allotments, state leased land and private
land, (2) forcing them to comply with certain utilization
restrictions, [3) allowing other uses such ag recreation and
wildlife tc dominate livestock grazing, etc . These concerns and
impacts are specifically described below. This Plan must be
revised to correct these concerns.
THE PLAN VIOLATES MULTIPLE USE MANDATES OF THE FEDERAL
LAND POLICY AND MANAGEMENT ACT
The Federal Land Policy Management Act (FLPMA) requires that
the BLM manage for multiple use. 43 U.S.C. § 1701(a) (?) . According
to BLM regulations, domestic livestock grazing i» a major component
of multiple use. 43 C.F.R. 5 1720.3-3. Although under the concept
of multiple use, not every uae must take place on every acre,
making 1 ivestock use inferior to all other uses throughout the
resource planning area is illegal. For example, the Grass Creek
proposed RMP manages for an increased yield 1 n wildlife and
recreation valuee and decreased domestic livestock grazing.
Specifically see the general criteria of the Plan listed on page 7
which states that grazing practices must be compatible with other
resource management objectives.1 Page 199 of Lhe Plan states that
livestock grazing restrictions will be used to benefit wildlife and
to increase their populations . In contrast , there are no
1 See also the discussion of ecosystem management and
biodiversity. These concepts guide the proposed RMP but ignore
traditional multiple uses.
565.3
requirements stating that other management objectives must be
compatible with livestock management. These examples, as wall ac
the specific RMP requirements listed below, violate multiple use an
defined by FLPMA.
A. Management of wildlife in Violation of Multiple Uae
1. Elk3
Page 142 of the Plan states that 21fi,000 acres o£ public,
state and private lands are currently elk habitat . Included in
that amount is 81,900 acres of crucial elk winter range. Page SB
of the RMP also notes that up to 76,000 acres will be managed to
achieve desired plant communities (DPC) for elk winter range and
44,000 acres will be managed to obtain the DPC most favorable for
elk calving grounds. Livestock grazing would not be allowed ir, elk
calving areas in 2 3 al Torments from May 1 to Juris 30 . In the
remaining areas described as elk habitat , livestock forage
utilization will be limited to 25% to 3 5* of the current year' s
growth if grazing occurs during the growing season. In other
portions of «lk habitat where livestock arc grazed when the plants
are dormant, the utilization limit will be 60%. Once the maximum
utilization level is reached, regardless of the type of use (i.e.
livestock or elk) that causes the maximum utilization, livestock
will be removed. in other areas designated as elk habitat , no
*■ Although the Hillberry Cattle Company is concerned about
the favoritism the BLM shows for elk over livestock, the
pro tec tione for elk apparently do not affect the Hillberry /Hart
allotments. However, the discussion illustrates that the concept
of multiple use is violated because livestock are subordinated
throughout the Resource Area.
493
565.4
livestock water deve 1 opmen L a will be allowed. Certainly the thrust
of the elk management guidelines is that livestock are dominated by-
elk in violation of multiple use.
2 . Big Horn Sheep'
Dp :o 13,000 acres will be managed to obtain desired plant
community objectives for big horn sheep. RMP at SB. Currently big
Kom sheep use 11,800 acres. Plan at 142. An additional 34,000
acrea would be excluded from domestic sheep grazing in favor of big
horn sheep, Id, Again this ie an example of how livestock are
dominated by wildlife use.
3 . Moose4
Page 14 2 of the RMP states that moose use approximately
107,000 acres in the planning area and up to 7,4D0 acres of habitat
will be managed for moose reproductive success. The riparian areas
within the elk habitat will be largely managed in favor of moose.
Tliis is yet another example of how other uses dominate livestock.
4 . Dear
Up to 304,000 acres In the Resource Area will have a desired
plant community objective for mule deer winter range. Of this,
Although the Hiliberry Cattle company is concerned about
the favoritism the BLM shows for big horn sheep over livestock, the
protections for big horn sheep apparently do not affect Lite
Kiliberry/Hart allotments . However, the discussion 11 Uist.rst.Ha
that the concept of multiple use is violated because livestock are
subordinated throughout the Resource Area.
Although the Hiliberry Cattle Company is concerned about
the favoritism the 3LM shows for moose over livestock, the
protections for moose apparently do not affect the Hillberry/Hart
allotments . However, the discussion illustrates that the concept
of multiple use is violated because livestock are subordinated
throughout the Resource Area.
565.6
clear that in these areas, the management cf livestock and the
welfare of the ranch operators will be secondary to the antelope.
6. Upland Birds
According to the Grass Creek proposed RMP, up to 343,000 acres
of habitat will be managed to achieve the desired plant community
for sage grouse. Map 35 specifically indicates that strutting
grounds and breeding and nesting grounds are located on
substantially all of the Buffalo Creek and Coal Creek allotments.
These Strutting and nesting grounds also appear to encompass
private and state lands owned or managed by Hiliberry Ranches. The
Prospect Commons allotment is substantially covered with sage
grouse habitat complexes, although the Plan apparently does not
define what a sage grouse habitat complex is. Again, this habitat
designation is of great concern to Hiliberry Ranches and Tim Hart
-is it is clear that the majority of their allotments will be
managed to . favor sage grouse production as opposed to livestock
production .
7. Wild Horses
Domestic horse use will be restricted on 14 allotments. In
contrast, the wild horse use area will be incrassad by 17% r.o
114 , 000 acres . To accommodate this increase , 1 ivestock grazi ng
will be decreased in this area and may be entirely eliminated if
utilization standards are net met. The wild horse area i3 located
in the Fifteen Mile Creek watershed which is designated as an Area
of Critical Environmental Concern (ACEC) . Additionally, the BLM is
willing to spend money to obtain water and land for the wild
565.5
1, 4 91 acres of riparian aroa, representing 71% of the entire
planning area, will be managed for deer. Therefore a total of well
over 1,000,000 acres will be managed for deer habitat.
The deer habitat provisions create a serious concern for the
Hiliberry Ranches and Tim Hart. Map 34 indicates that a
substantial amount of the Buffalo Creek allotment is designated as
deer winter range or deer crucial wintar range. A large portion of
the Prospect Commons and the Coal Creek allotments are also
depicted as deer crucial winter range. Within these areas,
livestock use will be held to strict utilization standards again
meaning that livestock will be removed once the utilization
standards are met. Therefore, it is clear that the majority of the
Hill berry/Hart allotments will be managed for deer over livestock
in violation of multiple use.
5. Antelopo
Page 147 of the Plan notes that there are 1,327,000 acres of
antelope habitat and that 126,600 acres are designated as crucial
winter range. Page 60 also notes that up to 111,000 acres will be
managed to obtain desired plant communities that best suit
pronghorn antelope winter requirements. An additional 4,700 acres
will be managed for a desired plant community thai, facilitates
antelope reproduction.
Hiliberry Ranches and Tim Hart are also affiafltad by the
designations for pronghorn antelope, large portions of the Buffalo
Creek and the Prospect Commons allotment are designated as
pronghorn winter or pronghorn crucial winter range- Again it is
565.7
horses, although the Plan does not indicate any BLM expenditures to
improve livestock production. Again this is a violation of
multiple use.s
B. Use of utilization Restrictions and Desired Plant
Communities Violate Multiple Uae
Utilization of forage is defined as j,3g or destruction of
vegetation from all usee including hail storms, insects, wildiife,
livestock er.e. RMP at 3 9.6 However, while this definition
recognizes that the other forage uses contribute to forage
utilization, only livestock will be removed from an area once
maximum utilization restrictions are exceeded. This is a violation
of multiple use.
There are several other reasons that the landowner/permittee
object to the proposed utilization standards. First, the
utilization levels are unreasonably strict. For example, in areas
where DPCg are act for wildlife species, livestock utilization is
restricted to 25% to 35%7 for use during the growing scoscn.
Although any regrowth that occurs after livestock are removed would
decrease the utilization, such decrease will not be measured.
In areas grazed after the plants are dormant, the utilization
levels are 60*. Still because no other wildlife species are
Additional wild horse concerns will be further addres
1 As will be illustrated below, this definition
"utilization" is illegal under existing regulations.
hi.m manuals define utilization of 30* to 40* as light
494
565.8
ill
the
governed by these utilization requirements, wildli
clear advantage over livestock grazing.
Second, even though DPCs are established for the other forage
users, no area under the Plan wil3 be managed for livestock DPCs.
In addition, all vegetative treatments will be designed to benefit
DPCs. RMP at 42. Since there are no DPCs for livestock, it is
clear that none of the vegetative treatments will b« designed for
the benefit of livestock. For example, the Plan calls for 9,000
acres c£ prescribed burns*1 (a burn is a form of vegetative
treatment,! therefore no burns will be prescribed for livestock
benefits. RMP at 184.
Third, on page 39, the Plan states that grazing strategies
will be designed to accommodate key plant growth and their
management objectives . Again these objectives favor wildlife or
vegetative management not designed to improve livestock grazing.
This is a concern to Hillberry Ranches and Tim Hart because the
majority of the forage management on their allotments will be in
favor of deer, antelope and eage grouse. Again this is a violation
of multiple use.
C. The Planned Reduction in Livestock Grazing Violates
Multiple Use
Table 17, page 190 anticipates a decrease in the active
livestock preference from 101,000 to 66,000 AUMs. Such reduction
! These burns are to improve habitat for elk, deer and
moose. RHP at 23 and 184.
565.9
will include a reduction of the AUYs on private and state lands."
Many of the AUMs which are considered unsuitable for livestock
grazing" will be managed for elk, moose, sheep and wild horses.
On page 70, the DLM also expresses the intent to manage its land
for the Wyoming Game and Fish Department's (WGFD) habitat
objectives. Although the landowner/permittee have not had the
opportunity to comment on these objectives, it is certain that no
objectives for livestock habitat are included. Again, this is a
violation of the multiple use concept.
Second, although the 3LM is actively pursuing plans to
■nt:r^3KK recreation, wild horses and wildlife, the Plan
specifically forbids any increase in the active preference for
livestock grazing. See pace 71. The result is that livestock
operators will have no opportunity to regain their preference AUMs
that are currently held in suspended non-use . In addition to
violating the multiple use concept, this also violates FLPKA. In
the past, Hillberry Ranches have agreed to cuts in their native
AUMs and to participate in range improvements so that these AUMs
would be returned when the forage improved. However, the AUMs
resulting from improved forage will, along with existing livestock
AUMs, be taken from livestock to increase wildlife.
* AUMs on private and state Land will be decreased by over
19,000 AUMS.
10 The questionable suitabi '. ity criteria used by the 3LM
will be discussed in greater detail below.
565.10
D. Other Multiple Use Violations
In addition Lo Lhe above comments, the following points also
illustrate that livestock are not being managed as an equal
multiple use.
1 . While the Plan includes provisions to fence riparian
areas from livestock, it includes no similar provisions to fence
wildlife or wild horses from riparian areas, nor does it even
lecoynize that wildlife and wild horses can impact riparian areas.
2. The above comment is also true for rar.gelands.
3 . Page 26 of the RMP commits to increasing aspen Cor
wildlife.
4. On page 72, the ELM states that it will manage riparian
areas and reservoirs for water fowl production, There is no
mention of mitigating the affects of this policy on livestock
grazing.
5. 26 miles of riparian stream will be managed for game fish
and another 6 0 miles will be managed for non-game fish. Again,
there are no such areas managed for livestock.
6 . Pages SI to 53 discuss the monetary resources the BLM
will spend to encourage recreation. Again, no money will be spent
by the 3LK to encouraqe livestock production.
7. On page 72, the Plan notes that fences will be modified
to favor wildlife. There is no discussion however on how this may
affect livestock and there is no discussion ot fence modification
to improve livestock production. Again because wildlife arc being
managed over livestock, multiple use is violated.
565.11
8. The table on page 126 shows that although livestock is a
relatively small factor in causing erosion, the BLM will reduce
livestock numbers to reduce erosion. Specifically the Plan states
that' livestock grazing is widely dispersed, therefore erosion
effects must be addressed- However, wildlife is also widely
dispersed and there are no provisions to mitigate wildlife caused
erosion; indeed, the Plan does net even acknowledge that wildlife
can cauce erosion.
Tn summary, the Hillberry Ranches and Tim Hart object to the
elevation of recreation and wildlife over livestock grazing
throughout the entire planning area. Such dominance can be seen by
the BLM' s (1) uso of DPCs and utilization restrictions favoring
wildlife, (2) willingness to spend time, manpower and monetary
resources to enhance wildlife habitat and encourage recreation and
(3) planned reduction in AUMs. 3ecause these actions violate
federal law, this Plan must be withdrawn and revised or it will be
successfully challenged.
THE PLAN VIOLATES THE TAYLOR GRAZING ACT
The primary purposes of the Taylor Grazing Act (TGA) are to
protect the range resource and stabilize the livestock industry.
Faulkner v. Waf.t, 661 P. 2d 309 (9th Cir. 1981); Barton v. U.S., 609
F.2d 977 (9th Cir. 1979); Chcurr.os v. U.S., 193 F.2d 321 (9th Cir.
1951) . However, the RMP which predicts at lease a 35% cut in
livestock AUMs, which will not meet these purposes."
11 Although the drafters of the BLM Plan have referred to
the 35% cut in livestock grazing as a "moderate" decrease,
Hillberry Ranches, Tim HarL and moat other livestock operators take
495
565.12
It: is also a violation o£ the TGA Lo subordinate livestock
grazing to wildlife and recreation. An Btated herein, on page 37,
Che RMP preferred alternative states that there can be no increase
In the current active preference. The use of the RMP to eliminate
the suspended grazing preference discourages ranchers from
participating in the development of range improvement projects .
Such a policy is purely outside of the Taylor Grazing Ace . Tn
addition, the principles of the Taylor Grazing Act are violated in
that the BLM policy of not allowing any increase in active use
means that the ranchers are precluded from receiving any benefit
from range improvement projects in which they have participated in
the past. Again if ranchers cannot increase their active use by
increasing forage or water availability through range improvements,
there is no incentive to participate in such projects.
Second, a substantial portion of the Grace Creek Resource Area
is made up of state and private lands . Many of these state and
private lands are involved in exchange-of -use agreements, allowing
the Rt.iM to assume management of these lands which are included
within allotment boundaries. The understanding in these exchange -
of-vise agreements is that the land would be managed for the benefit
of livestock. 1J However the BLH, by subordinating lives Lock.
great issue to this . If the drafters of the BLM Plan were
guaranteed a 35% or greater decrease in their income by the year
2005, they probably would not characterize it as "moderate."
17 On page 166, the BLM estimates that there was a total of.
256,400 visitor days within the planning area on all lands. The
recreational use of the BLM lands is estimated at only 81,175. The
BLM assumes that under the management of the preferred alternative,
the total recreation days In the planning area would be 373,435.
12
565.13
grazing throughout all allotments, necessarily subordinates the use
of the state and private land in the same manner, thereby violating
the exchange - of -use provisions under the blm regulations drafted
pursuant to Taylor Grazing Act and the FLPMA. 4 3 C. F.K . §
4120.2 (b) .
Third, Section 9 of the Taylor Grazing Act is also violated,
Section 9 guarantees the opportunity for an administrative appeal,
to an impartial hearing officer, for an evidentiary hearing,
regarding any decision negatively affecting the use of an
allotment. The proposed RMP mandates that each AMP be developed
with many provisions that will seriously impact livestock grazing.
However, there will be no appeal of those provisions at that time
they are written into the individual AMP because those provisions
are mandatory by their appearance in the RMP. While it is true
that the proposed RMP can be protested, the guarantee of Section 9
of the Taylor Grazing Act for a evidentiary hearing before an
impartial decision maker is lost.1'
Finally the BLH policy of managing its lands for the habitat
objectives developed by the Wyoming Game and Pish Department is
Only 118, 200 of those visitor days would be on BLM land.
Therefore, 255,238 of those visitor recreation days are apparently
□n state and private land . Tn effect , the BLM is managing the
state and private lands within the allotment boundaries to increase
recreation by 150,01.3 visitor days. The blm has no authority to
manage exchange -of -use lands in favor of recreation use.
13 Specifically, if an individual permittee protests the RMP
to the State Director, he will be at a disadvantage because he
cannot state at this time exactly how his individual allotment will
be affected, although he knows the effect will be negative . See
comments regarding desired plant community objectives , riparian
utilization standards, range utilization standards, etc.
13
565.14
also a violation of the Taylor Grazing Act . Allotments were
created pursuant to the Taylor Grazing Act and are defined as an
area of land managed for livestock grazing. 43 C.F.R. 4100,0-5.
Managing the allotments to obtain the objectives of a State Game
and Fish Department is a violation of the Taylor Grazing Act.
THE PROPOSED RMP VIOLATES THE PUBLIC RANGELANDS
IMPROVEMENT ACT (PRIA)
The Public Rangeland Improvement Act (PRIA) requires that
allotment management plans (AMPs) be developed in consul tat ion,
cooperation and coordination with the affected permittees and land
owners. 4 3 U.S.C. 5 1752(d) . However, there are numerous examples
in the proposed RMP where very important elements of the AMPe are
predetermined by the RMP. These will significantly and negatively
affect the livestock permittees and will deprive them of their
procedural rights pursuant to PRIA.
For example, the proposed RMP dictates that desired plant
community objectives for various types of wildlife habitat will
affect the majority of the land in all allotments. The RMP itself
also determines the number of AUMs which are unsuitable for
livestock grazing in each allotment, even though an on the ground
analysis has not been conducted. The proposed SMP predetermines
the ecological condition class of each allotment based on data that
is outdated. Wildlife management objectives have been set for
nearly a 11 riparian areas and reservoirs . The RMP habitat
objectives necessarily means that less livestock can be grazed .
These object ivee must be included in individual AMPs without the
consultation, cooperation and coordination required per PRIA.
565.15
THE PLAN VIOLATES BLM REGULATIONS REQUIRING DECISIONS BE MADE
BASED ON MONITORING DATA
The regulations drafted pursuant to the FLPMA, the Public
Range lands Improvement Act (PRIA) and the Taylor Grazing Act (TGA]
require that resource decisions be based on sound monitoring data.
43 C.F.R. § 4110, 3 et sag. For the categories li sted below, the
3LM does not include, on the record, the data justifying ita
decisions .
A. Reduction in aums
The 3LM Plan states that there will be a 35* reduction in
livestock AUMs. Unfortunately, the reduction is even greater than
the BLM states because although the current grazing preference is
for 143,140 livestock AUMs, 41,699 o£ these AUMs are in suspended
non-use. Therefore, the active preference in the Resource Area on
BLM lands is 101,451 AUMs. There are an additional 55,904 AUMs
available on state and private lands . Therefore , the total AOMs
available to livestock operators currently is 157,355, and if the
suspended AUMs were activated, the total AUMs would be 199,044
AUMs. See Table 3-2, Appendix 3. In addition, the original active
preference on BLM lands in the Grass Creek Resource Area was
184,000 AUMs. Livestock operators in the Grass Creek Resource Area
have already been cut by twenty two percent (22%) {front 184,000
AUMs to '.01,451 AUMs). The BLM Plan now calls for a reduction ir.
BLM AUMs to 66,000 by the year 2005. Therefore, the BLM proposed
RMP actually allows a sixty- four percent (64*) decline from the
orig inal blx preference and a thirty -five, percent (35% ) decline
from the current active preference.
496
565.16
Currently there are also 55,904 state and private AUMs.
Pursuant to the Plan, these state and private AUMs will be cut by
IS, 534 AUMs or 35%, to 36,370 AUMs. The 3LM lacks current valid
data to justify these cuts.
B. Utilization
Utilisation levels are not a scientifically valid method upon
which to base range management decisions reducing AUMa .
Specif ically utilization levels do not establish the resource trend
on an allotment; grazing reductions must be based on resource
conditions or trend data that show a deterioration over Lime. Once
trend is establ iahed, utilization data car. be used to determine how
utilization has affected trend but, again, it is inappropriate to
use utilization data as a soul basis for cuts to livestock AUMs.
Please see the article attached as Appendix i by Lee Sharp, Ken
Sar-ders and Neil Rindey entitled "Management Decisions Based on
Utilization - Is It Really Management?"
C. Suitability
The 3LM lacks the data necessary to determine which allotments
are and are not suitable for livestock grazing. For example, on
page 176, the Plan states that 43,850 AUMs would be eliminated
based or. BLM "suitability criteria.""
With regard to the Hillberry/Hart allotments, the table on
page 251 shows that the suitable AUMs in all three 13) allotments
M The range management profession outside of the BLM has
strongly objected to these suitability criteria sinc:« the 1980's.
The 3LH itself determined, in 1584, that these suitability criteria
were based on failed technology. As a result, the BLM itself
stopped using this suitability method in "-9S4 .
565.17
are significantly below the total authorized grazing use.
Hillberry Ranches and Tim Hart have used the Freedom of Information
Act (FOIA) to obtain all LiLM information on Lhese three (3)
allotments. The BLM file cor.tains no field data establishing
suitable AUMs. However, the proposed RMP'e suitability criteria
demands that their allotments suffer further reduc Lions in
livestock grazing. The bottom line is that the proposed RMP is
being used to arbitrarily cut AUMs without scientific data
supporting those outs.
D. Trend Data
Ak stated above Lhe proposed RMP would mandate reductions in
most, if not all, allotments even thought there is no current data
which establishes downward trend cue to livestock grazing. On page
297, the Plan defines Lrsnd data as the direction of change in the
condition or health of the range usually gauged in relation to its
natural potential and determined by observation over a period of
time. This definition is inaccurate . Trend data indicates the
condition or health of the range as determined by observation over
a period o£ t ime; attempting to attach trend in relation to
"natural potential" is incorrect.
With respect to the allotments utilized by Hillberry Ranches
and Tim Hart, the BLM has no trend data. The Table on 3-7 shows no
transects for trend data or. any of their allotments. Tn addition,
the allotment fiLes obtained from the BLM under FOIA contain no
trend data. Therefore, the BLM has no basis for determining
whether these three !3) allotments are in a static, upward or
17
565.18
downward trend. Without such information, any cuts to the AUM3 on
-these allotments can only be labeled as arbitrary and capricious.
Or. page 257, Table 3-7, the BLM purports to have use pattern
mapping data for the Buffalo Creek allotment. Use pattern mapping
is not a sufficient baoio on which to base aum reductions.
Finally on the Buffalo Creek allotment, there is a reservoir
which washed out several years ago. Hillberry Ranches and Tim Hart
have repeatedly requested that the BLM repair this reservoir,- the
BLM has declined to do so. Hillberry Cattle Company hae also
proposed to fix this reservoir in order to improve the livestock
distribution on the allotment. However, the HLM does not appear
willing to allow Hillberry Cattle Company or Tim Hart to utilize
the AUMs made available even if the land owner spends the necessary
money to fix the reservoir.
Since there is no adequate trend data as required by BLM
regulations, the AUM reductions mandated by this RMP should be
eliminated; any reductions must be based on proper scientific
evaluation, on an allotment by allotment basis.
E. Ecological Class
Table 3-4 purports to establish ecological class and acreage
on the publ ic land in each allotment . This information is
apparently based on a study by the Soil Conservation Service (SCS) ,
which is not reproduced in this document, completed in the 1970s.
The range conditions on the majority of these a! lotmcnts ,
including the Prospect Commons, Buffalo Creek and Crow Creek
allotments, have changed considerably since this data was gathered.
IS
565.19
Therefore, the validity of Table 3-4 is questionable given the
passage of time. As with most of the other information presented
in Appendix 3, the ecological condition of each allotment should be
set in consultation, cooperation and coordination with the affected
permittees and based on current data.
p. Desired Plant Communities
In addition to the comments above regarding DPCs, the
imposition of this requirement violates the BLM mandate for
adequate data upon which to base a decision. The Hillberry/liart
permittees are concerned that the D^Cs set for their allotments are
not achievable or attainable, specifically, it will take detailed
scientific monitoring to determine whether these DPCs are
realistically achievable. If they are not, the permittees should
not be forced to manage their allotments for a condition that
cannot be met . Again, adequate monitoring is needed before the
DPCs are implemented to determine if the BLM's goals con even be
met.
6. Erosion
Interested and affected parties cannot adequately comment on
the erosion portion of the preferred alternative because the data
which serves as the basis for Table 8 on page 126 is not presented
in this Plan. without the opportunity to review the methodology
used to obtain the data regarding erosion, there is no opportunity
for meaningful "comment which violates the planning regulations. Ic
is also interesting to note that Table B on page 12 G identifies
livestock grazing as a relatively minor source of erosion with only
497
565.20
temporary effects. However, a clear implication from page. 194 is
Char livestock grazing will be out baBed on erosion concerns. It
is further interesting to note that the Plan has arbitrarily bailed
to acknowledge that wi ldli f e can also cause erosion because
wildlife related erosion i3 not addressed.
H. Actual Use
Throughout the Plan, the BLM makes repeated references to Che
fact that permittees often do not utilize their full authorized
use. See, for example Table 3-3, Table 3-5 and the discussion of
the preferred alternative in Chapter 4. The clear inference of
these references arc that since livectock operators do not always
ub& their full authorized use, a reduction ir. use does not
significantly harm them. This inference is incorrect. First, the
5LM has chosen the years 1987 through 1991 and the years 1976
through 198 0 to determine average actual use. Both of these
periods were years of prolonged drought, therefore during these
years, livestock operators were running less cattle and removing
them early in order to protect the range resource . It is
unconscionable for the BLM to use their good stewardship as the
basis to justify cuts in their AUMs.
Hillberry Ranches and Tim Hart have often reduced their
livestock numbers or removed their animals early out of concern for
the resource. However, this does not mean that they do not wish to
fully utilize the authorized preference when range conditions
allow, if livestock reductions can be Justified by the fact that
average actual use has been less than authorized use, permit, tees
20
565.22
with emphasis on biological communities and natural systems to
ensure self sustained populations and an abundance and diversity of
wildiiie, tish and plant resources on the public lands.
The discussion of ecosystem management on page S is nearly ae
bad as that of biodiversity. The BLM claims that ecosystem
management is consistent with FLPMA. However the BUI cannot manage
the federal lands based on some policy that they perceive to be
similar to FLPMA. lB
It is Hillberry Ranches and Tim Hart's belief that the
biodiversity and ecosystem system management sections of this Plan
are an attempt by the BLM to implement the proposed regulations
know as Rangeland Reform ' S>4 . Because the Rangeland Reform
regulations do not take effect until July, thJ s action is ill
advised. If Rangeland Reform ia not successfully challenged in
Court, it may be changed in Congress . The BLM simply cannot
imp.ement a set of regulations that are not in effect and subject
to change.
There arc several specific areas in which the
landowner/permittee believe that BLM is implementing Rangeland
Reform '94. For example, utilization is defined in the current BLM
regulations as "the percentage of forage that has been consumed by
livestock during a specified period and the livestock grazing
utilisation pattern on the allotment." 43 C.F.R. 5 4103-5. in
contrast, the definition for utilization in the proposed RMP
l* The use of ecosystem management and biodiversity also
violates multiple use.
565.21
will have an incentive to utilize all cf their AUMs, even during
years when they feel it ia not in tba beat interest of the resource
or their operations.
Given th*C it is a violation o£ the terms and conditions of
the permit fur permittees to use more than their authorised use in
wet years to make up for AUMs not used in dry years, the average
actual use of past years will never equal authorized use.
Therefore, lowering authorized AUMs on an average actual use basis
is a never ending spiral. The use of authorized grazing as
compared to actual use is an arbitrary and capricious basis in
which to justify the currently proposed cuts in AUMs.
THE PLAN ADDITIONALLY VIOLATES BLM PLANNING REGULATIONS
The statutes governing the BLM's planning process are the TGA,
PRIA and flpma. The planning process is also governed by the
regulations which were adopted pursuant to these statutes. These
statutes provide no authority to manage the Grass Creek Resource
Area under the vaguely defined principals cf "ecosystem management"
or "biodiversity." Congress has never defined these terms nor has
it authorized the BLM to manage pursuant to those principals. Page
3 states "biological diversity is defined as a variety of "ife and
its processes, although vastly complex it concludes some measurable
distinctions like genetic differences within and among species,
species variations, associations of. species with each other and
their environments, and the patterns and linkages of those
biological communities across geographical ar«as . " The blm then
states that the BLM policy requires that habitats being managed
21
565.23
includes use from all Hources , not just livestock . This Is the
definition found in Rangeland Reform regulations.
Second, or. page 132, the proposed RM? discusses riparian areas
ir. terms of "properly functioning, funct ioning-at-risk and
nonfunctioning." This vaguely defined concept of riparian
management is also part of the Rangeland Reform regulations. There
is no authority to mange riparian areas in this manner. The
management criteria in Rangeland Reform must be eliminated £rom the
proposed RHP.
THE PLAN VIOLATES THE ADMINISTRATIVE PROCEDURES ACT (A? A)
The Administrative Procedures Act , !APA) & U.S.C. S SOI eL
&eq. , provides rhat administrative decisions must be made or. the
record and must be available for public comment. However, there
are several aspects of the Plan which represent conclusions drawn
from material that is not available for comment. For example, the
ecological inventory data from the Soil Conservation Service (SCSI
is not part of the current administrative record. rn addition, it
is unlikely that that material was gathered under the procedural
guidelines and mandates for public comment of the 3LM because the
Soil Conservation Service is not bound by the same federal planning
statutes. Because there was no opportunity for public comment on
this data, it cannot be used as a Oasis for BLM's decisions.
Sftcond, the proposed RMP will attempt to Rtaet, the Wyoming Game
and Fish Department wildlife hnbl tat objectives . Again, these
habi tat objectives were not developed pursuant to the planning
criteria that the BLM must follow. Therefore, the conclusions
498
immmaammoB
565.24
themselves, as wel 1 as Che methodology for reaching chose
conclusions, are not available for public comment.
Third, administrative decisions will be overturned if they arc
arbitrary apd capricious or not in accordance (rich law. 5 U-S.C.
5 706 i2) (a) For example, as stated above, forcing utilization
standards on livestock in favor of wildlife is arbitrary and
capricious and not in accordance with law.
Another example appearc on page 254 of the proposed Plan which
etar.ee "if livestock will be removed from the area during a growing
season, any regrowth will not be measured," Since the rcgrowth of
new plants during the growing season serves :a decrease the.
utilization, the failure to consider this regrowth in utilization
standards is arbitrary and capricious.
THE PLAN VIOLATES THE NATIONAL ENVIRONMENTAL POLICY ACT
The proposed RMP violates the National Environmental Policy
Act, (NEPA) 42 U.S.C. § 4221 for failure to consider a fill] range
of alternatives, for failure to include a true "no action"
alternative and for failure to include important considerations
effecting socioeconomic stability and the custom and culture of the
area. First, the BLM regulations at 43 C.F.R. § 1610. 4-^ state
that "one alternative shall be for no action which means
continuation ot presenL level or systems of resource use." The RMF
identifies Alternative A aa the no action alternative. However,
there are many provisions of Alternative A which clearly indicate
Chat it is not a no action alternative. Most notably Alternative
A will decrease AUMs from the current authorised use ot 130,926 to
24
565.25
111,450. Tnis does not maintain the current level of resource use
by the livestock industry and therefore cannot be considered a no
action alternative. Tn fact, Alternative A is more similar to the
preferred A ternative than it is to the current level of resource
uses . a
There 'are other examples of how Alternative A does not
represent : no action alternative. Alternative A calls for a
decrease in., the level of oil and gas production. The same is :r.:e
for hazardous materials and lands and realty management sections .
Under che livestock management section, Alternative A would limit
utilization of salt desert shrub ^nd salL bottom plant communities
to 30% to 50% « In other plant communities, Alternative A wqu! d
also limit the graair.g to 30% to 50%. Thece utilization standards
mean that livestock grazing will be eliminated once the utilization
from all types of usage or destruction has reached these amounts.
This is significantly different from the status quo.
On page 41, Alternative A would restrict livestock grazing
from May 1 to June 30 on 44,000 acres of winter elk habitat on 23
grazing allotments. Additionally, domesLic sheep grazing would be
restricted on 121,000 acres of pronghcrr. habitat in 64 allotments.
The desired plant community objectives are the same in Alternative
A as in the preferred alternative, showing that Alternative A in
not the status quo. The same problem occurs in the wild horse
management area. On page 70, Alternative A adopts the 19S9 Wyoming
came and Fish Department's strategic plan for wildlife habitats.
The above mentioned examples are by no means exclusive however they
25
565.26
suffice to 'show that the Plan is legally deficient as iL docs not
contain a tjrue no acLion alternative ac required by NEPA and Lhe
applicable .SLM planning regulations.
Second NEPA, 42 U.S.C. S 4521 et set?, and FLPMA require that
land use p ~ ns consider a full range of management alternatives.
California .. Berg-Jin, 513 F.Supp. 1C5 '(E.D. California 1979), rev.
in part, af.* 'd in part sub nam, California v. Block, 6S0 F.2d 753
(9th Cir. 982). Tho BLM Una not considered a full range of
alternatives.- the four alternatives ax'e much more similar than they
are different. For example, the access provisions on page 29 for
Alternatives A, B and C are identical to that of the preferred
alternative. On page 26, each alternative is required to be
consistent with wildlife objectives. See also page 17. Each of
the alternatives focuses on biodiversity and ecosystem management.
Page 4" of Alternative A requires periodic rest of the elk winter
area as do the other alternatives.
Most of Lhe restrictions on livestock grazing are the same or
practical 1 y the same in each alternative . The only difference
between alternatives is a si ighf. variation in the level chaL
livestock grazing AUMs will be cut. Each alternative is identical
wich rpspftcr to noxious weeds. Again this list of examples is by
:io means exhaustive however, it nerves to illustrate the point that
the 3LH has not considered a full range of alternatives-
Third, NEPA requires the agencies to "preserve important
historical , cultural , and natural aspects of our national
heritage- " 42 U.S.C. § 4 331 <b) (4) . Livestock grazing is an
565.27
important h storic and cultural aspect of the Grass Creek Resource
Area. However, rather than attempting to protect and preserve this
important historic and cultural aspect of the region, the BLM is
causing harm by subordinating this use to other objectives that may
ultimately lead to a demise of many of the area' a ranches. For
example, on page 192, the Plan projects an Increase in recreation
and discusses some or the management objectives to achieve this
increase. The BLM has net assessed what affect this may have on
I
Lhe 1 ivesr.ock industry. For example, as recreation increases it
usually follows that more houses, Mini Marts and other tourist
servicing structures will bo built. The land of ranchers who can
no longer make a living ranching due to the BLM' s management
restrictions will be converted into tourism Bex-vicing developments.
In addition, tho conversion of ranch land will have an adverse
affect on wildlife habitat. For example, due to the restrictions
some ranchers will go out cf business and sell their property to
developers or will aLLempt to mitigate their lo3S by fencing Lheir
private and state lands and managing them more intensively for
livestock grazing1' The fences on the private land may aEfect the
migration of wildlite. In addition, because they have lost their
traditional grazing AUMs, ranchers will be forced to provide less
lfi On page 119, the BLM notes that the majority of the elk
hunting in the area is based on privaLe land. However, if Che
private landG are fenced away from the BLM and managed more
intensively for livestock production or are sold to developers,
this elk hunting will substantially lessen.
27
499
565.28
wildlife habitat on their newly fenced private lands in order to
make them more productive for livestock. "
Table V on page 106 notes that the first cattle rancher in the
region was John D. Woodruff who setLled on Elk Creek i:i 1871. The
first irrigation ditch was built- in the 1860b. The federal
government is currently in the process of purchasing some of the
last remaining ranches in the Jackson Hole area to preserve the
area's ranching tradition. This action demonstrates that livestock
grazing 13 a hiotoric use. The Grass Creek Resource Area should
recognize this historic and cultural importance and protect it as
required to do under NEPA and the Taylor Grazing Act.
Fourth, the RMP does not consider socioeconomics as required
by NF.PA. The Plan the purports to increase tourism by 46V, however
the Plan provides no supporting documentation to support these
assumptions . On the other hand, it is certain chat livestock
grazing and the resulting economic contribution from that industry
will be seriously curtailed .
The proposed HM? also anticipates a reduction in full time
jobs associated with the natural resource industries. However, the
BLM assumes that those full time jobs will be replaced by
recreation and wildlife generated jobs. The BLM fails to address
17 For example, Hillberry Ranches and Tim Hart are nearly
certain to receive significant cuts on their "ir.common" allotment.
!See discussion infra). To mitigate this, Hillberry Ranches will
consider fencing their private lands. Once these private lands and
state lands are fenced away from the BLM land, Hillberry Cattle
Company will be forced to convert prime sage grouse, antelope and
deer habitats into pastures that are managed exclusively for
livestock .
26
565.29
the fact that recreation associated jobs usually pay less than
natural resource based jobs. For example, a job at a Mini-Mar r
does not pay as well as a job associated with the mineral, timber
or livestock industries. Therefore, even if full time employment
were to remain Lhe same, the average wage may well decrease.
On page 180, the Plan discusses various contributions to the
local economy. However, since none of the alternatives truly
represent the status quo, there is no economic analysis of the
contributions to the economy from the natural resource industries
and specifically the livestock industry if the status quo were
maintained. Each livestock AUM :s worth 532.43 in direct income
and S44.6B in indirect income for a total of 977.11 per AUM.1"
Therefore, the economic contribution of the livestock industry, if
analyzed under a true status quo alternative, would be
significantly greater than that which ia anticipated in the
preferred alternative. '"
Finally, the DEIS and RMP fail Lc predict the population
affects on the community. For example, the individuals who drill
for gas, hauls logs and run ranches are not the same individuals
ls See letter from Joseph 7. Vessels circulating background
information used in the Grass Creek Resource Management Plan to
estimate socioeconomic effects.
" The analysis of socioeconomics impacts contends that of
the 12.94 million dollars of economic activity generated by the
grazing industry that only 44V or 5.8 million dollars is derived
from livestock grazing on federal lands. However, this is
confusing because out of the 167,826 total AUMs ot grazing in the
area, 130,000 of those AUMs are based on ELM lands. This equals
70% of the AUMs in the resource area. It appears unreasonable that
78% of the AUMs would only contribute 44% of the AUM baaed economic
contribution. Please clarify these star.isr.ics.
565.30
who will take the jobs in the service industry. Therefore, the
result of the Plan is that many of the residents who make up the
existing employment base will leave in search of jobs in their
occupation.
Because of the BLM' s failure to develop a true no action
al ternative, the failure to analyze a full range of alternatives
and the failure to assess the effects of the Plan on socioeconomics
and culture, this Plan is legally deficient and can be successfully
challenged in Court.
THE DESIGNATION OF THE FIFTEEN MILE WATERSHED ACEC
AND ADDITIONAL WTLD HORSE HERD MANAGEMENT AREAS
DO NOT COMPLY WITH BLM REGULATIONS
Pursuant to the proposed RMP, the northern portions of the
Buffalo Creek allotment and one states land section within the
Buffalo Creek allotment will be included in the Fifteen Mile
Watershed Area of critical Environmental Concern (ACEC) . The BLM
regulations provide several criteria for an area to be eligible for
ACEC designation, however the portions ot the Buffalo Creek
allotment included in this ACSC do not meet this criteria . 43
C.F.R. $ 1610.7-2 requires that data shall be collected and
analyzed to determine whether there are areas containing resource
value systems, processes or hazards eligible for designation as an
ACEC. In order to be an ACEC, the BLM must consider (1) relevance;
the area shall be present a significant historical, cultural or
scenic value, fish or wildlife resource or other natural system,
process or natural hazard and !?.) importance; the above described
value, resource, system, process or hazard shall have substantial
565.31
significance or value. This cenerai-y requires qualities of more
Khan — locaj significance and special worth, consequence, mean,
distinctiveness, or cause for cencerr..
The Fifteen Mile Watershed ACEC may have some of the above
mentioned resources, however it docs not have importance of more
than local significance . Even if other portions of the proposed
ACEC meet the criteria for importance, the portions of the Buffalo
Creek allotment that ara currently within the ACEC do not. In
addition, a significant portion of the Buffalo Creek allotment11
designated as an ACEC is state land and is therefore ineligible.
The balance of the Fifteen Mile Creek watershed ACSC should be
reassessed i±s to whether it meets the importance criteria ir. the
BT.M pi annir:g regulations.
With regard to wild horse herd management, the preferred
alternative on page 66, proposes a thirty-seven percent (37%)
increase in size . That seems -. r.ecui table given that 1 ivestock
grazing ia being decreased by thirty-five percent (35%), The RK?
at page 66, also states that the horse area would be managed tor at
least seventy (70) and no greater than one hundred sixty 1160]
mature animals. Increasing the wild horse herd population above to
numbers that existed in 1971 is a violation of the Wild Hors* ar.d
Burro Act . Further, expanding the herd into areas that did not
" Please refer to the ACSC nap in the proposed KM?. H-.nce
the boundaries are close, it is possible that the Buffalo Cr-eek
allotment is not included aa part of the ACEC . However, based on
Lhe shaded areas of the maps, they appear to overlap.
500
565.32
contain horses in 1971 ts also a violation of the 1971 Wild Horse
and 3urro Act -
Finally, given that wild horses can be very hard or. the land
and riparian areas, the BLM must answer the following questions.
Has Che BLM considered the affects of the wild horse herd On the
ACEC objectives? If the AC.F.C nhj^ot-i vrr are not met, wi 1 L the BLM
reduce the horse herd? In addition, will the BLM reduce the horse
numbers if the utilization standards are not met? See Map 19.
What stepa will the BLM take to protect private land? Finally,
does the BLM have the budget to control wild horses when they
increase in size? Because of the adveiae affect that the increase
in wild horse ares and numbers can have on private property,
private property rights and investment backed expectations, the BLM
Should perform a takings implication assessment, pursuant, to
Executive Order 12360 regarding possible trespass of wild horses
onto private land.
MISCELLANEOUS CONCERNS WITH THE PROPOSED PLAN
1. On page 31, the Plan states that applications for desert
land entry on public lands would not be considered and that public
lands having agricultural potential and water would be considered
for disposal by sale or exchange only. This prevision is invalid
because it violates the desert land entry statutes. The desert
land entry statutes allow homestead entry to be made on arid lands
where the entryman can cause the lands to be irrigated. All landc
that fit the desert land entry statute criteria are available for
entry by an eligible entryman, unless formally withdrawn from
32
565.33
desert entry. The withdrawal of land from entry requires public
notice, publication in the Federal Register and protection of
existing rights . Unless this piocedure is completed, this
provision in the proposed Plan in invalid.
2 . In its discussion of noxious weeds , the Plan fails to
note that the National Undesirable Plant Management Act (NUPMAJ
requires federal agencies to enter into Memorandums of
Understanding (MOUs) with state noxious weed management aqencies to
control noxious weeds according to state law. Therefore, this
section should be written to follow state noxious weed law.
3. Map 7 in the proposed KMP depicts right-of-way
concentration areas and right of-way avoidance areas. Hillberry
Cattle Company is concerned that the map depicts a right-of-way
concentration area which crosses their private property. The 3LM
is hereby put on notice that the right-of-way concentration area
depicted on the map to cover private lands, contains no public
right-of-ways. Additionally, the BLM has not consulted with the
land owners reqarding the proposed right-of-way concentration
arcci3. Therefore, Hillberry Cattle Company hereby requests the BLM
to complete a takings implication assessment pursuant to Executive
Order 12360 in all areas where right-of-way concentration areas
cross or come near private land.
4. The proposed RMP discusses the pooaibility of
transplanting threatened and endangered species. RMP at 53.
Hillberry Cattle Company feels that the proposed RMP already makes
their livestock operation subordinate to other multiple uses and
33
565.34
that it endangered or threatened species are transported into the
area, they will be subordinate to additional objectives. Hillberry
Cattle Company would like to go on record as opposing any
transplanting of threatened or endangered plants or animals into
areas affecting their allotment or their private lands. In the
event that the BLM attempts to introduce endangered or threatened
species into the area, the affected landowners, permittees and
local governments must be compensated pursuant to applicable law.
5. The preferred alternative discusses Visible Resource
Management areas (VRMs) on page 62, stating that the BLM shall
maintain or improve scenic values throughout the planning area .
Map 19 depicts three (3) different resource management areas;
however, neither the map nor the preferred alternative indicate
differences between the three (3) classes. Hillberry Cattle
Company and Tim Hart appear to be effected by VRM class 3 rind VRM
c^ass 4. However, the Plan does not indicate how these individuals
may be affected nor is there any indication how the VRMs affect
livestock grazing. The BLM should expand their discussion of the
VRM since they encompass the entire resource area so that
interested individuals can assess if and how they are affected.
OTHER COMMENTS ADOPTED
The Wyoming State Grazing Board has submitted comments on the
oroposed RMP and draft SIS for the Grass Creek Planning Resource
Area. Hillberry Cattle Company and Tim Hart adopt those comments
and the issues raised therein as if they were specifically restated
in these comments.
34
565.35
The County governments effected by the draft EIS and proposed
RMP have submitted comments. Hillberry Cattle Company and Tim Hart
adopt those comments and the issues raised therein as if they were
specifically Btated in these comments.
REQUEST FOR RELIEF
Hillberry Cattle Company and Tim Hart respectfully request
chat the proposed RMP and the draft SIS be rewritten to correct the
technical arid legal deticiencies described above. Additional ly,
they request that a Takings implication Assessment (TIA) as
described by Executive Order 1263 0 be completed assessing the
effects of this Plan on their private property, private property
rights and investment backed expectationu .
Sincerely,
Frank J. Falen
BUDD- FALEN LAW OFFICES, P.C.
Hillberry Cattle Company
Tim Hart
[Included with this letter were pages from the RANCELANDS 16(1), February 1994,
annotated "EXHIBIT A"-ED.]
501
BECE1VEP
MAY-9BS5
BUREAU OF LAND SAHACESW i
b(cl6
To BLM C/O Bob Rocs
Grass Creek Area Draft EIS
P-0 Box 119
Worland Wy 82401-0119
Fax (307) 347-6195
I object to the significant financial impacts to businesses,
individuals (and consequently to Che 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 know! edgeable 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 mv
comments below. '
T obj ect t
Alternative
management decisions on each allotment
established and stated
the reduction of Grazing AUMs proposed in the
Real, current scientific data should be used to make
Targets should be clearly
I object to the expansion of "Wild Horse Management" areas X
recommend eliminating all "Wild Horse Management" areas in the
Grass Creek area RMP. Return all wild animal management to the
jtcte Game and ?ish, ar.d 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 sinal
expansion.
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.
I object to restrictions that hamper the current primary businesses
ana individuals who use federally administered 'lands to generate
income ana support our communities through taxes.
7 object to the severe and -undue number and level of restrictions
or. 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 .
566.2
1 object to the small consideration given to the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
snould also be factored in.
I object to the lack of detailed descriptions for restrictions.
L?5^?5t t0 Che discussi°n of threatened, endangered and candidate
wllOlltt species. specifically unsubstantiated Gray Wolf
inferences, and Prairie dog, Black-Footed Ferret inferences
MAY - 9 I!
567
To KM C/O Bob Ross
Grass Creek Area Draft EIS
P.O 3ox 119
Worland 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 cas and minerals
industry, timber and local and state governments.
1 appreciate the opportunity to contribute to the very important
Grass Creek Area Environmental Impact Statement. Please find mv
comments below .
I object to the reduction of Grazing AOKs 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" a-eas 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 Privat'f. aar-rnr c
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.
I object to restrictions that hamper the current primary businesses
and individuals who use federally administered "lands to generate
income and 3upport our communities through taxes.
T 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
auainst minerals, grazing and recreation.
I object to the proposed blanket restrictions contained in Off-Koad
venicle Management .
567.2
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 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.
£M*3£
r
502
MWI7S66
I IW1EAU OF DOS HAXAGEMf N i I
BiiBjga
April 23. 1995
Bob Ross
BLM Team Leader
P.O. Box 119
Worland, Wyoming
U.S.A.
Dear Mr. Ross:
¥•:"_
I am
riting In reference to the QLM's draft Grass Creek Management Plan.
I find the BLM's proposal lo open wilderness study areas to hard rock
minerals mining, motorized vehicle use. and oil and gas development to be
ill advised. 1 feel that the Bl-M should manage more of the Resource Area
for semi-primitive, non-motorized recreation activities, The areas of
critical environmental concern should be off limits to oil and gas leasing
and development.
Furthermore, though I am in disagreement with your determination
regarding the eligibility of the South Fork of Owl Creek for National Wild
and Scenic River status this area merits protection from oil, gas, and road
development regardless of its status.
The allowance of carte blanche oil and gas leasing on all legally available
land throughout the Resource Area is both clearly excessive and in direct
conflict with your own multiple use mandate.
The final plan should focus more attention in the betterment of rangeland
and riparian zones as well as a greater emphasis on fish "and game
1 1 takes no eenius to see that ihe opportunity to wisely mananc a vast area
oi natural resources is an increasmelv rare one. wnv turn mis Dan ot our
wondertui wvormne into that mucn closer a Dlace to evervwticrc else.
Htstorv stronaiv suasesis mat tne roaa vour ararr manaecment oian taiecs
is a one wav nam. ism it wortn anotner iook.'
KCsoecuuuv vours.
569
I strongly object to the alternative plan on the BLM. I do not want Babbit in
charge of our lifes and resources. We love our land and wish to keep rt-not
give into government plan for its use.
1%I Kay B. Hopkin
1 229 Rd 1 1
Lovell Wyo
82431
RECEIVED
570
m i
RJMAU Of LAND MAN,V.'
Friends of Wild Wyoming Deserts
6361 Highway 26
Dubois, Wyoming 82513
May 6. 1995
Mr. Bob Ross
BLM Team Leader
P.O. Box 1 1 9
Worland, Wyoming 82-101-0119
Dear Mr. Ross:
Thank you for the opportunity to comment on the Resource
Management Plan/Draft Environmental Impact Statement for
the Grass Creek Resource Area. In general, ihe Friends nr Wild
Wyoming Deserts support Alternative C As an organization of hunters,
recreation ists, and scientists, we favor maximum protection for continued
public enjoyment and use of the wildlife and wildlands in the Grass Creek
Resource Area.
Specifically, wc advocate the management actions in Alternative C that
would meet the Wyoming Game and Fish Department wildlife objectives
and "allow the expansion of wildlife and fish into high potential habitats."
Wc request utmost protection for all, not just 'crucial', winter range for
antelope, deer. elk. moose, and bighorn sheep.
Eased on years of field inventory, we have seen that the rangelands and
riparian zones in the Resource Area show signs of historic and chronic
overuse by grazing ungulates. Pedistalled plants, eroding soils, deeply-cut
stream courses with crumbling banks, loss of riparian vegetation, an
abundance less-desirable 'tncreuer" forage- species, decadent sagebrush
Stands, and the nearly complete elimination of crypto biotic soil Indicate
depleted range condition across much of the Resource Area. BLM must
work with local grazing leasees and the Wyoming Game and Fish
Department to correct the past over-use by ungulate species and improve
rangelands and riparian zones. Much work has been done in recent years
to demonstrate that conscientious, sustainable range management can
benefit the leasees-ihiough higher weight gain to their stock, and support
healthier and higher populations of wildlife and fish. BLM must designate
more funding and staff power to research and improve range conditions in
the Resource Area. Additionally, if it has not been done already, detailed
study shouid be made of the effects of the range pitting In the Fifteenmile
country and beyond. Has the pitting ultimately improved or harmed
species' composition and soil stabiliry in the area? Considering the effort
initially spent to pit this vast area, conclusive research shouid follow now
to assess the repercussions.
570.2
We heartily support designation of Fifteenmile Creek, Meereetse Draw, and
Upper Owl Creek Areas of Critical Environmental Concern. Because of the
unique wildlife, scenery, and cultural values in these areas, we urge BLM to
withdrawal! three from oil and gas leasing and mineral development. If
not withdrawn, lease stipulations may limit disturbance of crucial game
ranges or cultural sites during the initial drilling phase, but the new roads,
pipelines, and maintenance activities in years following will surely
compromise the integrity of these areas. For the same reason, the
Wilderness Study Areas, and the additional acreage proposed in the
Citizen's Wilderness Proposal for Wyoming BLM Lands, should also be
exempted from oil and gas leasing and mineral development. These areas
contain beautiful open landscapes, quiet habitats for game, scientifically-
important fossils and ecological community types, and fragile, erosive
soils. Further development or roading will not serve them well.
Regardless of Congressional action, these areas should be protected and
used in ways that will enhance, rather than damage, these special values
for coming generations.
We support BLM's efforts to provide protection from development to
Legend Rock Petroglyph site and public lands along the Bighorn River.
Roth locations are fragile and important.
We must disagree with BLM's assessment that the South Fork of Owl Creek
is not eligible for inclusion in the National Wild and Scenic Rivers System.
It is a scenic corridor with outstanding wildlife and recreation values, most
deserving of federal recognition and protection from development.
The National Natural Landmark candidates-Gooseberry Creek Badlands.
East Ridge-Fifteenmile Creek Badlands, and Taiman Mountain-identified
by the National Park Service as having nationally significant ecological and
geological features should be designated as NNLs, and protected with VRM
II visual resource management classifications. They should be withdrawn
from oil and gas leasing and mineral development, and protected and
used to their full value as paleontologic and geologic treasures.
Wr also support the establishment of four Special Recreation Management
Areas -Absaroka Foothills, Badlands, Bighorn River, and Red Canyon Creek.
These areas should be removed from oil and gas leasing and mineral
development.
From a scientific standpoint, we find that the Environmental Consequences
analysis of the Draft LIS is gravely deficient. The assessment of
environmental consequences of the analyzed alternatives is largely a
description of changes in program accomplishment, rather than a
disclosure of the effects each alternative will have on the physical
503
570.3
environment. BLM's analyses determine effects to resource program 3
Targets and local economics, rather than effects to physical resources such
as air and water quality, biological components, or ecosystems. For
example, although the Affected Environment section of the document
notes that airborne dust, ''relatively high levels of hydrogen sulfide", and
sulfur dioxide arc pollutants associated with oil and gas fields in this part
of Wyoming, the Environmental Consequences section gives no description
of the level of air pollution associated with the potential development
scenarios described. How will the emissions affect air quality in Bobcat
Draw, in Worland. in the Class I airshed of the Cloud Peat Wilderness?
Specifically, how will soils, rare plants, biological diversity, water quality
for livestock, and other physical factors be affected in each alternative
analyzed? The Draft EIS does no; contain enough information for the
public to assess the true and total resource costs of each alternative.
The Draft EIS states that forests in the Resource Area "need to be
harvested over time to maintain a healthy, vigorous forest." To the
contrary, modern timbering practices result in a number of unhealthy
impacts to the forest, including soil compaction, removal of nutrients from
the nutrient cycle, increased soil erosion and stream siltaiion. and
degradation and fragm en ration of fish and wildlife habitat. How has BLM
judged dial leaving 1 0 percent of the forest in old-growth stands is a
healthy level:' Would 20 or 40 percent be heahhien' How will SIM
maintain the stated level of old-growth in the event of a wildfire in the
remaining stands? Plainly, there are too many impacts of questionable
environmental value to support the timber harvesting levels proposed in
the RMP.
Overall, we believe the RMP places too much emphasis on the production
of timber, minerals, and oil and gas at the expense of orher valued public
resources. As the tourism sector of Wyoming's economy grows, and as
remote, undeveloped recreation opportunities become more scarce, BLM
should not be facilitating further roadingand development in the Crass
Creek Resource Area. With the increasing human population pressures
that the future is sure to hold, undisturbed game ranges, clean water and
healthy forage for livestock, places to camp in solitude, or open country to
ride quietly across on a horse will only grow in importance. BLM must
consider seriously its role as a land steward, and revise its Kesourcc
Management Plan to reflect this role and better protect public resources.
Most sincerely,
Lynn fCiriter
Director
RECEIVED
H
MAY I 2 1995
BURUO Of '.'JO :■.-.■ ■
To BLM C/O nab ROSS
Grass Creek Area Draft EI
?-0 Box 119
Worland 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.
1 object to the reduction of Grazing AUMs proposed in the
Alternatives. Real, current scientific data should bo 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 awp. Return all wild animal management to the
State Game ana 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.
J object to the small amount of land considered for aubu-ban
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 BLJ-1 Administered lands.
1 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.
J. 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.
571
and the bias
I object to the bias tor recreation disturbance
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 the economic impacts
to businesses and also tax bases. Beneficial impacts of businesses
should also be factored in.
r 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
571.2
m I 5 I99S
572
May 8, 1995
Douglas L. Mulvey
Illinois State Geological Survey
307 E. Healey, Apartment #2
Champaign. II 61820
Bob Ross, Team Leader
P.O. Box 119
Worland, Wyoming 82401 -0119
RE: Grass Creek Resource Area Resource Management Plan, Draft
Environmental Impact Statement
Dear Mr. Ross:
This letter addresses my concerns relating to the Draft
Environmental Impact Statement (DEIS) for the Grass Creek Resource Area.
Overall, I find the DEIS to be well thought out and organized. 1 do have a
few concern though with some of the content and tack thereof.
Although the DEIS adequately addresses and describes the future
management options for the 968,000 acres of public land surface and
1,171,000 acres of federal mineral estate administered by the Bureau of
Land Management, I feci that it falls short of addressing erosion and
sedimentation concerns and completely ignores wetland issues. Finally,
there is no mention of costs for implementing plans or programs or those
associated with losing access to previously accessible areas.
On page 65 of the DEIS, it is stated that, "to reduce the amount of nonpoint
source pollution entering waterways, pollution prevention plans would be
developed for actions that qualify under the Wyoming Storm Water
Discharge Program." No where else in the DEIS arc possible solutions from
this manual addressed. Numerous Best Management Practices (BMP), such
as swales and sedimentation basins, are available to control the magnitude
of present and future erosion in this region. Although dense stands of
vegetation do somewhat control erosion, page 195 that the amount of
erosion delivered to streams would be about 460.710 tons per year or a 2
percent decrease. In order to address vegetative management, one of your
key resource management issues, larger reductions in erosion than this are
needed.
504
572.2
On page 27 in Table 8 (Activities Affecting Soils), the main culprits of soil
loss are addressed. 1 think the optimal solution to the erosion problem
would be to reduce each of the major soil loss activities eg., pipelines,
exploratory wells, flowlines, bentonite mining, sand and gravel quarrying,
and ORV usage as much as feasibly possible and then look to BMP solutions
to control the remaining problem. This solution would not only address
erosion and sedimentation and how it relates to vegetative management,
but it would also address major stream water quality issues related to
sediment and mentioned on page 131.
On page 171, it is stated that "within 5 years of seeding with native bunch
grasses in the Fifteenmilc Creek watershed, soil loss would be reduced by
50 percent in the seeded areas." I figure this to be a rather hopeful
number. Erosion control using natural vegetation is limited to low flow
velocities- With the nature of the slope and soil structure in this region, I
would suspect the 50 percent control value will not be achieved.
I was particularly concerned about the impacts of erosion on wetlands in
this area. I fail to see any mention of wetland issues except on page 195
where it states, "... wetland and riparian areas would receive less water,..."
Although it is hard to speculate how wetlands will be affected by the
previous statement, I presume that wetlands will be impacted in some
way by this project. 1 would like to see some information given on
wetlands and their relationship to this project in the Final Environmental
Impact Statement (FEIS).
Finally, I noticed no cost estimates were included for this DEIS. Even
though there may not be that many direct costs related to the project, both
direct and indirect costs should be addressed in the FEIS as well as any
mitigation and control measures that are being considered for this project,
Although the DEIS is well laid out and organized, I think the issues I have
mentioned should be addressed in the FEIS. I look forward to your
comments and thanks for letting me comment.
Sincerely,
Douglas L. Mulvey
Civil Hngineer
RECEIVED
MAY 1 8 1995
573
Mr. Bob Boea, tiM Leader
Bureau of bead nenaBeeeut
norland Matrlct Office
P.O. Boa 119
norland, Vroalut 82*01-0119
Z.V:
Gr.es Creek Beaovrcc Are. Kaneteeeot tlm - 0-I.1-S.
De«r Mr. Road!
fc„,„t of „« public land- «od tb. unique ouallt. of 1U« 'oo»J J» ■*•
return for (A* Public.
**"L ill- to~~»« ti*«i*. to «ui» a* -iMii ;« «""« *EHL.u,
tJik-r^ltlllxio. various aothod. lucludlnB selective cuttlws that eill
US. thc^aSu. .oUter, »««. to 5. S— - I«-X —ItU..
vlldllfe protection end other recreation .
2 amend the nee of fire IreetavaU: la the attire "~»~« ere. to e
«5mm of th. mw "'• treat—* of to. ft S-10 pear.. <
isatelj 20O0 acraa.)
3. Halntaln the liveetock .carina. «T1 a. char ere pre^cly authorlsad for
both the penlcted .«••■ aod actual ua. Iff. for 1990. hW
iudivldual altotueot oa thalr own bail. •««=■■■ Bt«fl» »*■**■■ . V
Probl-. To. .tat. " b B-aral t—ra. conditio.. « •*£.£«**?'
planulu, ana. lucludlnB rente vesetetioa. aeterahed and ulldlife habitat
L, »ot the mlt of livestock B^^-""* .!!!, "v! aajLaSued' or
ouch poor condition or doaneurd trend that char eaaoot ha •alacaloal or
anhaacad or chat uould aarsaat eliadnarlnn of livestock traaln, oo
public lande." Therefore, the proposed reductions of um a is Bm
MBITO I Every effort should ba aada to keep raocblnt viable In the
a. Off Boed Panicle eanaseeent nunc have a aora clearly defined designation
and have a strong auforceaent proerea for violations, the praaeuc plan
doea not addreee this laaual
5. * predator coatrol proerea Boat be developed and lepleueuted for the
resource area rtlch considers livestock, wildlife sud buaaa balnea. The
- proara. suae ennaider the eefety of tie aultlple aaera, aad If
necesecry che predatora ehould ba reao™d or eU.le.tud. Ulcbout such
a proam It vill ba ebest iapoe.lhle to expand the bird populetloee 1.
Che resource srna.
p,X. 2, cOQCltUtui
573.2
n». raciatie. ke~- SS^USTSS, MmVTSmimi'.
.tat. et «P— J. ■^'J^J^TJ! "S S a, ,,^1. W*.
couatl<*a am»i>NeiI with tn*» "«««» •»■■.
sot rJliBlcatc rtuti.
iiJll Baa (1C«c> *~ld b. «rtd«. Ire. ta. d«~t.
. — , ... ,___ ud hi. ad caa Slid Bor^ Beol.uUab la two
loUJ tb. arc A« •• cf ««* •>-«"• — aBaaaaajaJ c««m-4
erp^dlai the nnaber of Iwr-eo 1" ." ■ viae u~ "{. =« aouan , .
9. ists-tt. rtUr-Mve. aaaa M •— providel. J**t, ^mbjjaat.
rgatS at »>. 'aaauu Bart..ia..t.t >W .«<»«»»)■
Kr Sou tba PB1S m publl^xd la a ela«r arccapt Co raduca aolrlpla -aa.
p^U.aUrU, tbdmlaa. mil I ». dermal— t -d Mv~»ct H'g»«-
rta LvIraiuatT W roar ~as, acauaaat "U. ar- ,»a (oacttoa^ "taar
that -te^c the ra»»iae «a«. char prarlde. Ite eeVaseaaaaa aeau _,
•aiupla ««» .ui del tbr «»uaaU da^ajatto. a* dl^car tb« tla praauu
plan aroanaea.
Plrano pa^Ui dacall. al bow rou propoae I
into the plan aad bcloc a
^^^j^J
HAV2 2BSB
574
May 4. 1995
Bob Ross. Team Lender
P.O. Box 1 19
Worland, Wyoming 82401-0119
Dear Mr. Ross:
I am writing to coinmctu of the Draft Environmental Impact Statement for the Grass
Creek Resource Management Plan. I am currently a research assistant in the Environmental
Engineering Department at the University of Illinois at Urbana-Champaipn. I have traveled
several times through northwest Wyoming, and I am very interested in the future management
of resources in that an:a.
I found this Draft Environmental Impact Statement lo be very well organized and easy
to understand. The use of tables to compare alternative management actions and
environmental consequences is very efficient and effective. These tables cut the amount of
needed text and make a large amount of information easily accessible. Another important
asset in this document is the numerous maps of the Grass Creek Planning Area. In addition to
the comparison tables, these maps clarify the various land-use conditions under each of the
proposed alternatives.
I would suggest including a topographic map of the planning area in this document.
Throughout the Affected Environment and Environmental Consequences sections, references
are made to highly erodable areas, high elevation areas, and scenic overlooks, '["he locations
of these sites could be easily seen on a map that displayed elevation contours. A topographic
map would enable the reader to see the location of the Absaroka Mountain Range as well as
the deep canyon portion of Owl Creek. This map would also highlight inaccessible areas for
mining and motoriwxl recreation activities.
The DEIS explains the proposed management aclions in extensive detail, but it does
not describe how the current or proposed actions would be enforced. This document should
discuss how limits will be imposed on surface-disturbance activities (off-road vehicle use,
deforestation, mining, and construction). These limits, consisting of No Surface Occupancy,
Controlled Surface Use, and Timing Limitations, are probably viable management techniques
for these activities, but I fee! that it would be difficult lo effectively enforce these limitations
throughout the entire 35 square mile planning area. The liming Umitalions seem especially
difficult; prohibiting surface-disturbance activities during certain periods of the year due to
wildlife considerations would have to be done on a ensc-by-case basis.
Enforcement of the off-road vehicle restrictions may also be troublesome. Violations
of these restrictions would result in erosion problems, destruction of vegetation, and
disturbance to wildlife habitats. Detection of off-road vehicle violations would probably not
505
574.2
be made unti] after this damage is done. The Environmental Consequences section may need
to address this damage tn its discussion of recreation impacts.
A third area of potential enforcement problems lies in the livestock grazing
restrictions. The Preferred Alternative establishes maximum forage utilization percentages by
livestock during the dormant and growing seasons. The actual percentage of forage consumed
by livestock is probably difficult to determine to- practice. Thus, this regulation may be
troublesome or even impossible to enforce. It may also be difficult to limit or prevent
livestock grazing in various winter and crucial winter ranges. The DEIS .should explain how
these regulations will be enforced throughout the study area.
After reading the description of water and soil impacts due to the Preferred
Alternative, I feel that a water quality monitoring program should be established as part or the
Resource Management Plan. This could include periodic sampling from the major streams in
the study area 1 believe that water quality monitoring is essential due to the negative impacts
from erosion, livestock grazing, and produced water generated from mining operations. This
monitoring program would assure that the produced water entering into a surface water body
meets the standards of the National Pollution Discharge Elimination System. The DEIS did
not specify how the produced water is currently monitored. This document should describe in
more detail liow each of the surface-water polluters listed above will be regulated.
My final concern with this DEIS lies in the economics behind the management plan.
All of the Environmental Impact Statements I have read address the relative costs of each
examined alternative. In this particular document, I fcel that some discussion of costs should
be included to assure the reader that each management plan can indeed be implemented. The
DEIS does not explain any funding issues associated with protecting cultural and natural
history resources, revegetation of harvested or thinned foresllands, or fencing wetland /
riparian areas. Many other management actions are described in the Comparison of
Alternatives table, but no explanation is made as to how these actions would be funded. I feci
thai this is an extremely important aspect that should be addressed in this document.
Overall, I feel that this DEIS is an extremely thorough and well-written document.
The major resource management issues are addressed in detail, and I feci that the Preferred
Alternative represents a healthy balance among environmental protection, recreational use,
and natural resource utilization. I appreciate your consideration of my suggestions above, and
I hope to visit the Gmis Creek Resource Area Lhc next lime 1 travel through Wyoming.
Sincerely,
CI <
Chris English
RtflKft^$IfcTAT|S ENVIRONMENTAl PROTECTION AGENCY
region viii
' Denver, Colorado 80202-2496
WW z 6 MS
575
BUREAU Of WiDM^AfiFv
SWM-3A
Bob Ross, Team Leader
Bureau of Land Management
norland District
P.O. Box 119
Worland, Wyoming B24Q1-0019
He: Grass Creek Resource Area, WY
Resource Management Plan / Draft
3nvirorxiental impact Statement (DEIS)
Dear v.r . Rose,
In accordance with our responsibilities under the National
Environmental Policy Act (NEPA) ar.d Section 309 of the Clean Air
Act, the Region VIIT office or the Environmental Protection
Agency (BPA) has reviewed the DEIS for the Grass Creek Resource
Area Resource Management Plan (RMP) and offerB the following
comments for your consideration in preparing the Final
Environmental Impact StatemenL (?ETS) . We are providing our
comments from a perspective gained from recent reviews of other
Bureau of Land Management (BLM) and Forest Service land
management plans. Additionally, the issues addressed reflect
E'PA's comments submitted to the BLM during the scoping process
for the EIS (Robert R. DeSpain to Joseph T. Vessels, 12/27/91).
ALTERNATIVES
Therange of the four alternatives, analyzed in detail,
appears inadequate for analyzing substantive differences in land
use planning. In "Table 2, Comparison of Alternatives", it
appearB that the management objectives and actions for
Alternatives A, B, and C typically state "Same as preferred." for
each of the various land uses or resources. The Pinal bis shojld
highlight significant differences in the alternatives and
.indicate how the philosophy or objectives of Alternatives B and C
contrasts from the Preferred Alternative and the Current
Management A Alternative.
CUMULATIVE IMPACTS
The RMP does not address the cumulative impacts of the
selected alternatives over the life of the RMP, nor does it
address impacts from activities occurring on lands adjacent to
the Grass Creek Resource Area. NBPA requires that cumulative
effects be addressed as a summary of the individual effects of
both the proposed action and any other "reasonably foreseeable"
projects, including those generated by other entities and
k Printed 01 Rtcvetta Piptr
575.2
occurring on other ownerships. The cumulative effects analysis
should summarize the site specific impacts of past, current and
proposed projects and occurrenr,Rfi upon physical ecological
resources, such as water quality, air quality, vcoctation and
wildlife.
ECOSYSTEMS AND ECOSYSTEM MANAGEMENT
The discussion on page S defines ecosystem management in
general terms and indicates that ecosystem management will be
incorporated into implementation of the RMP, site-specific plans,
and daily management decisions, since applying this concept to
the land management process is relatively recent, it would be
beneficial for the BLM to describe more specifically throughout
the EIS how the ecosystem approach will be applied toward
balancing various BLM land uses, such as oil and gas development,
grazing, and forestland management, which cross jurisdictional
boundaries (i.e. Shoshone National Forest, Wind River
Reservation, and private lands) . As an example, the Forestland
Management preferred alternative states that. "The management of
forest and woodland resources would. be consistent with ecosystem
management principles." (DEIS, p. 24) How will an ecosystem,
management approach for land management activities differ, on the
ground, from the existing 19S3 Grass Creek Management Framework
Plan?
WATER QUALITY
Tables 9 and 10 in -he DEIS (pageB 128-129) indicate the
planning areas watersheds and stream uses and classifications.
Otherwise, as stated in the EIS, the determination of existing
water quality conditions for the planning area appears to be
fairly limited.
Section 319 of the Clean Water Act (CWA) requires States to
identify nonpoint source threatened or water quality impaired
streams and the sources and categories of pollutants affecting
water quality; best management practices (BMPs); and to provide
for a process of reviewing Federal activities to assure
consistency of application 'and effectiveness of BMPS necessary to
maintain or achieve water quality standards.
To supplement water quality information provided in the
DEIS, we recommend that the BLM reference the Wyoming Department
of Environmental Quality 303(d) list and 305(b) report. The RMP
should summarize information from the references including water
quality impaired or threatened stream segments, the pollutants of
concern, the pollutant sources, and achievement of designated
water uses. Such information is considered to be a key planning
tool for assuring compliance with the Clean Water Act during
site-specific project implementation.
575.3
MONITORING AND EVALUATION
The RMP contains minimal information regarding monitoring
and evaluation requirements. The Final EIS should be modified to
address monitoring and evaluation of resources in terms of the
BLM's Resource Management Planning regulations stated below.
43 CFR S 1610.4-5 Monitoring and evaluation.
The proposed plan shall establish intervals and standards,
as appropriate, for monitoring and evaluation of the plan
Such intervals and standards shall be based on the
sensitivity of the resource to the decisions involved and
shall provide for evaluation to determine whether mitioation
measures are satisfactory, whether there has been
significant change in the related plans of other Federal
agencies. State or local governments, or Indian tribes, or
whether there is new data of significance to the plan. The
District Manager shall be responsible for monitoring and
evaluating the plan in accordance with the established
intervals and standards and at other times as appropriate to
determine whether there is sufficient cause to warrant
amendment or revision of the plan.
BEST MANAGEMENT PRACTICES
The Final EIS should provide a discussion of best management
practices (BMPs) designed to reduce or prevent environmental
impacts en resources. The discussion should describe how BMP5
will be used to design agency initiated projects and to develop
conditions for proponent initiated projects. The discussion
should also address how projects will be monitored to determine
the accuracy of BMP implementation and the effectiveness of the
practices. BMPs must meet the minimum requirements of the
Wyoming CWA 319(b) nonpoint source management plan.
The recognition of BMPs is of particular concern given that
water quality impacts in the planning area have resulted from
erosion and sedimentation. The DEIS notes that past watershed
treatment treatments are no longer effective in addressing
erosion and sedimentation concerns (page 131) . What activities
are planned to address this situation?
RIPARIAN FUNCTION
The discussion on riparian function (page 197} notes
relatively modest improvements in functioning condition can be
expected during the life of the plan. What basis was used in
determining proper functioning condition (PFC) and how recenfv
was the analysis completed? What limiting factors restrict
506
575.4
obtaining greater improvements in PFC7 BPA encourages a stronger
emphasis be applied particularly to the downward trend acres to
avcid further losses to a nonfunctioning condition, we also
recommend that the RMP incorporate concepts currently being
developed for the purpose of sangeland Reform implementation and
consider whether further improvements to rangeland health may be
achieved as a result.
Using a spring development BMP similar to NRCS Practice 574,
EPA encourages the ELM to promote protection of springs in
grazing practices.
Based on the procedures EPA uses to evaluate the potential
effects of proposed actions and the adequacy of the information
in the DEIS, the Draft EIS for the Grass Creek Resource Area
Resource Management Plan will be listed in the Federal Register
in the category BC-2 (environmental concerns, insufficient
information! . This category indicates that BPA has identified
areaa of potential environmental impacts that should be avoided
in order to fully protect the environment. Also, the EIS does
not contain sufficient information to fully assess environmental
impacts that should be avoided in order to fully protect the
environment .
We appreciate the opportunity to review and comment on the
Draft EIS. if you may have any questions, please contact
Larry Kiirmel at (303) 293-1697.
Sincerely,
!_J. William aeise, Jr., Acting Chief
Environmental Assessment Branch
Water Management Division
507
1
U.S. DEPARTMENT OF THE INTERIOR
2
BUREAU OF LAND MANAGEMENT
3
I
WORLAND DISTRICT OFFICE
CRASS CREEK RESOURCE AREA
5
f,
7
TRANSCRIPT OF PROCEEDINGS
3
9
10
1 1
IN HE: GRAS3 CREEK RESOURCE AREA
1?.
RESOURCE MANAGEMENT PLAN
13
ia
DRAFT ENVIRONMENTAL IMPACT STATEMENT
15
16
PUBLIC HEARING
17
IK
BL.KS LOOOE
1<>
BfiifralAL £l04 Coi)urn Avenue
20
Norland, Wyoming 82401
21
April 3. 1995
27.
23
GONSALEF, REPORTING
Ranee L. Sonsala*. RPR
24
420 S. 8th Streer
Worlandr Wyoming 82101
35
[3mi-347-?719
PRESENTATION
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PRFSF NT AT TON-
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INDEX CONTINUED
BY JOHN CAMS
BY DAVID BAYERT
BY KAREN ANDERS
BY ANDY FRANKLIN
RY WTI.1.TAM CRAFT
SY JIM HTLLBERRY
BY TIM MORRISON
BY BILL TALIAFERRO
BY DALLAS VALDEZ
BY LYLE SPENCE
BY DOROTHY MILEK
BY ALLAN HOWARD
BY KATHLEEN JACHOWSKT
BY DENNr.4 JONES
BY MARTIN DOfliiON
BY MONTE DOB SON
3Y GARY ANDERS
BY LOIS HERRST
BY JOHN PREIS
BY GORDON PREIS
BY DICK LOPSR
BY KEITH HAMILTON
3Y PAUL (SALOVICH
102
103
110
110
113
117
122
126
129
131
134
138
141
143
146
148
151
158
1 6 1
OPENING REMARKS
PRESENTATION BY
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PRESENTATION BY
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BREAK
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INDEX
BY MR. DANIELS
BAILLIE MILLER
JTM MAGAGNA
SYLVIA GAMMS
RAY PETERSON
MIKE BAKER
BILL BLANZ
JAY MOODY
BERYL CHURCHILL
CHARLES JOHNSTONE
DARVTN LONGWELL
JTM GOULD
JAMES KIRSCH
FRANK KELLY
JIM FOREMAN
KEN COOK
MIKE DAUBRNKEIM
JCF. ICENOGLE
BRYCE REECE
PAT CHILDERS
RILL OARBARD
PAT MOORE
«
1
INDEX CONTINUED
2
PRESENTATION 3Y CLARA YETTER
163
3
PRESENTATION BY DON GILBREATH
164
4
PRESENTATION RY MATT BROWN
161
5
PRESENTATION RY JAY MATHEWS
173
5
7
fl
9
10
11
12
1.1
14
15
Ifi
17
13
19
20
21
22
23
24
25
508
MONDAY, A^RiL 3. 1S95. 4:00 P.M.
MR. DANTELS: 1 have 5:00, HO wft ' I 1 bring
this public hearing to order. Good afternoon and welcome Lo
this public bearing that has been convener] by the Department
of the Interior, Bureau of L,and Management, Worldrid
District..
The purpose oi this hearing is to receive comments
concerning the Draft Environmental Imparl statement and its
Preferred Alternative for managinq the BLM administered
lands and resources within the Grass Creek planning area.
My name is Bill Daniels. I'm from the BliM Wyoming
State Office, Division of Resources, Policy, and Management .
T ' vb been .inked to be the presiding officer at this hearing.
I do not participate In this process except in the limited
role as presiding1 officer, T make nn recommendations In
connection with Chin proceeding and have no lurther
involvement in the outcome.
Tn addition, the following representatives of the
Borland District BLM; Joe Vessels, or. my left of the Grass
Creek Area Resource Manager, and Bob Ross to his loft, the
Resource Management Plan Tenm Leader are here to receive
your commentfl-
The purpoco ol the Draft Environmental Impact
statement was to document and compare the analysis of four
alternative land-use plans, including BLM' 8 Preferred
Alternative, and to provide an opportunity for public
involvement, in the planning process.
With the refinement of the Draft EIB and continued
public Involvement, the BLM hopes to develop a resource
management plan that will guide management of the Grass
Crefk arw for the next Ifi to 20 veare . The resource
management plan would provide needed changes in BLM's
current management direction for the planning area. An
update decision for the management of resources, both
mineral and surface administered by the Bureau of Land
Management .
The current BLM land use plan is the 1983 Grass
Creek Management. Framework Plan. We call it an MFP. Policy
and management changes have occurred since then including
need to comply with the National Environment.!*] Policv Act
recnilrlng an updated, comprehensive, and environmentally
ad «quat a management guide.
The Grass Creek resource area published a notice
in the register on October the 19, l&SH, indicating the
intention of the BLM to prepare a resource management plan.
A notice of filing also appeared in the federal register on
januarv the 7, 1995. announcing the availability of the
Draft 6IS and beginning the 90 day comment, period. The
comment period has been extended to May the 7, 1995.
All comments received at this hearing will
provided the Worland District with additional information
for review and developing the final Environmental Impact
Statement. The comments received todav will bo formally
responded to in that final BIS document. This hearing io
not an adversarial pioceeding, and commentors presenting
their views will not be placed under oath.
The purpose of the hearing is Lo gather
inlormation arid not. to exchange views. Your testimony
10 should be relevant to the Draft Environmental Impact
11 Statement. The agency representatives may ask clarifying
questions or seek additional information at the conclusion
of the speaker's comments. Any questions that mav be asked
should not be construed as indicating any pre- determined
position of the official or of the Bureau uf Land
Management, but are simply to get further information for
the record.
It should be mentioned here that, all communication
to the BLM on this topic is a matter of record, whether in
the form ot letters, faxes, phone calls, visits, or comment's
during scoping, open houses, and assorted meetings. Any
communication made tn the BLM as specific comments on this
Draft Environmental Impact statement will be a part of the
pub I ic record.
A copy of this record is available for review at
1
(I
the Worland district of! ice. Because of the number of
2
comments anticipated, the Worland district requests that if
3
possible commentors specifically identify the section and
4
page on which the comment is provided concerning the ETS.
5
that. is. This does not mean that your qeneral comments are
6
not desired, they certainly are. But where possible please
7
identify the area of the document you are referencing. In
fi
addition commentors are asked to provide suggested wording
9
changes wherever possible.
10
In order to ensure a complete and accurate record
n
of the hearing it is necessary that only one person speak at
12
a time. Also it is requested that everyone remain as quiet
13
dR possible when the hearing is in progress.
M
An official reporter is here today to record this
IS
hearing and provide a verbatim transcript. She's sitting --
16
seated at my right, Ms. Ranee Gonsalez. If commentors have
17
an extra copy of their prepared remarks, it would be helpful
i 6
to the reporter that that copy were given to her before or
19
after your presentation. This is for the reporter's
20
assistance. And your remarks will be recorded whether or
21
not you follow a prepared text.
22
Tn order to give all who desire to speak the
SI 3
opportunity- to do so. each speaker will be permitted a
7A
maximum of five minutes for their presentation. I will let
2b
you know when you have one minute remaining SO rhut you may
509
9
1
sum up your comments in an orderly manner. Usually you will
2
fine, me get up and come to the podium when you have a minute
3
lei E to speak.
4
Speakers will be called in the order in which
B
their names appear on the List furnished to me for thill
6
purpose. Tn the event that a speaker is not present when
7
h i b or her name .is called we will proceeti and that person's
8
name will he called later after we have gotten through the
9
liBt of speakers that we hove- Please forgive my
10
11
pronunciation ot speakers' names for I have not necessarily
seen them previously and have not had the good fortune l.o
12
know each speaker personally.
13
Each speaker should beflin his or her remarks by
14
providing his or her name, occupation, and if desired vour
15
organization or group represented. Written statements are
IE.
encouraged. If any speaker wishes to submit additional
17
written testimony, please provide that materia) to the
ia
reporl-ei and it will be marked as an exhibit and made parr
J 9
ot the record of this hearing. The Worland district also
20
will accept written comments from parties who prefer to
23
provide written rather than oral submissions or from
22
individuals unable to attend l he public hearing.
23
Written submissions on the Draft Environmental
24
Tmpacf Statement should be postmarked by May 7, 1995. They
25
should be addressed to the Bureau of Land Management ,
10
1
Bftrland District Office. Bob Ross, RMP Team Leader. P.O. Ho.x
:■!
119, Worland, Wyoming. 82401-0119.
3
4
All comments timely received wil] be analyzed and
considered in the preparation of the final Environmental
5
Tmpact Statement. Copies of the transcript of this hearing
6
■i
nay be obtained by making the necessary arrangements wirh
the court reporter.
8
Mv role in this hearing again in co ensure that
9
the hearing is conducted in a fair manner, to maintain
10
order, and to guarantee that everyone has the opportunity to
13
present: their comments on the Draft Environmental Tmpact
12
statement for the Crass Creek Resource Management Plan.
13
T would add, please retrain from smoking in this
14
building during the formal hearing.
IB
In case that you are interested, the anticipated
16
completion of the final document should be sometime in the
17
fall or perhaps as late ac the first of the calendar year.
IS
T will answer any questions on the hearing
1 H
procedure now il there are any. So if them are any
■/.{■
questions, feel free to ask them on the hearing procedure.
21
Tf there are none, we will start with the speakers
22
then. We like to allow officials ot the - - representatives
2.1
ot the state and the counties to come forth first , and tho:n
24
hie go down through in the order in which people have signed
25
up.
Our first speaker will bo Baillie Miller, a
represents! ive of Congrosswoman Barbara Cubin.
BATLLIE MILLER: I'm Baillie Miller. I'm the
district repreaent.at.ivH for the Big Horn Basin for
Representative Barbara Cubin. I'm out ot out rasper office.
1 can't, believe I have got to go first.. Anyway this letter
came from Barbara.
"1 appreciate having this opportunity to comment
on the BLM's Environmental Impact statement and its
Preferred Alternative for managing the public lands and
resource in the Grass Creek planning area. Baillie Miller
from our Casper office will be representing me on the
comments made during this hearing. While T do not intend to
micro manage the Bureau of Land Management. T am concerned
about the large number of comments I have already received
on the issue.
Many fear that this signifies a new direction for
the BLM away from the traditional balance or multiple users,
in favor of wildlife and recreation. The proposed reduction
in AUMs for livestock raising and various restrictions on
surlace uses which impact the oil and gas industry are cited
as examples of the shift from our resource industries.
Likewise, the designation oi areas of critical
environmental concern are viewed by many as de facto
wilderness areas made without the blessing of Congress.
12
1
I will be closely monitoring this issue. These
3
proposed, changes have the potential to cause serious harm to
the four counties in this region. I did not come to
4
Congress to wstch the federal government slowly strangle
5
Wyoming's economy by tightening ita regulatory noose around
s
the nock of our multiple users.
7
I thank the BLM employees who are all listening to
a
our comments today and 1 would 1 ike to ask that they keep in
9
mind the impact, of their decisions on the people of Wyoming.
10
Finally, I ask that T continue to he kept informed
11
on this issue as it winds its way through the process.
12
Wyoming interests need to be heard everv step of the way and
13
a healthy balance must always be our goal, with warm
14
regards, Barbara Cubin."
15
(Applause) .
16
MR. DANIELS: Thank you very much. Our
17
second speaker will represent Governor Geringer, Jam
1 9
Kagagna .
19
MR. MAGACNA: Thank you. I'm Jim McGagna.
20
Wyoming Director of State. Lands, representing Governor
2L
Garinger today. 1 would like to preface my remarks by
22
stating that we're not fully aware of what input, into the
23
process and development, ol this draft, might have come from
24
the Governor's office under the previous administration, so
£5
pleane understand thai, we're — our comments today are based
510
on the perspective of Governor Geringer, tttfi current
administration, and we view this as out initial input into
this process.
I'd like to begin by addressing the grazing issue
because I think if. best-, exemplifies one of cur major
concerns, and that is with the choice of alternatives in the
plan. Based on our experience with pievious Environmental
Impact Statements and the process ot identifying
alternatives, we view the [quote) "current management
al ttirnat ive . " as one that should represent a commitment to
the sl.ai.ua quo in terms ot what the agency has agreed to do.
using grazing as the example, current management to us would
mean a commitment to manage the lands in order to provide
the level of grazing that is currently authorized on the
land .
What we find in reviewing this document it would
appear is that all 01 the alternatives represent changes in
the current authorized uses, it's just a -matter of the
degree of increments of change that separate one from the
other. A good example, as I say, la grazing, where the
proposed alternative reduces the authorized grazing by 35
percent, but the (quote) "current management.. " reduces i L by
30 percent. We simply don't find this acceptable hs
addressing the current situation, the current commitment of
the resources to meet the needs of the people ot Wyoming.
These same numbers have a very significant impact
economically for Wyoming agriculture as well because whether
some of those ALUs are currently being grazed or not, they
ol l.ar, form the economic basis tor lenders to qrant credit in
the agricultural industry. And the impact ol having
reductions of 35 percent on the ability of agriculture to
continue to finance itsell are a maior concern to us. And
in fact looking at the socioeconomic impacts identified in
the document, it we take the assumption of the document that
the difference between the (quota) "current management," and
the Preferred Alternative, 5 percent of the AUMs represents
a 4 percent change in the economic impact, to agriculture
within the Grass Creek area, then I believe it's a safe
assumption that the difference beLween current authorised
use and the authorized use that will be permitted by the end
of the implementation period of proposed action will
actually represent a 28 percent decrease in whet could be
the economic viability of agriculture, ol grazing in the Big
Horn Basin.
Hoine of the specific methods usud in grazing,
again concern us. The use o! utilization standards as
nearly the sole basis upon which to base the majority. The
hiqh percentage of the reductions, and soma of these
standards being as low as possibly 25 percent, in some areas.
We would suggest to you that given the definition oi
15
1
utilization in there that includes not only forage
2
consumption by wildlife and livestock, but forage
3
consumption simply through trampling and use be it by animal
4
or human, the 25 percent or greater utilization in many
5
cases could be reached without a single head of livestock
6
being out upon the land.
7
We're equally concerned with tho use of desired
i
plant community without a role Cor the State m identifying
9
what is desired in these plant communities for Wyoming. He
10
realize thai, this ia not. a bad direction to go, desired
11
plant community is certainly a realistic way of dealing with
12
what- we want out there- The problem is with who gets
13
involved in deciding what it is that we want out there.
14
Let me move on quickly to some of the other areas
15
that we also have concerns in. Mineral development. Under
16
the proposed action, again compared only to the current
17
management., a doubling of non-surtace occupancy, and h
18
doubling of controlled surface use, even more than that when
1<3
It comes to seasons!) use restrictions. We are supportive of
20
thooe types of restrictions where they are based on a
21
legitimate scientifically identified need to protect habitat
22
and to protect certain wildlife species. We're concerned in
23
this particular case that many of these were rather
24
arbitrarily developed, and that the scientific development
2S
is nor. there to support them.
16
1
The oft-road vehicle use, general broad
2
prohibition identified on page 49 of the document, again we
3
feel is excessive. There's a reference under recreation to
4
(quote) "primitive recreation," We feel that the wide
g
variety ot recreation ot the people ol Wyoming as well as
6
our many visitors engage in are from backpacking, horse back
7
riding, off-road vehicle use, that's not primitive in our
8
minds, that very much in the 20th and 21st Century. And
9
it's somothinq that we think needs to be treated with that
10
level of dignity and allowed for in thre opportunity provided
11
12
for in the document.
Finally, let me comment -just brie-fly as state band
13
Director on rcy particular concerns with regard to this type
14
of a management perspective. There are many state lands
IS
intermingled with the BLM lands and these allotments. To
16
the extent that the BLM so significantly reduces the
17
authorized use on BLM lands de facto, you've i educed the
ia
authorized use on the state lands because thev are not
19
fenced lands. They are not separated lands- Under state
20
policy tho people who hold tho surface leases tor grazing on
21
these lands pay tor every AUM that's out there every year
22
whether they can use it or not. We feel it's an injustice
23
to these peopln when we at the state are heing reimbursed
24
for these AUMs and the policies oC the federal government.
25
are denying them that use.
511
On the other side we have a concern for those
state lands that are not directly intermingled with BLM
lands, but are orten contiguous to private lands and do lend
themselves to be used independently. That arj the rhrusr of
reductions and reductions continue on federal lands, w*'r»
going t.o see a tendency to over utilize those private and
statu lands to the detriment of a very Important resource of
the people ot Wyoming.
And finally, another major concern that we have
identified ir. the document in hhn commitment to the ril.M
together with the Nature Conservancy and the Fish anfl
Wildlife Service identifying areas for the transplant of
threatened and endangered species? We feel that this is
totally inappropriate. It totally ignores the legitimate
interests of the state. We're concerned about protecting
those species. We don't want to introduce mora problems by
transplanting them into additional areas.
In ciosing, let me make two requests on behalf of
the Governor and the State of Wyoming. First, before this
process moves forward, an alternative is included that truly
represents meeting the current legitimately and legally
authorized uses lor all multiple uses on these lands.
Whether or not Uut alternative is the one that's finally
adopted, it gives us a benchmark against which t.o measure
the variety of other alternatives that are provided.
19
1
pre-hoaring briefing in Thermopolis, and the over-riding
2
concern ot atl of those groups that attended there tro* the
3
county aommisstonerfl, to the leases, the oil and gas
4
producers, sportsmen and casual users is the economics,
5
and the lack of concern for local custom and culture, you
6
can't raise taxes high enough to offset the revenue, local,
7
county, and state are receiving from current permittees and
8
from the nil and gas. You cannot suggest the reduction of
9
44,000 AUM'S and claim not to impact, the counties and their
10
11
abilities to fund schools, hospitals, highways, and other
eervi n«s .
12
Agriculture and the livestock industry is
13
particularly important to the economy of Wyoming;. The
14
livestock industry is the mainstay of our state agriculLurc
industry. Eighty-two percent of all Wyoming agriculture
1.6
resources are derived from the livestock and agriculture.
17
And T have more facts and figures going along with that
ia
which I will submit.
19
Most residents of the impacted area are true
20
believers in the raul t iple-use concept. Multiple use has
31
been implemented and successful for over 100 years. This
22
plan would close down multiple use. It cuts back on oil and
?. 1
gas, grazing, timbering, and recreational use. I didn'i get
?.A
too far into that DEIS before I disagreed. Page one, where
25
it says all alternatives are unit iple-use oriented. I would
And finally, we would like to request that the
opportunity be provided for a high level of state government
involvement through the Governor's office and through a
number of affected state agencies an you itiovp forward w-.r.h
this process.
Again, thank you lor your time today.
(Applause) .
MR. DAMTET.S: Our next 3peaker will be our
state representative, Sylvia Gams.
SYLVIA GAMMS: I am Sylvia Gams. I'm State
Representative- from House District 2f>, and T currently chair
the Agriculture Public Lands and Water Resources Committee.
I appreciate the opportunity to address you today
and to bring to light soma ot our concerns. And T would
like to first oi all thank everybody for coming and
participating in this process today. We did send a request
forward to have this opportunity, and I want everyone here
to know T appreciate them showing up and lending their
support .
My county is 8.1 percent federal lands, so you can
understand why we're concerned about the economic impact
upon our counties. My oral comments today may tend to he
philosophical in nature but my written comments will include
more faciual information.
Most interestingly to me when we had our
suggest that in this plan we need a better definition ot
multiple use if we are to agree with this plan being truly
mul tiple-uco friendly.
We question the figures that WBre used i.n the
analysis as being historical use numbers. Cattle prices and
impacts were at a five-year low, and drought was being
experienced during much of the data gathering. The
reference section in the hack of that book is something
else. I suggest that references more reflective of the area
could have been used by on-site agencies; Wyoming agencies,
Soil Conversation Services, State Engineer's Office, records
available from the Wyoming Game and Fish Commission, plus
reports from the University of Wyoming regarding impacts on
federal lands. Your references relate earthquakes,
biological c 1 i ia n t o charges, global climate changes, and
water quality management dating from 1979. With all those
references available to your department. I suggest you could
have come up with more current and efficient reporting
methods .
The Wild Horse Management. A suggested change
here would be simply to reduce the wild horse herd in this
arfi.i. It's not necessary CO have a wild horse herd this
close to an authentic. And a real wild horse herd is
located up in thp Pryov Mountains less than 100 miles from
here. The money spent on the Wild Horse and Burro Act, 16. '.>
512
million this year T might add, could b" weJ l spent in othBr
areas. Many of these wild horses could be eliminated. We
do not agree on the suggestion that the DLM purchase an
additional in, 000 acres of private land to expand the wild
horse habitat. At this point in time with the national
budget , this money could be better saved.
And I also agree with Mr. Magaqna where he quotes.-.
the part about the Nature Conservancy on page h.l whore ir
aaye, "BliM would participate with The Nature Conservancy,
U.S. Department of Interior Fish and Wildlife Service and
other agencies in the evaluation of areas tor the potential
transplant of protected plant, species on BL.M administered
lanrin." To this suggestion I would like to just say no. we
have enough problems in the area with weed control as it is
and we don't need -.ew ones being introduced. And quite
frankly who is the lead organization in this proposal?
Nature Conservancy? Sierra Club? Conservation Coalition?
That in not an option that my groups! will go along with.
The restrictions on nc surface occupancy for oil
and gas I » n blatant shutdown of the mul tiple-113© concept.
And T will provide more documentation to that.
Nearly 67 percent of the total natural gas in Rig
h"orn County comes from federal lands. We are v^ry concerned
about the potential impact from closing down oil, ga3, coal
and natural gas explorations-
One aspect we're not so proud of in Big Horn
County is the fact that government is the largest employer
in my county, followed by service, retail, wholesale trade,
and then agriculture. Together these four sectors represent
nearly 70 percent of the total employment, in Big Horn
County. Another aspect that the ULM may not want to own up
to is the fact that their staff has nearly tripled Hince
1975, More than 90 percent of those BI..M employees are here
in the West. During that sare time grazing leases have
declined from 77,000 to 71, a 7 percent decline.
We have talked about the Fifteen Mile area of
critical environmental concern. Nine-hundred square miles?
Do we need another wilderness area? Fifteen Mile Creek has
been identified because it causes sedimentation problems,
but according to a report that J have, most of the
sedimentation problem in caused during rainfall events. T
would like to submit, to you that, an ACEC designation is not
going to change the rainfall in the area. I would suggest
that perhaps you could follow up on some of the other
government reports available and could correct this part in
your report.
In that same report it describes the rangelanc as
in fair to good condition. What means are necessary to
measure rangeland condition and improve riparian arita^i when
even the BLM's reports show the rangeland to be in good
condition. So I believe we can safely say we need more
supporting data, current evaluations, and real input and
consultation from the groups listed in these other reports.
Wildlife numbers are up. Wildlife numbers by your
own count are up. Do we need federal - the Bl.M helping us
to manage wildlifo in this area as has been suggested? Our
answer to that la also no. From 1950 through 1989 BLM's own
estimates showed tremendous increases of wildlife on public
lands.
As I mentioned before when wc had the pre-hearing
meeting on the wolf it was very interesting to m« that, at
the very time that the federal government is inflicting the
reintroduction of the wolf on the State of Wyoming, they are
stating it will not impact or aitect private property rights
in surrounding counties. I note on page 150 of your report
thai "evidence supporting th« presence of the Northern Rocky
Mountain Grey Wolf in the planninq area has been reported-
Large wild canine sighting, tracks, scat, and howls indicate
that the wolf may frequent the western quarter of the
planning area." However this was neglected when we were
doing the report in introduction into the park. "The wolf
most likely would be present around concentrations of big
game and away from people." There's so many contradictions
in this report. We say that the wolf isn't there, then he
is there. That we will not be increasing recreation and
on. And I thinfc that you
and figures iust a
then we will be increasing recrt
need to go over and have your f;
little bit more clear.
So much for our trust, in the federal government
and their promise to contain the wolf and not infringe- upon
private property rights, when wc already see in this
statement your plan for expanding his boundaries.
A concern in the meeting that was brought up was
the lack of predator control by the BLM. Here we are
introducing more predators, or the potential to introduce
more predators. And in your report there is not a predator
control plan.
Tt'K been slated in the report that tourism would
pick up for the money that would be lost to our counties
through the cutbacks in the grazing, oil and gas leasinq.
and timbering. You couldn't build hotels fast enouqh . And
accordinq to the reports that I have, and that are available
to you from the University of Wyoming that was just paid for
by our tour-county coalition, during the summer months, our
hotels in this area are at maximum now. There is not time,
room, or apace, or services available for enough tourists to
make up the difference in economic impact.
We talked about access. And the hunters and
sportsmen at the meeting in Thermopolis thought that access
would be increased. And in my documentation I will present
513
25
1
how that is not exactly the case.
2
SO tn case you are wondering, are we opposed to
3
this plan, 1 would suggest that it needs to go back, it
4
needs to b« written with current facts and figures, dad with
5
true consideration for local custom and culture. It is
6
narrowly focused and wil.b questionable methodologies, And
7
I'm not a school teacher, but I think that 11 I was a school
8
teacher and you handed me in that report I would probably
9
hand it back and say couldn't you do a little better job?
ID
(Applause) .
n
MR. DANIELS: Thank ynu, very much. Our next
12
speaker will be Ray Peterson, County Commissioner from
13
Cowley.
14
RAY PETERSON! My name is Ray Peterson. I'm
l!j
a County Commissioner for Biq Horn County. I uill be
16
submitting a document and T will just k;nd u[ paraphrase
17
from that document and quote a few things.
m
On page 31 we talk about Waste Management In the
is
BhM proposal. He hope the 1,220 acres will help in luture
20
expansion needs. It talks about landfills and expansion
21
needs of the communities of Thermopolis, Basin, Borland, and
22
so on .
23
L&Bt yfiflr BtiM policy cost Big Horn County aver
24
$100,000 having to purchase private qround tor a landfill.
as
There io no excuse for any lederal agency not to assist with
local needs, we as a county don't have the choic
nd EPA. Tt would he n
of not
having to deal with waati
your assistance in these land matters next time. The
wordiny in this document "would he considered," has ua
concerned to nay the least.
Propound AtJM reductions total nearly 60,000 when
you talk direct and indirect. This means nearly flva
million dollars in lost revenue and nearly 200 jobs. These
are real figures that will directly affect the lifestyles of
the people of our four-county area.
The promise ol assumed, projected increase in
tourictr, to replace this loot revenue Sees not convince Big
Horn County residents. According to your figures, it would
take a 71,2X0 increase of total visitor days just to replace
those grazing dollars lost, and wo haven't even talked about
the loss o:" oil and mineral yet. This Increase in tnuriam
usage must be outside visitor use. Local use will not add
any money to our local economies hb Lhe grassing and oil
moneys do. To project a 32 percent increase in tourism is
just a pie in the sky estimate made to offset the loss of
real dollars of reduction of oil and gra2ing. Fliq Horn
County history proves this point that tourism will r.ovor
replace the aq economy that was lost in the Yellowtail area
with the development of the Yellowtail Dam, Thirty years
later the tourism hasn't happened a»d we are still
27
1
recovering from that loss of our economy.
2
3
Concerns of the economic study done for Iho BLM by
the University of Wyoming. It mentions recreation. If we
4
are to compare tourism dollars to replace oil. gas,
5
minerals, and grazing dollars lost, then we must throw out
b
all resident usage. These are not new incoming dollar:).
7
These dollars do not contribute to our valuation, schools or
S
services as the oils and gracing dollars do. Your forecast
9
tor outside tourism increasing is overly exaggerated in this
1 11
study.
11
Agriculture; 1590 was a poor base to use. We
12
would suggest taking a medium, a composite of a number ot
13
years in a live or ten year period and use that as your base
11
which would give you some real figures to go by. In order
Tor this plan to be complete is has to address each county
16
individually as to the effects that each of these reductions
17
and added controls will have on each county. Big Horn
Ifl
19
County La requesting: these figures ■
Oil and Mineral; This area is very f lightening to
:-iu
counties that realize nearly B0 percent or more of the
21
county valuation based on this industry alone. Unless this
22
23
to decrease this industry on public lands, this plan will
24
not stand or be accepted by nig Horn County.
25
And then to summarise and then l will present this
2G
1
to the recorder. These are a f*w of the areas we as Dig
2
Horn County commissioners are concerned with. Kith federal
3
Agencies controlling over B0 percent of our county and the
4
current trend to accommodate the environmentalists and
tOttriSta vc are afraid that our way ot life and very
6
existence in this area : s being threatened. When our input
7
is considered on the same level as input from anyone else
8
from anywhere else it concerns us as to how valid our input
9
is and to what cont.ro! we have over our own lands and lives.
10
Tourists will never pay the bills in wyonunq. Ovx economy
1 l
is divorsi find and must remain so. To put unreasonable
12
controls on the very industries that contribute to our
13
lifestyles and economy for th« purpose of making the drive
11
to Yellowstone more scenic for tourists driving through this
1?
is nonsense. Your agency controls nearly 70 percent of our
16
county. You must help us preserve our land and our
17
lifestyles without, sacrificing the economy of the people you
18
serve.
19
Until we see these suggested changes made ro rhio
20
plan and the report requested of how these proposed changes
21
will effect Dig Horn County alone, we stand against this
22
document and suggest you file it right next l.o the Range
23
Land Reform idea.
24
(Applause) .
25
MR. DANIELS: Mike Baker, statu
514
representative fron Thermopolis .
MTKF BAKER: Thank you f.or I. he opportunity Lo
comment today. Oni> thing I should make clear belore I
start. I have no blm permits, i have no consideration in the
mineral development that miqht take place. T am simply a
farmer and state rt-preKent ative on the side it you will. My
real occupation is agricul rure and private land, completely.
My comments today will focus on three particular
areas and then the documenr ar. a whole.
First, let me say be) ore I get too tar that In me
words mean things, And T think that they should mean things
tn all of Ufl. We must, use words as they are defined, or we
risk losing nil meaning that any document, any statement, or
any communications that we have, and we will lose that
meaning.
Specifically. T would like to comment on page 147
under the title Neotropical Migrant Birds. The draft EIS
states that [quote), "The planning area provided nestings
habitat for around 100 species for neotropical miqrant
birds- The population of most of those species are
declininq in port duo to the habitat fragmentation on the
breeding grounds in the pLanninq area. Some example at
these species are swallows, warblers, flycatchers and
sparrows." What habitat fragmentation is occurring and what
decline in bird numbers are documented? And why Hhould
30
1
these statement* be made if there is no documentation. It
2
3
■1
makes me wonder what possible neotropical migrant bird still
next will be listed. And then what - - an an endangered
species. And what requirement does that entail if in fact
habitat Iragmentar .ion 1^ uccurr incj? Ones that lead us to
r.
more federal concro'V Are we going to need f.n change
7
fundamentally what occurs on the acres here?
a
Secondly, on pages 2lfi and 819 the lint of those
9
(quote) "consulted." It include* all elected officials in
10
the Big Horn Basin. Consult in my dictionary means -- has
13
words like counsel, advise, refer to, and consider. Fn tact
12
ia
having been contacted by one mailing in June of 1993. I do
not consider that I, myself, have been consulted. And so I
1 1
have a little problem and request, that you remove any
ifj
reference to me or my office from that consulted list.
16
Thirdly, on Table 3-5 on page 251 through 254 has
17
in it a column list.i ng (quote) , "sui table AUMs. " Thai
IB
clearly implies that some AUMss are not. suitable. And if
19
you look at that table, the table shows a reduction in
20
authorized Al'Ms from 137,000 to a recommended 130,589. *nd
21
suitable ;s listed at 101,000. If all the rest are not
22
suitable, then how could any agency clearly Hay we're going
2 3
to continue to do this. Tt neems to me that this document
24
is setting up \.he BLM for what may b« a friendly suit. By
that very document you believe thai suitable AL'Ms are being
1
31
1
exceeded. Well, maybe cattle tres by "93 didn't work, ao
2
cattle reduced by '95 will.
3
My clear belief behind this document is to reduce
4
the traditional uses of grazing , timbering , ail product ion,
and mining, and increase the recreational opportnni ties , and
f>
Wyoming will grow by it, according to the dooumont. But.
7
that defies financial sense. The average worker in the
H
racreational field in Wyoming cams a wage of 312,300. The
9
average worker in the other fields we have talked about
in
Earno in excess of 300,000, in most situations. I didn't
11
figure a complete average, but mineral production is well in
12
excess of — 1 said 300,000, I meant 30,onn per worker. Mow
13
can Wyoming balance a budget on the backs of those people
14
who are in fact earning below the poverty level. it will
15
not work.
15
So let's admit our biases- Mine in toward
17
Multiple: unci if the culture that has made Wyoming what It is
] B
today. This document seems to be lock up the land, and
19
shrink from consumptive uue.'i of naturally occurring iind
20
regenerating resources. Let 'a throw cut. this plan and ioin
21
together in coming to a new plan that truly consults with
22
the public and builds a broadly based economy Cor Wyoming
23
and tor the Big Horn Basin. Th*nk ycu.
24
f Applausa) .
MR. DANIELS: Thank you very much. Our next
32
1
speaker will be County Commissioner Will Glanz from Worland.
2
KR. GLANZ: Good afternoon. 1 am coming here
to read you a letter that we prepared as County
4
Commissioners from Washakie County. The letter is addressed
5
to DarreH Barnes and it's in reference to the firass Creek
6
Resource Management Plan.
7
The Washakie County Commissioners would like to
8
thank the local Bureau of Land Management -- r have been
9
thanking them all day today office for extending the
10
comment period and allowing the public hearing on the Draft
11
EI8 and proposed land-use plan as requested by the tour
12
count Lea . He appreciate that .
13
Our comments will h* geneial in nature that we
14
15
will have entered Into the record today. More in depth
concerns iaenti lying specific sections of the plan will be
1 IS
submitted at a later date. T might add, the May 7th
n
deadline for comment* is only enough time to study one
i a
section of the plan at a time. The Bureau ol Land
19
Management has taken lour years to prepare this document,
20
and we received our first, draft in January of '95. Four
21
months is hardly enough, time for us to address all the
22
Issues properly.
23
The law, through NF.PA and FLMVA procees requires
24
federal agencies in the planning process to involve local
25
and county governments at the planning table. We disagree
515
33
1
with the Bureau ot Land Management that an invitation to an
2
open house held by the Bureau of Land Management ig tlie same
.1
as sitting together throuqh a planning process, as required
4
by law.
Our local economy and reduction of out tan base we
C
foci is It risk and could cause extreme haicr.hips on our
7
local civilians that are left to pay the tax bill if this
8
plan io implemented. That tax base ran be identified under
9
limiting oil and gas exploration and production. Timbering
10
is also viable to our local economy. Plus limiting
LI
reareationists, limiting hcchkk by merest ionistn and
12
hunters «o feel will also afTum our tax base.
13
A major problem the county has is the reduction of
M
the AUMs by 26 percent. Whan there has already been an
IS
approximate 35 percent reduction in the last 20 yearn.
16
Reducing the AUMs and doubling the wild horse herd range is
17
to ub, ridiculous, and certainly does not support any
IB
economic benefit, to our county. Concerns we have cannot be
19
researched by the May 7th deadline and could take as much as
20
two years we feel .
21
To go on, the State: of Wyoming, six years ago, in
22
cooperation with the county governments developed a local
23
Uiq Horn Basin Master Water Plan. That plan Identifies
24
50,000 acre teel of water still to be used for irrigation
&B
purposes on newly developed land in the Big Horn Basil).
Fifty-thousand acre feet could be doubled under the interior
Department's new Conservation Plan. The Big Horn Basin
Master Water Plan identifies approximately 60,000 acres,
along with the water, of federally controlled land that car.
be put under irrigation. That plan went, on to say that when
the market can afford the development. The feasibility of
that developing of such land is gel ting closer. The lands
identified in the master plan are located from Thennupolis
to Powell and are within the boundaries of the Crasfi Creek-
Resource Area. If we could put 50 percent of the
identified land into production it would be a fifteen
million dollar economic boost to the four counties here in
the Biq Horn Basin. And I am talking direct dollars,
annually. The 30,000 acres proposed to he developed are a
very small percentage compared to the nearly 4,000 acres
this plan wants to sot aside for critical environmental
concerns .
Nowhere in the proposed Crass 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 could be a great economic
loea to this county's future.
To go on, the glossary we feel should be expanded
to include definitions of all the terms used in the
document. An index must be added to the document to
3 5
1
facilitate analysis. We feel that reference should cite
2
specific publications and authors, especially for
al 1
3
decisions made in the document tor which there is
4
disagreement or controversy in the scientific and
business
r>
community. Lack of a complete glossary and index
and
6
complete reference section has made it difficult,
if not
1
impossible to analyze the Hraas Creek Resource Ma
lagement
8
Plan.
9
And In this management plan, perhaps in
place of
10
this management plan, perhaps a CRM plan would be
more
11
acceptable or coordinated resource management pla
that
12
could be developed.
13
In closing we as county commissioners are deeply
14
concerned about our customs, cultures, and our ect
nomic base
15
being eroded. Thank you.
16
(Applause) .
17
MR. DANIELS: Thank you very much.
Our next
IB
speaker Jay Moody, and he is from Cody, Park Coun
y.
19
JAY MOODY: Thank you. As Bill sai
d, I'm Jay
20
Moody and T am speaking this afternoon on behalf of the Park
71
County Board of Commiws ioners . And the comments
hat I will
22
make this afternoon come from a letter that our board has
23
written which is addressed to Mr. Bob Ross.
24
Proper management ot our public lands ar
6 the
2 5
unique quality of life it sustains is important to the
36
1
citizens of Park County. We must think in terms of the next
2
50 to 100 years and manage these lands Cor our children and
3
grandchildren. With this m mind the Board of Commissioners
4
from Park County offer these comments which are based on
5
input from our county task force assembled CO evaluate the
6
Draft P,rs for the Grass Creek Resource Aroa.
7
l! Fire Management: The plan is calling for good
a
tire management, but this is not followed through. There
9
should be details included with acreage, location where
10
burns are prescribed, fuel load, and a time table with on
11
annual percentage target with a maximum of a 50-year burn
12
cycle. It is better to manage through scheduled burns than
13
to change the plan and cut allotments. Th* BLM should work
11
with private landowners on burning agreements so that full
15
suppression would not be necessary. We support fire
16
management over chemical spraying.
17
Proper lire management would also have the added
18
benefit of improving sagu grouse habitat, and improved
19
habitat would help keep the ;;aye grouse off the endangered
20
species list .
21
2) Fish Habitat: Enhancing potential fisheries
22
in the area does not seem to improve the ecology of the
2.1
area- New species should not be introduced into the area.
24
A) Forectland Management: The restrictions on
25
harvesting firewood along desert waterway a and the 8ig Hon.
516
wKMammwmmMmmamam
37
1
and Greybul I Rivers are not appropriate in all casco. ft
2
better management option, in some cases would be to allow the
3
removal ol standing trees. Table 19 does not promote the
■1
regeneration and conversion «f old-age forest. The mature
5
and over mature stand is excessive and does not support the
ft
objectives set forth in the table . All Lour alternatives
7
are inadequate for managing a aland that is Rfi percent.
H
mature.
9
4) Grazing Management : There needs to be three
It)
viable alternatives. Much ol t.hia auction iy the aanie
11
throughout, that is "same as preferred." There arc no
12
comments In the document that this a; ea is in a serious
13
deterioration mode. Hence there is no Justification for
u
cutting AUMs, except for where individual abuses can be
is
Identified. Every effort should be made to keep ranching
]f>
viable. One possible alternative could be holistic resource
17
management. The data used is based on 1990, which is not a
18
typical year. Data should be averaged over all years
19
available to establish a proper baae lino.
20
5) Off-road Vehicle Management: Signing and
2]
enforcement arc not. covered in the document- Areas for off-
22
road vehicle uwe need a clearer designation. Fines should
23
be established for driving in areas closed to ORV use. The
24
proposed scenic interpretive road loop in the badlands; area
25
may increase off-mad vehicle use.
6) Oil and Gas Management: In reviewing the
historic aspects or. the fields involves restricting their
use. We do not support the review process. The no-surface
occupar.cy and timing restrictions do not take new
technologies into account. A more reasonable proposal lor
this area would be to allow corridors of access and to
propose reasonable cluster development. standard leasing
terms and conditions sufficiently cover many of the concerns
being used to justify the Preferred Alternative. The
recoverable reserves projected arc not baaed on fact.
Estimates should have low and high ranges with the high
range supported by data from similar fields in the area.
7] Special Management Areas: Creating an ACEC
in the Fifteen Mile Creek watershed should not be done
wi thout adequate justification in the document .
8) Vegetation Management: The format used for
planl communities is insuf f icient . Key apeciua should he
identified in each group and further broken down hy species.
A species list would be useful in the evaluation of areas
for potential transplant* of protected plant speries.
91 Watershed Management: The benefits of water
discharge from the oil fields needs, to be recognized on a
short-term basis Eor the productive lifetime of an oil
field. In obtaining water rights, co-filing should be
encouraged between the BT.M and permittees. When fencing off
39
1
reservoiis, reliable sources of off-oitc water should be
2
made aval 1 able.
3
10) wild Horses: We would like l.o see the
-5
money allocated to wild horse management used tor range
5
improvement. ; that is watershed, wildlife, and grazing , and
6
concentrate the wild horse -■ the wild horses in the
7
McCullough Peaks area. The wild horse herd should be
8
eliminated. At a minimum alternative B should be followed.
<?
The detrimental effects of having wild horses include that.
10
they compete with the wildlife and bring traffic into the
11
area. This program is not cost effective and the money
12
could be better spent elsewhere. Also the 2,300 AUMs could
13
be additional allotted grazing opportunities.
1-1
lit wildlife Habitat: Discussion on proposed
15
increase-? in wildlife herds should occur with the Wyoming
16
17
Game and Pish Department and permittees before any
reductions in AtlMs for livestock are implemented. Ground
18
analysis of actual use by threatened and endangered species
TJ
should occur before areas are withheld as crucial habitat.
20
Thank you Eor your consideration ot these matters.
21
Respectfully, the Board of County Commissioners of Park
2.2
County, Wyoming. John .1. Winninger, Chairman; Charles W.
23
Johnstone. Commissioner; Jill Shock ley siggins,
24
Commissioner; Beryl Churchill , Commissioner, and Jay Moody ,
25
Commissioner.
4 n
1
1 am submitting a written copy o£ these comments
2
3
together with a detailed comment compilation from aur
advisory group.
4
(Applause) .
5
MR. DANIELS: Beryl Churchill, Wyoming Rural
ft
7
0
UevHlnpmenr Council .
RERYL- CHURCHILL: My name is Beryl Churchill
and I'm a Park County Commissioner. 1 appreciate the
9
opportunity to comment on this very important management
10
plan and ask you to enter this statement into the record.
1 1
first let me say that I support, without
12
reservation, the letter commenting on the plan which was
13
submitted to you by the Board of Park County Commissioners.
10
1 5
These comments are based on the input of a county task force
which Wfis assembled to evaluate the Draft EI8 for the Crass
If!
Creek resource area. This task force devoted many hours to
1.7
study the draft and are to be commended for their thorough
18
review and intelligent conclusions. 1 would ask the task
19
force comments be given serious consideration in the final
20
ETS .
21
The task force's comments cover the major points I
22
personally believe are unacceptable in the plan. However,
23
there .is one statement in the vegetation management section
24
to which I strongly object and would like to comment on it.
25
In thin section while discussing the issue of candidate and
517
threatened and ^ncanqered plants, the suggestion le made
that the (quote), "BLM participate with Nature Conservancy,
U.S. Department of the Interior and Wildlife Service, and
other agencies in the evaluation areas for the potential
transplant at protected plant species on BLM admini stared
lands" {unquote) . 'Che Nature Conservancy La a private
organisation. This statement suggests the conservation
group somehow has the came status as Federal ayencJ.es in
determining the course of action on public lands. Not so.
While it is logical to ask Cor the Nature Conservancy's
input, it should not. b« the only privaFe group which
contributes to a management plan. The Farm Bureau, multiplw
-use associat tons, livestock organizat inns, and many other
representatives of the diverse groups which use public lands
for commercial or recreational purposes should be asked to
participate in writing a plan. Participation by University
of Wyoming specialist?! in also, l believe, critical.
For me, perhaps the biggest disappointment: with
the draft EIS was that the public was not notified before
the first draft was written. The initial comments on the
preliminary draft were largely ignored. At a meeting held
1n May, 1994, the public was told what would be in the plan
without an opportunity tor input.
Don't forget the customer base of this resource
area. By enlisting the help and cooperation of natural
resource-based industry representatives ir, the four counties
a plan could be written which would correctly address the
needs of this customer base. T believe it would be
reasonable to allow the counties to fake the lead in
preparing a preliminary plan which would then be submitted
to the state director of Bl.M for reference before an
environmental statement is written.
It has been nearly 13 yoaro oince a plan has been
written. In the future. T urge you to prepare I management
plan in a more timely manner and encourage local involvement
at the very nafliMt stage of development ,
Again, I appreciated !he opportunity to express my
views.
Mao at this time, Mr. Chairman, I have a letter
from Jack Winninger who had some problems today and is not
able to be here. I would like to have it entered into the
record. And it is hi a personal comment on the plan.
(Applause) .
MR, DANIELS: Thank you very nt.uch. It's 5:00
and we'll take a ten minute recess and start again at about
12 minutes after.
{Whereupon a Break w.*a Taken) .
MR. DAM ELS: if we can bring the hearjnq t«
order again. Our next speaker wli: be Charley Johnstone,
Park County Cnmro i ss toner .
4 3
1
CHARLES JOHNSTONE: My name is Charley
2
Johnstone. I'm a Park County Commissioner, Forester, a
3
logger, and a lumberman. I'm also a member of the Sierra
A
Club and the Yellowstone Coalition, not because l subscribe
9
to their philosophies, but because T l-.ke to get their mail
6
7
B
before I read It in the paper.
The people of Wyoming, the Biq Horn Saain, and
Park County derive the bulk of their livelihood and tax base
9
from natural resources reaped from public lands within their
10
respective political subdivisions . Since the federal
11
government, at least for the. moment, owns or controls most.
ta
of the land within F.hwRe aoMlviaiona, Lhey control the
13
natural resource derived therefrom, and thus our economy and
14
t ax base .
15
Thia proposed Draft Environmental Impact Statement
16
will have a serious negative impact on the economy of the
17
families, cities, and counties in the R:g Horn Basin. We in
18
Park County are constantly being naked to provide more or
19
higher levels of service from our citizenry.
20
Simultaneously! we're faced with ever shrinking budgetary
21
funds, largely because of the decline in revenues From
22
public lands resources;.
23
The residential, subdivisions resulting from the
24
influx Of people to the county do not pay their own way.
2b
They have a net negatives impact, on the county budget- Even
44
1
you as government employees can he included in that group,
2
in that you are among the direct beneficiaries of our public
3
lands resource-based economy.
■1
Hi this draft, you propose to reduce everything
5
that has a positive economic impacL on our counties. Your
6
blanket proposal to reduce grazing AUMs substantially is
7
unacceptable. If you have isolated specific areas of
8
concern individually, then handle them individually, not
9
with this meat ax approach. Much of the AUM reduction is
10
based on data from the old Crasa Creek plan which the
11
Bureau, itself, determined to be unreliable. The reduction
12
of livestock AUMs in favor of the wild horse ranqe expansion
13
is a complete waste. Were you to do a cost benefit analysis
14
ol wild horses the result would almost entirely be on the
J 5
cost side of the ledger. And I would be hard pressed to
16
find tax revenue in the Park County budget that could be
17
traced tu wild horses.
18
Clearly, the commercial timberlands In the Crass
Ifl
Creek area do no: remotely compare in leims of productivity
20
to the rain forest of the Pacific Northwest, nut, they
21
could be- much more productive than they are than IFiey are
22
now if they were properly managed. The only way to induce
2.3
productivity into a forest that is 86 percent mature or
24
over-mature is to substantially thin it out.
25
The oil and gas industry in the Big Horn Basin is
518
15
1
clearly our principle benefactor. Anyone who does nor.
2
understand that is either out of touch or they have been out
.1
of town. Rather than mj going Into great detail regarding
A
this industry, T would defer to those much more qualified
5
than l io address thai i3sue, and simply submit six pages of
6
comments prepared by the nil and gas industry to which 1
7
stipulate.
Q
T am convinced that this Draft EIS is nothing more
4
than another battle to be fought in Secretary Babbitts war
10
on the West, it is remiss in addressing the customs,
1J
culture, and economy of the four counties in the Big Horn
12
Basin, and thus ifl clearly, in my opinion in direct
1 3
violation of the NKPA Act. I strongly recommend a complete
14
rewrite with the artive hando-on involvement of the four
\h
affected counties and their respective tank forces. Thank
16
you for the opportunity to speak. I submit these comments
17
for the record.
Ifl
(Applauaal .
19
MR. DANIELS: We would ask the speakers to
20
please speak up and speak into the mike if possible. Some
21
people in the back are having a difficult time hearing you.
22
Our next speaker will be Hot Springs County Commissioner
23
Darvin Longwell .
24
DARVIN LONGWELL: T'n Darvin l,nngw«U, County
as
Commissioner from Hot Springs County. This ta a letter from
46
1
the Hot Springs County Commissioners to the BLM people.
■>.
The Hot Springs County Commissioners thank you for
3
4
your attending the public meetlnq held In Thermopolis on
March 21, 1995. Also we appreciated the opportunity for the
7
B
hearing today.
Ke nope that all concerns of the people ot Hot.
springs County as presented by the committee persons will be
taken under serious consideration by the BLM -- of land
9
management. The plan you have set forth will have a serious
10
negative economic impact for this area, if implemented as
1 1
written we agree it spells financial disaster for Hot
12
Springs County.
Various industries have spoken loud and plain on
14
the issues and we believe these spokespersons have the
15
support of all the people of Hot Springs County. The Hot
IS
17
Springs county Commissioners do strongly support the input
from the people who have the expertise in oil, minerals,
'IB
agricul Lure, recreation, and timber industries, and have
19
spent Lime researching the Grass Creek Resource Area
20
Environmental Impact statement.
21
Tf the Grass Creek Resource Management Plan is
22
implemented as drafted, the Hot Springs County Board of
23
Commissioners cannot support this plan. Yours truly, Darvin
24
Longwell, Hot Springs County Commissioners.
25
(Applause) .
MR. DANIELS: Thank yon veiv much. Our next
speaker will be Jin Gould from Park County Conservation
District Meeteetse.
,11M r.otlbi): I am Jim Gould. T'm chairman of
the Meetaetse Conservation District. Today T am speaking on
Meeteetse Conservation Oistrict'3 behalf. 1 would like to
thank the Bureau of Land Management for holding this public
hearing.
Meeteetse Conservation District, hereafter
referred to as BCD has the responsibility to provide for the
conservation of soil, and soil and water rights resources of
this state, and thereby stabilizing ranching and farming
operations, to preserve natural resources, protect the tax
base, control floods, prevent impairment of dams and
reservoirs, preserve wildlife, protect publ ic lands, and
protect and promote the health, safely and general welfare
of the paoplo of this state. This is by authority of
Wyoming Statute Title 11, Chapter 16, 101 through 120, and
United States Public Law 56fi.
MCD is a local government and therefore enloys all
the provisions and protection oi NKPA. HBP* 12 EJSC at
Section 4332 (C> fi (v) states that the comments of local
government are to he included in the Grass Creek Area Draft
Resource Management Environment a I Jmpaet statement ,
hereafter referred to as the draft, through its entire
review process. The Bureau of Land Management js currently
in violation of NEPA in this section for the BLM has not,
included the written and verbal comments provided by MCD
during the scoping process. MCD is not. listed in the
required reviewers on pages 218 and 219 of the draft.
MCD in the initial stages of this scoping,
requested the BLM to consider the Preferred Alternative of
holistic resource management, hereatter referred to as HRM
or Coordinate Resource Management.
The range utilization established by the federal
government do not reflect climatic change as an often and
overriding variable on grazing allotments. To reflect
climatic change correctly in the range utilization levels,
holistic resource management techniques must, be applied to
the resource health, and sustained grazing use. Cutting
AUMs based on uncertain quantity of data, as prescribed in
the draft will r.ot benefit the custom and culture and the
economic base of the oooperators of the MCD.
MCD questions why the important benefits of
livestock grazing on public land resources are not
identified in thft draft, such as that sustained livestock
grazing can thicken, support, and sustain the multiple plant
communities; that livestock hoof action works minerals into
the upper soil hori2ona by the laying down of plants, to
litter, combined with dunging and urination, completes the
519
mineral cycle; the elimination of sequencing (minerals and
other ftutriftnt* beinq lost to the atmosphere or held in
suspension); the incrnan« of litter improves soil's
resistance to wind and water erosion, and improves the
moisture retention capability of the soil. MCD does not
find the above mentioned qualities, benefits, or terminology
such as water cycle, mineral cycle, enerqy flow and
succession which are enhanced by cattle grazing, in the
draft.
The BLf. has followed the same standards year after
year only to suffer the same pitfalls. The existing
proposed standards cannot be the same for every grazing
allotment- Therefore wo need a new set of tools for true
and effective management Eor the wide variety of resources
for both the public and private benefit.. The Bl.M must
adopted the HRM guidelines and tools in order to effectively
and economic.! 1 ] y manage and improve and sustain the Grass
Crank area. These proven tools will take into consideration
the entire resource base, the economic well-being, and the
custom and culture of the individuals and communities within
the Crass Creek area. MCD strongly recommends as evidence
we entered into the scoping process that the BLM consider
the goals, policies, HRM concepts 01 the Meeteetse Land Use
and Resource Management Plan, 1994, and that it be used in
reviewing and establishing revised management standards in
the final decision for the Crass Creek area.
Ths draft is not acceptable to the cooperators of
the Meeteetse Conservation District in its present format.
The draft must be rewritten to reflect the concerns and
comments for tJlfl improvement received by th* BLM officials
Irom the past public forussa sponsored by local communities
and correspondence offered by affected communities in the
Grass Creek Resource Area.
The comments recently made- by BLM officials
regarding paper AUMs versus real on-tha-ground AUMs is
disturbing, and Meeteetsp Conservation District suggests
that the history of adjudication of all existing AUMs on
existing grazing allotments were well conceived and not done
erratically or without reqard to the reBourcf. We suggest
thai, the history o! the adjudication of grazing allotments
be researched and made part of the revised draft. For the
FILM to maintain that, a change is necessary in the existing
number of AlIMs on existing grazing allotments without
conclusive evidence or a financial resolution thereof is a
taking of private property rights subject to the provisions
and jurisdiction Of executive order number 12630.
MCD will provide the BLM with a video, the "New
Ranqeland Compact." We believe that the I5LM needs to employ
the concepts and ideas represented in the video. You have
asked for positive input, please lead by example, employing
5]
1
positive output.
2
3
MCD requests that the BLM use its new tools nt SIS
to identity prcbJem areas and start working t-herB.
4
1 have more comments, but my time is up. I will
5
submit them along with Meer.eet.se Conservation'* Management
6
Plan. Thank you.
7
(Applause) .
8
MR. DAWTELS: T would next like to call on
•i
Mr. Jijn Kirsch, 'i'herniopolis.
10
JIM KIRSCH: My name is Jim Kirsch. I'm th«
1 1
Manager of Hot Springs U.S.A., Incorporated. We're a rural
12
electric utility that provides electric ssrvios in the rural
13
regions of Hot Springs, Washakie, Park, and Big Horn
14
counties, excluding the towns; of Thermupol is , Worland, and
15
Kirby. He provide electric service in Hamilton Dome, Little
16
Buffalo Basin, and smaller oil fields withir. the area.
17
I noticed in the Draft Environmental Resource Plan
18
there are three goals; Vegetation Management, Special
19
Management Area Designat ions, Resource Accessibility and
20
Manageability.
21 !
I believe there are three areas that the plan is
22
lacking. 0n», the plan does not Lake intw consider a t.i on the
23
economics ol the residents of the resource area, the ability
24
of the residents to increase their economic product.) vi ty ,
25
and does not support or encourage multiple use of the public
52
1
land a .
2
We notice that this document recommends fewer
1
A
units of livestock and more restrictive mineral extraction
practices. A multiple plan which causes increased hardships
5
on the people who live, work, and protect the area by their
6
presence. It's not in the public interest.
7
I am particularly concerned about the section that
a
deals with rights of way. 1 see that those areas where
9
existing power liner, are located and where people reside atf
10
1:
areas that are asked for restriction of right-of-way. T
notice that it is requested that we stay 500 feet away from
12
riparian areas. I would suggest to you that it would be
n
extremely difficult to provide electric facilities to places
14
where people wish to refi-.de and enhance the economic
15
opportunities of the arfd if we are required to be th.if far
16
away from riparian areas, current restrictions already
17
delay installation of facilities and are cor.tly for both the
18
utility and the member requesting service.
IS
Any significant economic development will involve
20
both transmission and distribution facilities. This
21
document only addresses transmission facilities and is
22
totally riilcnt with regard to distribution facilities. T
2 3
would hope that this document does not. in any way make It
24 i
o-.ore difficult fur richer the utility or the members to
2'>
obtain rights-of-way.
520
mmaatamsBmxaaa
53
1
On page 79, Table 16. a 1 percent change in 2.4
2
bill inn dollars in not thought to be significant.. That 25
3
4
million dollars, even spread over 14 years is a. significant,
change to the residents ot Hot Springs and adjacent
g
counties .
fi
We believe this document should Bttfee it easier for
7
people to promote economic activity in the Grans Creek area.
a
Hot Sprinqs R.E.A., its members and employees provide *
9
stable population base which stimulates local and state-wide
10
activity, Multiple use ot public lands in Wyoming is a
11
major factor in our members' quality of life and their
12
abi 1 1 l.y to provide for thei r fami 1 ies .
13
Today's family members are the future Wyoming
14
19
citizenry base. Thank you for the opportunity to provide
these comments.
16
(Applause! .
17
MR, DANIELS* Thank you vary much. Mr. Frank
18
Keiiy, 6reybull«
ID
FRANK KELLY: My name is frank Kelly. I am
20
speaking for the membership of Grass Roots Alliance for
21
state Sovereignty. Our concerns are lor the assumptions
22
that the Bureau of Land Management, has the authority to
23
Impose regulations.
24
I refer now to the Declaration of Independence tor
25
parallels between th« past and what is being attempted in
54
]
this room today. "We hold these truths to be self-evident,
2
3
that all men are created equal, that they are endowed by
their creator with certain unalienable rights, that, among
4
these are Life, liberty, and the Pursuit of Happiness. That
5
to secure these rights, Governments are instituted among
6
men, deriving their just powers from the consent of the
7
governed.
8
"And when a long train of abuses and usurpations,
9
pursuing invariably the same objective evinces a design to
10
reduce them under absolute despotism, it is their rLqht, it
11
is their duty, to throw off such government.
12
"The history of the federal government is a
13
history of repeated injuries and usurpations, all having in
14
direct object the establishment of an absolute Tyranny over
15
these state*. To prove this, let facts be submitted to a
lf>
17
candid world.
"Ho has obstructed the Administration of Justice,
lfl
by refusing his Assent, to Laws for establishing Judiciary
19
Powers.
20
"He has made Judges dependent on. his win alone.
21
for the tenure of their offices, and the amount and payment
22
of thei r salaries.
23
"He has erected a multitude ot new offices, and
24
sent hither swarms of Officers to harass our people, and eat
25
out their substance."
55
1
Do you see a parallel between the past and what is
2
being attempted in this room today?
3
"He has affected Lo render the federal agencies
4
independent of and superior to the local power.
f>
"He has combined with others to subject us to a
6
jurisdiction foreign to our constitution, and unacknowledged
7
by our laws; giving his assent to their acts of pretended
8
legislation.
3
"For protecting them by a mock trial and phony
10
regulations from punishment for any intrusion of privatr
U
property rights and personal liberties upon the Inhabitants
12
of these states."
13
Do you see a parallel between the past and what is
14
being attempted in this room today?
15
"For imposing T^xes and fees on us Without our
16
17
consent :
"For establishing therein an arbitrary government,
1ft
and enlarging its boundaries so as to render it. at once, an
19
example arid fit instrument for introducing the same absolute
20
rule into thane states:
21
"For takiny away our charters, abolishing our moat
22
valuable laws, and altering fundamentally the forms of our
23
Government :
24
"For declaring themselves invested with power to
25
legislate lor us in all cases whatsoever."
56
1
Do you see a parallel between the past and what is
2
being attempted in this room today?
3
"In every stage of these oppressions we have
4
petitioned for redress in the moat humble terms. Our
repeated petitions have been answered only by repeated
6
injury. A government, whose character is thus marked by
7
8
every act which may define a tyrant, is unfit to be the
ruler of a free people.
')
"Nor have we been wanting in attention to our
10
federal brethren. Be have warned them from time to time of
11
attempts by their regulatory agencies to extend an
12
unwarrantable jurisdiction over us. We have reminded them
13
of the circumstances of the great state of Wyoming entering
14
the union. "
lb
Do you see a parallel between the past and what is
16
beinq attempted in this room today .
17
For farther reference we refer you to the U.S. and
18
the Wyoming Constitutions.
19
The opinion of Grass Roots Alliance for state
20
Sovereignty is you have no semblance of authority to even
81
bring forth such a document for our consideration, nor does
22
the state have the authority to diminish the rights of the
23
citizens, so says, the Supreme Court in the case of Hurtado
24
versus California- And Crass Roots intends to hold the
25
federal governmen I. accountable to the supreme law of the
521
57
1
land, i.e., the U.S. and the Wyoming Consti tutions .
2
T do have a copy of my speech , but you should
.1
already have it. Tt is called the Declaration of
4
Independnrirr;. And our forefathers fouqnr a revolution to
5
end those worts of abuses.
6
(Applause! .
7
MR- DANIKLB: Than): you very much. Mr. Jim
K
Foreman, Ter.sleep.
9
JTM FOREMAN: Well, thank you. I have had
10
the- opportunity to study the 490 pages in the the two draft
n
reports. The mission today is to L-ondense 25 pages of notes
12
into o few observations for presentation to you in five
13
minutes.
14
The BLM reports represent a lot of hard work. And
15
1 would suggest that we don't shoot or blame the messengers
16
here today. That will become evident at the end, T believe.
17
My belief, is very simple, that permittees have
18
paid for the leases, but we are still lessors of public
19
lands. We have- a responsibility to fix what we damage
20
through livestock grazing. If it's broke, fix it. The key
21
question is where is the significant damage now?
22
The problem is 16-year old ecoloqical inventory
22
ahOWfl that 35 percent of. tfai 95.1, 000 acres of BLM ground is
24
in fair condition, with the balance in good or excellent
25
condition, or not measured.
58
l
Vegetation morii lonng data hao been collected
2
3
■1
since 1983 using various techniques on 60 percent of the
allotments, but with inspections only on the remaining 40
percent .
The current OOnOlUSion is that 83 or 53 percent of
6
the a! lo Linen ts are in the improved category, of which 2.1 or
7
15 percent, have had inspections only. Determinations are
a
baaed primarily on subjective criteria which differs from
9
the criteria used on the Washakie Resource Area.
10
Of the 2,260 acres of public riparian areas, 880
1 1
or 39 percent ,ire in downward trond or are not functioning.
12
That's not many acres.
13
The £18 document shows a major 35 percent decrease
14
in allotment use under the Preferred Mternative. And as
15
originally stated by Jim, a 30 percent decrease under
16
current plans. The reported data indicates significant
17
reductions have already been made during the past 15 years.
18
The impact, what does that mean? Current plana
19
show the numbers, and I win lust read a couple of them:
2 0
1-6 million dollars per year economic activity loss, a
21
personal income loss of 8354,000, and a loss of 27 Jobs in
22
the next ten yearu.
23
The preferred pi.an is somewhat higher. Economic
24
losses trc important, but the impact on people is
devastating. Just Look around at the Crass Creek permittees
in this room. Over 20 percent, perhaps, or one in five
could be out of work in ten years. How many ranches will be
sold oil. will the Meeteetae High School close. This is
why you have heard some and you will hear a lot. more, I
believe, of fear, frustration , and concern.
This impact Is a high cost to pay for the defined
ba.OQO acre increase in upward vegetation trend, and a 38
percent or 330 acre reduction In the downward trend of the
880 acres on no.i-functioning riparian acres. The projected
massive 45 percent increase in visitor days that yields
seven Co 14 new jobs does not compare with the loss in jobs
existing today. There must be a better way.
There is a possible solution. There's absolutely
no reason why Wyoming people, as represented in this room,
and those many that arc not here, environmentalists, cannot
work together to objectively determine the problems due to
livestock qra?.:nq. A combination of permit tees,
recreational isls, environmentalist , profess tonalit, and D[,M
personnel working in the field should he able to agree both
on Lhe problems and a corrective action needed.
T am confident that the 880 acres of public
riparian lands in the downward trend can be surveyed in one
or two weeks. Why not. try a pilot program on one allotment?
Let's find out where the problem is. Wyoming has an
excellent track record with CRM programs. At present
bO
1
there's 80 that exist in the state. Let's build on the
2
3
In conclusion, I would like to offer just three
4
simple observations. The BIS current plan would reduce
S
livestock grazing by ^ft percent, compared to the 35 percent
6
7
in the preferred plan over 15 years. These reductions are
simiLar to the 26 and 28 percent reductions in Rangeland '94
R
over the next, ten years. It appears there's a strong effort
9
to remove livestock from public lands. Could this and the
10
recent Bureau of Reclamation plans indicated a conspiracy
11
between the current administration and the extremists.
19
national preservation organizations in Washington? Think
13
about it. We don't have time to blame each other or the BLM
u
me-asonqors, this is unproductive. Let's work together to
lb
change the future. We certainly can't change the past.
16
Thank you.
17
(Applause) .
1 H
MR. DANIELS: Ken Cook, Mayor of Burlington.
19
KEN COOK: As the Mayor of the Town of
30
Burlington l would like to present gome figures to you that
21
will probably illustrate in a very dramatic way why we as
22
elected officials in the Town of Burlington are vitally
23
concerned about the management of Wyoming's resources.
24
Tnh town haei a budget of approximately $55,000 per
2fS
year. Now of this budget approximately 85 percent comes
522
from three sources; the mineral royalties, the severance
taxes, and the sajer and use tax.
Now, the amount, of course, of the aalou and uce
tax if) directly related to the health of the gas and oil
industry, l.he mineral Industry, and the livestock industry.
Therefore, it is easy to see the se::ious impact thai,
decreases in the productivity of these three industries
would have not only for the Town of Burlington, but for
every town in the State of Wyoming.
I would Like to emphasis Chat in ten years Lhe
Town of Burlington, it's been incorporated for approximately
'.en years, ha3 been fortunate enough to put in a town water
and sewer system, develop parks for the children, improve
our irrigation system through underground ditches, and build
a now town hal l .
Now the reason 1 mention these projects is because
the vast majority of the money that was used to implement
and complete these projects, as you've probably guessed, has
came from the severance taxes, and the mineral royalties
through the Farm Loan Board.
Therefore, ae you can see the Town of Burlinqton,
and speaking for every town, has much at stake in the future
wen-being of these industries. If these industries that
I've mentioned falter due lo over-regulation, it Ol course,
would create a much higher necessitate the creation of
62
.1.
much higher taxes for the cities and counties in the state.
2
3
And needless to say, the progress of the cities and counties
in the state would slow to a snail's pace.
4
Because the federal government controls so much ol
5
the state, our tax base is, of course, very small.
6
Therefore, Burlington would oppose any new
7
management proposals for the rtraas Creek area that would
8
hamper or impede the productivity of these three industries
9
that I mentioned. Thank you very much for your time.
10
(Applause) .
11
MR. DANIELS: Mike Dfttwrufoein , Cody.
12
MIKE DAUERNHEIM: Good uf teniooii. my name is
13
Mike Dauernheim and I work for Marathon Oil Company aa the
14
Manager of Oil and Gas Exploration in our Rocky Mountain
15
Region office in Cody, Wyoming.
16
The primary objective ol Marathon's efforts In the
17
Rocky Mountain Region is to cost affectively replace our nil
18
and gas reserves through increased recovery ol hydrocarbons
19
from our existing fields,, and from exploration for new
20
reserves in yat-to-be-discovernd fields. ft is not an easy
21
■job. Many o: you are probably aware of the precipitous
22
decline in oil production in our state in the last ten years
23
I mm over 120 million barrels in 1965 to the present doy low
24
or around 70 million barrels. This decline is particularly
2rs
true in the Big Horn 3asin with its predominance of mature
63
i
fields and relative lack of exploration for new reserves.
?.
Oiven the fact that many other operators have pullad out of
3
the Big Horn Basin to focus on greener pastures in other
4
states and countcies, the stage is sot for a continuation of
5
these declinec. Marathon is still a major player in the Big
&
7
Horn Hasm and plans to be here for Che long haul. Thai, is
why we are extremely interested in this DF.TS.
a
From the technical Side, we believe there is .in
9
abundance ol hydrocarbons to be produced in thin basin.
10
However, wo feel that the Preferred Alternative with its
n
additional restrictions over and above those already in
12
place will make it i acre a 8 1 ngly difficult to convince our
13
upper management that work in this basin makes economic
14
sense.
15
In our opinion, overly aggressive restrictions
16
would hamper our ability to explore tor and develop
17
reserves. This, in turn, would do d severe disservice to
1 R
the citizeriB of the Grass Creek Resource Area where during
19
1990 the oil and gas industry contributed over 260 million
20
dollars of revenue to the local and state economies. We
21
teel strongly that our operations can continue to exist in
22
harmony with all other uses of the lands in this area
23
without the need for those heavy restrictions. Our families
24
live, work, and often retire here, and it goes without
25
saying that it is definitely not our In ten Lion to harm the
stste in any manner. We are proud of the lobs we do and are
committed to continue conducting our business with n high
regard for health, safety, and stewardship of the
environment .
Tn our opinion, the DEIS does not accurately
reflect the impact of the four alternatives on the oil and
gas industry. In contrast to the DEIS' assumptions, there
is no question Lhat the various alternatives would lead to
dramatically different exploration and development
scenarios. More restrictions lead to less activity, and
decreased activity leads to diminished production.
Production declines lead Lo fewer Jobs and lean revenue at
the local, state, rind foderal levels. The current
management, under Alternative \, is sufficiently restrictive
that many exploration and development projects are already
di acouraged .
The DS1S contains only limited socioeconomic data
relating to oil and gas development, and it appears that
this information was not a significant factor in the
development of the Bl.M's Preferred Alternative. We feel
that a comprehensive analysis of the socioeconomic benefits
of oil and gas activities in the area must be a major
component of the decision-making process. We recommend that
the BLM show in the analysis a comparison of the cost of
administering the minerals program and the industry's
523
HHHHIHHBHHHHB^^H
financial contributions to local , state, and federal
treasuries. The study must, include a risk assessment and
coyt/bcnef it analysis Co determine whether the benefits
outweigh the ri:;kn at allowing ler.e restricted nil and gas
development in the area.
we oppose the Preferred Alternative contained in
the DEIS because it would arbitrarily double the use of
restr ictive lease stipulations in the Grass Creek Resource
Area. The BLM has failed to present any data in the DEIS
which furnishes a basis tor the significant increases in
restrictions on future nil and gas exploration and
development aetlviti«M». The DEIS a La tec it La BiM policy to
Show the need for constraints in planning documents and that
it. must also be demonstrated that less restrictive measures
were considered bur found insufficient to protect, the
resources identified. A general statement thaL there are
sensitive or conflicting resource values or uses in the area
certainly does not meet analysis or policy requirements.
Clearly, it does not constitute justification for expanding
lease or operational restrictions. Discussion of the
specific resource to be safeguarded, along with a discussion
of the perceived conflicts between it and oil and gas
activities, must be given.
Marathon recommends "ho adoption ot Alternative R
which provides [or minimum across-the-board restrictions.
Under this alternative, environmental , cultural , historica 1 ,
and other concerns can be handled on a case-by-case basis
under the provisions of Section 6 of the existing federal
Lease Agreement. This states in part, and I quote. "Lessee
shall conduct operations in a manner that minimizes adverse
impacts to the land, air, and water, to cultural,
biological, visual and other resources, and to other land
uses and users. Lessee shall take reasonable measures
deemed necessary by Lessor to accomplish the intent of this
section, to the extent consistent with loaco rights granted
such measures may include, but are not limited to
modification to sitting or design of facilities, timing of
operations, and specification of interim and final
reclamation measures." In our opinion, this would be a
common sense approach to public land management whicft would
enable the potential impacts of oil and gas operations on
specific lands to be evaluated at the time work is proposed.
Thank you.
[Applauds] .
MR. DANIELS: Thank you very much. Our next
speaker is Joe Iccnogle, Cody.
JOE TCENOGL.E: I'm JOS IcenOgle. I'm a
excuse me. I'm a Certified Professional Landsman, but I am
here speaking tor myself. And T have gone through this
draft EIS and this is thB first time I've had an opportunity
67
1
to comment on one of these.
2
However, I've noticed or. Chapter 1, page 8,
3
"flcosystems and Management. And I've noticed that the BLM
4
has numerous definitions of ecosystem management, but in
5
this DEIS you have it down as, "A process that considers the
6
total environnenL, it requires that skillful use of
7
ecological , economic, social , and managerial principles in
a
managing ecosystems to produce, restore, or sustain
g
ecosystem integrity and do3ired conditions, uses, products.
10
values, and services over the long term." Well, my question
u
is, is this an official BLM definition, or is this one thai
12
a staff person has generated, because I have participated in
13
a bulfalo resource area management plan and in that
14
participation there was a report completed by William
15
Reiners and Robert Thus ton out of the Department of Botany,
16
from the University of Wyoming, in which they had three
"17
definitions of ecosystem management, none of which are
18
incorporated into this report, they also state in that
19
report that ecosyytem management has been practiced for
20
numerous years by de facto by the managers in the first
21
place, that this is not a new concept.
22
In addition, I have here a copy of an ecosystem
23
management definition which I have obtained from the Norland
24
District BLM office a year ago. and it states that,
2 5
"Ecosystem Management is the," interrogation -- excuse me,
"the integration of ecological, economic, and social
principals, to manage a defined aroa or region called
ecosystems, to maintain or improve natural diversity while
sustaining the economic and social viability of people and
communities." Well, 1 think the reason that we have so many
definitions of ecosystem management is that after reviewing
this DEIS, it appears that the BLM has little interest in
sustaining the economic and social viability of people and
communities. I mean it's sort of appalling when you read
this, the increase In no-surface occupancy, the increase in
controlled surface uses, it does not give industry; oil and
gae . agriculture, timber any credibility t'or the new
technologies that all these industries employ.
Number two, in developing alternatives under page
13, I notice that it states right there, why they didn't
address eliminating livestock grazing? why they didn't
address eliminating timber harvesting or eliminating oil and
gas leasing? How come thty didn't address increasing
Livestock grazing, increasing timber harvesting, increasing
oil and gas leasing? In today's ecological environment
there's not one reason why the American people can't have
healthy, multiple-use industries co-existing with a healthy
environment .
Or. Table 2. page 16, you talk about Air Quality
Management. The Preferred Alternative increases dust
524
control mwdHures for all construction ar.d other surface
disturbing activities*. Well, this is a broad and undefined
definition. Does it apply equally to drill -site
construction, off road vehicles, livestock herding, and wild
Morses? What will be r.h* cost benefit analysis at an
unfunded mandate of this type?
T notice under Table 2, page 24, Forcctland
Management, The Preferred Alternative for the management
objective, does not mention commercial forest products.
Therefore, the management objective does not address the
socioeconomic benefits derived from the commercial forest
products. The BLM needs to incorporate people and their
livelihoods into the Resource Management Plan a.i per the
Horland BLM District's definition of Ecosystem Management.
Under Table 2, page 44, Sfle and Oil. The
Preferred Alternative increases the no-surface occupancy
acreage to 20,200 acres, of which 2,130 acres has been
identilied as high potential. Is r.his in the be3t interest
of the American people? T think not. Even with the
technological advances in directional drilling the 17 , 1 00
no-sur!ace occupancy acres is uneconomical ly feasible.
Therefore, this acreage will not be leased. Therefore, the
state ant] federal treasuries lose bonus income and potential
roya 1 ty income , and r en ta 1 income .
on Table 3. pages 79 through 82, Wildlife
Resources. Well, again 1 think the BLM is trying to lock
out industry without scientific data. It. appears that the
majority of current stipulations will tighten up under the
Preferred Alternative. My consideration and my concern is
as mentioned prev:ously, that the EIS look at very strong
Alternative B, the standards stipulation under Section F> of
the oil and gas lease which was quoted before me. ]i
protects archaeological studies, threatened endangered
species, and I believe the multiple-use Industry people
should be added to the endanqered species li3t, and how the
leasee will conduct its operation in wildlife and veqetation
resources, cultural resources, arid watershed resources.
These are all covered by the oil and gas lease. We need to
take it on a case-by-case basis. A broad stroke of the wand
is not beneficial.
In Air Quality, page 103, Chapter 3. In the Last
grammatical paragraph, second column, wherein natural
geothermal activity is addressed, I believe this should be
expanded to include hydrogen sulfide and sullur dioxide. We
mention how it is associated with gas and oil operations,
but we do not talk about how much ot that occurs naturally
in our state parks, which it should be modified -- ex-ruse
me, JL should be monitored and documented.
The last thing is Chapter 4, Environmental
Consequences, page 191. In the di»c:iission of Controlled
Surface Use, the Draft EIS states that, "Maintenance and
Operation of the new fields could be curtailed for six to
eight months of the year." Well, qentlemen, there's no oil
field operator in their right mind that is going to shut in
an oiJ field for Hi:< to eight months. This La
uneconomically feasible. The technology is not there.
Every tima we shut in a field you have a potential to lose
that production. This is -- excuse tue, this is prohibited,
we cannot allow this to happen.
1 respectfully request that the RMP team re-write
the Grass Creek Resource Area RMP and DEIS to incorporate
scientific data, instead of assumptions, because the impact
this document will have an impact on the livelihood of
thousands of people and the economies of local, county,
state, and 1 ederal governments. J appreciate my
opportunity. Thank you .
(Applause) .
MR. DANIELS; Thank you very much. Mr. Bryce
Reece, Caspar.
9RYCE REECE: Thank you for allowing me this
opportunity to present the comments of the Wyoming Wool
Growers Association on the Draft Environmental Impact
statement on Inn GrartB Creek Resource Area Resource
Management Plan. My name is Bryce Reece, and I am the
Executive Director ot the Association-
72
1
The Wyominq Wool Growers Association represents
?.
over 1,200 active producers of lamb and wool in the state of
3
Wyoming. Many of our producers live directly in the Grass
4
Creek Resource Area and many more depend, in varying
degrees, to this resource area for crucial livestock forage.
6
so this draft EIS is of vital concern to us and our members.
7
I will be submitting complete, detailed comments
ft
on the entire Draft BIS this week, which currently totals
9
over 25 pages, in which I will address our concerns in full.
10
T am going to address today what 1 see are the more onerous
11
and underlying themes which we believe entered into the
12
drafting of this BIS, in the resulting Conn that it is
13
today, which we, to say the least, find troubling.
14
Our organization has been actively involved in
lb
refuting and opposing the Clinton Administration's Rangeland
16
17
Retorm initiative for more than two years. Rangeland Reform
is, in our estimation, the vehicle through which the radical
1R
environmental groups, in full cooperation and collaboration
10
with the Clinton Administration, and many of those within
20
the federal agencies themselves, intend to force the western
21
livestock industries off of lands currently overseen by the
22
federal land management, agencies. This would then, in turn,
2 3
destroy the entire livestock industry of the Best. While
24
Secretary Babbit, due to the political winds that blew last
25
November 8 has delayed implementation ol the Rangeland
525
Keform tor at ieast six months. Upon reading the Draft
Grass rreek ra BIS, It is readily apparent that indeed
Rangeland Reform is here.
The underlying premise and theme of the BLM, in
terms of livestock grazing that we find running through out
(his document is that livestock grazing and wildlife are
mutually exclusive. While this philosophy has been adopted
and promoted for self-serving political and financial
purposes by radical environmental and preservationist groups
such as the National wildlife Federation, Earth First, the
Wyoming Wildlife Federation, and the Wyoming Outdoor
Council, this ia not the caau and in fact is absolutely *nd
totally false and absurd. yet it appears that the BLM has
joined in lock-step with these groups in adopting and
promoting this philosophy, and documents such as this EIS
are and win he the result of such misguided drivel.
And ideal case in point <-•( the tactics used by
Lhasa groupu is the well-timed press release of the Wyoming
Outdoor Council which appeared in an environmentally
manipulated stare-wide newspaper yesterday announcing and
chastising this very plan. It is ludicrous and dangerous in
our estimation far anyone l.o begin to believe that a radical
environmental group such as this really finds fault with s
plan that advocates, among other thingu, a reduction of
livestock AUMs by a minimum of 35 percent and which more
than doublet; the number of acres in this resource area which
would have controlled surface use restrictions placed upon
the oil and gas industry. I submit to you that- these groupB
do not represent the majority of citizens, and in actuality
represent a very minute segment of the general public. If
the 9LH is seriously concerned about the views of the public
it would be well advised to listen, take to heart, and
incorporate the suggestions and wishes of the four county
commissions, and Governor Jim Geringer presented here today.
These are the two representatives of the public which the
Bureau should be concerned with.
we firm very Little sound scientific justification
for many of the proposed actions under BLM's Preferred
Alternative. One aspect of this plan which we find
particularly disturbing and onerous is the theme throughout
the entire Draft EIS which is not stated specifically
anywhere in this document, but which should be, that BLM
apparently believes there is a serious lack of numbers of
certain species of wildlife in this resource area,
specifically deer, antelope, and sage grouse. This then is
used as justification for the drastic reductions proposed in
the Preferred Alternative in resource industry use of these
lands, landa which these industries are critically dependent
upon. While we do not dispute and in fact agree with the
facr that there may bf a shortage ol these and other
75
1
wildlife species in the (trass Creek RA, we adamantly dispute
2
the fact that the fault for this lies with the use of these
3
A
lands by industry, nor does the solution to thi3 problem lie
in the elimination or curtailment of industry use.
5
Tn fact, if this plan were to be put in place, as
6
suggested in t.h* BLM's Preferred alternative, without
7
addressing the c eal sources of these problems, vary likely
R
the past decline of wildlife numbers which has been seen,
9
would continue. T would submit to you in fact that if the
10
sheep industry in particular is forced off these lands as
11
proposed In the Prefprrnd Alternative, the decrease in
12
aeveral of thes« wildllie species would in fact accelerate.
13
We maintain that the lose of most of the wildlife numbers in
14
this area is not due to loss of habitat or modification of
15
habitat. The loss of numbers can be attributed, in our
16
estimation, to a number of factors which the BLM either
17
inadvertently or purposely ignored.
IB
Specifically, one ol the most, if not the most.
]'-!
significant reason tor the loss of wildlife in this area as
20
well in most orhor areas In this state, is in our estimation
21
due directly to the horrendous effect which predators are
22
having on these animals. We in ths sheep industry know very
22
well that Wyoming has become a slaughtering ground for nor.
21
only our livestock but for much of the wildlife in the
25
stats. In 1994 the sheep industry lost an estimated 96,000
76
1
head of sheep and lambs to predators which ia 18 percent of
2
the producing sheep population of Wyoming. Tt.'e not hard to
3
imagine if the sheep industry is suffering these types of
4
losses on .ini IBS 1 S which in many cases ttavfl 24-hour per day
5
protection, the level of loss which has t.o be inflicted on
6
the state's wilclife rfiaeurens is disastrous.
7
Another area of serious concern to us with the
fi
incomplete, inaccurate, and misleading analysis which the
9
BI.M has done on this proposed increase in economic activity
10
and resulting increase on local economies due to the
11
proposed changes in management, and focus of the BLM from
12
resource development enhancement by industry to tourism.
13
It's our contention, based upon several reputable and
14
respected economic studies, that local economists which
IS
shifted tourism for their base, end up losing in the long
1 6
run. Nowhere has the 9LM attempted to quantify the cost to
17
local and state economies from the relatively low paying
18
jobs which are a result, often times, of increased tourism. ■
19
The cost of providing basic services alone, such as schools,
20
roads, governmental services such as increased law
:-;:
enforcement, entitlement programs, etc., are never recouped
22
from low wage paying jobs which often accompany increased
23
tourism. Tn fact, the net of such shifts are in fact costs
24
to the state and local communities, rather than gains.
25
Wyoming Governor Jim Geringer has alluded to this several
526
77
1
times in public addresses, and has clearly 3tated that, the
2
3
A
focus of his administration would not be on jobs for jobs
ftfikfl, but rather on well-paying, long-term jobs which
positively support and enhance both state and Local
5
economies, tho types ol jobs provided by natural resource
6
industries.
7
MR. DANTELS: You're out OS time, sir.
8
BKYCE REEtlE: Thank you.
9
MR. DANIELS: Thank you.
10
[Applaus*] .
11
MR. DANIELS: Pat Childerc from Cody. Could
12
we inter mm you and take a short break? She needs to
13
change her machine. About ten m&nutaB, please.
14
(Whereupon a break was taken) .
15
MR. DANIELS: Our next speaker will be Pat
16
Childers from Cody.
17
PAT CHILDERS: My name is Pat Childers. 1 am
18
a resident ol Park County, Wyoming, the President of Park
19
County Multiple Use Association, and the Government Affairs
an
Coordinator for Marathon Oi 1 Company's Rocky Mountain
21
Region. As <i representative of Park County Multiple Use, I
22
would like to thank the BLM for the opportunity to comment
23
on our maior concern with, the BIS.
24
On pages 122, 123, is the BUM'S summary ol the
25
socioeconomics tor the flrass Creek Resource Area in 1990.
those numbers. At this time we have not completed our work;
however. I have some preliminary comments. Thero arc two
oil and two gas prediction scenarios in Appendix 4 of the
BIS that were developed by DLM personnel. In our opinion,
those two Rcenarios indicate that the higher production
number ei for both the oil and yas predictions could reflect
the use of Alternative A or current management- Also, the
lower numbers could reflect the use of the Preferred
Alternative, or a projection of current production without
any new exploration. While uur analysis is ongoing, wc feel
our assumptions are within reason considering what is
proposed for management of our industry in the fiis.
Working with the agriculture economists at the
University of Wyoming who are under contract, with the BI,M, I
suggested that the university develop two economic
comparisons for me using the production predictions shown in
the EIS with minor wodil ications. The results of their
study of the oil and gas activities on federal lands are as
follows: For what ws call the current management
alternative, the total economic activity impact from 1990 to
2PM would bo 8,8* billion flol3ar», tn 2005, government or
tax revenues including royalties generated would be 23.4
million dollars as compared to 2«.8 million dollars in 1990.
For what wo call the Ptcferred Alternative, the
total economic activity impact fiom 1990 to 2005 would bw
This section does not reflect all the revenues generated,
nor the direct as well as indirect economic impact. Since
the oil and gas industry provides over 9(1 percent of tho
direct revenue within the ftrhM creek Resource Area from
federal lands, I would recommend including a mote detailed
study of that industry's economic impact.
On page 194, the BLM ' s prediction of the oil and
gas industry's impact from 1990 to 2005 reflect their
estimated economics for not only the Preferred Alternative,
but also Alternatives A, b, anrt c. The niiM is assuming that
none of the proposed alternatives "ill change the future
hydrocarbon exploration in the resource area. The oil anrt
gas industry, however, believe that the BLM' a current
management Ot the area will result In very little, it any,
exploration m the future. The use of either the Preferred
Alternative or Alternative C will result in no future
exploration on federal lands. Alternative B, in turn,
should result in incentives to lease and explore for
hydrocarbons. For these reasons, I think the predictions of
production and revenue impacts from our industry should be
very different — very different — for each of the four
alternative*: rather than the same.
Since I volunteered to develop new predictions of
Oil and gas production tor the four alternatives in the EIS,
T have been working with personnel in my industry to develop
1.78 billion dollars or a reduction of 21 percent from
current management, or a total revenue loss or an average of
31,6 million dollars per year. In 2005, government revenues
generated would be 14.3 million dollars as compared to the
23.4 million dollars from the 2005 current management
values. From this simple comparison, we feel that the
economic impact ol the Preferred Alternative will be
significant to the oil and gag industry and to the
surrounding communities.
Those of us that are evaluating the production
scenarios will continue to work on this data and with the
13LM. 1 would hope that our efforts will result in a more
reasonable approach to management of tho Grass Creek
Resource Area in the final EIS, and in turn, also result in
a more favorable economy to the surrounding communities, and
still aiinimize any environmental concerns. Thank you.
(Applause) .
MR. DANTELS: Thank you vary much. Mr. Bill
Gabbard. Norland.
BILL GABBARD: My name is Bill Gabbard and 1
own and operate a small oil field service company here in
Worland and have done so lor the laat 24 years. Vn work
throughout the Big Horn Basin and parts of the rest of
Wyoming. I'm also President of the South Big Horn Basin
Multiple Use Association. As president of the Multiple Use
527
Association I have concerns about nearly all of the Draft
ETS, but with only five minutes I will address only the par;
that, concerns my livelihood.
At s time when our domestic oil production ia
decreasing, at an alarming rata, and our demand of import of
foreign oil are Increasing .it an even higher rate, it seems
odd to me that the BLM is proposing even more and more;
restrictions on the exploration, drilling, and production of
oil and natural gas. The Draft EIS for the Grass Creek
Resource Management Plan in regard to the oil and gas
industry seems to put severe restrictions on exploration,
drilling, and production of. oil and gas.
Alternative [) addresses minimal restrictions that
could be handled on a case-by-case basis, using Section 6 of
the Federal Lease Agreement, We recommend adopting
Alternative B and we feel that environmental concerns can be
minimized.
The controlled surface use, no surface occupancy
and timing limits add up to 40 percent of the total leasable
acreage involved in this plan. There ia no doubt that this
would severely discourage any exploration or development.
It would seem to rae that the BLM should encourage
exploration at this time and proceed with all the concerns
addressed in the Draft BIS in mind. I' a seismic survey is
being planned, it could be planned at a time of the year so
20
21
22
23
24
as not to conflict with wildlife or damage the resource.
The same would also apply to exploration drilling. It is
obvious that if a well was drilled and was a dry hole or
non-productive, that particular area would no longer he of
any interest- wells that have already been drilled in the
area and have found to be noncommercial would seem to be
eliminated from any further interest or impact. I think
that the Bl.M as managers cf the land owe it to the
communities that they live in and to the American people to
allow the industry to prove one way or another whether that
a leaye is productive or not. This would allow for the
environmental concerns that we all share, whereas in a few
short years clown the road when we are faced with critical
energy shortages and people don't have fuel for their cars
and their toys, most ol them won't give a damn about the
environment or the Grass Creek Resource Area.
On page 19b there's a reference to produced water
that implies that the water quality may be lowered. Correct
me i f T am wrong, but produced water has been discharged
into Cottonwood Creek. Grass Creek, and other drainages for
years, and has benefitted wildlife and livestock, and in
some cases been used lor irrigation. This (taction should he
changed to show these benefits.
On page 62 it is stated that the visual resources
would be considered before authorizing land use. Oil was
discovered arid produced in Wyoming even before Wyoming
became a state. And Lhe oil and gas industry are a part of
our culture and our heritage. And for that reason the
visual restrictions should be dropped from this plan. The
BLM in tact should promote this historical part ot our
heritage and our past, rather than putting on even more
restrictions.
on page 150 under the heading of Threatened and
Endangered Species, it is stated that there la evidence of
the presence of the gray wolf. It is too bad that the BLM
did not share this evidence with the Fish and Wildlife
Service during the hearings on Lhe reintroduction of the
gray wolf as it. would have been illegal to transplant these
wolves when there was a native population already present.
To get away from the issues concerning the oil
industry in my remaining time there's one issue that seems
to have been overlooked totally .in this plan, and that is
the West River Project.
As you know, this project was a project that was
to bring thousands of acres of land under irrigation west of
the Big Horn River. There has been hundreds of thousands of
dollars spent on the feasibility of this proiect. Due to
the depressed economy in agriculture, this has been tabled
and moved to the back burner for tho present. Even though
this project has been tabled for the time being, ir should
84
1
be included in the EIS lor the trass Creek Resou.'ce
2
Management Plan.
3
4
In closing. I want to thank the BLM for holding
this public hearing and letting us have input into the
5
process.
6
(Applause) .
l
MR. DANIELS: Thank you very much. Pat
8
Moore, from Jackson.
9
PAT MOORE: Good afternoon. Gentlemen, I'm
10
hearing a a lot of frustration here, and 1 wanted to enter
11
into the record a docurent born of those frustrations, from
12
the State of Wyoming, Joint House Resolution N'o. 0017.
13
Conference of the States. A Bill tot a joint resolution
14
authorizing Wyoming to participate in the Conference of
lt<
States.
ii
Whereas, the- United States Constitution
17
established a balanced compound system of governance and
18
through the Tenth Amendment, reserved all non-delegated.
19
non-prohibited powers to the states or to the people; and
20
Whereas, over many yearn, tha federal government
21
has dramatically expanded the scope of its power and
22
preempted state government authority and increasingly has
22
treated r,tates ae administrative subdivisions or as special
24
interest groups rather than coequal partners: an:!
25
Whereas, the federal government has granted
528
MBM — ■ BMMHMMi
HHHi^^HH^iHi^H
massive deficits ami continues to mandate programs that
state and local governments must administer; and
Whereas, the number of federal un funded mandates
has qrown exponentially during the last 30 years and has
profoundly distorted state; budgets thereby handcuffing the
ability of the state leaders to provide appropriate and
needed services to their const ituencies; and
whereas, since 1990 the federal government baa
enacted at least -12 major statute? imposing burdensome and
expensive regulations and requirements on the states and
local governments which is nearly equal to all of those
enacted in the prior two decades combined; and
Whereas, p*rfi1«tent state led endeavors have
consistently failed to generate any substantial reaction
remedied from the federal government; and
Whereas, the United States Supreme Court has
repeatedly determined that the states must look to Congress
and related political remedies tor protection against
federal encroachments on reserve powers of the states; and
Whereas, in recent years, state and local
governments have been principle agents of government reform,
and with local governments have been pioneers of government
innovation, thus responding to Lhe needs of their citizens;
and
Whereas, the Council of State Governments has
87
1
officer of that house. No more than two of the four
2
legislators may be ol the S3me political party. Each
3
4
presiding officer may designate two alternate legislators,
delegates, one from each party who have voting privileges in
5
the absence ot primary delegates.
ft
(b) That the delegates of the Conference of
7
SLaleB will propose, debate, and vote on elements ol an
8
action plan Co restore checks and balances between the state
9
and national governments. Measures agreed upon will be
10
formalized in an instrument called the States' Petition and
11
1?.
returned to the delegation's states for consideration by the
entire legislature .
13
(c) That the Conference of the States shall be
M
convened under the 501 {cl auspices of the Council of State
15
Governments in cooperation with the National Governors'
16
Association and the National Conference of State
17
Legislatures no later than 270 days after the legislatures
IB
ol at least 25 states adopt this resolution without
19
amendment .
20
(d) That prior to the official convening of the
21
Conference of the States the steering committse created by
33
the Council of State Governments will draft:
23
(i) The governance structure and procedural
2-1
rules [or the conference.
25
(ii) The process of receiving and
recognized a sense of urgency in calling for the Conference
ot the Slates whereby each state would send a delegation to
develop a comprehensive action plan to restore the balance
in the federal system; and
Whereas, the Council of State Governments with its
regional structure and groupings if elected and appointed
officials from all three branches of state government
reflects an entity ideally suited to promote and facilitate
such a conference; and
whereas, the Conference of States will communicate
broad bipartisan public concern to the extent to which the
American political system has been distorted and provide a
formal forum lor state governments to collectively propose
constructive remedies for a more balanced state federal
government's partnership for the Slat century.
Now, therefore be it resolved by the members of
the Legislature of the State of Wyoming: Section ], that a
delegation of five voting persons from the State of Wyoming
shall be appointed to represent the State of Wyoming at a
Conference of the States for the purpose described in
subsection (b) of this section to be convened as provided in
subsection tC] of this section. The delegation shall
consist of the governor or one of the other four state-wide
elected officials designated by the governor, and four
legislators, two from each house elected by the presiding
rebalancing proposals.
tit!) The financial and administrative
functions of the conference, including the Council of State
Governments as t iscal aqent .
(e) That the hylaws of the conference shall:
ti) Conform to the provisions ol this
resolut ton;
[ill Specify each delegation shall have one
vote at the conference; and
tlii) Specify the conference agenda be
limited to tundamental , structural and long-tern reforms.
{f> Upon official convening of the Conference of
States the state delegation will vote upon and approve the
conference governing structure, operating rules and bylaws,
section 2 —
m. DANIELS: Your time is up.
PAT MOORE: All right. 1 would just like to
conclude very quickly here that the last time we had a
Conference of the States, gentlemen, was in 1786, and that
was one year before we had a Constitutional Convention. And
I think that you should deliver this message back to Bruce
Babbit, that. \f he thinkr, breaking up this country is worth
it, then he bettur be ready for the consequences. Thank
you.
(Applause) .
529
MR. DANltiLS: Thank you. Mr. John Henry
flams , Cowley.
JOHN RAMS: T'm John Henry Gams. r*m
President of Big Horn County Multiple Use. In 1990 they
uorae at us with the Yellowstone Coalition. w« kind of
bristled up. In '94 they come out with range-land -■ - this
book. We bristled up some mora. In "95 this is it.
Everything here contains Big Horn County and Northern
Wyoming. And All these are EPA's and whatever. This is the
Pig Horn National Forest. This one here just come out, just
got it in the nail. It's out of the Bureau of Reclamation.
I like this book, it's honest. The- needing is Proposed
Acreage Limitation. It tells us what's going to happen.
Now, this whitfi book. A lot of what I had i,o nay
has been Said. But on page one, Mt«m*tfl Multiple Use
Orientated, T d1 eagre* with that, i think if you are
orientated i r ' r. in a negative way. Gracing is doallnod by 7
percent , t imber 27, and of course the oil indust ry, you ' ve
heard from them.
On page 27 thsrs won't be any woodcutting along
the Big Horn River because of the owl, that curtails a lor.
of country and a lor ot people depend on woodcutting jusr
for beat.
And then on page 150 and 201 it's beer, eta tad
before that there is restrictions on endangered species,
90
1
mainly the wolf. And of course, they put the wolves in the
a
3
park and made a welfare statement out of him. And then when
Lhcy did turn him loose tt cooS turn what, three days rn
■i
1*AV« the- park? Where does that put us?
5
i think that thin statement is a continuation <.;f
n
'■ h« Hoosystom, the Yellowstone Ecosystem. Thu park does not
7
manage their livestock, which is their elk and their bison.
ft
The BANGS deal Is very serious, l don't know if you guys
9
know what brucellosis is m humans, it's undulam fever.
10
Tn& expecting us to manage not only the buffalo and iheir
11
elk, but also their wolves.
n
Mrm in a statement on page 40 there'* a
discrepancy of water development. Cn page 40 there's no
n
water development Dr. 76,000 acres. Then on page 69, water
is
development will be improved.
1G
Also, I got « quearion on what variety of methods
17
will be used in grazing strategies. Besides losing the
1?
4^,850 auhb in the beginning, there's also restrictions on
i q
120,000 acres for the elk, and the wolf probably. 47,000
20
acres for Big Horn Sheep, and r.liH wolf, and 121,000 acres
2j
tor antelope, He still might be hungry. This is a total of
22
2B8,ooo scree, now many aums is than on top of this 4.1,000.
2.1
You're penalizing the ranchers in this are-i
24
because the Increase in the wildlife if; an indication that,
25
to mc, that the range is in decent condition. Aid these
91
1
people have cut back cm tfteir AUMs to improve the land, and
2
3
because they have done this you are going to take it away?
Is that working with them?
4
And then we have; been led to believe that we were
5
told to decrease grazing to benefit wildlife and wild
ft
horses. And you've led us to believo :nat the Game and Fieh
7
aro in favor of the wild horses. Well, these horsoo up
8
9
there, it's a proven fact that they are feral horses, which
is a domesticated horse gone wild.
10
The March 1995 issue ot the Wyoming Game and Fish
11
there's an article in there on the feral horses and what it
12
is doing to the habitats. In thin Alternate R, the effects
13
on the land uses, I think the wild horses should be
14
eliminated.
IS
In another comment-, most Of the sedimentation ot
If.
17
Big Horn River comes from the Fifteen Mile Creek, and that's
more from the horses.
18
And on page 107 Native American Sacred and
19
Spiritual sites, there'* nine kinds of sites. If you read
20
tHifl about the Big Horn Medicine Wheel, you better take a
::i
look at that, a little further.
22
Just a year ago I Stood at this microphone facing
23
north iookiriq it the majestic dominant bull elk. You guysi
24
didn't like him looking over your shoulder. This year you
got me facing south under the Beeter Bunny. What direction
12
1
is it going next year and under what mascot?
2
(Applause) .
3
4
MR. DANIELS'; Thank you very much. David
Bayer t , Basin.
5
DAVTP BAVFRT: T'm David Bayerft. Pretty
0
tough act to follow. My letter here is kind of brief. It's
7
already been submitted for the. record in written form. But
8
I've jotted down a ten more things as I've listened. And
9
thank Cod I came. I've learned a lot. T would like to
10
thank you for this heariny, the extension of the time. I
11
understand that this hearing was not originally scheduled,
12
this particular one. So for this extension, I do thank you.
13
I've been gone oui ot the country for a while. I also work
14
in the oil field and hud to go up to Canada to make a living
15
here the lust couple of yews.
16
fio anyway, I'll just kind of read this letter.
17
It's to Mr. Ross, but 1 guess actually it was written to all
1 3
concerned.
1.1
Please acknowledge initially that. I believe r.he
20
local BLM personnel who, T assume, have worked diligently to
21
prepare this Draft E1S, have done their jobs in accordance
3.1
with official policy ot the U.S. Department, of the interior.
It is with this policy under curreni administration that 1
24
take issue.
25
First of all, I believe that federal
530
93
:
bureaucracies, such aa the Department of the interior, have
2
no legal authority to restrict' public land use and to
3
develop land use policy on lands they don ' f own. The State
i
of Wyoming And the counties in which the lands are situated
8
Should be responsible tor planning, developing, and
ft
enforcing policy. It. is my understanding that the state and
7
county representatives have bt*en basically, for all Intents
8
and purpose;, excluded from the drafting of thic F.Tfi. Now,
9
we, Hih people who live hero, are thrown a hone called
10
public comment to ba considered along with the comments of
11
preservationists who don't even live here. This you say is
12
publ id involvement .
n
rt Che tll.M is to be further entrusted with tha
14
management of Wyoming's public lands, J suggest that you
15
really Involve the Wyoming public. I'm tired at taderal
1C
oppression thai", comes wi th ha J Is Of local cent ml and local
17
18
In summary 1 suggest that the Grass dr«Hk Resource
19
Management Plan Draft Environmental Impact Statement, be
30
submitted to the State of Wyoming and the commissioners of
21
park, Rig Horn, Washakie, and Hot Spring? Counties for
22
amendment arid approval by the people.
23
The other suggestion I would make is to put DLM
24
under author i ivy of 1 he individual states rather than the
35
politically driven beltway mentality of the DepartDtenl of
Interior, which has once Again revealed our federal
government's insatiable appetite for powrcr and control over
the lives of the American people. Sincerely, David Bayert.
And 1 also WOUld 1 Lkt? to ask a question. I would
like to find out how much money the American taxpayers spent
to put this mess together?
Another thing I would like to say La 'hat. being a
responsible person an far as paying my debts, how can a
nation who is over five trillion dollars in debt, justify
the cost of what, was the figure, fifteen million dollars a
year tor wild horse development? How can a nation in debt
justify the cost of all the millions ol dollars that it. took
to put rh1a together? How can a nation in dPht Justify
cutting federal revenues by decreasing oil and gas
production? It doesn't, mafce sense. People w« have gotten
plum irresponsible at the federal level. You are about to
break the American people and we're tired of it.
(Applause) .
MR. DANIELS: Mr. Gams?
JOHN GAMS: I forgot thesn. but there's some
added letters.
MR. DANIELS: Okay.
JOHN GAMS: There's a couple of them that, got
the corners ripped off of I hem that people signed them then
tore their signature off because they were scared of what
95
1
would happened. That's why thty are like this.
2
MR. DANIELS: Our next speaker is Karen
3
Anders, Greybul 1 .
4
KAREN ANDERS: My name is Karen Anders and T
b
have about lour points that. T wan tod to make.
6
First, I believe that it never works to have rules
7
made by thowe who are detached fro* Che issue geographically
ft
or from the effect of those rules- This is particularly
9
unfair when rules drafted for -- excuse me, when ruins
10
drafted are intended for others to live by without regard to
11
the negative- impacts the regulations will have on residents,
12
businesses, and the economy. I've never done this before,
13
sorry .
1-1
18
Second, Wyoming has an abundance of apace. Some
of thlr, npace is usable for a variety of purpose both for
16
recreation and business . Should an area requ i re restrictive
17
uses, Wyoming should be imposing the restrict. 1 ons necessary.
18
Oh, T am shaking. Should an area require restrictive uses,
19
Wyoming fthnuld be imposing the necessary restrictions. 1 am
20
flr» in my belief of what the r.fi. Constitution and that of
21
Wyoming Clearly states, therefore -- wow -- therefore,
22
underscoring the rationale of my comments.
2 3
Third, 1 oppose this document and ail oubocqucnt
2-5
documents. I strongly urge local citiznn participation in
as
the writing of any plans, contingent on the obvious impact
06
l
on the lands, rer.jdontn, businesseK, and economy. Wyoming
2
should write the next plan tor Wyoming.
3
Fourth, I do not believe that anyone who is
■1
living, or derives a living elBflvhere should have one word
5
of input as to the use of Wyoming's land. The very fact
6
that Wyoming is so coveted is proof that Wyoming can handle
7
Wyoming because we have.
e
Furthermore, I believe that all others have
9
disqualified themselves having lowled their own nottts-
10
Thank you.
11
(Applause) .
12
1 '\
MR. DANIELS: Andy Franklin, Cody.
ANDY PRANK! TN: T hadn't noticed the Faster
u
1 5
Bunny. My name is Andy Franklin. I live in Cody. Wyoming.
14 year tax paying resident of Wyoming. I am employed in
ie.
the ecosystem enhancement and resource management business,
17
in other words, the oil industry. I am strongly opposed to
is
the Preferred Alternative outlined In the DEIS. I strongly
19
oppose the indiscriminate doubling ol acreage managed under
20
no-surface occupancy and controlled surface use, and the
21
reduction in acreage of lands covered by standard lease
22
terms and conditions- I am in support of the language found
2 3
in Alternative B of the Draff Environmental Impact
24
St alement.
25
Tt is my understanding after reading the document
531
in Hie proposed alternative it is based on ti perceived
impact- to wildlife;, wafer quality, <mrt soil condition that
occupancy, specifically oil and gas development and grazing
would cause, t question th« legitimacy oi the deis*
conclusions and can find no supporting data in the document
to justify thla support tor the Preferred Alternative, in
fact I would suggest that other more viable reasons for the
perceived and not documented Impacts on wildlife populations
are neither mentioned or addressed. I am referring to
predation, drought, and severity of winters. I strongly
request that data, not conjecture, he. mrniehed to support
the conclusions of the Preferred Alternative. Further, I
request that the data used to r*fut* the alternative of 1«ab
restrictions, Alternative B, be shown to the public to
demonstrate that these measures were insufficient to protect
the resource area.
Although the document contains little data to
support any of the conclusions used in developing the
Preferred Alternative, of equal concern is the rapid
development of socioeconomic impacts that will result iti the
Preferred Alternative. There is little tangible development,
of thftse impacts in the document, and wh.it is presented can
bost be described as questionable and hastily prepared. In
my opinion it is disappointing that a document of thin
nature would neglect to Inn Turin the significance of federal
revenues generated by commodity users in this resource area.
As much of this revenue ends up in state and local
government treasuries, the DEIS does not accurately reflect
the impacts ot these entities the proposed alternative would
have. I would remind the authors that revenue collection
from mineral extraction is second only to the IRS in terms
of federal revenue generation- Further, 50 percent ot the
federal royalty generated by oil and gas in federal lands,
100 perctuU of the lease fees and bonuses in a dinwt
contribution to state and the local Lr«aituf itt».. AgH-.n, T
have to question this data not being specified in the
document and wonder if the bim's own internal support lor
this Preferred Alternative would have been ftxlted had it
bc-en accurately presented.
Finally, I request that the authors ot the DEIS
definitively answer to the public why the conditions ot
approval found if the standard lease terms, Section No. 6,
are irWHtff tflient to adequatply address and protect, the
amorphic concerns suggested in the DEIS. By fsxample, can
data be supplied that would suggest that the historic
compliance with the standard lease terms has been
insufficient to protect the resource?
In summary, 1 believe that the Preferred
Alternative in the DEIS is a weak attempt to appcaso a vocal
minority residing outside the State a! Wyoming, r ask that.
the authors of the document remove the Preterred Alternative
from consideration and initiate research that would defend
such an approach to those residents of this state that would
be negatively and significantly impacted by its
implications. The authors have not done their job if these
socioeconomic Impacts are not clearly and accurately
identified and presented to these human residents of this
ecosystem. The continued practice of this and similar
avoidance in RMPs, will result in the employed human
habitants of these ecosystems becoming the real endangered
species. And 1 thank you.
(Applause) .
MB. DANIELS: William Craft. Greybull.
willtam CRAFT; I thought perhaps you had
avoided me on purpose. I was interested to see John Gams
carry up a stack of papers that high :o tell us about what
people have been doing for the last two or three years. I
have a couple of books here. One of them in the
constitution of the State of Wyoming, The other, believe it
or nol is C.hs Constitution of the United States, the Dill of
Rights, and the Deri arftt.ion of Independence, all in this one
llttlfl document. And I Oatl assure you that what is in these
books exceeds by a hundred told anything worth while that
you have in ihat. statement that you put together.
( *pp] aUBel -
100
1
WILLIAM CRAFT: Naturally, I appear in
■?.
3
opposition to the Grass Creek Draft Management Plan- 1
won't pick it apart piece by piece because it is 90 flawed
1
that it really doesn't deserve that kind of a study. The
5
opposition is not only because of the detrimental substance
6
7
of the draft, that would dramatically affect the economy of
the arpa, but because Ql the restrictions on every use of
8
the area Which are not in l he best interest of Wyoming and
9
its citizens.
ID
13
The very fact that we ure bring fluked to accept
management is something tnat ihe federal government , and the
12
Interior Department in particular, have no constitutional
13
authority to be o par:, of. and to me it is disgusting.
l-l
1. refer to you Article 21 Section 2 of the Wyoming
1 5
Constitution. In that part icular article It cl earl y states
16
upon statehood or being admitted to t.he Statu that all land,
n
all resources, personal, real, monies, credits, claim;, and
18
everything else was allocated to the state of Wyoming within
19
the boundaries of the state of Wyoming became the
,10
jurisdiction of the Governor of the State of Wyoming, the
21
Legislature of the State of Wyoming, and in particular the
22
county commisBionprH of the State of Wyoming.
■?.\
1 just I cert't understand how you people who
live in this country, work for a government and I [ova
2b
sod very much the idea that any df you really appreciate
532
101
1
either the constitution of the State of Wyoming oi the
2
federal constitution as well. And in a few daya hence.
3
we'll again be asked to accept, arbitrary rules from the
Suramj of Reclamation, another of Rabbit's agencies — we
h
know where thin is coming from, J realize that. It doesn't
6
come from here -- on the natter of all oi our water rights
7
and t.hat'3 through the Big Horn Drainage.
a
I refer yon again to the Wyoming constitution
9
Which clearly states that all water, that -irises, that
10
originates within the 3tate of Wyoming shall only be
1 1
controlled by the state of Wyoming and its agencies.
12
There's not a damn thing in there that says anything about
13
the federal government having anything to do with uur water.
14
The fact ot the matter we have precedent over water law
15
because we have entered into ■•- the State of wyominq has
15
entered into compacts with various other states and allowed
17
them the use oE out overflow of water. And believe me, the
18
very instance, the federal government had nothing to do with
15
those agreements.
20
In thin morning's paper we notice that in all
21
probability cattle grazing will be blamed lor the threat to
22
gome kind of a toad. Again this cones from the Department
23
of interior. They never mentioned coyotes, they probably
24
eat thorn as wel 1 .
25
The whole purpose ot the Department, of Interior is
to make it unprofitable to pursue any business venture, even
on private property, and T re[«r you to the wetlands deal,
thus creating this huge western park that due to the
restrictions r.o one will be able *o use because of their
conflict with nature. This is nothinq but the Yellowstone
Ecosystem Plan b*>ing presented with a little different coat
of paint. That's what it actually amounts to.
We no longer place first, priority on our lorest
for lumber and homes. And If we do not put. an end to this
insanity that exists by these agencies there, will not be
enough trees lift to even satisfy the paper reQlli rements of
the federal government.
(Applause) .
MR. DANIELS: Thank you. Jia llillberry,
Powell.
>jim hillberry: Thank you for affording us
the opportunity of speaking again regarding your Grass Creek
Draft E1S. I spoke with many of you before and many of
these issues will probably start to seem redundant as we've
expressed various ideas, flownver, today I am speaking nn
behalf of spring Gulch Coal Company, a private operation in
the Grass Creek Resource Area. Prospect Land and Cattle, a
cattle operation in the Grass Creek East Resource Area with
both BLM and privatn lands. Spring Gulch Cattle Company, Dee
Hiliberry, and myself Jim Hi!] berry.
The proposed plan is of great concern not only to
those that I speak nn behalf of, but to local communities,
county governments, county and state agencies, livestock
producers, and all other users of public lands. For the
document would be the handbook, the guide, the Rible, if you
will, of the Grass creek Resource Area for the, next ten plus
years. Therefore, it is ot utmost importance that
information used as a basis for the decisions and the goals
presented in the plan be complete, accurate, scientifically
based, with all currant alternatives considered.
Your open houses and many meetings with the groups
throughout the resource area are to be commended, however it
has become apparent that there is much information lacking
that has been presented at these various opon house*;.
Specifically economics, custom and culture, and in some
cases at these open houses conflicting information has been
given by the department.
I'm especially concerned with your statements
found on page eight, and 1 quote. "The principals of an
economic management. or excuse ran, erieisys tew iiMnagerarml
used in the BLM day-to-day management ot the public lands
and resources include recognition that, people in [.heir
social and economic needs are an integral part of the
ecological systems . "
And on page 11, the challwig* is to protect
1C4
1
resources, but still allow uses for activities that support
2
the local economies such as oil and gas development, mining,
1
ORV travel . 1 i vestock graz ing . and t i mber . And yet it
4
appears to me that many of your Freterred Alternatives in
5
fact do just the opposite with such things as no-cur face
6
occupancy, reduction ot AtTMs , limited 0RV travel.
7
Page 13 of the draft, again, in general, resource
8
conditions on public land.i in the planning area including
9
range veqetatlcn, watershed, and wildlife habitat, are not
10
the result of livestock grazing alone and are not in a state
11
of mich poor condition or downward trend that they cannot be
12
maintained or enhanced, or that: would warrant elimination ot
i a
livestock yraxing on public lands.
id
Yet in your Table 17 on pagi 190, that's
15
corrected, the Preferred Alternatives indicate a total
IS
17
117,762 AUMs total authorized grazing, which in a reduction
of 39,593 AUMs, or approximately 7.n percent reduction of
18
authorized AUMc from the 1990 base level. Yet. resource
19
conditions are not in a state of poor condition, downward
20
trend, that, they cannot, be maintained or enhanced. Then why
21
the reduction in the Preferred Alternative? The total
22
authorized grazing should be left at the present level, the
23
1^7,000 plus AUMs- And I recommend eliminating all the
a 4
other alternatives *nd use as a base the authorized AUMs for
25
this resource area. Manage them with individual operators
533
105
1
to continue the PoonomjeK, the custom end culr.urv; that this
2
resource arna has provided.
3
Also, on that same table the active preference
-i
presently is 101,4*11 AUMs, yet rhft Preferred A 1 ternati ve
5
Shown 75,(138. Again approximately 25 percent, reduction of
k
AUMs.
7
Economioa 1 ly , what does that amount to? On page
°.
123 it. tBlls uo that in 1990 the livestock grazing on public
9
lands administered by the ELM accounted for 5.8 million
10
dollars, as well as 1.38 million or the area's personal
11
income, and supported 101 Jobs. Assuming that there be no
12
reduction in Livestock AUMs we will continue to provide thai
13
!i . R million dollars, however with the 25 percent, reduction
14
that reduces to -3 - 3"5 million. Very important reduction Into
15
the roRoun:« ;-iran.
16
With the 25 percent reduction of our operators
17
over there now with the limited numhorn of livestock that
18
they use, how many are going to bo in the business by 2005?
19
MR. DANIELS: You are out of time, sir.
20
JIM HII..I..BERRY: ckay. I will provide my
23
written comments to you. Thank you.
22
MR. DAMIW.U: Thank you very much. Tim
2:\
Morrison, Meeteets^ .
24
TIM MORRISON: Thank you for this opportunity
25
to speek. My name is Tim Morrison and I am representing and
The reflection is very evident because the percent of
increase on the resident iai only assessed valuation hetwncn
the years 1992 and 199'J increase by 23.9 percent.
The BLM should be encouraging, not penalising,
small businesses and corporations by realizing the ti ue
socioeconomic impacts of the restrictions of the Grass Creek
Resource Area Management Plan.
I'm also a surrogate person for Terri M. Sporkin
who is al6o a resident of Meeteetse, Wyoming, who offers
comments thai, are in written form. And they are very
specific, but here's the statement.
After reading the Grans Creek Resource Araa,
Resource Management Plan Draft Environmental Impact
Statement, T have found the BLM took the shortest way out in
its development of the EIS, which also leaves out a possibly
more affective alternative if they had done more thorough
research, and had more up-to-date data and statistics than
from 20 to 10 years ago. The IHiM seems to have forgotten
that NGPA requires current and reliable data and statistics
fur an EIS.
The BLM will say they had involved the community
groups, ranchern, farmers, gas and oil, and people involved
in recreation at the very beginning ot the process.
Probably, yes, these groups nnd individuals did submit
opinions bur th<* BLM probably did no! think they fit into
speaking for President Craig a. Griffith of the Meeteetse
Multiple Use Association. Thank you for allowing our group
to comment on the proposed land-use plan for the BLM
administered land within the flrass Creek planning area. The
ultimate goal of our organization is to attain wise
management of resourcer, without, sacrificing the custom and
culture of this area that evolved over the years.
The Draf- ET" has focused on three key resource
management, issu&ai special management area designation,
manageabi i i l y Qnd accessibility ol resource!,, and vegetation
management. All of these issues are as important as the
other in developing the framework for managing and
allocating the public land anil resource uses. Our
organization feels it is unacceptable to restrict oil and
gas, grazing, timbering, mining and all other tax base
providers. The Draft EIS lor the Grass Creek Resource
Management Area is not acceptable and c.hould be rewritten to
reflect the accomplishments ot our past resource developers
and stewards of these lands.
Any commodity access restriction will reduce our
tax base and ultimately shift the tax burden to the property
owners and small businesses of our communities. Park County
has already seen a negative 15.3 percent decrease in
assessod valuations of ag lands, residential, commercial,
industrial and minerals between the years 199H and l'J'14.
10B
1
what they wanted in the EJS. Unfortunately for the BLM, the
2
EIS shows tio such Involvement, because the reading of all
3
four alternatives definitely expressed the BLM's point of
■1
view and really shows no differences among each alternative.
5
If the BLM truly felt the People had a right to express
6
their opinion in the plan, they would definitely find tout-
7
entirely individual different alternatives, than what is in
8
the draft pi an now.
9
Ranching, farming, hunting, gas and oil, and
10
recreation wee baa greatly changed in the last R5 years,
11
even in the last 10 years and much of it is for the
12
betterment of the land and wildlife. BLM personnel are not
13
the only ones who have any form ol education concerning land
13
management. A majority of the farmers and ranchers today,
is
to make it In the business, do have education beyond high
16
school. They have taken courses or etudy-up on the material
1?
involving land management and environmental issues
1ft
concerning maintaining the land, and have been applying this.
19
information in the every-day management ol the land.
20
It Wftj also noticed that the Yellowstone Ecosystam
21
was mentioned in the Draft HIS but was not discussed iii the
22
Draft ETR. What are the Bureau of Land Management goals and
23
objectives of the lands in the area ot Ypllowstone National
$4
Park? How much input on this subject was brought forth from
25
the united Sr.at.en Park Service and the United States Forest
534
Service, and what is tftfl ultimate- goals on this subject?
Last but not least, this uhrti* Draft EIS is
definitely written to ultimately al3 type* of resource
production, gas and oil, mineral, lumber, cattlfi and
domestic shfifip production from BLM public: lands in the Grass
Creek Resource Area. When this has been accomplished 1
would highly rsconaisnd to the people in any western blm
office to start looking for other jobe, bBcauBs recreational
or tourist activities and wildlife do not pay tbS CSSO, let
alone the re» idem i a] and business u^g that pay your
salaries. Sincerely, Terri M. Sporkin.
(Appl ausD] .
TiM MORRISON: Lastly, I have some similar
comments by myself. One of the questions I've raised in the
past was concerning NEPA end the relationship of having good
eaiantlfic data to back up the plan- That seems to be a
question that's been addressed here- today- J would hope in
the future if there's an FAX final, that it's actually
addressed in the final.
Specifically, on pag* 2C2, and T believe LI 'a the
rhirri paragraph on the left-hand aide of the first column,
the statement in hare 1»< "Planning area-wide grazing In
riparian areas affects channel stability, riparian
vegetation, and fish hah
I don't see any discussii
I more than any other land use.
St all in this document why that
bureau and bureau personnel that's used jus! Tor that
purpose, This is a pretty good act, which says in fact that
you are going to enhance the cultural re-source!? of this
country and ot the West. And any rancher in here that 'a
over 40 years old, and that's what the bureau uses as
historic, and T auppOSS most of these ranches and most, of
the oil producers in this area are over 50 years old, most
of those communities are over 50 years old, T think it's
your obligation which says in part 4 under Section 1, "The
preservation of this irreplaceable heritage is in the public
Interest so as by the legacy of cultural, educational,
aesthetic, inaplrat ional , economic and energy benefits" I'll
refute again, "economic and energy benefits will be
maintained and enriched for future generation!! of
Americans." Nowhere in this; document, have you — is there
any economic benefits, or maintenance, or enrichments.
1 think what you are doing in Section 5 nf the
first part of Saotion 1 it says, "in the t ace ol ever
increasing extensions of urban centers, highways,
residential, and industrial developments, the present
governmental and governmental historic preservation programs
and activities are LMtfsqUttS to ensure luture gsnsrations a
genuine opportunity to appreciate and enjoy the rich
heritage of this nation." This document, Like documents
throughout Wyoming by your agency, is forcing the ranchers
is. T mean there's no discussion whatsoever-
Thar.k you for your time, arid T appreciate it.
(Applause) .
MR. DXNrEIiS: We'll take a ten-minute break
and our next speaker will be Bill Taliaferro.
(Whereupon a break was taken).
BILL. TALIAFERRO: T'm Bill Taliaferro, Rock
Springs, Wyoming. T have no permits in the area, but I do
think this is another boiler plate* Draft Els document
typical of the BliH.
First of all, T S«a no reforonce in this EIS thar
deals with Wyoming's strategic Plan for Agriculture. That
took about four years with a great deal of effort on the
part of state government, the Wyoming Department of
Aqrioulrure, and people throughout thu slate, and there U
no reference and there in no — this document doss not
enhance Wyoming's Strategic Plan tor Agriculture which has a
pretty fair section in the Big Horn Basin in enhancement of
the livestock industry in this arua.
Secondly, 1 don't see where this document is
relevant to *n act that wat; paused in 1966 called thrt
National Historic and Preservation Act. And this act was
not built' to beat up people, and unfortunately T've seen the
oil and gas industry, and the- mining industry, and now the
livestock Industry come to this with interpretations by the
to sell and subdivide, and do exactly what you don't want
done, or at least what. Congress didn't want done.
1 sit on the board of trust**** of Western Wyoming
College and I can tell you that with the tax basis going
down, with everyone shutting in nil and gas well, with Wesco
not doing any exploration in southwestern Wyoming, and with
the proposals you have in this area and I assume Newcastle
and some other BLM areas and forewt areas have similar type
Hi.ruol.ures on EISs. that with the 79 million dollar budget
deficit next year for the State of Wyoming, and that was
before all these oil companies started shutting in gas
wells, that the community colleges throughout Wyoming are
going to be in a dire financial atrait. And if they do down
into a (Siri financial strait bftCSUBfl ol rule?! and
regulations, and most ot thaw have been federally mandated,
and most of them have been carried out by your agencies we
will all know who to blame. And I and the board of college
trustees most certainly are going to lay that at the foot of
the BLM, Secretary of the Interior, and the President
himself, because we're under dire financial stress.
And it's amazing thai ws have to take -- 34
percent of the students fwntng into out college have to have
remedial math and remedial reading to start qualifying, and
we're talking about shutting in oil and gas wells. And I
ran talJ you that, the collages, the recreation centers, the
535
tennis courts, the sewer systems in Wyoming are not paid lor
by homeowners and ranchers, it's our vast mineral industry
and natural resources that pays for that. And most
certainly you keep this up, your children are going to be
more em-umbered than nur children ore-
(Applause) .
MR. DANIELS: Thank you- Dallas Valdez tram
Laramie.
DALLAS VALDK'/: Hello, my name is Dallas
Valdeie, and 1 represent the Wyoming Resource Providers
Coalition, I'm their state coordinator.
The BLM has proposed four alternatives, however
these lour alternatives do not provide the required range of
potential alternative?, provided by law under NEPA. The DETS
fails to adequately address socioeconomic impacts of the
alternatives, within the .100-page document. there*:; very
little discussion concerning impacts to the livelihood of
the citizens of these counties. The socioeconomic
presentation is superficial .it best* even though the BLM has
a 1 50 to 200 page document from the university of Wyoming
rfddressinq socioeconomics. The R1..M socioeconomic breakdown
of the area is very general in nature. For the
socioeconomics to have value to the average citizen, i I.
should he broken down into geographic areas, such as
counties. This has not been donp hut could be produced
us
1
The counties would have had to secure the remainder of
2
4
needed funds ■] ••whar*.
it is this caliber o 1 developing partner ships .
consensus building, and puhlic awareness with which the
5
Bureau of land Management, should exhibit as standard
6
operating procedure. The Wyoming Kesouroe Providers
7
Coalition wants to see any final document reflect full and
fl
serious economic models for each involved county.
9
Within the DEIS, there is no explanation ot how
10
the BLM derived thu numbers it supplied to the University
11
economist. We ail know that for models to be accurate we
12
need accurate input thai ran be Justified and explained.
13
The BLM, like anybody else, must explain ar.d justify the
11
numbers they used to represent uni tn of production under the
15
socioeconomic study. Without this justification, these
If.
numbers are unacceptable. Currently, the BLM has not
17
explained or justified the numbers it supplied. Where) did
IB
they come from? Are they historic trends?
JO
I whs informed by the economi st that had he
20
gathered the data tor the study, he would have contacted
21
industry, local communi tiew within the study area, the BLM,
29
and other groups. He would have also contacted these
23
individuals to gel the numbers that, accurately represented
24
the value of a unit of production. These numbers would he
25
used in the models rn generate I he economic impacte from
quite easily from most of the counties. Currently, the
University has a model for Washakie and Big Horn counties,
and has a partial model for Park County.
By separating the socioeconomic impact into
counties, each county'? officials and citizens could
understand the impacts to their area. With this information
available, they could then respond accurately to areas of
concern to supply information to the BT.M that refutes or
agrees with the analysis. The document does not currently
analyse the fiscal impacts to the local communities
introduced under the various alternatives. What will be the
loss in monies for public services including the agencies
under each alternative? This is an important par" n! the
socioeconomics of an area's ability to survive.
The BijM's general isi approach and development, of
the socioeconomic impacts reflects the agency's lack of
genuine concern and interest for the communities and
counties involved. \ concerted effort should have been made
by the BLM to have a model for hot Springs County developed.
Wyoming's citizens would h*V« been well served if the BLM
had presented Itself formally before each county commission
with the express purpose of profiling how important and
necessary a county-spec i ! i? economic model would be.
The BLM ahould have used such opportunities to
offer to earmark some of its \'FPA funds for these efforts.
different levels of production. Once this was accomplished,
he would present the mwbers to the individuals affected to
see if the study accurately represented current and future
projections of expenditures in rhe area.
Currently, the BLM has not supplied adequate data
t.a represent differences for mineral expenditures under the
various alternatives. Under each alternative, different
stipulations are implemented, r-,uch as timing, and no-surface
or surface occupancy. But, the socioeconomic impacts of
these different eHpulhtion* are not rally »ddr«»««<l. The
BLM roust address changes in the level or cost of production
to mure accurately address the stipulations within each
al t.ernal i ve. it there is no- surf a oe occupancy in an area,
the potential expenditures for mineral exploration or
development, deteriorates because the cost, becomes tou high;
this needs to be more fully addressed and accounted for
according to University representatives,
Another concern is that the data used tor
recreation may over-Inflate the actual contribution to the
area. These numbers need to come from a primary survey of
the area to actually interpret if use La by a community
member or SB outside individual. The only real value added
to the economy is from people that come into the area.
These numbers could be derived from the individuals tn the
area.
536
To ultimately improve Lhe socioeconomics of the
2 DEIS, it is recommended thai the BLM work with Hveryone
3 involved in the arcd. Bob Fletcher, University ot Wyoming,
aaid that, ha worked on a document in Sheridan that Included
representatives from industry and business in the area, an
well as, environmental groups and the press. They fell that
the socioeconomic document received little resistance
because everyone was involved in its preparation. The BLM
must take into account changes in expenditure and make
Adjustments in its numbers for production or cost within
each alternative.
It ia very disturbing that the communities have
had very little input into the DEIS as they will b^ the most
severely affected party over the next 1 5 years. Mr-
Fletcher and his Associate stated that it would be
beneficial to all if the economic impact section was
presented as a stand alone document that could be pulled out
and analyzed separately- Most importantly, the BLM should
include the communities in the preparation of the document
and allow them the opportunity to present alternatives for
Study. Thank you.
(Applau.ee} .
MR. DANIELS: Thank you very much- Lyle
Spenc** , Borland.
LYLE SPENCE: Well. I was told whftn I
registered that I was number 23 on the agenda so my recap is
it's opponents 22 and proponents o. ftnd I hope 1 can hold
the streak.
I would also want to say that Jackson, Rack
Springs, and Laramie, are a long way from here. And I would
1 ik« to have you assign one of your people the ta3k of
adding up all the miles that all the various witnesses drove
to be here and express their Eeel trigs on this.
But 7 want to thank you for letting ur. 3pcak.
Thank you for hearing us. There was persons of the BLM that
asked me when I walked in il T was liar* to of Or my lull
support. And I do support havinq a management plan, that we
need to have a management plan, but the problem 1 want to
.•ipcak r.o \a the appearance In this proposal must, be
predisposed against agriculture, and livestock in
particular. And my point is that it shouldn't be
predisposed against agriculture.
My name is Lyle SpertCe and I live in the city of
Norland. 1 don't have an agricultural or mineral operation
Of any kind. Don't hold any grazing permits. T am an avid
cmtiloorsman, and my wire and I spend virtually all of our
recreational time out hunting or fishing, or otherwise doing
something to do with the natural resources that are the
r.ubjecL of this hearing and thin ntudy. I am telling you I
have a very keen consumptive interest in the wildlife
resources that are such an important part of this study and
that's part ol my qualifications tor testifying hero today.
I also speak Iron the informed source of my
employment with Farm Credit Services, which it a lending
institution that deals almost exclusively with farmers and
ranchers. And I personally administer loans to larmers and
ranchers throughout the northwest part of the state of
Wyoming. My comments are my own, but. they <ir« founded in
part, on the information that I have through my employment .
The reason that. T am her.; la Chat I think there's
an Area of Critical Economic Concern, or an ACEC , that is
negatively impacted by this proposal, and that ACEC is the
whole Grass Creek Resource Area. There's a species in that
whole area whose long-term survivability is not adequately
considered in your proposal. it's the species that manages
the land and pays the taxes that build the roads and
schools, and supports the communities and industries that
make this whole region habitable by all of us, and enjoyable
to ihocti who visit. That species is the agricultural
producer.
Now during this last year's hearing on Range land
Reform '<*4, r provided an example of a typical ranch family
and their historical, financial performance in order to
provide wore examples for your study. But nobody asked tor
any more- And I brought more with am today. 1 have in my
hand a summary ot a study ol earnings el t ioiency of IB ranch
operations in northwest Wyoming. Five of the 18 ranches
summarized here graze livestock in the Crass Creek Resource
Area. Now 18 ranches you say in not. d lot, but those 18
ranches have 10, ODD cows, and summarized here are 65 years
ot combined income statement? on those ranches. And if you
took those statements and stacked them end-to-end, they
would reach 75 feet in the air, T think taller than any
building in the city of Norland. Tf I did my matt: right
this represents 37,000 cow years of financial performance
data, all of it occurring in the 1990s.
In the nummary it BhowC, on average, those ranches
had an earnings efficiency ratio of 22 percent. What I mean
by that is out of every dollar generated in revenue, they
had 22 cents left after wxpenses were paid. With that 22
cents they fed their families, they paid their lenders or
made their payments on land, they had to replace their
capital as it wore out, and they had to Improve their lands
and grow their business, if possible. And that's all
accurate historic data. But relate that to current
economics.
T attended) participated here in a Boef Industry
Symposium in this very room last Friday. There were a
number of very well qualified speakers on the issues of the
cattle industry. And 1 don't remember seeing anybody here
537
from the M,H. Rut the conclusions and tire fact today is
thai the feeder rattle market is 22 percent lower than it
was ii year ago. The Est car tit* narket. is 19 percent lower
than ii was .1 year ago. The cost ol financing ore .10 to 3B
percent higher than Eft»y were a year ago. xn respect to the
outlook for the next three yearn, price* will remain at the
same 1 rycIb .
These people's historic margin of 22 cents is gone
for Lhe foreseeable future- And what that means, to go
back, that's money that they feed their familial with, pay
back their lenders with, they replace their capital, improva
their lands , and build the it businesses. Wol 1 , thai' ' h not
going to happen in the current economic environment. I'm
not hare to press the panic button this year, but wo have to
dea] with the reality that this industry cannot bear any
more burdens: whilt? chesti rami lies try t.o adjust: to the
current and foreseeable economic environment. And that
translates into reductions of AUMs, and that is dii economic
reduction of resources that they have available, and ii huLh
more pressure on the economic viability of these
agricultural oomtruni t ies.
I want to lUosft by asking you to do three things.
Number ono is gather the data on this species because it's
not that hard. I've done il and I'm not very smart. But 1
did 18 ranches in this analysis between breakfast and lunch
123
1
I do want to say that in the 1700s there was a
2
Frenchman that Waited the United States. And lie said at
1
that time, I'm not exactly .sum the percentage, but it was
something like when 70 percent of the people of a country
5
are government employees, then you no longer have a
6
democracy. And i think we're rapidly approaching that. And
7
I don't think that's any one person's fault, i look at you
8
people as neighbors rather than adversaries, but some way we
9
hav& got to cut back.
10
in a time when the United States is so deeply in
u
debt, as has been noted over and over here, 1 think your
12
statement is and shows that you arc- going ahead with perhaps
13
programs that arc- too expensive ot this time.
14
1 5
And I'm a recreationalist- I've enjoyed hunting
with my family- J come ErcHH a ranching family here, but my
16
children are employed in the oil and gas industry. No f
17
have many mixed emotions about this booklet that you have
18
put out.
H
First Of all, I do not want to see the public
20
lands sold, which has been advocated by some because it's
21
the only plans Cur people, the recreational 1st* like myself,
22
to go where Lhey can move about frealy and not, worry about
23
it. However, T don't think that recreation ia one til the
24
most important things in the world. T think livelihood is.
25
and 1 think that's one of the things that we've had to
on Wednesday morning, so it's not that hard to do. And 1
would invite anybody putting their data in this nanple.
Number two of which I would a.«k today that you
propose a plan to address the continuing viability of these
agriculture producers.
And number three, rw.ngn.1 se that the human ecology
of our communities deserves a: least as much respect as the
wildlife ecology, and naybe even more. Thank yuu .
(Applause) .
MR. DAKTEI.S: Thank you very much. Our next
speaker if? Dorothy Milek, Thermopolis.
DOROTHY MILEKl I'm Dorothy Milck from
Thermopolis. And I worked on the eommlitsimiers' appointed
committee to go through the book, and T was really glad that
: did. Since I've known about this study I wanted to study
it myself but. i i. wai too daunting to look at that book and
try to go through the whole thing myself. Bo it was a real
opportunity to be able to break into groups and each of us
tjke part in this study.
1 appreciate your beinq here and continue to
appreciate the fact that there's been a lot ot work done by
the RhN. And I think that it's a hard situation people Ar^
i:i. And I realize there are a lol of people out there that
couldn't care loss about what we're saying here today, and I
think that's part of the trouble.
consider here. And frankly if the wetlands sold, I do not
think that we should kid ourselves, these local ranuhfcr* are
not going t.o be the ones that buy it. Tt wi I i be purchased
from people with lots of money who will keep ail o! us out.
I do want in say that in our area, at least in
rhemopolia, we're talking about retirement. A lot of
people are wanting to come to this area to retire. It's a
lovely place to be. no crowds of people, but if the in
economics continues, there will be no one without a lot of
money who can retire in Thei-mopolic or Worlcmd, because
there won't he — we won't he able to pay the Taxes that
will have to be paid. Without oil, we're lost . And [ think
wo have to look down the road. We need to look at the
future, because some day there won't be any oil. what are
our children and grandchildren going to do? And i think
that is something that in a way the SLM has been looking at
HtMtnlVN.
However, at the present, time I do not think that
we can stand to have oil not be -- not have exploration.
And you will have to exouee me, I can't turn in my notes
here because I've scribbled over the top of I hem Several
times today. So I am kind of jumping from place to place.
However, I do think we need to keep the quality of
recreation in Wyoming. This is why people come here. This
is why I enjoy being out, as I love the isolation. ; like
538
m&BtiH^H^BHBBHHiaBi^HHaHHSS^BB^aHeaH
the vsptness of it. And I do r.hink that we have tn by
careful ilirti our oil industry doesn't okay, one minute,
all right, air that it doesn't lust destroy snmp of the
th Ingn that we like. Rut I think that the mitigation
process can take caret of that.
1 would like to -lddress one uC the things you have
proposed, it's doina something at the c;f.bo Coal Bite. And I
think that's a good proposal, tr's an acceptable area, it's
a place whtre people can go to learn about, the history. The
same thing with the oil, you have proposed putting some
recreation areas in the nil Intel prei i ve areas, in some ol
the oil areas. I think this is groat for the larger oil
fields, but .1 do not think that it's viable, for smell
inaccessible areas ■ 1 don't see going into these
inaccessible areas, drawing into them, where it's going to
COSt so much money.
The Meeteetas rock area is another place I would
like to see acoef.E to, but J do not want to nee development
there. T don't think the cost to patrol those areas ia
going to be feasible. I think that you have to pi o tee I, them
somet imen by keeping them isolated .
I have a final question on recreation. You have a
map on page 120, arid T do have some questions about those
areas that arty called Semiprimi r i vc Non-motorized
ReareaMon, Semiprtmitive Motorized, Rosded Natural, ;a n0
Rural areas. And T think those arc found unr» on private
lands than they ire on public. 1 would like you to take a
second to look at that map. Thank you. And I will get a
written statement to you.
(Applause) .
MR. DANISMS Thank you. Craig Griffith?
Craig could not be here but he submitted comments. Okay.
Allan Howard.
ALLAN HOWARD: When r ! irst start fid my study
of r.h:f. EIS I went to hVhHt.fi rs and looked up the word
"mult i pl«, " and ! t reads as follows : "a: cons iating of ,
including, or Involving morn than one; b: many or manifold;
C: shared by many; or d: having numerous aftjiecl n or
functions. It should be obvious, therefore; that multiple
use of public lands means Chat the land has more than one
use, ihat it: ts shared by many, and that it- has more than
one function-
I think we have all agreed, r>r most of the people
agree here today that the Bureau's definition of multiple
use and the def in' t ior. of the community at large, at least
in Wyoming, is not the same.
Over the last several decades, public policy
regarding public lands has shifted from a concept of true
multiple use to the current policy which increasingly
separates out. parcels of public land, isolates then, or, by
127
i
means of a variety of increasingly onerous restrictions,
2
partially to the Bureau's way ol thinking( if you have a
large parcel of public land, for example the Or BBS Creek
Resource Area comprising of approximately 368,000 acres, and
ft
you divide those lands into numerous single use sectors, you
6
therefore have multiple use.
7
a
It is accurate to say that partu ol the public
land do enjoy true multiple use. In a typical nil field,
*
for example, there may well be oil production, cattle
10
grazing, hunt ing, sightseeing , wildlife habitat , and
1 1
wetlands all using the public lands at the same time in the
12
same area. This is multiple use in the truest, sense of the
n
definition. The trend, however, over recenl years has been
14
to decrease the opportunities for true multiple use and
i5
replace them with more and more examples of single or
IB
restricted tifle .
17
When lawn and regulation:! are passed, iormulated.
M
or interpreted in such a way that limits the true multiple
19
use of the public lands, then all of the public auffnrs and
20
pey» the price.
21
Wyoming has long been considered one of the top
22
six oi seven oil producing stateH in America, oil companies
23
did not place the pntroleun reserves here and then decide to
24
come and produce them. The oil was here. It' didn't choose
25
to be here, it's jUBt here. And it the federal lands become
more and more restricted in use, and that certainly is the
trend, the economic impact on the Ptat.es within whose
borders the federal lands exist, becomes more and more
devastating. Not only are local economies impacted through
lost tax revenues and fever jobs for their citizens, bui
stats and national economics are impacted as well. Every
dollar, or almost every dollar that tlows into (federal
coffers came from somebody, or somewhere, in some state.
Increasing rentri cMons towards multiple use of public lands
ia destructive of the economic wall-beiny of the federal
government, as well as The state and local governments.
As J mentioned earlier, the Gratis t:rnck Resource
Area contains 968,000 acres of public surface lands and
about. 1.15 million acres ol federal mineral estate, of
those acres, 595.000 ar<* restricted to oil and gas
development in one manner or another, whether that
restriction is by means ol no surface occupancy
restrictions, controlled surface requirementn, or other
types of restrictions, the fact remains the same. Out of
that 595,000 acres thui we're restricted from developing,
485,000 this comes. out of your own documents -- 4fl5,00O
of those acres have a moderate potential tor the occurrence
of recoverable miners! assets. That's 90 percent. Out of
t.hrJf., 159,000 acres make up the non-surface occupancy lands
and controlled surface occupancy lands, and 147,000 acres or
539
ia*
,
92 percent have a high to moderate potential for the oil and
2
gas occurrence, it. is no*, known how many of the 339,000
1
■1
acres make up air and qaa which you hav* placed timing
rest rid ions on. Seventy to 75 percent of I hose land.i have
5
high to moderate potentials for occurence ot gas and oil.
6
The effect is that of the 4flr>,ooo sores, 80 percent of those
7
restricted acres have a high to moderate potential for oil.
As you look through the documents there 'a rtol one
9
paragraph, there's not one sentence, one. phrar.o, or one word
10
that encourages development of those aHsers. I understand
LI
and appreciate the fact that you feel you ftava to coma forth
12
with a balanced document to meet all the public. If that's
13
the case then you have failed, because that document
14
Increases the uses of the environmental concerns and not one
13
Issue does Increase the use of oil and gas, or grazing, it
16
detracts from them as it is not a balanced approach. It is
17
set up for the environmental movement, and it seems to me
13
that the intention is Tor the regulator agancy managers to
19
eliminate oil and gas potential on these lands- If this
20
policy la put into effect and others like it down the road,
21
it will not be very many years before there will not be any
22
oil and gas production on federal lands at all. Thank you.
23
MR. n.\NTEl,R: Rftthlaen Jaohowski, Cody.
34
KATHLEEN JACHOWSKI: Thank you, My name is
85
Kathleen Jachowski, and I am here today as a member of the
Greater Yellowstone Coalition. You will probably not be too
happy, but that's unfortunate. The opportunity to have this
much needed public hearing should serve as a clear message
to the BLM, that citizens of the counties involved" take the
contents and intent of this DEIS very seriously.
Unfortunately, the citizens seem to have taken the impacts
more seriously than the employees ot the BLM, entrusted to
develop SUCh documents.
simply, the Draft EIS does not otter an adequate
range of alternatives as required under NEPA. Table 2,
Comparison* of the Alternatives, explains why. Out ot the
8-1-1 possible alternative comments that were possible to
compare the alternatives with the Preferred altarnaxlve, fin
all said, "Came aa the Preferred" Alternative. Clearly this
is a transparent ai tempt to follow process and produce a
meaningless DEIS product, Ir. any final document that does
result from these efforts, know now that the public will not
accept eye wash to substitute for needed real and high
caliber intellectual effort.
Secondly, culture and custom as it relates to the
socioeconomics Mill hopefully be vastly improved as a result
of the public's overriding concern, arid needs to bring
insight into this continuing procene. The records should
show that this member of the public wants BLM employees to
demonstrate understanding and insight into these concepts.
While the public welcomes the opportunity CO provide needed
information, it does not. want to be astounded by any DEIS
exhibiting, a lack of understanding of both the NFIPA process
and the concepts involved.
In conclusion, I would like to sec the final
document put forth a couplw of alternatives that call for
increased commodity activity. There is no justification for
a battery of alternatives that do less- a full range of
alternatives by definition would include such consideration.
Thank you.
(Applause! .
MR. DANIELS: Thank you very much. Dennis
Jonas , Thermopoiis.
DENNIS JONES! Thank you for this opportunity
to speak. I am Dennis Jones, rancher from Thermopolis and
the following are my observations and opinions concerning
the Brass Greek Resource Area Resource Management Plan Draft.
Environmental impact statement.
On page 17, Concerning Ruck Ait. I have seen soma
potroglyphs on our land disappear in ray lifetime, due to
weather and titte. To record i.hetn for history we take chalk
dust and fill the indentations, than photograph them. This
seems to me to be a wore economical solution, than trying to
make Them available for the public arid then protect then
from the vandnlH.
132
1
On page 37, Livestock Grazing Management-
2
Concerning elimination of livestock gracing 011 the public
1
4
lands along the Big Horn River, the buffalo and game animals
all grazed the river bottom extensively with little or no
harm done. 1 see 11c reason to exclude livestock grazing
6
from this aiea.
7
Page 39, Livestock Grazing of Dormant Plants.
a
winter usu can be much more than f>(> percent, i attended a
9
meeting where the previous Borland district director stated
10
that fiO percent and possibly even 90 percent was no;
1 1
considered harmful.
13
On page 40 to 41, livestock Gra7^ng Restrictions
13
for Sheep. These restrictions are outlandish and
14
unnecessary. When the Wind River Canyon planting ot Big
15
Horn Sheep was completed your of I Ice and Wyoming Gane and
16
Fish personnel indicated no impact would be felt. Sheep
17
ranching has a greater economic input in the area than
18
antelope and Big Horn Sheep hunt ing.
19
On pegs 47, off Road Vehicle Management, it is
20
Implied that access Ls secured for Red Canyon creek. Tfiia
22
p^ga 49, BwnraaHoTi Management. The proposed
P.I
trail h«ad at. Red Canyon Creek, when access is secured, ic
2-1
approximately 200 yard* from a sage grouse i*k.
Page M, Recreation Management. I in curious how
540
saeBBSBaBK^:' .
an interpretive site lor the Mexican Pass Trail would be
developed on the tflnd River Indian Reservation.
Map 3. Cultural Resource Management Area. The
Mexican Pass Freight Road did not gr> where Indicated.
Map lb, off Road Vehicle Management. My R«d
Canyon private land is included for orv use end no access,
S8 yet, is available to the public.
Table 9, Watersheds. The great majority n{ Ihi*
watershed area for Red Canyon Creek is on the Wind River
Indian Reservation. I estimate at least 90 percent. Your
document, indicates fifi percent, of the watershed is on BLM
lands which in vnry much in urror.
Table 10, Stream Claftnif i nation. Red Canyon Croak
is normally dry and there are no fish. Tt'a listed as a
type four t tehary.
Page I7g, Socioeconomics- The difference may b«
insignificant in the alternatives, but the economic impact
in reality would be huge. This document, i£ enacted, would
be devastating to the entire Big Horn Basin.
Pay* 226, wild and Scenic Rivers. Red Canyon
Creek is designated as free flowing. This is in error, aa
The major water source )s diverted tor irrigation during thi*
growing season .
Page 246, Actual Crazing Use. Actual uoo is
incorrect Cor alloLmrsnt 02505. It is considerably higher.
Page- 254, Stock Levels, Actual Use and
Suitability. Allotment 02505 has already suffered a 47-1/2
percent reduction and the table indicates some more is
desired. This is unwarranted and unnecessary.
In closing, something Is badly out of whack when
Wyoming Game and Fish game Dumber goalc arc used to cat the
number of AUMs ranchers can run. It hardly seems fair that
an agency that Uvea or dies by the number of licenses it
cap sell is deciding th* viability of our ranches. Thank
you.
(Applause) .
MR. DAKIBL.S: Thank you very much. Martin
Dobsov. , B'jrlingr.on .
MAFTT"f DQBfiONi I'm Martin Dobson and I live
in Burlington.
(off the Record) .
MR. DANIELS: II you can Lake your seats.
Martin, we'll try again.
MARTIN DOBSON: Well, I'm thankful for this
opportunity to take a minute and to have the hearing that we
have today.
T am most appreciative of the representatives that
we have had coma before us today who are elected officials
or representatives ot elected officials that included
federal representation and state representation with Sarb
135
:
Cubin's office, and Jim Geringer, and our county
2
commissioner a in eanh of the four counties who got up and
spoke, and some of the local mayors, and other elected
4
of f iclaJ s. I see thai as a vei y important step in the
5
representation process.
6
7
It was very clear what their message was, very
defined, and they were a] J in very un-uni(]Uft harmony on
8
this- They were lined up in the same direction. And that
9
fact alone speaks very strongly, but the strength of it 1?.
10
that the things that they speak have been spoken before.
11
And it's obvious thai someone wasn't listeninq or we
12
wouldn't b« to the point that we are in this process right
13
now. This hearing would not have occurred if they had been
U
incorporated into that process in the beginning.
15
They are elected officials, they are
i-Bpi-i'STiaM v«M( t.hey. have Land use planning people r th*y
17
heve expertise, and that they ai«n taiK with their
18
constituents. And I suggest to you that a heating has to be
in
move chan just hearing the words and letting it roll off
2U
like water oil a dUOJt'B back. They have to be input in
23
terms of not just having the input laid out, the input has
?.?.
to be applied, taken 1n, and used. I think that, that's Che
23
strength of this and that message should be heard several
24
times here, because rhat seems to be what's lacking in this
25
whole thing .
The Comments can go on here for the next 6, 10,
12, 25 hours, whatever you want to sit here for, and if
those comments are not used again -- and I will submit to
you that they have been ignored, and that they are many' and
numerous - and as long as they ax-p-. iynored and the people
are. ignored then this process will go on arid it will come to
again a lousy conclusion.
I do have a few specific comments I would like to
put forth. The economic impact to the oil and gas industry
of this kind of proposal is severe. The mitigation for
environment and disturbance impacts art- already taken care
of as have been indicated in Section 6 of the lease
agreement. And if there is mitigation that needs to be done
adjacent to state lands, the DEO and other environmental
ofEices within the state, th« county also deals with this,
can toil Mltn ttua.
1 would sucfgest to you that the elected officials
such as specifically our county people should be
incorporated tnto a new alternative, and that would be the
one I would support, because T haven't heard anything that
they have proposed today thai I would not support. I'm
behind them.
When 11 comes to rantje management, the wild horse
is not a wild horse and I hope that someone ralkr. about
that.. He Is a cultivated horse. I have neighbors that have
541
137
1
been Otlt tin the range when they have collected those. I
2
understand there's only Paint etude thflt am plantd our.
3
there. It would be interesting CO see if we hat! a coyote
4
population out there that were only selected Jot a Paint or
5
Pinto coyotes as a management strategy, well, they arc not
6
wild. Those horses are not wild, guyo .
7
You talked about this great resource we have out
8
there for all our wild animals. Well, a Lot of Ihorssi deer,
9
antelope, and nthar things winter on the r^nrhlandc. or on
10
Lhe farmland adjacent to the BLM lands. I have
11
approximately fifteen miles of fenou line that borders the
1?.
BLM. You don't maintain the fence lines and neither do your
13
(quota) "wild horses," youi cultivated horses. They tear
l A
them down.
15
I have a sect ion of ground that I have been
16
trading - trying to trade the BLM for out - about three
17
mil«et from my house into DLM country. I've been trying to
18
trade that for threi; generations, My grandfather started
19
that process and we have been turned a deaf ear for three
20
genera tj ons . Not even d , "Wall , let's work on It and see
?.\
what we can do," it's more of a stonewall. Very
22
frustrating. Those areas hav* access, and that access comes
23
through ray property. NOW yon may have land out there, but.
24
it can be fenced off and county roads can be closed eo that
25
the only access would be by helicopter •
i would suggest to you thai, your proposals to
recreation have costs that yon have nor. estimated or placed
out here. Do T still have one minute?
MK. DANIELS! No, your time is basically up.
MARTIN DOBSON: That's time? Okay. I'll
wrap up my comments. T went through this end looked through
the alternatives. The Preferred has restriction Lhe
verbiage is restrict ion , 1 ( mi ted, and protection , as its
common phrase throughout this Pi«f ei red Al ter native. And I
counted up over 70 places where that term occurred. I've
also highlighted in the recreation management area, and you
can do the aame in your EIS, each place that it says ihat
access will he grantee", development will be included, a
scenic interpretive loop will be enhanced, and fa"e-i!itlen
will be established. let's see what the COfltS ol those are.
That's the only place in this whole thing where I see that
kir.c of addition.
And again, I will submit my written comments to
you at a latei time since we have a Cew more days. T
appreciate the opportunity to do this. And again 1 stand
behind m\ county commissioners who represent me on "his.
Thank you.
(Applause! .
MR. DANIELS: Thank you. Rente Dobsron , Cody.
monte dorson: I'm Monte Dobscn from Cody.
139
]
J'VB benn raised in thin country, been here all of mv lite.
■1
And ] would like to put Lo rest the talking ol this romantic
idea ol these wild horses where all this money Is spent jn
this area.
Like Martin said, thouc horses are not wild. Rack
when 1 was a young man there wan three times the amount, of
7
s
cattle running in the Fifteen Tatman Area, Fifteen Mile
country In the Tatman Atea. And not only was it that. but.
?
the wild horses there was wild horses then. And there
10
was the Pitchfork ran a lot of sheep down in that country at
11
that time.
L2
13
And rhen fh<=. m.M, because o* the dry, the years
were trettlng arl«r, the BLM said, "Veil, now, w« hava gat to
14
cut down on cattle and we have got to find some way to get
15
rid of some of th^se horses. And they come In the period of
ifi
those yaara we ■ they cleared oil; better than 6,000 head ol
17
wild horses. There was sight head Ictl on Tatman Mountain,
18
there was 15 head left over by the Duttes, and those were
19
hunted down and shot- There was no more wild horaes in that
21
area .
.Vow as years went by and tractors come in more
22
33
prevalent, people didn't know what to do wir.h a lot. ol' their
horses. They didn't want to sell them, but t-hny kind nf
24
wanted a plar-e Lo put them. Well, T had a cousin and a dirt
and some of the other neighbors, but this cousin in
HO
1
particular, and he put these horses out on his ground, of
2
3
course, like it's been stated, horses don't think much of
fences and they tear them down. They got out. They were
■3
T helped them round them up once, And the colts were taken
off and put bock out .
C
Okay. Then the 3LM come in and said you are going
7
to have to clean up these horses and get them ofr there. A
Fl
hired horue wrangler was brought in and he took off two
<J
trurkloads which wasn't half oi l.hem. The other horses wore
10
lett and the BLM took over the management ol thes« horaen.
11
And this is where this herd of horneR come from today. 1
12
1 s
know a lot of these horses were Paints and so forth <*« has
been atal •■•A,
14
now ynu car. go down to ■■ - the oldTimere ii£**d to
\h
have a name for these type of horBes, nn<\ you can go dowr:
16
nlong the riineient ranches and you can r.oe them all over.
17
1H
would address them by. Those horsos were not particularly
L9
skilled in anything. They are too small to be working
20
horses, and they weren't a satisfactory tiding horse. They
21
have no gate. They have — they were rough to ride and
22
rhat's why he turned them out, b>?Orius=e he didn't want lie
a:i
w„*nM. particularly proud of them, h'e run them in, took the
24
colts off and sold thorn as poundage flesh for a while until
2b
the old tame mares died off, then he couldn't got them in.
542
So this is ■-■here this bunch of horses came from.
And this is where all this money is being ypent now as a
wild horaa refuge. And I do not think that. it. justifies
that money be spent on horaaa of this caliber ro he able to
spend this money and then say, tell the public they are wild
horses. They are no:. And I Juet: wanted to put that before
you . Thank you .
(Applause) .
MR. DANIELS: Thank you. Our next speaker is
Gary Anders, Greybull.
GARY ANDERS: I'm Gary Anders of Greybull. I
run a real small cow/calf operation in the Crass Creek
Resource Arwa, all on private land. Unlike your
Environmental Impad Statement, my remarks will be vwry
brief.
It's my fouling in the entire GrdSfl Cru«k douUmunt
is totally invdlid, and just another step in a well-
organised effort to deceive the American people. By the
Bureau of Land Management 's own admission, the preaent
management is working fine. The only leason for changing it
is to exert tyrannical control over the American people. To
subject frae people to absolute control by our till powerful
federal government you mum Mrs! remove th*ir rights and
freedom, remove their free speech by making it politically
incorrect and unlawful to express an opinion contrary to the
federal government, removp their right to protect themselves
by taking tneii arms away, remove their rights to own a.nd
control private proprrty or lease state land. Thera'e no
such thing as federal land in Wyoming, except military
reservations -
The Endangered Species Art and Ecosystem
Management Plan, euch as the Crass Creek Plan are only a
ploy to control the American citizens by removing their
oonsti tutional rights. The ESA and Bcoaystan Managements
may have had some merit, but this has been perverted by all
reason -- beyond all reason by Secretary Babbit and
President Clinton* T am certain that Mr. Babbit or
President Clinton would not rscag.ni*8 j Bruno spring Snail,
or a Snail Carder Mino if it appeared an their dinner piste,
but they would readily shut down million:: of acres to
protect these or any other fictitious species i hat they feel
is endangered. This is not About, protection, it is about
control of the rabble, that is the common American people.
After all, the average American citizen cannot be trusted to
make (.hair own decisions. This must be done fur them by the
Washington elites.
We have hesrd from the Governor o£ Wyoming and our
senators and rep: esentat i VCfi Eron all levels of government;
they unanimously oppose this document. Therefore, the Grass
Creek Plan violates th« Tenth Amendment to l.ha Unites States
Constitution by usurping the control of Wyoming state land
and Is therefore invalid and illegal. Thank you.
(App] auflS) -
MR. DANIELS: Thank you. Our next Speaker is
LoiL' Herbal., Shoahoni.
LOIS 1-lKRBST: That i-J Shoshoni, named after
the tribe on thtt Wind River Reservation. I ranch in, right
at the southern border of your Resource Management Plan. T
also ranch in two other counties and several different types
of your permits, and I haven't been happy with any o£ the
treatment given to ranchers in the past few years under the
plans. I am spectking today as Private Lands Chairman with
the Wyoming Stoekgrowers Association. X also served as
President of the Fremont County Farm Bureau, and I am an
elected member of the Lander District. Wyoming Start- Grazing
Board representing parmllfceBH on Topper Mountain, which la
t.n the south ot your plan, and in sore ot your plan.
I will be sanding you a written analysis. I hope
co outdo Dennis Junes, my neighbor on Copper Mountain- He
just. gav« an e.\collenl analysis. But I don't think you have
adequately addressed the private lands issue. Looking at
your laud ownership pattirne on page 109, 111, and your
Appendix 3, Tab! e 3-1 it refers to the private lands in
grazing allotments, does not address the Unpad of those
private lands. And there is oth*r private lands that aren't
even tallied in. And these lands that aren't in the grazing
allotments will have a higher tax base because of your
reduced income from commodity production on the federal
lands.
Your riparian areas on page 198 gives no
indication of how much of that riparian area is on private
lands. Throughout, the state it is runninq 70 to 75 percent
of the riparian areas involve private lands.
wtldlifa habitat, what in the basis, the law that
allows Came and Fish to dictate the numbers of wildlife
running on the federal lands- I asked several years ago
what the quota had been for elk on Copper Mountain. Khan
they introduced the elk they got permission from the
ranchers' cooperation. There was to he a certain number.
Well, the good old ranchers didn't go home and
write down numbers, there was nothing in writing, because
it's not in the files of the cam*1 and Fish Commission. And
talking to one of the olOtimera r w*s told that it was 7^
head of elk. When ir. reached 75 head they were — that was
it, there whs to be no increase in that herd. And in the
drought of 1988 my huehand wanted to rest out: Copper
Mountain land, which only IB percent of it 18 RLH land, and
we leased land elsewhere. And neighbors who have time to go
do things like this, they enjoy hunting, but they wore just
up there looking around in the summertime, counted IllO head
543
MS
1
ol elk in that pasture that, we wore trying to rest. The
.1
■1
neighbor thought it. looked so good he turned his c.aLl.ie. in
on it with the elk. Not the neighbor who was speaking
tonight, ei t her .
R
One ot the things 1 wtis Interested in was the
f>
basis for this whole plan. Ami i read your planning team
7
reviewed Che executive orders, the acts Involved with
B
grazing and so forth, but I Ju»t wondered i£ they reviewed
3
the portions that dealt with, tor instance, the Grazing
10
Taylor Act was enacted to give stability to the livestock
1 1
industry and the communities. There's requirements to
12
consult, coordinate, and corporate. X think that's the
13
three Cs. I get thorn mixed up and have trouble remembering
u
them, but they are definitely — there was a basis for
13
working together. And i hat basis is living us. Everything
16
that comes out is punitive, it Iff a reduction in our rights.
17
it's as though they are trying Lo lower the values r.hit. we
Ifi
19
you are not the ranchers, the producers that you think you
Sfl
.».■
21
And another thing, nobody ever put this government
22
as
— thoy were not supposed to be owners of real estate. When
our Constitution was written and our country was formed the
^4
basis was the right to have private property arid use It lor
25
free enterprise. They did not want, the government to own
146
1
more than a third of this Country. Thank you. I really am
2
glad to have the opportunity to speak here tonight and 1
3
don ' l envy you your jobs one bit, thank you.
•1
CApplauae) .
MR. DANIELS: Thank you very much. Bill
&
7
Wilson, Ten Sleep. Sriar. Webster, Heeteetsc. John Preis,
Emblem.
a
JOHN PREIS: I am John Preis tron Emblea, a
9
rancher there, also Vice President of the Kig Horn County
10
farm Bureau.
11.
I'd like Lo preCaoe my remarks by Raying that the
12
13
people here today speaking to this proposal would prefer Lo
be doing something else, that this is a giant waste of time,
is
but something that we feel strongly enough that we need to
do.
16
17
The fact that we are here speaking against your
jnfrS ngemrTit of our rights speak a for itself . And the fart
18
that we are on our good behavior does not mean that we are
19
not vehemently oppor.ed to these proposals. In other words.
20
we're nut using the words B.R., but it is In the back of our
21
mind.
22
I wish to thank the 9L.M for taking the time and
23
making the effort to niv" the area people a chance to
7A
respond l.o Lhe various proposals, which have beisn presented
concerning the Braes Creek Management Area.
!<J7
l
Some hearings are necessary so that we are all
2
3
4
aware of what the "our," is thinking. I do ha\a one
suggestion, though, concerning hearings , and that is that,
there be some listening on the part of the ELM. One-
5
suggestion is that you listen lo some people who have a
P.
vested interest in t.hw area and are directly affected by any
7
management decisions.
8
Secondly, the economic impact of your decision he
9
positive for both aides. Any reduction in income to the
10
users of these lands is a reduction in the tax base, which
1 1
is a reduction in money that can be spent In managing the
12
1 ?,
area, therefore reducing the economic activity. It will put
us both out of business.
lr>
Over the past several years we have had area
hearings on reintroducing wolves in the Yellowstone area.
IF.
There were at leant three hearings in three states nn th*-ep
17
different occasion:! . i did not attend all the hearings , but
IB
the ones that 1 did attend were 9 6 percent against, any
19
reintroduction plan. Yet you say the majority of the people
20
wantnd the rej ntroduot ion . The majority of people were not
21
directly involved. The majority of people did not have a
22
PA
vested interest. t would not be opposed to having wolves in
downtown New York sinca I have no vested interest in the
outcome of such a propositi.
2C.
It's time that the BLM and other government
1-18
1
bureaucrats begin listening to the concerns of the people
2
involved and review the basis upon which this country was
rounded, namely, "0£ the people, by the people, ar.d for the
people." Thank you. And you do heve a copy of thia
!>
already.
6
7
(Applause) .
MR. DASIELSl Gordon Prei3,
8
GORDON PRE13; Hello, tny name is Gordon
9
Preis, This is going to sound kind of redundant because
10
it's been said over and over, time and time again today.
n
In reference to Uie Cif««e Cr«tik Ruuource
ia
Management Plan, what I understand of thia proposal is that
13
the RI.M is trying to take our laud and change H from j
14
multiple use to their single-use plan. Their proposal was
is
to tun wild horses toi the amusement of tourists ar,d
16
preserve the natural beauty ot Wy owing wild.
17
l haven't been able to do p. lot of research myself
ia
on the Environmental Impact Statement, due to Much ahOCt
l 9
notice, but I'm sure that the BLH has done no quite
?.o
extensively and quite poorly -us I havB understood today.
21
I ask the question, have they looked into the
22
economical impact that this propose! would have on the State
23
of Wyoming and its people. Th i e proposal will eliic-.nate
24
mining oF many minerals, a: 1, for which is quite important
25
ac lar as the store's monies. I'm not sure of the number*,
544
but a great, sum nf money is collected from thin which is put
intu the State'* budget. Without this our statu will have
to make up differences somewhere else because w* are already
hurting tor mon^y.
They also propose to take the cattle ot t the range
because <if environmental hazards ro the- preservation of the
landscape. They t ry In tell cht people that the reason for
all the ailments ot rhe landscape: is directly related to the
cattle; over gran i ng, trampling, cattle trai is, etc., ate.
They dun' i ir.ll that we have been through a drought or
wxtreme weather condition. And they always take their data
at extreme times. They don't tell you that the reason the
rancher doesn't do a Lot of management 1b because of all the
rules and regulations that he has to follow, which doesn't
let hi Bi do anything. And Eh* people that manage the land,
fcha BLM, don't have a clue as to how to best manage cattle,
and won't 1, in ten to someone who doss. So they blame it on
th» cows.
The cattle and the cattlemen do good things for
the range and th« wild animals that live therein. For
example, one of the beet grass and nutrient feeders la
placed on the back of a cot,. They are quite generous with
it also. The ea«tt*tm«n aim> provide water at different
locations where water isn't normally avnessiblH, and the
wild horses and wild animals also take advantage of this.
im:
1
without this it would either eliminate sum** of the range
2
that the wild horse could use, or cost the taxpayer money to
3
provide and maintain them. Another advantage of having
4
cattle on our land is the money that the BLM and the state
5
get from the leases which will have to be made up somewhere
6
else, if the cattle are taken from the land, which will
7
increase taxes .
8
Now, it the cattle are taken from the land it will
9
make the cattleman have to scale down his income, and when
10
revenue goes duwn he pays less in taxes, 3tato and federal,
11
which is less money in the kitty. He or she spends leas
12
money in town at youi business, doesn't need all them parts
13
and mst-hinery at your businesses, your income goes down, he
14
has to lay off workers, and it goes on and on. The diners
15
and the oil companies fit into this category also.
16
You people that feel that this proposal won't have
17
any affect on you, either way it. will. If this proposal
ia
goes through, the state will have to make up the funds
19
somewhere else, and it will affect everyone in the 3tate and
20
higher taxes a lot higher.
Z\
What is it in this proposal for the state and the
22
people? The BLM says that this proposal will help the wild
23
horse herd and draw tourism. This proposal will create a
24
tew jobs, but they are all tax-paid jobs. The horses also
25
need to be taken care ot , so that will cost more tax money.
151
1
They are proposing to build roads and rest areas for the
2
tourists which will cost tax dollars and create a few mom-
3
short-term jobs that are also tunded by tax dollars.
4
There's a lot of expense with no income to back this
*,
expensive proposal. We already have the first wild horse
6
herd to be controlled by the gov«rnment living in the Pryors
7
and it Is expensive and not managed very el l iciently, and it
8
doesn't bring in very many tourists. We also have the
9
YollOW tail Dam and Big Horn Recreational Park which brings
10
in veiy little tourism compared to Yellowstone . Our big
11
drawing card is Yellowstone, and that is why the people com«
12
13
here, not to drive through the sage brush to see wild
horses. They have to drive through the badlands to get
1-1
there on our present highways and they are not going to
lb
schedule another day to drive in them some more. A lot of
16
tourists that I know would like to see, and come to see
17
cattle, cowboys, and not wild horses, sage brush, and dusty
18
dirt roads without cattle.
19
With all this expense there's no income to support
20
this proposal, hot to mention the money that would be lost
21
by the state and BLM eliminating mining, oil, and grazing
22
fees. So now Wyoming is in this big hole, not enough money
23
for the regular things that the stale presently doe«, but
24
more expense to add to it. So what happens, they come to
?.b
you for more taxes. Remember, the state and federal
government has no money. It's our money they use, and we
don't have any more to give. You have a copy already.
(Applause! .
MR. DANTELS: Thank you. Dick toper, Lander.
DICK LOPER: Gentleman, I'm Dick Loper, I'm
here on behalf of the Wyoming State Grazing Board's Central
Committee. I live In Lander and work for this group as a
federal lands consultant. There are five boards around the
state and they are primarily set up to provide some
terhnical advloe and assistance to permittees on BLM- type
problems .
I've been doing thi.'i for about 1 8 years and I must
tell you that 7 don't think I've ever come across, and T've
done 93 documents now in 18 years, and T haven't yat -- this
is -- this is the worst with raspeot to being overly biased
against the commodity users. T just, don't understand why
the balance isn't there that uq normally see. And it's
going to become almost impossible, if not -- well, it is
going lo become impossible I think to cuiae up with a
balanced final product final RMP , final CIS, unless there's
BODie balance taken from these public comments.
I will give you a copy of my written comments here
and I hill just paraphrase some parts of it. Most ot the
narrative in here on the technical purtUmtl of the range
management portions which I have some qualifications in, I
545
HnH^HHHMBHHHHHM
lcli^iit^.'',..;>^i=*ait
153
:
don ' l think ;epreswnt the current stare of the art, anil iL'e
2
a frustration to range, management, people, range BCi«nli#ts
:•.
outside "f ihp nQRiieHaa, We just do nor understand why the
4
■agency n^rmi; to bo the only foul ball when it cones to being
fi
able to road literature and understand what the literature
6
Bays <*nd iniL-rpret Ll on federal lands. And there shouldn't
7
bo this dichotomy against the rest of rim profession in the
B
agencies, but there cooms to be and I just don't have any
9
explanation lor it..
LO
13
But for example, the ranchers that reduced their
livestock numbers during the drought period, now those aums
12
during that drought period are utMd hk a benchmark for how
1.1
many At'Ms people need in this area. The Hl.M pwople know
14
better. They know thie U not. the number ol AUJJe that.
15
people need to run a sustainable operation. Ranchers took a
16
reduction during this drought period- They practiced propei
17
range management, and now it's kind of Ironic that that
18
practice is now coming back to haunt them in the proposed
10
action by the BLK saying that This It all they really need
20
because they haven't used any iKOTa than that.
21
The table in Appendix 1 Appendix 3, Table 3-4
22
La an Ecological Condition Class and Acreage of Public Land
33
by Mlotment. And 1 want bacft to the 1982 Grass Creek ZSI ,
24
Lhis yellow book we call It, and there's a similar table in
25
there. And I tried to compare the numbers* both on acreage
15-1
1
and range condition to see if T could determine whether or
2
not t here might have been either progress or r<sgr*ss in some
3
of the rang* condition*, and t can'f even get the law about
4
acreages to match up allotment, by allotment, so that throws
5
everything intn a tisuy because than you cannot go to range
fi
condition estimates by acres because the act an don ' t evnn
7
match up allotment by allotment. Ami sometimes they ate off
8
by many thousands of acres. So It 'a difficult for some of
9
us who review this document to be able to compare the two,
10
1982 document to now. We con ' t know which one _s correct.
11
On* of them is wrong and on* is correct. We don't know
12
which one it Is,
13
Table Appendix 3, Table 3-5 is on Suitability.
: 4
You've heard some comments about that today and you heard
15
some comments Eron me before this particular hearing on
16
that. I think a lor ot US outside the agency were very
17
shocked to see this information in thie draft because it
16
19
again this yellow document. The technology uaed to develop
20
the information in '82 was an office procedure, i r wasn't a
2\
field procedure, it wau directed by the Washington office
22
of the BLM as a field — or exeunt* me, an office procedure.
2 3
Ami the criteria that were provided ware discounted by tha
24
riiiye prof easional almost in total.
2b
In facr., my understanding Is thai one ot the high
l
158
level officials in rum in the range staff actually was
7.
transferred because of his adamant support tor this field
3
technology. And hare it shows up in this document again.
-
And it's just amazing to me that aomnonc doesn't have tne
5
perspective nn that particular item, the suitability item,
b
7
and allow U to go forward in ihi.s par Until Hf document, for
whatovftr reason, it's misleading tn the public, rr's on a
8
fail technology and it should not be her.;. And someone
9
should honestly be embarrassed that ;t is hero.
in
Table 3-fi on the nubjed ol uiiU?.ation. Myself
13
and other technicians in the stat*> have, provided a number of
la
ourrenl literature i.o the Btfl b«rr in Borland and other
13
Offices in the districts! here in Wyoming on utiHaation. I
1 A
can cay with certainty, because I know this Information
15
rather well, In (act I'm the one Dial sunt it 10 you most of
Ifi
thft time, that basically the current statu ni t he Art nn
17
utilisation ir. that it's appropr iat t- to consider it it you
1 H
manage Lhe extremes; manaqe too much use, manage too little
19
uSt. And everything in between dowwnM matter, if yog try
?.o
to manage the 40 and 50 percent utilisation levels it's a
21
waste of public rime and money because it doesn't change any
22
vegetation. It's fust an exercis« in futility. And w«
23
don't understand why once again the ag«nr_y people who read
24
these things, look at your articlnn, don't, come to the same
conclusion thf rest of ua do. It's net h H«», there must
156
i
be something else going on that we just can't figure out.
-;
The wild horse expansion proposal in here is --
:
well, jn my opinion is just simply against the law. I den ' t
*
sec where you have any authority whatsoever to double,
5
basically double Lhe a:ze of the horse herd ar^. The 1871
6
law say* you are to manage as best you can the nurrhers ot
7
the horses In the areas that they asi3ted in 1971. And I
a
can tell you from communication with t.h«fl« people here end
9
with BbH officials that your proposal is outside the scope
10
of your authority under that Uw. And you hava got to give
11
1 3
that SOUS consideration or there might be some legal action
an thai, nut from the State Grazing Board because we don't
do that, but somebody is going to pick up on that.
1-1
He are in support of the proposal that talks abuut
15
the rotation of the Salt Desert Ranges. We think that is in
16
fact, an appropriate evaluation cut those ranges. They should
17
be managed in a rotation system and not season long, and not
18
r.he same time every year. But- we do think chat's an
appropriate thing .
80
On a more personal note, very quickly, I'd like to
?.-\
have the final document represent -- tell us what the
criteria are for reviewing public comment. You've heard
23
public comment today rather consistently. You probably get
24
some public comment from other point!* of viuw, but not here
25
at the hearing today. But it's obvious to all of us that
546
HBfflBiB^aHIHBfa£Bga
it's goinq to be an overwhelming imbalance against this
document. And yel we don't know what thp criteria are for
review of our public comment. We don't know if it's just
going to be a waste of time, or whether or not our nomstentB
ar« in Etct going to be used by you. And we would like to
know whal the criteria are.
T was told hy a friend of mine in the Rock Springs
BLM Diotriet that was on an EIS team down thsro, dinturbi ny
comments he told me. Hr- said if somebody on the team
doesn't like the comment, it doesn't go anywhere. And I've
tried to ri>ad the BLM documents that provide the guidelines
tor interpretation of public comment And they are not there.
So we'd like to know. I'd like to know un behalf of. the
State Grazing Board and all the permittees, how do we know-
how you are going to take a look ar our public comment? is
it going to make any difference at all? How do you judge?
Ill all hoiWSty I've set back there and watched
your foreheads get a little red today ami your ears get. a
little bit red, and I know some of you personally. And I
don't think that if you individually had a«t. down for the
purpose of writing a document that, you would have come up
with this kind of a document. And sn it's incredibly
disturbing i.o most of »« thai a team of RLW employees could
get together' and comet up with thlfl, when Individually we
dun ' 1. tblllk that they would. We know n lot of l.hein. They
are good people. And how in the world can you come up with
this kind of a document that nouses this kind ot reaction
from the state and from the Big Horn Basin. Please 30 home
tonight and reflect on that,. we need you to act like humans
with compassion, not like bureaucrats. Thank ynu ■
(Applause] .
MR. rjANTET.S: Thank you, nick. Keith
Hamilton, HyattviLle.
KEITH HAMILTON: I'm Keith Hamilton. I'm a
rancher from north of Hyatlville. I'm here today on behall
oi the Wyoming Farm Bureau. I serve as their vice chairman
ot their neb Committee. And we have come up with some
goneral eommant.o and observations I'm going to present hero
today ar.d reserve the right to bring some later ones before
the dead! inc.
The Draft ETS treats agriculture as second-clans
uSBim. On page 5 it says, "The livestock grassing practices
that are compatible with other resource management
objectives," We question why livestock grazing is being
singled out to measure for compatibility.
Discrimination ifl continued on page 14, paragraph
one, the Draft EIS doesn't consider the plan for Wyoming's
agriculture industry 1990 to 2000, hereafter referred to as
the plan. The plan lists eliminating factors for beef
production, federal policies which limit grazing. This is
159
1
on page 24 of the plan. And federal land policies limit
3
expansion of sheep ranges, on page 37, ae a limitation for
3
sheep production.
1
cine ot the plan's goals for rhe beef industry is
5
ensure no net loss in federal and state AUMs. One goal
6
listed for the sheep industry is increase stock and cheep
7
numbers to one and a half million head. This document
a
appears to ignore this plan and instead of seeking to
9
enhance livestock production .is outlined in the plan seems
10
1 |
to reduce or eliminate livestock grazing.
The Draft EIS suggests improving (quote)
12
"ecosystems" (mmuoie) an an important management.
13
consideration, but doesn't provide ranchers with maps
14
outlining which ecosystems will be managed.
15
The Pratt Ers on page 8 discusses the dovelopment
J 6
or mi Ligation needs. The document is unclear as to what the
17
B1.M considers a Iquote) "surface-disturbing and other
in
disruptive activities™ (unquote) .
19
rt is unclear in the definition section whether
normal animal husbandry practices such as fence repair or
2]
construction, water development, or even grazing would be
■>,?,
considered a surface disturbing activity, and need to be
2:t
mi Ligated-
34
The Draft FTR disctiR.sas management for biological
2*.
diversity without providing baseline data as to what level
of bio-diversity the managers are going to manage tor, what
measurements will determine whether the BLM in successful or
unsuccessful 7 Is this a ride to the risen management goal?
The Draft ETS on page 35 say* that the Management
Objective for Livestock Grazing in to, "Improve forage
production and range condition to benefit livestock,
wildlife, wild horse? and watersheds." We find no
requirement that wildlife and wild horse management be used
to benefit livestock. Why? Indeed we find that in table 16
on page 176 the livestock MJMb will be reduced 43,850, or
aiound 35 percent. We question why this document tries to
mislead the public into believing the livestock grazing will
be managed to benefit livestock when it is apparent that
Wlldlil* and wild horses are the beneficiaries of these
reduced MJMs.
Wc find the document, leans h<>aviJy in favor of
recreation development with no clear indication as to what
recreation truly is.
In Table 2, rage 49, the document wants to (quote)
"enhance opportunities tor primitive recreation" (unquote! -
The 1990 State Comprehensive Outdoor Recreation Plan,
acronym is SCORP, suggests thai resident participation in
primitive recreation activities is stable to downward
trending , on page 33.
The Table 15, Assumption for Analysis by
547
i!Mti!lMmimHmtmmmvim>mviwuw
Alternative lor Recreation Management, page lfifi, also points
out the BXiM increased ramping by 85 percent, hiking by fil
percent, sightseei ng by 102 percent, at. our current estimated
levels. Again, the 1990 SCDRp donuBsnt states that
noticeable decreases in camping, sightseeing, ami picnicking
are noted.
The Draft EIS is inaccurate, incomplete, and
i nadt-tquate . Tt needs to tie withdrawn and redone. Vie hop*
these comments help. Thank you.
tAppl ause) .
MR. DANTELR: Thank you. Paul Galovich,
Thermo polls ■
PAUL OAT.nVICH: Thank you. I appreciate this
opportunity to nnwment. T do not have any prepared
tftm.KUtint to present, to you, although I would like, to go on
record that T was unable ro attend your meeting in
Thermnpolis back on the 21st. And again my name is Paul
Galovich and I reside in Hot Springs County. And I am just
an average everyday citizen residing in that, county.
And T wish to have go on the record that T aw
opposed to the present Grass Creek Draft EIS plan. There
have been a multiplicity of reasons that have heen stated
hare that I don't need to reiterate, that express ray
v i ewpoints.
There are a few things thai T would like to
162
1
request that you do and encourage you to do, and that is to
a
cater to the Hot Springs County Commissioners and other
3
county commissioners, and their recommendations and
4
proposals. And I hat is cons* i tut ional .
5
l also, through my utufly ot the EIS, l taa3
6
directly that it has a very strong environmental flavor to
7
it. And I wish to point out to you and all those present
ft
here the hypocrisy thai T see in the environmental
0
preservationist policy thai exists in our docility today.
in
directly in the United States of America.
1 1
It's my understanding llial environmental limits as
12
perspective of a global perspective and if you consider it.
13
in that regard being a global perspective, the most
1 4
regulated, and Hatched and monitored policies of resource
IS
use is found within the United Slates nl America. And
16
therefore those proponents of the environmental movement
17
should support resource use in America, should support
18
resource use in Wyoming, and not oppose it, because it. can
19
be regulated here.
20
I work in the oil industry. Oil spills and other
?.l
hazards are not even measured unti] they are possibly
22
hundreds or thousands of barrels. We're very well regulated
23
within this country.
24
philosophy or my opinion In regard to the environmental
163
1
movement, that it is a Hippocratic movement and they should
2
encourage resource use within this country, within the
3
state.
4
X want to let you know that I am a recreational
h
user, that 1 intensely use- the wonderful outdoors of Wyoming
fi
lor recreational purposes In hunting and fishing, and Ly me
7
that would be of no value if I didn't have an income or
ft
source of income to be able to go out and enjoy those
9
resources. T feel this will have a direct economic impact
10
within our counties, strid I would love to see you address
11
that issue more in mora detail as to ihe affect ol economic.
12
impact it will have on our counties and on our individual
11
families. Thank you.
14
MR. DANIELS) Thank you very much. Clara
15
YeLLer , Meetcctse.
18
CLARA YKTTER: Clara Vet-tar of MeeUetsc.
17
And I note on page 14, which has not been addi cssed today I
18
don't believe. Elimination of Timber Harvesting". "Possible
IS
elimination of a} 1 Vimbpr harvest 1 ny on public landn in I he
20
planning area was considered. However the 14,000 acr>>s of
21
BLM- administered forentl ands capable of sustaining forest
22
production need to be harvested over limb to maintain a
21
healthy, vigorous forest. Because f:re and, to an extent,
24
disease have been eliminated by human Influence, the
?.h
harvesting of forest products helps sustain the ecological
1<>4
1
processes that maintain the healthy condition of the forest.
?.
Finally, harvesting forest products is consistent with 3LM ' s
3
multiple use Management policy and closure to t:-iece
4
activititiH would be unreasonable and unnecessary." Vow you
•>
are singing my song.
6
For many years the Forest Service and T argued
7
about the necessity of harvesting timber, but they didn't
8
cing that song. And I think perhaps the reason that the
g
change has come about is Chat the timber industry is in its
10
death throws in this are.1!, and they are not of any concern.
11
There in very, very little timber harvesting, has nut been
12
[or some years. This is to me proof thar regardless ol who
13
writes these statements, these little bnnka , the intent is
14
to remove multiple use from the State of Wyoming- Thank
15
you.
16
(Applause) .
17
13
MP. DANIELS: Thank you. Don Uilbreath,
Heeteet.se.
19
dom gUj&reath: rhank yon. After reviewing
20
ill i y EIS it La clear tha: it i a en attack on tha culture arid
21
custom of the public ot the feet. I feel that the authors
22
of this Eis have Iom touch with reality. With the
33 1
Constraints writ-ton Into the EIS, our tax b«DC and
241
livelihoods will no longer be- viable. let v. move forward
2F-.I
wi ;.h pi ogr>.'SLi , nor retreat hark lo i tie Stone Age. We are
548
16 B
1
working with renewable resources in our grasslands and
3
forests. Our lossil fuela drp an accomplishment Ot
technology and progress.
The millions of pieces of paper this document is
5
written (ffl cams from our forests. To deliver these products
r>
to us, tin? consumer, was done by our fossil fuels. 'The fuel
B
tn heat this building, warm nur homes, build our highways,
and cook the food or on r table came from a major undertaking
9
by private enterprise. The major portion of our meat intake
10
came from our renewable grasslands. The excess water that
11
Mother Nature generously gives us, allows us to drink to
12
maintain life, cleanup ourselves, and see in the dark of
13
night. This water also lets us have recreation ami to
LI
preserve in our dams and reservoirs foe periods of shortage.
15
All these resources are what sustain our culture
16
and custom. Let's r.or make the way ot the progress and the
17
future extinct. Thesa resources help pay the bills. The
1 ft
oil, gas , and coal industry nays the major portion of the
19
taxes in thi s area of concern . If i i wa«n ' t for these
20
Industries, landowners and taxpayers, the tax burden would
21
22
be outraqeoiis. Our tourisa; and recreation industries would
not be able to support our conimuni t ley . Then the tatX llASB
23
would shift ro property owners with the farm and ranch
24
industry picking up the slack. Folks, you'rr killing our
25
communities and your jobs. Remember, "W» the people," ar«
still paying your wages. The ones that utilize the
resources also justify your jobs-
Some comments on sons of the proposed actions:
Air Quality. The EPA and 0F.Q already have laws in effect.
We do not. need any more federal control or agency involved.
Culture Paleontological and Natural History.
Preserve and protect okay, but don't lock the other
resources out. An area can be protected and its resources
utilized. By getting public access doesn't necessarily
preserve, with public access is Lhte BuM going to be
responsible for infringement on private property and state
rights? If public access is gotten, wouldn't that be the
best place for right-of-wavs since the disturbance is
already done? Why arc existing developments good for
history and research a/id new developments are condemned?
F-.re Management. It is a very good tool to help
protect the resources. We need to enhance fire management
and make it logical and economical. Timber production needs
to be maximized to help heal our forests and slash burned to
develop our forests to their potential for our wildlife and
ourselves, r.ne public. Presently the governmental
mismanagement ol our forest and grasslands are killing them
and our livelihood©. The forests need to be logged and then
cleansed by lire. The forest floors are dead and
unproductive, and dying of disease. The VellowBtonS fires
167
1
of '88 vara a disaster in one sense, but on the other Hide,
s
was the hesl thing that ever happened. From a standpoint of
a
common sense, logical thinking and economic*, it would have
j
been better to log the Yellowstone area first, then burn the
slash to htalp it heol and reproduce. Rut do it. over a
6
hundred year period, not Cive months. yes, we can work with
7
Mother Mature.
3
Federal Access. Why does the Rl.M want, to increase
Q
acces.i to one are.i and restrict it to others?
in
u
Land Ownership. 1 1 eel that there i s anough
federal control over private property. By acquiring more
i '?.
13
private property il will only be making big government a
larger public enemy. Don't lake private property and rights
14
away to make amends for past governmental failures.
15
Right-of-ways . Ma jor right-of-ways are along the
16
major routes because of common sense and economics.
17
Livestock Grazing Management. In the records on
18
page m there's 157,375 available MJMs- Let's not start
19
with a lower number and get our minds set on something
20
that's wrong. Wildlife and livestock are compatible, tut
21
bias studies by the RIM is not compatible. Key area studies
2-1
Cor utilization are very biased and a lazy man tool to prove
33
false statistics. An example would be 1,000 people eating a
21
meal and only 100 people- ate the meal or a portion of it.
25
But, these same 100 people all eat at one table and the
188
1
other <*00 didn't eat at other tables. But by key area
selection we go! RO to 90 percent utilization when ar.rually
there liksly wasn't a 10 percent usage. Yes, this his and
A
is being done. Trend cannot be determined in two to five
f,
years. Trend cannot be measured in time of federal
employees in resource area durations. Past studies have lo
1
be used along with the knowledge of the people that have
8
been on the ground for generations.
9
Oil and Gas. L«r';< not restrict the experts from
10
finding and developing our resources by new technology.
11
Remote areas can be developed by new techniques not used
12
five years ago. It can be done to protect the environment
13
and managed for the bettermant ot all concerned. It will
14
also develop access to public grounds. This cannot be done
15
as long as there is a no-surface occupancy and al3C time
16
limitations in nigh geological areas for oi) and gas. The
17
wildlife love the oil fields- I've worked in oil fields
18
today for twenty some years. I've lived tn an oil field mi-
10
whole life. And they raise and bear their young there all
2Q
the time and seem plum happy.
21
Wild Horses. Vcs, I love horses, but I also
22
manage them lik* the Wyoming Game and Fish manage the
23
wildlife. Jt I have too many or not enough feed, I sell
24
them t.o help protect tny land and improve my checkhook. 1
25
don ' t i ake another ' s rights away for my mismanagement . Come
549
on, folks, the wild horse overpopulation is a burden. Let's
manage thom and sell the exness to help the treasury and oar
taxes.
HpcrpatifJii. As long ds we have multiple use of
the puhlic ground we will have recreation, if wa starl
restricting rights, then nveryone will soon follow. This is
h tree country, let's keep the West free and under multiple
USD for rill to enjoy. Thank you.
(Applause) .
MR. DANIELS: Thank you, Matt Brown,
Thertnnpol i s.
MATT BROWN: The following are my comments on
the Grass Creek Resource Area Resource Management Plan Draft
Environmental Impact Statementi Ny name is Matt Brown. I
reside at Owl creek Route, Thermopolis, Wyoming, Eor the
past -13 years.
T appreciate I:Mr opportunity to comment on a
government document that will adversely direct my family and
conmunj ty.
i am the fourth generation of my family in grama
public lands in the Grass Crock Resource Area, and fen
provide stewardship of these lands.
1 believe in the multiple use of public lands. I
bel ieve that wildlife, recreation, minerals industry , and
livestock grazing can and do co-exist on public lands. Most
170
of my comments are tailored towards the livestock grazing
2
portion of this document.
3
-J
The Preferred Alternative Eor Livestock Grazing
Managem«nt is covered from page 35 through 42. I totally
disagree with the Preferred Alternative as it in written in
6
many areas.
7
Page 3fi . The level of actual livestock use would
9
not. exceed active preference- Current active preference is
9
101, -151 AUHfj. why waun't tela number part of your Appendix
0
n
3, Table 3-sv
Pegs 36. why wasn't there input from the
2
permit tea* before their allotments wore placed in the M.I.C.
13
na t.egories?
L4
Page 37. And I quote, "Authorised livestock
-5
giazing preference nay be reduced in areas with excessive
.6
soil erosion, poor vegetative condition, or as nece.ssati , to
7
provide forage Eor wildlife and wild horses, or to improve
8
the visual quality of tends with high recreational value."
Th i k paragraph should be stricken from the document because
to
■A
the First part ending with "vegetative condition," is
provided for in the pievious paragraph. The second part of
■:-'
trie paragraph unjustly restricts the multiple use of public
!3
land;), Live* took find wildlife have po-existed. and as a
M
livestock graT'.er, 1 dnn ' t think it is appropriate to cut
livestock numbers because someone has arbitrarily decided to
171
1
increase wildlife numbers, especially when this action will
3
adversely affect my right to use my deeded lands within
3
4
these allotments .
Page 37. Livestock grazing monitoring should be
done only on BLM lands within the allotment, not private
6
7
lands.
Payea 37. And j ti«otn, "tfhet-w pc«utEc;Hl, the
H
public tracts along the Big Horn River would be closed to
9
livestock grazing unless grazing is used as a method of
10
vegetative treatment." This paragraph should be removed
11
because it gives no foundation for this action and restricts
12
the multiple use of this public resource-
13
Page 38. And X quote, "BLM livestock grazing
H
permittees and other interested parties would implement
IS
management actions including the use of grazing systems,
10
land treatments, and range improvements." Thii paragraph
17
should stare the interested parties would participate i n
IS
decisions on BLM lands within the allotment only. This
19
paragraph should also state that, the qovernmenLH win
20
actively pursue funding for a.-rinns taken to develop grazing
21
systems, land treatments, and range improvements.
22
Page %$,, lut me state that T feel that fencing
23
wetiandu causes as many problems as it. was designed to
24
eliminate. Wetlands arc the most productive parts of a
25
range. If fencing is done, then adequate access to water
172
1
must be maintained.
2
Page 38. Ana I quote, "When prescribed fire or
3
mechanical treatments can be used effectively as techniques
4
for managing vegetation, they would be proTorrfid over
5
chemical spraying." There is no supporting documentation
6
for such d statement. This paragraph should be revised to
7
read that chemical spraying, fire, and mechanical treatments
8
are all effective techniques for managing vegetation* all
9
methods should be considered for each application.
10
Pages 39. And I quote, "Grazing strategies would
n
be designed to accommodate plant growth requirements of key-
12
vegetation species and their management objectives."
13
Grazing strategies should not be designed solely by Hoy
14
vegetative species and their management objectives. The
15
16
giazing needs and goals of the ranching enterprise should
also be a factor. Key vegetative plants should be used as
li
well as no-key plants- Historic uses and economic factors
18
should play a role in determining what is now the key
19
vegetation In each allotment.
20
Pages 39- Appendix 3 is mentioned as providing
21
applicable information on utilization data. These tables
22
overlook a very important point- Tc. utilization hascd on an
23
average use of the allotment? If not, who will determine
24
where utilization samples are taken?
Page «f) through 44, r strongly disagree with all
550
^/:''.,^_.;.:;^:^
171
1
of the Preferred Alternatives found on paq« 40 through 41.
7
i firmly ballave thai UvestocK and midlife can and do
1
exist an the same range*, Due to past grazing practices,
4
wildlife numbers have increased in an areas throughout -.he
5
Grass Creek Resource Management ^rea . Rather than recognize
6
thtH tiHnotll which wildlife ha3 teo«ivnrt from the livestock
7
industry, this document chose t o penalize the livestock
8
grazers by i educing their AUM utilization.
9
Page 42. Restrictions of use proposed by t he rim
10
or. vegetative treatment areas ls so financially hurdenr.ome
11
to 1 ive stock permi M r-es that a.i i practi ra 1 matter i t
12
eliminates this practice.
13
MR. DANIELS! Time* is basically up.
14
MATT BRnwN: Well, basioally, 1 think theVfi
IS
the- document, in closing, should be thoroughly reviewed and
LG
that the comments spoken hero tonight should be taken to
1?
heart. And I will submit the rest of my objections in this
18
written document. Thank you.
19
MR. DWIELS: Thank you very much.
20
(Applause) .
21
MR. DANIELS: Pv* been QOJftplaf flly through
27.
the signup list. Ts their anyone else here who has not
23
gotten an opportunity i.o speak that would like to do so?
74
JAY MATHEWS: My name is Jay Mathews and ray
25
wife and I have a ranch out here on Gooseberry Creek, and we
174
1
have Home signif -.cunt private holdings in the Fifteen Mile
-•■
k's t wrshed. I also hold gracing; privileges and spend much of
3
4
my time with my Hvflstonk in ! he North RonsehRrry arid South
ciooaeborry allotments, i point this oui as a frame of
5
raCaxence £u you will understand that unlike many of the
(.
comments yon will receive, mine are LMi-j*ri on real
7
familiarity and understanding ol what is actually going on
fi
9
out thare in the field.
I have reviewed th« RMP document and have several
1 Q
1?,
comments and serious questions that I would appreciate
answers EO. My observations relate exclusively to number
nni?, ACEC designations; two, grazing, livestock management
n
and range data; and three, economic assessment and data
.1.4
IB
analysis .
Table 3-5 is admittedly in error, and my question
Ifi
in what conclusions and other analysis were based upon these
17
erroneous data by BLM staff? Ts there a domino effect here
1?
that preiudicas other facets of this document? what credit
19
or analysis haw the BignU Leant amount h at non-use and range
20
management improvements over the past. ] :>, years made in this
11
RMP document?
22
On Table 8, on paqe 1X6, indicates livestock
23
grazing -represents the least detrimental impact of all iisps
24
in terms of soi 1 losses . Why La • h i :; acl.i v. ily then
25
considered to be one of the focal points of the RMP anc
ITS
1
specif Leal 1 y I he proposed ACEC designation?
2
The 35 percent AUM proposed reductions are
reportedly preference or paper AUMs and it. is suggested that
4
this win have no Impact; on ranching operation*. If this is
5
true, then where is the benefit to the ranqeland to make
6
7
these ad just mentis and tor that matter, why do it at. all? 1
suggest that there will he significant economic ef f acts tc
8
ranch values, collateral and hanking institutions, as wr> I |
9
as to the individual ranch families- This is what custom
1C
and culture are rually about.
11
Plwase explain what cannot be done in the Fifteen
12
Mile watershed with ACFC designation. Historically, the HIM
i:s
hat spent millions of dollars doing watershed improvements
14
In the Fifteen Mile watershed and to what avail? Have they
15
stemmed tha erosion and silt loads in the Biy Horn ltivnr? I
16
think not.. By tha way, how was all this accomplished
17
without, the benefit of LtB own ACEC designation? In reality
1 E
this is a geologic phenomena occurring over geologic time
1.9
and the Bl,M Li trying to blame the rancher for the problem.
20
I understand that the rtl,M intends to usa this designation as
21
a lever in Allotment Management plan negotiations yet to ba
22
inii.iai.ed against the gtazers in the North Gooseberry
21
34
a 1 ldtment .
I submit th.it the fcflRr designation is unnecessary
25
and i:; simply yet another labs] overlapping three wilderness
176
1
study areas and a host of other use restrictions which win
2
ultimately only high grade an admittedly otherwise sensitive
3
geologic area. The additional use to be expected as a
4
result, of more designation will likely create evsn more
5
impact from human use than currently exist from livestock.
6
Whore is the plan to implement this ACEC and what axe the
7
costs and impacts going to be identified? Let's 3hov all
a
the cards now before we get into another expensive
9
boondoggle that accomplishes nothing. I also have a
10
significant private holdings within the Fifteen Mile
11
watershed and neither I or my neighbors have beer, consulted
13
on this. T;. is simply someone's dream either come too soon
13
or too late, but not now.
14
On pages 74 and 75, alternatives A and B piopose
15
no hC.SC, yet. ELM Indicates the same prescriptions aw ;n Lhe
16
Preferred Alternative.. Why designate it at all then? If
17
Fifteen Mile watershed is really a sensitive riparian are-?,
li!
then why of all I tr. nqs are we proposinq exfiansion cl the
19
wild home rimri and numbers in the watershed?
sta
21
In conclusion, t have Deen proposing to exchange
my private lands in Fifteen Mile for yaars. It would seem
■?:?.
logical and prudent to deal with this proposal hefore
33
imposing your designations on me, or at least discuss this
option in the land tenure adjustment portion of the ETS.
25
Please define what ORVs are in the context of your
551
ajT«a*M«M» ■ || IMIiil i .
1.77
1
proposal . ti. would bf banaf Ini al if the explanation w«ra in
2
3
plain English and not cfta bureaucratic jargon in the rmp.
Regarding the sconomic analysis, T find the
4
nuabflrn projer.tad unbelii>v^h1p. Billions of rtollaru to tna
ft
planning area in the next nine years l« pret.ly hard to
h
swullo*. Where arc these impacts addrftssfid? Thank you for
7
the opportunity to comment -
8
(Applause) .
9
MR. DANIELS: Are there any nthsr^ that would
in
1 i k« l,o Riwdk tonight? If not, 1 thank all or you
11
part 1ci pants tor cominq out tonight and staying with us
12
through all of thie. it'n bean a '-onq avoning and the
13
hwarlnq is now adjourned.
LI
toi f iiu- record aft i-.z*, p.m.)
15
16
17
1R
19
20
21
22
23
24
as
BIG HORN COUNTY
178
REPORTER'S CERTIFICATE
3
STATE OF WYOMING )
] ss:
4
COUNTY OF WASHAKIE )
5
T, Shhrvi h. Gonzalez, a Registered
6
Professional Reporter, do hereby cttrtify that I was the
7
Substitute Reporter, who at tha time shown in the aforesaid
a
transcript , took and transcri bed i,h* foregoing proceed inoa -
9
.irid I certify the same to be true and correct.
10
IN TESTIMOWY WHEREOF, T have hereunto set ny
11
hand at Worland, Wyoming, this ISth day of April, 1995.
i a
13
14
lb
/I |
16
'-. -■/ot^j. S/ J^yot-^lU
' RANEE L. Q0KSRLEZ, V-PR
17
, J
1$
13
2.0
31
22
23
24
>:■>
SUPPLEMENT TO PUBLIC HEARING
TESTIMONY BY RAY PETERSON
This packet contains
Big Horn County Commissioners Response
Big Horn County Land and Planning Concerns
Letter from Commissioner Charles Monk
552
DIG NORM COUNTY COMMISSIONERS
April3,l995
BLM
Attn Bob Ross Team Leader
PO Box 119
WoriandWy. 82401
Re. Grass Creek Resource Management Plan.
Big Horn County Commissioners submit the following concerns
In the document,
1. Land ownership Adjustments, Page 31. Waste management, we hope ihc 1,220 acres will help
in future expansion needs Last year BLM policy cost Big Horn County uver 100,000 dollars
having to purchase private ground. There is no excuse for any Federal agency not lo assist with
local needs. We u a county don't have ihc choice of not having to deal with the waste and EPA il
would be nice to have your assistance in these land matters nest time around. The wording
"would be considered" has us concerned
2 Page 33 "16,000 acres of privately owned land" Our county land use policy states "0% gain
of federally managed lands in Big Horn County." We can'l afford any more "Federal land."
3 Page 34. Rights of Way. "Adverse effects on scenic value. .." This needs morejustification.
To sacrifice economies and lifestyles so the area will look good to the tourist driving through is
not a good enough reason.
4. Page 35 "Mineral withdrawal" Where along the Big Horn River? We need specific locations.
5. Page 37. "Public land tracts along (he Big Horn river would be closed,,,
specific locations
Where? We need
6. Proposed AUM reductions total nearly 60,000 This means nearly 5 million dollars in lost
revenue and nearly 200 jobs. These arc real figures that will directly effect the lifestyles of the
people of the four county area. The promise of assumed, projected increase in tourism to replace
this lost revenue does not convince Big Horn County residents According to your figures, it
would take 7l,22G^Mt increase of total visitor days to replace just the grazing dollars lost We
haven't even talked about the loss of oil and mineral revenue yet Also, This increase in tourism
usage must be outside visitor use Local use will not add any money to our local economics as
the grazing and oil moneys do. To project a 32% increase in tourism is just a pic in the sky
estimate made to offset the loss of real dollars of reduction of oil and grazing. Big Horn County
history proves the point that tourism will never replace the ag economy that was lost in the
Yellowt&il area. Thirty years later, the tourism hasn't happened and we are still recovering from
the loss of economy
7. Page46. "The sale of sand and gravel..." How far away from the rivers? What areas7 We
need a specific idea on this. Will this effect any current active selling areas?
8 Page 66. Wild Horse management "The herd area would be increased by about 3 1 ,400
acres..." This will make two wild horse ranges in Big Horn County Doweneedtwu? Are these
actually wild horses of the Spanish breed such as the Pryor Mountain kind? The reasons for
enlarging the herd? Does the current number of horses require the additional area? We are
opposed to enlarging the range based on a desire to enlarge the herd
9 Page 67
this mean''
"November through March sheep use. " What change over present controls would
10 Page 67 "Some cattle use would be allowed
what this means to the individual cattle users in ou
" What is some'' We need specific ideas o
county.
II. Page68. "On the 31,400 acres added to the herd area...
What decrease would it be in this area''
What are the present ATMs
12 Page 71. Wildlife habitat "Along the Bighorn and Greyhull rivers. ." "As one measure "
Arc there more measures? Is firewood harvesting permitted in these areas now"? How would this
effect our Big Horn County residents''
13, Page 72. "Fences would be constructed..." Where? Again we need specific areas or an idea
of proposed fencing. We need to know how this will effect our local ranchers, farmers, access,
etc.. in Big Horn County..
Concerns of Economic study done for BLM.
Recreation, If we are to compare tourism dollars to replace oil, gas minerals and grazing dollars
lost then wc must throw out all resident usage. These are not new incoming dollars. These
dollars do not contribute to our valuation, schools and services as the oils and grazing dollars do
You're forecast for outside tourism increasing is overly exaggerated1
Agriculture; 1990 was a poor base year to use. The study should have taken a composite of a
number of years in a five or ten year period. We need solid figures to judge by The economical
impact that these reductions will have will threaten our ranchers and farmer's industry as (hey will
be forced to reduce their herd size, some will even be forced out of the business all together.
This will not help our already decreasing valuation In order for this plan to be complete it has to
address each county individually as to the effects that each of these reductions and added controls
will have on each county. Big Horn County is requesting these figures
Oil and Mineral; This area is very frightening to Counties that realize nearly 80% or more of the
county valuation is based on this industry alone. Unless this plan addresses these concerns and
reverses the current trend to decrease this industry on public lands, this plan will not stand or
accepted by Big Horn County
These are a few of the areas we as Big Horn County commissioners are concerned with With
Federal agencies controlling over 80% of our county and the current trend to accommodate the
environmentalists and tourists we arc afraid that our way of life and very existence in this area is
being threatened. When our input is considered on the same level as input from anyone else from
anywhere else. It concerns us as to how valid our input is and to what control wc have ovct our
own lands and lives. Tourism will never pay the bills in Wyoming. Our economy is diversified
and must remain so. To put unreasonable controls on the very industries thai contribute to our
lifestyles and economy for the purpose of making the drive to Yellowstone more scenic for the
tourist driving through is nonsense Your agency controls nearly 70% ofour county. YOU must
help us preserve our lands and our lifestyles without sacri6cing the economy of the people you
serve.
Until we see these suggested changes made to this plan and the report requested of how these
proposed changes will effect Big Horn County alone, we stand against this document and suggest
you file it right next to the Rangeland reform idea.
EL Ray Peterson
Big Horn County Commissioner
EVALUATION OF GRASS CHEEK RESOURCE AREA
DRAFT ENVIRONMENTAL IMPACT STATEMENT
20 MARCH 1995
PAGE 36 2nd paragraph
The current amounts, kinds, and seasons
of livestock grazing use would continue
to be authorized
The 1994 amounts, kinds
HAP 20 why is the area used for wild horse management: going to
be increased?
MAP 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 BLM doing to cause this decrease?
PAGE ISO 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 ELM gra2ing in cur area?
PAGE 131 SOCIOECONOMICS RECREATION What is going to increase the
value of recreation on BLM land by 3 million and the local area
by 13 million dollars? Is there a program out there? How many
tourists does this equate to? Where are they coming from and
where are they going to stay?
PAGE 183 WILD HORSES I don't see anything in 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 I'm even more confused about expanding the range.
553
SUPPLEMENT TO PUBLIC HEARING
TESTIMONY BY JAY MOODY
PARK COUNTY
Crass Creek Resource Area
Task Force Comments on Draft E1S
March 2H, 1995
would be applied, and when anC how it
Tabic 2 - Comparison of Alt* rnalivcs
AirQimlilj- MnnflEemcnli
GENERAL - Information is needed on what diisi conrrol it
would affect new arid ousting uses.
SPRCIPIC -- 'Air quality standards pa tunumwt! bv tin- Wyoming HFO. I Sec the Affecta! Environment
L-.hipfpr lor these Standards . At quality permits would lie obtained imin fl-Q he-fore pres,gih'.'d Hiw are sqr on
imiij," Brush'innbei pie* iMnKKlimeiii should be allowed to bt controlled by means of hurouij;. and should rrni he
limited by smoke pollution riscr.etiors. fin mvH be Itfi as a management tool
"Pus: control ricusijes lo reduce sisibi.itv impacts would be iq:ui;cJ for all construction iiDd.Oth.cr
sorluce-d,isp,ii hir.r- acrivitic." Under what conoinntis would mitigation be necessary'-" Hii* needs lo be more clwiilj
identified, and no evaluation oi'rnvs and benefit! should he included.
Cultural. Pukonlolordcnl. ami Nalural History Resoim-i-s Mmimiei.ifiHl;
lilt purpose would he In improve knowledge i-l die historic siun.fiiVHfi- " P r rn- li- ds an.) lacililnlc Ihe BpprfiV.il of
tutmc development ar.d rcela-ration aclivilics The following fields woald be included: H mil lion Pome. Crass
f'rerk. anil Cebo." Does review nr'the hi.stnne aspects of fields restrict then use'.' Idem ideation is not B problem if
there is nu associated restriction. There have been requests to the RI.M for more inform ;u ion about what Is
im|-H>rh»ni and the restrictions imposed, but (hart hu tuen no response. Alto, some of the historicnl resources have
already boon moved trom seme of these sites. Mid foundations are all thai remain
Fjrr, Mwii:tgrnifnt:
GENERAL -- The piar it calling Fw good tire management, hul ihis is net followed through, Irtslcu: of
business w iwuai, there should be deiadi including data nu acreage, where lire will he p-escribcd for specific plant
communities, fuel load, and a timetable fur burning, There should be t f»Mrc relation* section with education M
part of dw goal. There should besoaie discussion to lend to uiidcisiaudinij of the importance of fl« managanwnti
rear Arnold no! be part of the plan Vote ficreopc should be prescribed in Ih; fire mLragctr.cnt section with on
annual pflrttentaaa tarj-er. Tirr.rs lot) people are chunking, >■ is belter to manage tiirough lire than lo caungc the plan
arid CUt allotments betialltt of Ihe political risks.
ornriv>itel.in^.properri'..eiiBiiiidoilfidJii, imnorlnnl riparian habitat orhiiman life" Is 0.25 mile or any fixed
distance adequate in A!.!, case*?
•ic.i.es." Is full rappntwion to protect private land?
landowners as possible lo allow ;ire as a management opi
suppression.
"The (ira..s BWtJt Bjtfflttg flUa Eits jflflBJKttfflal pt;t" MtgttMJa
am? lmpJemeiik-tl. 11 n: nLin w'.mlil address ceolnficiil areas far tire m;nii:i;e:rient based on lire eieolfJgy_sctl.dJk.s.ailll
would tjabUtti desired plum comiTiLfiiv and ufldjam VQtk thai BBIMH btetegiea} dJ
■lit loiuls. uomntising aboot 219.800
DLM should Uy tu gel prc-ayLCUients with Hi many
i In Unit way, wild fire would he subject lo only limited
revised. M necessary.
i. The plan would a
iuliliess soecfif appliranops rS nrcscnjed fire M meet resource iihieelives " This plan is essential lo good
manapemenl of ice land. The conditions tor lire mAnflfernenr need to he fleshed out and defined, and Ihe effctls
identified as well m deftKitlfi die bum cycle. An ccolojiicaJ plan lor the re-souree area with Uetails and concepts of
uk management should be let up as poor management leads to erowcfl, etc. ts [he present olan really based on a
1WX) year bum tytle? l.slhepuhlu. limiling gw>d misna^emeni so u ten to u lifiy-jtair t>clc etnrot be promoted .'
Thc*c issues need to be addressed
•ftlien prisssTibed. [ire or nifL-hanif-al rrfamrn;.^ c-vi ht uswl «rfcrTi»f lv ,v. nrhniqn^ -or jTianagrng
wetmHlon. t^gv, woi;IH ha prtiVrcd over chemical spraying." Tills st-itcmont is .supported and should be retnir.sd
:\punded upon.
Fnrcstlanrl M.inapewpnt;
SPT.rinC - '_'MANACi:MENT OBJECnVf: Mainia r and Mhanre ihfi iealih proriortiyip mj
provided lo piCKUliUid.fLl.1lll.C aenejaiivKs, Tjv n-.iicjgcrrn'n: of forest it-d woodland rCM^.i-res w,h]1<j lie tonM.ityni
wilh eeosv:;le:n iTiarmiiertitiil niineioip." "Ecsvsysieni iiianagciiienl principles" need lo be defined Cleareut
objectives need to be defined better ab well as the visual breakup in cleareul areas. Alteraai.ve "13" is '.oo UHU6.
ALT£RMA I'lVB "<-'■" ■■ IHsad coastr^ction tor hars ettint' timber or lor |;»nd,uciiTvj ■oresi m an a cement
practices ww'.c oe rrobibi'rd nn slnprs i;tea:r- tb^n llnercen;.! Is there i conllici berween Liis acron and the
f oreai Service?
"Severely nistleiot- infested s-nitl-i wnidd rn-.-l-nrt-i: while slaeiuiled, and overaiocksd pcle Urnber slaiUs
woilc be aftaaflJOjua bi y vhancc ua mcv gaiHaaeaJ alih Bmjai gBBaafe and ctodaa gjldfia thermal
■•rivf;r '' Is Ihe fiisi part flf fhla slalernen'. refcrrri; in svmd staf-nated'.1 This needs to be clarified.
"fJver-jlnq-fcl Morillnf. sanlinfi .ir.d pole stands would he preenmmtirciallv thinneii pj up in WOO acres to
included here? This is in conllici with the objective
"AH harvest areas Would be reeer.eia-.ee bv natural or nnirtainl menus If n the rnri r,t -1rVr *nr, my
fJBtSUJ ar« taik to rcecn^ratc naturalK. plnnrint- and flftfl ngdu..!s ayflllld bfl tHtcl IB assure refene-.ni.in i in !,■■■.
cQuvenirifr IQtfif ttSflM to another type isjfaj nMeertva." fhere is a need tn define and specify what is bein>; dnne
with aspens.
acres! in an\ J.rcciinn Wildlife esi.ipe rnver would be nvnaincil bv kerning e ci-mdo- ol -.'nber a-o.md. g rjfl
Wit W irc^c ^idc s>f. re-ads, ckartub. parks, w-jiiamis. and gaflaa Trees and siurjs woiiid lot be cm if rhps_
provide jinprirrani hnhimi for eavity or snag-nestinij wildlife " Wiiy i.s this limited to no more than 1 5 acres'
separate llraiti here, iw ynoa u
■ desen water\vjvs and the l.tiflhpni ii
;d GrevbuM Rivers would be prohibucJ."
iipen stands, regenerate old .ice fores: <tanris msn^e^ |
;sirf..'. ilief.rssion.il sla^s ,unl forcsl specie:; i-.TiipoMlioti. anj rrl-a'-'dnatc. harsea ,'.rfn ' "able I Q does not
■onole reyeiieratiun and conversion of old aitc (oKSH. The rjMtute aud OVW maiure stand is ences-sive, ^nd does
11 support this objective Numbers should be includcc m show atrua>tc to be treated, and how this :s related lo elk
id deer habitat objective*,
undsand Realty Mana^invnl |
CiPNCHAL •• A prioniy should be i
i he clearly defined as to where public
SPECIFIC-
identify private lands affected by access to public lands. These in
need to he clearly defined as to where public access occurs or is lo occur for planning purposes.
en acj/.n-sition of access to public lands BJJ thp )3; shorn jncj
Crevhull Rivers to enhance rccrcfltisaa. Qjrjo.Ttiriiies and wiidlifc WW&W& 1"nc «««• s'.ies should be
careful ly phinned and weL defined. Tins public needs it> be educated on die importance and value of access.
upper QaiflBBUBd t-'fcct,. and upper Soi-.M: Y.y '■, »f n» ; C^.-V ■-■■!» oi'ihc.Absai.oka Mogutam foothills r„.nK
'VOL: J be 111 Koyije vehk:le.a.CLesj.:n_ih^ y-o'Jth r'orl, '■;" '?w| Crs-Cs L'j improve fi sti in j.' au.1 nihrr r^rreatmnnl
tinoof.-anil if >. and to aenuiiv lo.n imd bjaCKtlBt USBB tfl '!'c Shostiniie Nntmnal forest. AM .i.ce.j would he In
meed lobe ideiinfied rr
ijeasonalh and .o .pe- t'n Teles as appropriate ,] The taijwt a;
specifically.
"Access lp srrtfifk areas mat be clow J or restrn-ted to pn.ieel public heaitn and su'erv and sii;nifi
fraailc MJUHUtCi,'; When, wficrc, and undor what eondilmns llns would apply needs to he specified.
t.unduwnership Adjustments:
SPLCIRC - "Agricultural m-spass r|n ri|h|ic |^nr| wfm|ri Efn.-rii|lv p.» :wnlv^l 1,x
unauiiiorir-vfl use, however, landsa'r-r.rlr-a^^eoi.i.i n»olye agricultural tres
BBJ to develop thr tends B Bflflia '>-1 ami Covei iueas, AjjiicuJi
afirmi BLM land in agiicullutid trespass should be eviiiuatcd to determine the historical uses of that land, ni
laud bus been lii>tonciUly used fur agriculture, it should be protected (an alternative should he provided to r.
the use), huruiennore. the lands in question should be identified spaci ileal ly.
••AKJlirailfjn.'i.ira.difivn.land cnrji,- on public kinds would not he e .nns'rlf rad Public land-, hjajjtf
nmtowLsBWBal mi ^r.r. WHlts! K conMckred for disposal oils hv sale [ggBBhjiBB " 1'he first stateiv
would be changuis ihe law through the plan, and should bo withdrawn lbs second statement is unclear as t.
" ADPmxinwIv n 700 ai.i- or pnhlic lands llial afe difficult or ■■neeonojl
r f.i- piililk
to nnotbrr si-encv tlrh^r proposals for these.
-^„...,.,,,.,v,,w,,„MjBj^fyl^JUWfluJll
lie. Recreation and 1'Liblic Purpose Ar< ie.-*- eg n.ilcnl. cxchim^R. nrrroinfer
r any other public lands ,n [fa
" How arc lands lo be dispersed? i
illt would.be pursucyjin
planning arf-a.^-rmlJ also be considered oi
plan is needed. What will be done alwul access issues?
about IS.OOfl acres of nrisaielv-oivneJ i:n:d " Why i'i there such a focus oi
Rights u/Wpy:
SPBCIFTC -- IMbj,; s'f'hc $mW KM B&M be Bpgfl forriaht.t-or-ivav desL-lupinciii. Pronusals would
he adpresscd OR an.ind)vidual baits with einnhiisis on avoidim- certain conPiri o- scrsnive arr^s," What enacily is
meunl by "most" of thepla.ining area''
Withdrawals:
tsdenninated and the lam:.-; would he- rcnimrd to
JISS^. How would this affect lucul Boveriunenl? How can the government chsnue
the lr»\s wirhiu an l-IS or MmirU
if Plan"
Liveslocjt Crawiit Mmapwail:
liBNBRAL -- This section should have at lcu.ii. three t mh|r; alternatives ■■ much of this section is |hl nnu
Lhrou^himt ("Sume us Prelerred. j One possible alternative proviced by be Meeteetse Conservaiion Distriol is
"Coordlnawd Kcsource Management" (CRM). which was noi considered in ihe rtrafi The point was raised diai
(RM is manapement inrensive. lairtety untested, and has received some iitaative reports (ulthougtl niinimali in
Rnnyxlunth- II was coontered thai CIRM has worked well overall, and the BLM has used it in other area.s.
Ii was requested that a copy of the Conservation District's Lunti (_'«■ Plan be included with the county's
comments. I lolistic Iseiource Managerrieo! should ai least he included as an alternative oil an experimental basis --
most would like it as a viable alternative.
There was a concern with die cut ir. the AUMx. h.very effort should he made :n keep ranching, viable,
diererore, liolistit lesource management needs to be looked uL Ti tan he upphcd to Other areas as well, such as
limbering. Il wits pointed out thni elk follosv areas of livestock grazing so thai livestock is beneficial lo wildlife
habitat,
There are no comments In the document thai lliis area is in a serious deterioration mode. If it is not in
uetcrioraiiou. where is the rusiifirmion for cutting livestock grazing',' Then seems to he a hidden agenda to decrease
livestock grazing The ecocomfc unpavt of doing w has nol been fully eoasidcrcd.
Die piefcnvi: ..hell m live seems to be seared to increasuie, wildlife without serious discussion with Ihe
tiatnejnd!-i.shIJepartmcttt. fhere is concern that the area will not maintain the objective of the wildlife numbers
set forth, I'mjecuons- should h= included tor all game, and wildlife and livestock AliMs should be allocated
flccordinglv. Overall, reduction* should he done on a percentage, baits, instead ofllwatoek beinji GUI for wildlife
OBNfiRAL - Some resrrictions should be ruwvad as i
OrNRRAL - There is noiliing thai deals with signing or enforcement. Areas for off-road vehicle use need
[earer denanattoo, Are there any allowinow for handicapped access?
ECfftC ■- Jaifeliejandi near phegD MflBfltajq, Red 3une. Unbent I Vaw Itadlan.ls and ric unne: pan of.
liir Smith EaA oi'Qy] Crack (abau'. 52.460 acres' woaid t= m.maeeil as ejpafj m on v m „ntj| acrivitv BJmnJn
iEec.'i'Ca.lls addresses scmcle we m these urcii.s." How njeh tjnc is needed for activi-y plsmttalfj? .Should the
LUlllllliVlU;
mil;; ac;iv:l; pjajmimj awiyi fieri IK- addresses rhmr use " Ranciiers sonietinies rely on snowmubilc travel. The
prolection of crucial winter range should be specifically addressed. Game and fish needs to have specific stm
SPECIFIC
Paamill fef Bi*^*rvat'lon and in lerprei
Ik town of Gcbo and adjacent eonl mimni,; areas on public land would he
^.MaiiULiciiicnt could include acting [Jfca
ftoojflffinml "fun -Titemrctivc road loop or mmlsidr ttimoiH," This should be ad|U:
rcsrr.enons or. -Jie eadning iJebo Field.
'-A Koalt tine-p-r.ivs- road loW wojlj is. developed in ihe Badlands area. This could include »V
E^BaumJc l,_rcek. noiy- OitY jjII'J.Vl'IP i.'-jL. at.J -\r. 'jvcr.ook tit tainted fanyoir " A cosl-benelil analysis
should be done before taking union on Fifteeumilc Creek as there is forty to filly miles of road alone the stream
oed, This section eresten » possible conflict with the Off-Road Vehicle M«n Element goals in that it would tend to
increase off-road use. There should be a map included showing the proposed roads It was suggested thai the
Fiftveamile Creek proposal should be eliminated as counter-productive. However, it was also staled thiitifmorc
details w ere pi ovided, there might he an overall economic henefit oficcreHlioi! dolhus.
••DevelPPmeni of il camperpund would he nursued gtU Wvominy I2t\ aid i iooseocfrv Creek," here again
nwwt dotal!* ir« needed The specifics on how large of a campground would be pursued, and iis effecb on the
surrounding area should be included,
"TfuiUrcHds. dm use amis, tind other rccrcEtional sues would hj avnid«ri.-f aj
o the grazing
n't exclude
— LfliE&sBaiiaialitM
m^.aa.^iF,.,.-,-.w. ,,-^l'-rjrnej]Lolri:;:re;;ii,,r..: [;i.:,.:in-. wt.clu , .■[ :»■ i.-.-mded." This ststcment puts one resource
ah.ead of others without supporting information
Ye£-eii*-lJ«fi U anacfjncjLt ;
GOKERAL -- Then is no DPC for llvenoch, but it was pointed nut that this would fail in
section. Ecosystem maiiae.enieni objectives do not include domestic and non-native species, and c;
existing uses. It has been ;;hown that if a plan concentrates on one species, the overall produrriviry of the area
decreases. However, there was some concern thai this draft is managing for wildlife specifically. "
Wild turkeys are not mentioned, 'fhere is a question if they esist in the area, mid if so.'if thev should be
mentioned ;r -Jus and/or ether sections.
Candidate an J T&E Plants:
SPECIFIC - "IhiliJLM would ajtici3iUcw:l-ii.lcNflnireCons°rvnnev II g QejjflafiflUhtflUUMgto '
F^'i a"ii.Sms1lifc SwrvKf frVVSl. and Olhtr3i2fl»-ic- n ih,- evjlu.Hrrm of .ire-.v. for i'!- ■-...^■,ti..i n .-.rT-,rb,it nf
aruteeledplant specie* g) m M-admhvj^ref),)aiaf|t," Tbis shouhl be more cpecific. For instance, a species list of
plants would be nice, fhc other agencies should Include the Forest Service Research Lab fjacotkoed by name), the
nniure Conscrvancv sliouldn't be sineled out as Lie only private eniilv
-e Conservancy shouldn't be singled o
iVrM/eju Weeds:
SPECIFIC - •llonirol of noxious
BBJ tad l If herbicides nr<- nmnnsrd fty use, tlmse with r
I hjajfjajeaj i
•'xicilyto wr.rllil" :;-jjj .; i ->i -.vr.1: M he saleotrtl As
"m^ii',^hu!leL^^es;1s1HildlK.^Iv;ki^J!ollUMre:im.^nv<;r;. Uikvs . mo riparian jreas. includins lipra.ian urens
Blgjtg crrhctncral and inlcrmtrtcni streans " tirarmf si- mild be listed us one of the couiiul loothods.
554
GENERAL -- Some restrictions should be removed a
m commons on tabic 3
I Areas fur off-rcutd vehicle use
U IT-HO ad Vehicle Man nee men I:
GFNF.RAI. - Tim is nothing thai deals With si_nm_ n
a dram decgnalion. Are there any allowance for handicapped
SPECIFIC - ^pjjMicJ30jfcjQSiUL£hcQ»Mojui
(|a South Fork of Owl Creek (about 52.4fn) acres) wj Id re ni.inar-ed as ci.ncd to QHV use until acrivify
^enlit/idlv address vehicle ust m ihese urm_,"Hi
be closed the entire planning time'.' It seems in be a Inyo area
JsiWQjJd.bc subject to the HUM 0»
utb tirav is needed hr ?j
y planning? Should the ana
mlLgha _b_____
i, i:i.; .(f.ii ty pla;nir,£ svcufiwilry iiddiOjCj ih.cif use." Ranchers >e>n:ei:i:ie-i rely jii iiuwmuiiik travel. The
protection of crucial winmr range should be specifically lytdressed. Game and I- 1 nli needs in have specific Studies to
determine if a problem exists.
BtflBMJOl Management:
SPEClFiC -■ "l'i.iitiL';L:njf i:ie lowr, '■:" --ff ho and jdiLiL-:nt u;al nin.r.j' areas nil puhliL land would tic
ny^a^d tor preservation and imernrulation cj culiur.il ami hisjorn, fflfaJB, Mitnajjcmcnl could include actions like
development nt an lnlemrcLivc rond loop or nndsidi- nimont." This should be adjusted SO U not to cause nny
restrictions or the existing Gebo Field.
"A scenic iote-prctivc ro:iJ loop wM be developed in :he Badlands area. This could include the
Eyhmaflt CffigL ttoa Creek, und Qtjgr, tank, and an. overlook ^ Pnii;led Canyon " A COSI-bonelit analysis
should be done before takinp action ja riftcenmiie Creek as there is forty to fifty miles ofrmd along the nmin
Dcd. This section crento » possible conflict with the Ofl-Rowl Vehicle Management goals in that It would tend to
increase oft'-road use. There should be a miip included showing the proposed roads It was suggested that the
F if. eta mile Creek proposal should be eliminated as counter productive. However, t! was also stated that if more
details wan ptovided. ihcre mijjit be an overs J ccDnoieii benefit of red en I ion dollars.
"Hevcinnmeni of a campground would be pursuer! nca- Wyoming 120 and t ionschcrrv Creek."
. i.VjZc '.:
campground would be pursued, and its effects i
ailrnind-:. (biv use areas, and other n-crcaTimi.il sues would hf avoidance areas for surface-iliMurhine
e details are needed Tile specifies
uunilin? area should be included.
:ilitics would rot ix avoided." This stale!
litis prn ejilp t . re e re annual t;
ahead ot others without supportive. infrrmation.
Vegetation Manaf.eiiteni;
GENERAL - There is no DPC for livestock, bui ii was pointed out that this would full inio the graying
Motion. Rcosystem management objectives do not include domestic and non-native species, and can't exclude
tiriMir.p uses It has been shown that if a plan concentrates on one species, the overall productivity of the area
decreases. However, there was some concern that this draft is managing for wildlife specifically.
Wild turkeys we not mentioned. Than is a question if they eiist in the aica, and if so, if they should be
mentioned in this and/or other sections.
Candidate and TAF Plants:
SPECIFIC- - " The HI M wmilfl narticinn^ w-n i-f Nsmre Consprvancv -I i S. I tepamnent of thr Intenoi
Fish and Wildlife Iservirf fFWSl and nthfr agencies |fl ihe evalnaiior i>; mgg fnr \h> potential transplanl of
,i;i.ili, .(;■ I jii.un species on Rl.M .ulmini'ijerot IjidjIC This Jhoulu be aiore specific, for inslancc, <\ species list of
plants would be nice, fhc oilui lujonclai sbuuld uiclude the Forest Service RcscBrch Lab (nicmiouud by narov). l'hc
nttlare Conservancy shouldn-! be singled out as the only private entity
/Vp.jjoHi Weed*:
SPECIFIC • ■■Control nf nnx ions Wrtrk mnv inc'tire nunna:. mrrVar-r:,!' h:uloeic;Ll. ur chemical
mflhafa lfh,Tbind,-s aa rmiKn-d gg m Baa Bffll mio'mnrr: :o\icirv 10 wildlife and fish would he selected As
piiaU' ..buffer l
Biota.
■S wr»nlri he provided jtliine streams, rivers. Lakes •■■I'.c riparian areas _incli>rf.injj_cipnULUl metis
timii'ieiu HtrcHmH." fjntiint; should be listed as one of the control methods.
Dclired Plant Community tDK) Objective - Stanford Objective:
ObNEKAL - The format used for the plant communities is insufficient. Key species should be identified
in each group, and (Uftliet broken ckjwn hy the >;pef ie^ Furthermore, it should be demonstrated dun a desired plant
coinmiiiiity c.in exist in (nc area. Otherwise. manas;emcnl is focused on nonie thing that can't be done
Wuli wildiite. there is a queniior. on how emeus! winter habitni is d«ermined Is crucial hithi>ja based un
■sight iujts. observaiions Ot p.ant species, protection from the wcmw weather, or whit? This should be mid: clear
Also, the wildlife part of this section should be figured I o an AUM basis.
DPC Objectives for Fvrestlands:
SPECIFIC -- "Desired Plant Conmuriilv I'ihiertivf Manarje Kt)% nfforcslluncls fi-r h;dinfl Md ihtrtlial
cover t<iro .if these stands would have thermal aiser cliiirMCieristicl^LsiU'crcefij oJ.lbe l7eraLla"J) wpulo be
map"'}''" lot old KiQ"ih '" A oc'iniiicrn is needed for "'hid-.r.g and thermal euver". Also, there is a problem with the
definition of "old growth" How mucti mature and over muture arowth is there in the old growth areas now1 Once,
rhR proper dofini'ion or old yowih U determined, it oeerls 10 be figured whs! perceiltafte of old yowth currently
enists. and wltat ts desired
QFC Objective /or Moose Silnler Range:
GENERAL The moose habitat is not defined very clearly. It seems in be icstncted to stream bottoms in
the winter lime, and neglects the fact that vee.etaL.nr. on the slopes of the muunliinsidei is vfry imporanl also.
DM' Objectives for Moate Calving Hahtiat:
SPECIFIC -- "1'Jesired P'.jjii f .Mr.munitv QbjaffllB; Mi.<eJ ^nntflwn«iieiupc< Lt.mniunilics, IftcreKe
atrpge ofiisrien sLuida where fea=;h c. Ruarian Co-nmunitiev Maximi/e shrub iinti dtciduous Lgg MstalipiL"
Also, there is a uced to take bto acecunr tne ncn-npunjo areas, such as the mountain slopes mentioccd above.
DPC Objectives for Mule Deer Winter Range:
GENERAL-- The crucial wlntR runye fur mule deer needs to be better defined, Map M seeinsto irtdJcata
thore is a great dea! ot crucial winter habitat. Is all of this actually used by mule deer, or is it just based on
conditions.
DrC Objectives fin Prnng/iorn AnieAnne H inter Range:
GENERAL - Tha crucial winter habitat is mainly or. the east side of die highway The highway fencing
has cut into their migration routes
rtPC Obleclives fur Sage Crease Vesting Habitat:
GENERAL - A lot of available information was ft* used in this section, the species is on trouble because
of a lack ofdecaden: wee brush adjsccM to strip meadows. The chicks need this type Of habitat to provide
protection and for the meets to eat AgflK it appears as if the lack of tire as a mnnagamant tool his led to the poor
conditions and reduced die ideal hubilat.
wiliiies nr smicljres sect: B tBM
SPECIFIC -
minted, and orhprwisr tlc^med 'oh end with the 'unoundir.E IniKlacuilS.ll This
r.ost is within reason, hcrccning
•Jjaciliiiei nr strut
fit] wpIIs. and .stornue tanks would be sercaied.
objection able as lone, es the
rxample. can be very costly without much benefit
.n;>-j :a. ^xia3j-w.tl-dt,n)<:s3 Mudyjittftei. would b.';j.iesbjn.sfl-£o_ia
ffj]t|emefis sujMbiltiv." What is meant by "near"? This needs to be specific.
■ alujs iilonn m.vor rravr
'■■■: ■■■■■
s-J'ark. I
Does this mear. tjiat
I ban suited aloni: tha
by tins entire stuleaieni
ALTERNATIVE "A" -- "To proti
jijjf^if.fltnfiirihlv^^
cwsiinB nghM-of-way would be elirr.mutcd. It is generally felt that the utility njdib-ol-way r
highways.
WiUcrshod jylnnjie .rn en L
CENTRAL ■- flic benefits ot water discharge from ihe oil fields needs to be addressed, since this v.
meets the criteria set forth. Aiso, most water in the resource area is fresh water, not saline as implied It) the
SPECIFIC - ■-MANAt.KV.ENT OBJECTIVES: Maintain Qf IMflfflLBfflllU
,-,wi-f meliidiny vcucLulivc lillcr. aqidjiiaijiUii" -■■"v^"f y-rniiiior. ^it-r iT.riniv" How much sliuidme, vegetans, .
LhiBt Ii euidtng vcgciutiori on ihe tTOund. This lOCtlon should be broken down by plant species and goals should
be set by watershed
"fty The end of calendar year ?.0tH increase procerlv I'un-JtlOCUle rilMTIfJUCj^aJrotn.,^ pcrcyQl Qf the tatt,
public land Djoam aiiM i In I aafl m ? 5 maa °r aun tf flaa Bam niiLi how h tins proposed to be
iiccomplishcd?
watershed and ^W rMf^eee valuw- What I S.D0I1 acres ll teJUg referred [pj What are the other resource values'.'
aanmgl gnated CaHtttteH tim^SS '" ""' Planning area, csnvci j.iv on uplands injflfflLMflu
f.-nmpral ciTwditioti." this is not specific ennuCJi.
■To obtain valid BgB nchta. the Bl.M wpijjd_fili!.
" "u-filing sliouldbe e
piihlicJauds
the ill .M and the perm idee or
v will this be done? The rules
-ilIi iK- Wyomi
poniW'. ihe Game and Fish.
•■ To molcct waiershrd values rourf:, und trails would k closed and. BEBBMfl. JLB
emsion/washouts. Roads can be eiadcl to mmimiM the problen with the added benefit of providing wale
runoff fbf wildlife. Sanctions should be written into the plan, and fines levied for misuse to protect the arc.
^7.. prnwer watershed values driving wp.jjd be protibiletUlLwet sojjj md on slopes ft rea;
p,-n--m |f urtaecKStirv daitmf * 'o vf oetaiinn noils, o- u-^ler Liuiui'.v wottldufi"'*" '
need to he clearly posted, and sanclbns and fines imposed to carry the rules 01
-'to rorlncc the amount ul nuiiCpini polhilionj^ermi: waarwav. PQl
daeJ^^LJ^cjioiiajli.!! Qualify »rnkr UlC Wyom^^torp. WWr Qtoflggj Pro^rn, The ULM would be iolely
-es-nons'f'k foi this They should coopernle with the Conservaunn Districts to pooled soil and water.
"About 4Q0 BtfB wojld he planted with native pn.sse'; :o improve thr condirion of the riftecuiiiile Cfeek
\V?ifrshcd livestOfkitr.'.^iLH would hr df fcrred in :hcse area, nLdJjLvLdesired vea.ri.Tioii is csjabluima."
1 Ivestnck (.-.ra/itiK would be deferred, but what about wildlife and wild horse grazinii? What is to be accomplished
by \ktf "nils section needs io have the specifications and gatli more clearly idendfied.
yvjlO_ll!^SuMaii»IleJ!l£iiL . „. , . . .
GENbRAL -- The uroup would like to see the money beuiv. speni M the wil.1 Horse nerd neinn mnica.
usee tor range improvement (watershed, wildlife, and graz»>K). and BOlweusata ihe wild horses in the McCullough
Peaks Area Overall, the wild horse herd should be eliminated ifl this arcu Ai a ruirunllinl. Aliemalive "B" should be
followed The detriment*! afieW of having wild horses include thai they compete with the wildlife and bring iratfic
mlu the area. It is felt that the program is nol east effective, and ihe money could be better spent elsewhere. In
addition, the 2300 AUMs could be alloned H other wiUlife
Wildlife and I'ish llnh.tm MUUgfiHtflHi
GENERAJ. - 'l'hc wetlands map is questionable as it seems :o be
determine wttlaods'' If part of an area is a wetland, that should notmaao that the
SPECIFIC ■■ "Annnaj review and environni'jntal mv'
APHIS and eon^iliimisares BBUJd "e perluaLV-li B oceacii: Thfe need:
impaci the sage grouse.
WMifr Habitat:
SPECIFIC - "111 M would i>jriiciL)iiLiLmih_ths_r-W
u method was used to
a is included.
he Londnclcd widi
valti.iTjon inddrsHMiai ton el i;ri'.uillJ?''bl|aU:.'i
n^MEJjejLejjjld^lliered ^pexk^
fw,lri affect Lhese species, m M would consult with the FW&jueaui.cd t& flll rndanrered Stt&Ol Afl " This
sliould have a stipulation thai the area in question is aciuaily being used by ihe species. I he™ -=
Iherv should be an opportunity for public parlii.ipalion.'comment. Hnwcver. it was also sue.
c jmment should he limited lu Ihose widi wma expertise in the nana.
fijfl work wiLh the I. SUA Forest Se/yifj
Initian Uesprvnnon tribes ir develoniTiL: u health v biehom sheen herd in the. AjSUSt
Whm is considered "healthy "' It was pointed out -.hat H-c lass diversity is never spoken of in ihis di
talking about the health, of difTercnt species,
s, pr|d i-[her"ri'Hi-niial rnlif ;il bghJtatt related to hnntinc and
"Nest sites rotiits. ccaonw
umcjjtUuiiunjir.ciii fot.buiJjaui
measure to prolecl lliese habitats, firew'
tjl't!. lali; nlunij Ihe Bijfhoni and t.rfeybull Rivers. As one
yould be nrirfiitfji'^l in lliese areas." This statcmcnl should
clHrifylhai h applies to BLM land a nly. This aettOR could have Ihe negative etTect of cloufnjj off riparian area
access, dlcrcby Butting ofTlmating. On the other Hatid,ii>i>bid4_cui!le is still a threatened species and Steos need to
be taken to protect it Ihe dcfnr.ions for protected area md range from me I'WS could be incorporated
■Bl ,M would njrrJcJaM gflBUBBMS MJ WGFD m Ihe rvuluation of hal-it.il areas for ihe potcnltai
lfjlCJBlluiiijjf_j)iii.l«Lk'J Hsli -.-j-.c wildlife species on public Imids." It wit. sujjgeslcd Lhul this ihould be modified io
allow fur public involvement o: should follow the fJEPA process. It was countered ihat any action would require an
EIS or l:A which would provide opportunity fur public commeriL
nJgMgJaMi rhni m afadafeu natural movement of wildlife would he modified. Tencc
"Frinc.es o:
niiMlifieatiuns, would conforn t.-. tf.ii.-d
r. FILM ManiulSeciii
indOI7o. Priority would,-^
djawnintaiejisj
HVcd fprlhc tlmiii;; i!iiil..fiir..esiHlili:,:ij(|^_.it:L:eji.i,ible knee i-landiud;.." This h nccoptahle only if ihe BLM is
responsible for paying for the fence modifications:.
" n ol access to nuhlai lands on the fliefaon: and th-evb'jll Rivers 10
LEnaaaait
■nhancn ifncitional oopormr^ies BHJ wildlife mar.
iZ Has ihcic ever been a oroblem with acce
vildlife management" Enliancini; rccrearionEl opportunities may pose a conflict with rhe bald eagle objective
','titLM would tafiflaog) jhjj ennstrucLon of islands in reservoirs, encourage the gLOW.ih_ofjipar.iiiD
l md insinll ruaiiiit- slmolurcs lu rnanaac for waterfowl
t_gg_g_M| bv planlii
£_aaagj
proflnciion and jgflujrv area.-- near reservoirs. ' This ;s acceptable only if a reliable source of off-site water is made
a v.i i I. ilslc when fencing off reservoirs
Fob Habitat:
SI'h:riFIC-"Ki:s.--vi-iiisfiir, nn.iiiiiiiiiiciis wrjuki be inair.MinerJ .tojmprov,; i)i-_o„hanc.u pt.1-.-nt io:. nshonc.,.
Hie, l,tl,M would gUflQUJtBI 'he design of Btfl___a M enhance fisheries where potential exist,." What docs
enhancing potential fisheries involve? This doesn'l sccrr, to improve the ecology of the area. New specks should not
he introduced ii
)thcai
Tint Mnr
Fifteenmlle Creek Watershed:
SPECIFIC - _An "re.i of | ;hjc:lI ft__aO_U_L__ Coucern U
Cttek Wr-.lershgd on ahoul 274. ?w acr.-s 0_jbj_Jj_ land i.Sec |v,iap 3 Ik Tile suecifll mHnu_
nol aonlv to siate or pnvaic liwds." Creation a ACEC in Uiis area would be a grave mistake, and should nut be uUOC
wirhour adequate ;ii-Uli:,it:.'n c.iiineC in this documeiu. Conccnlration should he un fixing the esisliny problems in
the.nsa Instead of declaring it Bit ACEC. The sediment load enlcn.np Ihe Bitjioni River should be evaluated 10
detcimioe how much is geological erosion Management practices could be used to stabilise other tanors
contributiriE to ihe sediment load.
Upper Owl Creek Ana:
SPECIFIC - "Mjaiaiitfinem would include Imiiliue. or pruliibitim: MufaM-JistUfbiiut. activities and closinn
Hif. iirc.i tn the stakin_ and Je_e|f^jo,_EJjtfjr_aja_ tl_i_j!i l» rrniKl Irani its noil5.,i'3,it]c.lumlra. imnonjjii wiidiile
" 11 F.1-- CONSTRAINTS ON SU.RFACI>:.l]Sj'__t.lJJfc!Cr .VTlvnfS.T1
irface occupancy" in the Upper Owl Creek Art.i Tnit prohibition does not allow
w ;cch no logy, etc.
llierc is a itroug objection to "no
Bar raiiieatitm through the use of i
l'ahli! Ji - Constraints on Surface-Disturb in", Activities
IVJ.lKeiijiLiia3iis.j_ja_jr_:E.'.:
555
SPECTFIC - "Hastd on ■jilc-^Pctific environmental analyse--, s-.r-'aee distnrlvr.H .■viivim-.s would he limjigri
during w« weathf- rf rimK ,t irn?nt toils, and on slopes ureye: iJ>:u: ?^v. , visual impaets vnuikl ht- :niii-,'::ipil in
secilie MM: ivii.ul toiuurw; m.vi.^L-men: [VKM] d.ivi ; ,mH [| ,ri;:is> ^.rfaeu-disr.iriiin; .-le-Uyities would he
L'll'inrmcd within f<>0 ftri:: ut juriaee Water mid i.jn i:p,ir:;i:i a revs, ^rd surl'acc-dlMurhinc uUivilirrs wnnlri hi-
UHJKlwl in Qa UBIfflalUaa aamli Pi MHimiiciirU cultural unci Dtilcuii'plpeical rcT.ou.-cc sites, and within f).?-S mile or
within view (whichever i» rlos,--) of rock in anrl sifnili«int Ft-^-mcnTj-. of hsitoric Trails " Work is often required in
he none on rm/.en KhI in place-'; such U Alaska, and "Steep1' slopes should be increased to at least 30W. A definilioti
of'lnutwdbH vicinity" Is needed
fi'in
SPECIFIC -- "Sun J iind fl-jvcl rninmn >vmj|d be nrohihued wiiilin 0.5 m-:; of the Legend Kncx I'rrrr-ftly-iji
feUEJlte >vwld correspond 10 a N(.> Surlily i kcmvincy stiniil.vu.n tor ;w. .ird oil lc«siiij;. )' Is u half mile really
necessary, or is even more needed"'
Wildlife fle«mrc^:
CCNERAI.-Usmj: Alternative P> with lit liming restrictions in conjunction with (he terms and condition.'!
contained in the standard lease, the wi.dlite resources would be sufficiently protectee Shwrinp flown is an asininr
restrict inn; other methods would work.
SPSC1FJC ■ "Unless. SKc specific cnvironmcnlnl analyses denrnmarait thai edyjfflg effect,-. cjui.be.
} ci'Jj.m sprc.llic bir. >Mrnc erne u I verier ranges and hirThjni; arcis. in -.t|i;:;Hr l.T^dirn; ::r.-.. -ir.nni- lmhitm iirr'Ls-
ffiflhJH two miles of flj eerier Q] Bgjj i-iwisr Irks nn.l wiihi
atnpai
within virwn
boundary around sage grouse Icks is Kki r
appropriate habitat as a result of h lack of
(ttlfliatl BSUVily.
Altraittt-UaiiffliwiLStiBiiIatja
Lrictive. The real problem with tic baby chicks, a deficinecy of
jnlrolled burning, is nut addressed in the document. They largely Ignore
:in Pace arouse CL*mclia.an.-iis. surface- di murine aciivitie^ would Iv allow-d wiilun 0 •>* imlf of the.
.■■. >■,'.:. LLL.i.dnii; o, ■;-:•;:;: .1.1.! .>.]_. ■.■./.in !uni:..i m ,!■.■■: .::>.-;j ;,; CI: ifle; 1" -.):.; :-j:,Li..-.imii ^r.mk be Liu I lei il I'
\V« laereased to 0.5 mile. Thb change would not be mnvosonable since it would OUtj apply about J -4 week) a year.
Wilrilifc, SoU ml WatcrAepctiitintL and Scenic HflUUJgaiS
Kl,bCIKlC--~Sur:sCC7iisJJI^niWVJiV]1ICSWoi.di1.bo.p.rphlhit!:,-lrn ih.j ■V-.^rP1-..-! Mnnntrnn t::rlhills t llir
aaes. flJlii gmM BCganil Hi I tfa Surface Otiipanrv stipulation for gi» and oil lrmitic.f Then1 was an
ubjecttan tnihc "No .Surface (kcupjoey" part of dtis statem*tiL but it was a.-^aed that 0.25 mile is not dial bad
M«ti 9 - Existing Mineral Classifications:
win is ihe lurgeaiei f«T.*5N . r.%w. Included In ttie coal w phosphate cismiflcatwin'.'
Map 1ft - Mttn-ral Withdrawals (Preferred Alternative);
Whv is the lar^e area just tn the nnrtli oi Hiercnopolis WfltldnwD?
TnhkS- Acflvltiis Afffrhng Soils and Estimated Acr^ :intl Diiratinna «>f flfa&HTJafl«i
*l"hc soil luss is calculate
soil or any tmprovf merits dnnc ::
in the table.
ording to a eomputer model, a.id
mid reduce erosion In addition.!
K take into ace
nn coinpnnriit for wildlife included
■umntions fnr AnaKsij, bv Alternative:
Kire Manaermwit:
SPPCrFir -■ "Ahoul liOO x^ ot niL-l :■ l:mJ --nuLl be biniiril bv wiki jire dur ini: lligu;ii:K-,i:. perind ' Six
bundled aera itJCB£tirUulfIeteni The rcsoiuce area r-hould be set up on a laigmofa '10-50 year cycle.
I'lirf(l:tru I Ma imagine-ill:
UBMiRAi, -■ All four alternatives are inadequate for managing 8 Umber \!and Ihm is 86'/? mature.
SPrCIFIC - "Timrw tixrvcias. and ciher forest Tentm:nti would all'oct bOOU 1?CQ and 1900 acre* at'
puba: litrtd." This prngraru is tnidequate to deal wWl [lie rrsourre inventoried Altemotive "B". with the hiyhesi
acreage rengje, would slII be iundequme,
OiNTRAL -- Tl'.e focus should be oc ao; losing, asy access
SPECIFIC -
alvm.s ncrind " The l
v roads should be identified.
uXi'e vliuiuiei.1 on ubtn.i 10 to 20 icufc JwinB-ih.v
is :: base y
rfor analysis An ai
euiv widi RWQtdl V
Mtin.'igtmrnf:
GENERAL -- 1090 was not a. typied year, and slwuld nui I
over a mn.itc (if years wuuld be mucn better, for the AIM baseline,
.should beined.
11 has not own proven 'hat a deem*!* in At (Ms il necessary in the future, since the data that was wed is
invalid. It would be nice Hi mt B pfpgram wilb deflnttiv* encouragement for thtHK rinin"^ "oortjop. and IMCrtMl
for those who ate not. For oxtunple. reclaimed Al^Nls ahuuld be returned to good permittees
SPECIFIC - ""Riinue uroieeus Bfflj treauTica'.s would usually he developed ffl applied in "1" ra;ctim
dlotnents It in aimriiwri that nroicci devekoiiL-nt wuuld meludu const rue I inn of jfl miles of fence ?.fi reser\oir-;,
I'Jifiin^. If) miles nf pipelines and Ifl wrl!t ^irjni: in
good ion tibosc
category ), beeajse laey ^ar.'t impro
B period " This ner
:.h people ■
Minirali Management:
Cos and Oil:
OSKSRAL -- Revenues from oil and (as make up $273 million nut ofa total olS.100 million. Given this
feci, the economic importance uf ibis activity is downplayed in the document and its overall importance is not
Mressed enough. It wnsbroui;lil fortli thai the overall economic importance of coal and gnuinij are downplayed also.
S^rCli'lC ~ " I Tic recoverable reserves of mc new Heidi would be about 500,000 barrels of oil or 5 billion
unknown, the reserves ihuuld be listed in a range, ie,. 500.000 to ID million barrels. There isnonsasun for
mdJcaitng such a small pntentiul, and ihe potential ihould not be labeled "'very limlwd"
/^/&M)
KEY POINTS TO CONSIDER
FOR PROPOSED OIL & GAS MANAGEMENT
IN THE GRASS CREEK RHP DRAFF EIS
> For all four alternatives, the changes In the proposed restrictions would have
a rasultant change in the exploration and development potential for the oil
& gas industry, In fact, the current management in Alternative A is
sufficiently restrictive that exploration plays are discouraged. Alternative
B addresses minimal restrictions that can be handled on a case by case basis
"S,n9 ■»!! I III ||H I lull' II liu. iLJL— Ul. Our industry recommends
adopting Alternative B and thinks that any environmental concerns can still
be minimized. Our industry would prefer to work with the BLH to develop a
new alternative.
Since the oil S gas industry beliEVes that each alternative will result in a
resulting change in industry development, the production forecast in the
draft EIS is also incorrect. Also, by the negative perspective taken on paqe
293 concerning Future Potent ial, the BfH-'has excluded tnTHffilteiiBMttflri S
gosls; and significant increases 'in exploratory acTlvT^^^toMgher
hydrocarbon prices. Industry will be providing estimates of production for
the four alternatives to be considered. The socioeconomics in the EIS should
also be changed to reflect the changes in production. *TL BE I BBBflpI C
s <Uj.ua . 1hj^dJr3J5iij3&ludg_ag i mmgttlLjaBBBBB 0^TTnTF^_JjnTrjr:-1hB vitrini'r-
coMHtfrttC*«rB-of tlHMuibHg-jjndV' state 4 local owartMiant ofTftUH -rwiT
that data 1n order to maTe^recammendatlons on the EIS. The BLM should
seriously consider that our industry contributed 1273 mil 1 i on of the over
S300 million in revenues to the economy from the Grass Creek RA and the
proposed restrictions will result in reducing those revenues.
|eneral, the proposed restrictions of No Surfac
" tRET-tter-tttO?
Tmnrt-' ■
iiMBarj I JCffij^rqpX^rjH"^^*3--
est artfas of
e the Northeastern half of the
Grass Creek Resource Area (RA) has mostly moderate and high oil & gas
potential, it is an area that will require high dollar investment for the
deep gas play and will not probably nccur for a few years. The Southwestern
half of the Grass Creek RA, on the other hand, contains the more shallow
less expensive, plays (probably oil) and, in turn, would haveahigher
intej^stand potential for Jeyelopment at this time. Tfrr^ptaferrcd
merrnTTv^-s-wHjirrtcl^^ discourage util izing t'hYnew
technology of 3D seismic exploration and drilling of any potential plays.
The proposed restrictions cover|WUlr LIULBHI, IBIfcEcajjf high potential oil
& gas, 44% of the moderate potential, and 93?! of the low potential. The
total iirea for the restrictions cover about *HW ill In ffl II li. Ml"
atweage. As mentioned, these restrictions discourage development.
SUPPLEMENT TO PUBLIC HEARING
TESTIMONY BY CHARLES JOHNSTONE
1 The NSO, CSU, and 7L restrictions all result, mainly, from a perceived oil &
gas impact on wildlife, whether big game or sage grouse. In our opinion
imiii 'afffSw nitr- MiUujhiiju-M^u<n3ruljA^at.ijvjjiuTfltt|i>. imtrUmMn^it
ar4tf-~np- Our industry believes that there are other sources that
negatively impact wildlife more so than the oil & gas industry activities.
In fact, recent articles in the monthly publications of Oucks Unlimited and
The North American Pronqhorn Foundation are two sources of studies of the
effect of predators on wildlife. There also have been reports of the effects
of drought on wildlife. The BLM needs to include studies of these impacts
The proposed NSO restriction on the Upper Owl Creek area (17,100 acres) is an
area about 10 miles by 2.5 miles. This restriction implies that the area can
be developed by directional drilling; however, the restriction pushes the
technology unreasonably. For the depth of the potential plays, a horizontal
distance of 1/4 to 1/2 mile would be a reasonable limit for a well The
proposed NSO restriction would exclude most of the area from development.
A more reasonable proposal for this area would be to allow corridors of access
and propose reasonable cluster {some directional drilling) development For
— that is jJl moderate potential, the-tJpT3gr~CVt l-Tre* nree-wttfld
tfer~ttie -BLr^s--p>w>p«.a>-uT~rTSIE>
The |^:b"poTgi-J-~eStr restricThgr^rTTTte-Owl Cpgefc-Tootttins toTTTOO acres)
requires maintenance and operations on newly discovered fields to be shut in
for 6 to 8 months of the year for wildlife considerations. This restriction
is unreasonable, again because of lack of justification that was previously
mentioned, and does not consider the possible use of automation technology to
allow year round production with minimal human impact. This area is nostly
jnoderate potential and, as with the previous NSO restriction, it pT8We%y
*K±
BflWjpfcjwed,
The remaining proposed CSU restriction on sage grouse habitat and strutting
areas implies impact by our industry without justification. Unless
justification is provided, we recommend that this restriction be dropped.
Cultural or arcneological surveys are required by the National Historical
Preservation Art; however, most of any archcological finds [page 153) are the
result of oil 1 gas activity and most disturbances are noj. of significant
value. The regulations and the proposals in this draft F1S should be changed
to ninimize the extensive surveys required on our industry.
It is recommended in the draft E:s that at least ten oil & gas fields be
surveyed for determination of the historical significance of the fields Cur
industry does not have a problem with the surveys, if the BLM includes in the
final EIS stipulations that no restriction; on operations will be imposed as
a result of the surveys. We prefer that the fields be considered 1 ivinq
history and not preserved history.
556
- page 3 -
Since oil was discovered in 1881, six years before Wyoming was a state, we
thin* that the oil 4 gas industry are part of the heritage of this state.
For that reason, visual restrictions as proposed in the draft EIS should be
dropped. The BLM should encourage the visual enhancement nf our operations
with descripti'
iigns rather than visual restrictions.
• Page 195 - At th« bottom of the first column and the top of the second column,
the sentence implies that produced water mii lower the water quality. For
the most part, produced water discharged in the Grass Creek RA is of a
quality that It is used for wildlife, stock watering, irrigation, etc. This
section should be changed to document the benefits of the produced water for
the Grass Creek RA, not imply that it is detrimental,
• Page 126 & 127 - We believe the soil loss information for our industry's work
is excessive. Our understanding is that the data was developed from a
computer model. We would recommend that the model be modified to Include
artificial cover such as vegetation and gravel if that information has not
been included.
• Page 201 - The U.S. Fish & Wildlife Service's EIS for the reintroduction oT
the grey wolf specifically stated that once the wolf in Yellowstone Park left
the Park, the species was experimental and would not be protected. The
paragraph on page 201 In the Grass Creek draft EIS implies protection and
should be changed.
ENVIRONMENTAL CONSEQUENCES
toi'< J"£ peer
lury gas and oil production, and coal mining Itself.
During severe winters surface con! mrninjwoulfl not be
allowed II mule deer are on crucial winter ranges near
the mine. These protective measures would not signifi-
cantly interfere with coal development.
Gas and Oil
"No surface occupancy" (NSO) constraints on new
gas and on leasing wculu apply to about 2,130 acres ol
BLM-ftdmtftlMrtd mineral estate having high potential
'or gas and oil occurrence, 15.790 acres witn moderate
pote.nti.il, and 2,280 acres wi:r. low poiert.al.
Most ol those lends (17,100 acres) would be in the
proposed Upper Owl Creek ACEC. on Tertiary age
volcanic rocks ol the Absaioka Mountain rootWIla, Since
1965, six exploratory woDs have been dn'led in or
adjacent to the proposed ACEC. All wore dry noies.
Immediately south of the proposed ACEC. trie poteniial
lorgas and oil occurrence is low, because Mesoioic age
rese-voir rocks are absent, and exposed Paleozoic age
rocks have lost ttic-ir gas and o:' through erosion.
Future exploration in the Absaroka Mountain foothills
would continue northeast ol the proposed ACEC. where
lour gas and oil lie/as have been discovered.
"Controlled surface use' (CSU) constraints on new
gas and oil leasing would apply tc about 09. 900 acres ol
BLM-admimstered mineral estate having pilgh potential
for gas and oil occurrence. S9.200 acres win moderate
potential, and 9,700 acres with lew ootentiaL
On 61 ,1 00 acres, the CSU Constraints would protect
big game animals on ovcilaprjinc, wirier ranges. Dinning
areas, and migration corndors by placing seasonal
limitations on the operation and maintenance cf gas no
oil-producing facilities in newly-discovered fields
Dunng the analysts period, one or two exploratory
wells would be drilled or. fese lands which include pads
ol the Basin-Margin Anticline and Sub-Ansaroka jaa
ana oil "plays." Plays arc geologic projects wrier*
there Is a probability of commercial quantities of gas or
oil bemg discovered. This probability is about 1 in 19 for
exploratory wells ;n ihe Basin-IVargn Anticline play and
1 In 22 in the Sub-Absaroka play.
If commercial Quantities of gas or oil W«8 discovered
on lanos allected by tr.ese CSU constraints, mainte-
nance and ooeration of the now lieids could be curtate
for 6 it: B months ol Hie year. It Is anticipatec thai winter
and spring wpaiher conditions would require use of
these constraints during portions of afcoul '. 0 to 12 years
durmg :ne analysis period.
However, it is likely that operators would continue to
buy leases in areas affected by the CSU constraints In
the past, many of the prooiems associated with explor-
ing these areas nave been caused Uy adverse weather,
topography, and unstaale soils. These narjra: (actors
have cl03»d the lands to access sne would continue to
do so, even II administrative con slramts were not part of
this alternative.
The oilier CSU constraint (on ?7,7QQ acffiS) wou|d
be used to nrnicct sage grouse habitat complexes
(72, 770 acres), sage (jrouseslrurtngareas (4.00030: es),
preventinappropnaiedevelopmentonlanalills anc shoot-
ing ranges (4QO acres), and protect habitat and recre-
ational opportunities at Wardei Reservoir (450 acres).
Controlled surface use constraints would severally
require avoidance of Important naoitat or recreational
ooponunities throunh the selective placement ol Cas
and orl facilities, or other mitigation. In habitat com-
plexes, CSU constraints would not ahect exc^o-alion or
development unless 20 percent ol me habitat were
affected by direct surface disturbance or by indirect
human presence. Selective slacement of exploratory
wells and oiherslructures generally would De necessary
if the 20 oercent level were reached.
These constraints woulrj not be anticipated to affect
the numDer ol weiis drilled, and would have a mnor
influence oncosts,
Timing limitations would be used to protect mute deer
and pronghorn antelope on winte- ranges and prong-
horn fawninq areas, i hese would affect afiout 22G, 1C0
acres of 6LM-ailministerec mineral estate having nigh
potential lor gas and oil occurrence. 163.900 acre's w-th
moderate potential, anu 1 0.2C: acres win lew potential.
These limitations could prohibit exploratory dniling.
from two lo six months during the yea; but would only oe
used when big game animals are present and cannot
use adjacent lands. Winter and spring weather condi-
tions would require use ol these constraints dufing
pomons of about three to live peers during the analysis
period.
About 812,800 acres ol But- administered mineral
estate would b« leased With standard lerms and condi-
tions.
BestrinionSoii!].isanduifie.is.-:iuit.m^;eiyalf3c'!re
costs ol exploration and development ana can have an
effect on the numbers of gas and oil wells drilled Under
thisal[ernative,approxinjielyonee«io,aiorj..,velUvouia
be drilled each year to test ihe BLM -administered m.n-
eral estate. Other inlormalion on an:,c,pa:coexpicrauon
and development is contained m Table 15,
-ZZZE£1
BL^'s Grass Creek Resource Area
Resource Management Plan (RMP)
Draft Environmental Impact Statement (EIS)
This draft EIS outlines four alternatives (one preferred by the BLM) for the
management of the Resource Area. The Grass Creek Resource Area encompasses parts
of Big Horn, Hot Springs, Park, and Washakie Counties in the North central part
of Wyoming. The RHP proposes the management plan for 968,000 acres of public
land surface and 1,171,000 acres of federal mineral estate in the resource area.
One should note that the public land surface is about 65X of the total surface
lands (1,485,700 acres) and the mineral estate is 79* of the total in the Grass
Creek Resource Area. Additionally, the revenues generated from resources (i.e.,
recreation, livestock grazing, forestry, and minerals) were nearly $300 million
in 1990 with about 64X of the revenue coming from public lands. For the oil h
gas industry, about S 17.6 million of those public land revenues were federal
royalties. Those royalties along with the severance and property taxes in
Wyoming on public lands generated almost $40 million (estimated) in federal,
state, and local government revenues for that year. Those dollars helped provide
the services that we enjoy from government. Excessive restrictions on those
public lands would not only have an impact on the local economy but also the
state economy.
It appears that the BLM is proposing a major shift in the management of the
publ ic 1 ands for the Grass Creek Resource Area. The management restrictions also
appear to present a significant economic impact to the oil & gas industry. For
the ELM's preferred alternative of managing the 1.2 million acres of mineral
estate, the following constraints are proposed: 20,200 acres - rJo Surface
Occupancy (NSO), 138.800 acres - Controlled Surface Use (CSU), 399,200 acres -
Timing Limitations, and the remaining 612,700 acres - Standard Lease
Stipulations. Please note that Standard Lease Stipulations, many times, have
restrictions due to the trany laws (i.e., ESA and archeology surveys) utilized
with those stipulations. The hydrocarbon potential for each management area
varies and is as follows: NSO (20,300 ac. total) - 2,130 ac. high potential,
15,790 - moderate, and 2,250 low; CSU (138,800 ac. total) - 69,900 high, 59,200
moderate, and 9,700 low; Timing Limitations (399,200 ac. total) - 225,100 nigh,
163,900 moderate, and 10,200 low; and Standard Lease Stipulations (612,700 acres)
- 312,973 ac. high, 298,056 ac. moderate, and 1,771 ac. low. The CSU constraints
include seasonal limitations on maintenance and operation as well as avoidance
of some areas for development. Without reasonable access, that industry will not
he able to continue providing their part (905S+ of the pjblic and 6Cfti- of the
total) of the revenues generated in the resource area.
You arc encouraged to get involved during the public coi
May 7, 1995 and the public hearirg (notice attached.)
be submitted to the follo< "
ent period, which ends
ritten comnents should
wing:
Bureau of Land Management
Bob Ross, Team Leader
P.O. BOX 119
Worland, Wy 82407-0119
Should you want to ;ndividually read and evaluate the 30C page EIS, please call
Mr. Ross at 307-347-987] to get a copy of the document.
557
SUPPLEMENT TO PUBLIC HEARING
TESTIMONY BY JIM GOULD
GRASS CREEK RESOURCE MANAGEMENT PLAN COMMENTS
COMPILED BY THE MEETEETSE CONSERVATION DISTRICT
APRIL 3, 1995
MEETEETSE CONSERVATION DISTRICT, HEREAFTER RFFERREQ 10 fly
MCD MAS THE RESPONSIBILITY "...TO PROVIDE FOR THE
CONSSRVATION OF SOIL, AND SOIL AND WATER RESOURCES OF THIS
STATE. ..AND THEREBY S I AEJlL IZING NANCH1NG AND FARMING
OPERATIONS. TO PRESERVE NATURAL RESOURCES, PROTECT THE TAX
BASE, CONTROL FLOODS, PREVENT IMPAIRMENT OF DAMS ANO
RESERVOIRS. PRESERVE WILDLIFE, PROTECT PUBLIC LANDS, AND
PROTECT AND PROMOTE THE HEALTH. SAFETY AND GENERAL WELFARE
OF THE PEOPLE OF THIS STATE." BY AUTHORITY OF WYOMING
STATUTE TITLE II. CHAPTER J.fo, 101-120, ANU UNITED STATES
PUBLIC LAW S66. MCD IS A LOCAL GOVERNMENT AND THEREFORE
ENJOYS ALL THF. PROVISIONS AND PROTECTION OF NEPA. NEPA A?
USC AT: SECTION 4332 fC) « (V) STATES THAT ThE COMMENTS OF
LOCAL. GOVERNMENT ARE TO SE INCLUDED IN THE; GRASS CREEK AREA
DRAFT RESOURCE MANAGEMENT PLAN ENVIRONMENTAL IMPACT
STATEMENT, HEREAFTER REFERREO 10 AS THE DRAFT. THROUGH ITS
ENTIRE REVIEW PROCESS, THE BUREAU OF LANO MANAGEMENT,
HEREAFTER REFERRED TO AS THE BLM. IS CURRENTLY TN VIOLATION
OF NEPA AT THIS SECTION FOR THE BLM HAS NOT INCLUOEO THE
WRITTEN AND VERBAL COMMENTS PROVIDED BY MCD DURING THE
SCOPING PROCESS. MCD IS NOT LISTED IN THE RECUIRl.O
REVIEWERS" ON PAGES 218 AND 219 OF THE DRAFT,
MCO IN THE INITIAL STAGES OF THIS SCOPING REQUESTED THE BLM
TO CONSIDER THE PREFERRED ALTERNATIVE OF HOLISTIC RESOURCE
MANAGEMENT, HEREAFTER REFERRED TO A3 HRM, AND CR COORDINATED
RESOURCE MANAGEMENT PLAN. HEREAFTER REFERRED TO AS CRMP.
THE RANGE UTILIZATION LEVELS ESTABLISHED BY THE FEDERAL
GOVERNMENT 00 NOT REFLECT CLIMATIC CHANGE AS AN OFTEN
OVERRIDING VIABLE OU GRAZING ALLOTMENTS. TO REFLECT
CLIMATIC CHANGE CORRECTLY IN THE RANGE UTILIZATION LEVELS
HOLISTIC RESOURCE MANAGEMENT TECHNIQUES MUSI BE APPLIED TO
THE RESOURCE HEALTH, AND SUSTAINED GRAZING USE. CUTTING
"AUM'S" BASED ON UNCERTAIN QUANTITATIVE DATA A3 PRESCRIBED
IN THE DRAFT WILL NOT eEMFFIT THE CUSTOM AND CULTURE AND THE
ECONOMIC BASE OF THE COOPERAT0R3 OF THE MCD.
MCD QUESTIONS WHY THE IMPORTANT BENEFITS OF LIVESTOCK
GRAZING ON THE PUBLIC LAND RF50URCE ARE NUT IDENTIFIED IN
THB DRAFT SUCH AS: THAT SUSTAINED LIVESTOCK GRAZING - CAN
THICKEN, SUPPORT AND SUSTAIN THE MULTIPLE PLANT COMMUNITIES J
THAT LIVESTOCK HOOF ACTION WORKS MINERALS INTO THE UPPER
SOIL HORIZONS BY THE LAYING DOWN DF PLANTS (TO 'LITTER').
COMBINED WITH DUNGING AND URINATION. COMPLETES THE MINERAL
CYCLE; THE ELIMINATION OF SEQUENCING (MINERALS ANO OTHER
NUTRXfiNTS BEING LOST TO THE ATMOSPHERE OR HELD IN
SUSPENSION}; THE INCREASE OF LTTTFTR IMPROVFS SOU 'S
RESISTANCE TO WIND AND WATER EROSION. AND IMPROVES THC
MOISTURE RETENTION CAPACITY OF THE SOIL. MCD DOES NOT FIND
IhE ABOVE MENTIONED QUALIFIES. BENEFITS, OR TERMINOLOGY SUCH
AS WATER CYCLE. MINERAL CVCkS, ENERGV FLOW. AND SUCCESSION
WHICH ARC ENHANCED BY CAT"LE GRAZING, IN THE DRAFT.
THE BLM HAS FOLLOWED THE 3AME STANDARDS YEAR AFTER YEAR ONLY
TO SUFFER THE SAME PITFALLS. THE EXISTING AND PROPOSED
STANDARDS CANNOT BY THE SAME FOR EVERY GRAZING ALLOTMENT.
THEREFORE WE NEED A NEW SET OF TOOLS ^OR TRUE ANO EFFFCTTVE
MANAGEMENT FOR THE WIDE VARIE'Y OF RESOURCES FOR BO I H THE
PUBLIC AND PRIVATE BENEFIT. THE BLM MUST ADOPT THE HRM
GUIDELINES AND TOOLS IN ORDER 7C EFFECTIVELY ANO
ECONOMICALLY MANGE. IMPROVE AND SUSTAIN THE GRASS CREEK
AREA. THESE PROVEN TOOLS WILL TAKE INTO CONSIDERATION THE
ENTIRE RESOURCE BASE. THE ECONOMIC WELL BEING, AND THE
CUSTOM ANU CULTURE OF THE INDIVIDUALS AND COMMUNITIES WITHIN
THE GRASS CREEK AREA. MCD STRONGLY RECOMMENDS. A3 EVIDENCF
WE ENTERED INTO THE 5CGPING PROCESS, THAT THE BLM CONSIDER
THE GOALS, POLICIES, HRM CONCEPTS OF THE MEETEETSE LAND USE
AND RESOURCE MANAGEMENT PLAN - 1994, AND THAT IT BE USED IN
REVIEWING AND ESTABLISHING REVISED MANAGEMENT STANDARDS IN
THE ^INAL DECISION FDR 1HE URASS CREEK AREA.
THE DRAFT IS NOT ACCEPTABLE TO THE COCPERATORS OF THE MCD IN
ITS PRESENT FORMAT. THE DRAFT MUST BE REWRITTEN TO REFLECT
THE CONCERNS AND COMMENTS FOR IMPROVEMENT RECEIVE!} BY THE
BLM OFFICIALS FROM THE PAST PUBLIC h DRUMS SPONSORED BY THE
LOCAL COMMUNITIES ANU CORRESPONDENCE OFFERED BY AFFECTED
COMMUNITIES IN THE GRASS CREEK ORSA.
THE COMMENTS RECENTLY MADE BY THE BLM OFFICIALS REGARDING
'PAPER AUM'S" VERSUS "REAL ON-THE- GROUND AUM'S" IS
DISTURBING, AND MCO SUGGESTS THAT THE HISTORY OF THE
ADJUDICATION 01- ALL EXISTING "AUM'S" ON EXISTING GRAZING
ALLOTMENTS WERE WELL CONCEIVED AND NOT DONE ERRfi I r CALL v OR
WITHOUT REGARO TO VH£. RESOURCE, (l) WE SUGGEST THAT THE
HTSTDRY OF THE ADJUDICATION CF GRAZING ALLOTMENTS BE
RESEARCHED AND MADE PART OF THE REVISEO DRAFT. FOR THE BLM
TO MAINTAIN THAT A CHANGE IS NECESSARY IN THE EXISTING
NUMBER OF "AUM'S" ON EXISTING GAZING ALLOTMENTS, WITHOUT
CONCLUSIVE EVIDENCE OR A FINANCIAL RESOLUTION THEREOF, IS A
TAKING OF PRIVATE PROPERTY RIGHTS, SUBJECT TO THE PROVISIONS
AND JURISDICTION OF THE EXECUTIVE ORDER NUMBER 12630.
MCO WILL PROVIOE THE SLM WITH THE VIDEO "THE NEW RANUELANU
COMPACT". WE BELIEVE THAT THE SLM NEEDS TO EMPLOY THE
CONCEPTS AND 10EAS REPRESENTED IN THE VIDEO. YOU HAVE ASKED
FOR POSITIVE INPUT, PLEASE -EAD BY EXAMPLE, EMPLOYING
POSITIVE OUTPUT.
MCO REQUESTS THAT THE BLM USES ITS NEW TOOL - GEOGRAPHIC
INFORMATION DATABASE AND MAPPING SYSTEMS - WHIOH YOU HAVE
HEAVILY INVESTED IN TD FOCUS ON REFINED RESOURCE PROBLEMS
AND APPLY HOLISirc RESOURCE MANAGEMENT IDOLS TO ALLEVIATE
THOSE IDENTIFIED PROBLEMS. RATHER THAN APPLYING ONE STANDARD
ACROSS THE BOARD, ON THE BASIS THAT THE PROBLEM IS AREA-WIDE
RATHER THAN SITE SPECIFIC.
THE DRAFT FAILS TO TAKE ADVANTAGE OF ALL POSSIBLE LAND USE
IN THE UHA3S CREEK AREA, WHILE THE OLD HARD AND FflSl
INFLEXIBLE RULES AND STANDARDS ARE AGAIN 9E- iNG APPLIED IN
THE DRAFT. (2.3) MCO ENCOURAGES THE BLM "0 ENDORSE AND
IMPLEMENT NEW, BUT TESTED. RESOURCE MANAGEMENT TECHNIQUES IN
THC GRASS CPEEK AREA.
THE MEED FOR BURNING 13 NOT EMPHASIZED ENOUGH OR STUDIED IN
THE DRAFT. THE GRASS CREEK AREA WAS ONCE PART OF A TRUE
LAND MANAGEMENT CULTURE THAT USED BURNING TO ENHANCE AND
SUSTAIN THE RESOURCE EVERY TEN TO FIFTY YEARS. (4) THE DRAFT
DOES NOT EXPRESS THE FACT THAT OUR CULTURE HAS NOT BURNED
THF RESOURCE AREA FOR THE FAST ONE HUNDRED YEARS. NOR DOES
IT STATE THAT WE MUST EMPLOY THE BURNING TECHNIQUE HEAVILY
OVER THE NEXT TEN YEAR PERIOD IN ORDER TO RETURN THE
RESOURCE TO ITS HISTORIC LEVELS AND ELIMINATE THE TIME
BOMBING CREATED BY THE PRESENT AND PROPOSED MANAGEMENT
TECHNIQUE OF THE SLM -- LITTLE OR NO BURNING. THE MCD ASKS
THE BLM TO SPEND THE NECESSARY TIME AND EFFORT TO PROPERLY
RESEARCH THE NEED FOR BURNING AND ADDRESS THAT NEED IN THE
DRAFT.
THE CURRENT WAY THE SLM DEPINES ECOLOGICAL CONDITION OF THE
RANGE IS AS FOLLOWS: EXCEL!. ENT (3ERAL } , GOOD (LATE SERALJ,
FAIR (MID SERP.L), ANO POOR (EARLY SERAL). MCO INTERPRETS
THE DRAFT AS SAYING: SUSPECTED ALLOTMENTS WITH GOOD, FAIR,
OR POOR RANGE CONDITION WILL, BY REMOVING OR REDUCING THF
NUMBER OF LIVESTOCK, TREND TO CLIMAX CONDITION (EXCELLENT
AND SERAL ] . CURRENT SCIENTIFIC LITERATURE SUPPORTING AN
ALTERNATIVE WAY OF LOOKING AT RANGE CONDITION STATES THAT
THE REDUCTION OR REMOVAL OF GRAZING PRESSURE WILL NOT RESULT
IN A CLIMAX CONDITION. IF THE RANGE IS IN A STABLE I OWER
3UCCES5I0NAL STATE. (5; THE BLM MUST EMPLOY A PARADIGM
SHIFT IN ORDER TO ACCEPT THE FUNDAMENTAL CHANGES IN
ECOLOGICAL THEORY. THE OLD SUCCESSION MODEL IS NOW BETNS
REFUTED AND QUESTIONED. WHILE A NEWER MODEL. THE STATE AND
TRANSITION MODEL, IS REPLACING THE Qi-D THEORY BEHIND RANGE
MANAGEMENT. MCO BELIEVFS THAT THE FILM MUST MOVE FORWARD TO
A NEW WAY OF THINKING CONCERNING ECOLOGICAL THEORY, ANO
EMPLOY THE TOOLS AND PRACTICES OF HRM TO ALLOW THE
OPPORTUNITIES FOR APPLICATION OF THE STATF. AND TRANSITION
MODEL. (6) THE EXISTING DRAFT DOES NOT ADDRESS THE
DEVELOPMENTAL MORPHOLOGY ANO PHYSIOLOGY CF GRASSES AS
ADDRESSED BY 0.0. BRISKE, IN CHAPTER A, "GRAZING MANAGEMENT
AN CCOIOGICAL PERSPECTIVE". WE BELIEVE THAT THE BLM MUST
RECOGNIZE THAT THERE IS ANOTHER WAY TO MANAGE THE GRAZING ON
PUBLIC LANDS BASED ON NEW INFORMATION AND BY UTILIZING THE
TOOLS AND PRACTICES OF HRM . ( 7 )
THE ULTIMATE DRAFT MUST EMPHASIZE THE NEED FOR AND FOSTER
OPPORTUNITIES FOR INCREASED MINERAL PRODUCTION AND
EXPl ORATION. RATHER THAN ATTEMFTING TO ELIMINATE THE
POSSIBILITIES FOR EXPANSION OF THAT IMPORTANT SECTOR OF THF,'
WYOMING AND GRASS CREEK AREA'S ECONOMY. WYOMING GOVERNOR
QBRIN8ER SUPPORTS OUR VIEW ON THE NATURAL HESOURCE EXPANSION
EFFORTS, A3 HE WILL PROTECT ANO DEFEND OUR STATE'S BASIC
INDUSTRIES ANO ENSURE THE PERFORMANCE OF FEDERAL AGENCIES IN
THAT REGARD. IT WILL SE IN THE BEST INTEREST FOR "HE
MANAGEMENT OF THE 3RAS3 CREEK AREA THAT THE BLM REVISE THE
PUUCY THEY WISH TO ADOPT ON THE ELIMINATION OF PDTENTIAI
AREAS FOR HINERAL DEVELOPMENT IN THE GRASS CREEK AREA. MCD
SUPPORTS THE ELIMINATION OF IMPEDIMENTS TO ACCESS FEDERAL
LANDS FOR CONTINUED MINERAL DEVELOPMENT. THE PRODUCTION OF
NATURAL GAS WILL PLAY AN IMPORTANT ROLE IN THE ECONOMIC
VIABILITY ANO LIFESTYLE OF OUR COMMUNITIES FOR MANY YEARS TO
COME, AND WE WILL NOT LET THE FEDERAL GOVERNMENT TAKE THOSE
OPPORTUNITIES AWAY FROM THE COOPERATORS OF THE GRASS CREEK
AREA. IN COMPLIANCE! WITH THE POLICY OF THE GOVERNOR OF
WYOMING, THE MCD WILL BEGIN TO INVENTORY AND ASSESS THE
POTENTIAL USES WITH THE MCD INCLUDING PUBLIC ACCESS AND
RECREATION, SURFACE LEASING FOR TIMBERING AND GRAZING, AND
iHE POTENTIAL FOR MINERAL LEASING AND DEVELOPMENT. WE ASK
I HAT THE SLM LISTEN ANO RESPOND TO THE STATED NEW DIRECTION.
558
rnciTNQTFs
1. tlstabtishing Management linoer thi
F.R. Cflrpente'-, Rangeland Society
Vol. 3, No. 3, June 1931
2. Management Decisions Based on Utj 1 I^atian-Is It Really
Management?, Lee Sharp. Kenneth Saners. 4 Neil Rimbey,
Rargelands, Society for Range Management Vol. 16, No.l
Fabruany 1994
5. Utilisation Guidelines, William E- Frost, E. Lamar
Smith, and Phil R. Ogden, Rangelands, Society for Range
Manaqement, Vol . 16. No. 6, December. 1994
4. Evergreen Magazine, The Evergreen Foundation, Mar. -April
1994
";. Stable States and Thresholds of Ra"ye Condition on North
American Ranselands; A Viewpoint; by w.ft. Laycock,
Journal of Range Management, vol . 44 , No. 5, Sept. 1991
6. A Fundamental Change in Ecological "heory. Newsletter
(F46, Nov. 1994, Stan Parsons, Range Management
Consultants, Inc .
7. Crazing Management : An Ecoluyical Perspective, Edited
by Rodney K. Hei tSChmlcft and Jerry W. Stuth. Timber
Press. 1991
Submitted by Terri M. Sporkin PO Box 543, Meeteetse, Wyoming 82433 1-307-868-2354
CHAPTER 2 PAGE 13 COLUMN 1 PARAGRAPH 2
QUOTE "The chapter describes four resource management plan, alternatives, including BLMs
preferred alternative'
COMMENT: All the alternatives plus the preferred alternative were all developed by BLM with
no participation with impute by communities or groups So in actuality that leaves all the
alternatives and the preferred one with a limited point of view which is the BLMs, and not he
public*.
CHAPTER 2 PAGE 13 COLUMN 2 PARAGRAPH 1
QUOTE: "The Preferred Alternative, was developed to balance production of commodity uses
with protection of the environment".
COMMENT: The Preferred Alternative was developed with data that was extremely out of date,
and not with the in-depth research that should of taken place. Also the fuel that the community
groups, farmers, ranchers, gas & oil, people involved in recreation, and who ever else were not
involved in the beginning of the alternatives. Concerning commodity uses with protection of the
environment, today's farmer and rancher have the education and knowledge of many of the
development and uses, they applied it on their on land, and are applying it on public land. Lets
involve them more in the process they are not all stupid or uneducated.
CHAPTERS PAGE 14 COLUMN 2 PARAGRAPH 3
QUOTE: ■'Alternative and general management options that proposed maximum development,
protection, or protection of one resource at the expense of other resources were not
analyzed in detailed"
COMMENT: Why Not1 Something more beneficial could of come out toward developing the
other alternatives. Taking the short cut can allow you to come to a faster conclusion, but it also
doesn't always give you the best ways.
CHAPTER 2 PAGE 14 COLUMN 2 PARAGRAPH 3
QUOTE: "However, the alternatives analyzed in detailed do include various considerations for
eliminating or rnaxirnizing individual resources or uses in specific areas where conflicts
would otherwise exist".
COMMENT You can come to this conclusion because one has looked at these considerations
with the shortest way to the alternatives, and not with a total complete analyses
SUPPLEMENT TO PUBLIC HEARING
TESTIMONY BY TIM MORRISON
page 2
CHAPTERS PAGE 109 COLUMN 2 PARAGRAPH 5
QUOTE: "BLM has not acquired legal access on a majority of the roads currently listed on the
Wortand District Transportation Plan".
COMMENT: Why Not! An if not it should of been explained in the draft
CHAPTER 3 PAGE 1 1 1 COLUMN 2 PARAGRAPH 2 & 3
QUOTE: "Without considering the suitability the range land vegetation inventory for the plann-
ing area indicates allotment boundaries"
"These suitability adjustments were calculated for "I " (improve) BLM -
administered grazing allotments".
COMMENT: 1 believe if you read both quotes cor^dcring suitability, and how one comes up
with Their figures does not make sense. BLM did not really take a inventory of the land that they
are referring to. I question the judgment made on this issue
CHAPTER 3 PAGE 124 & 126 COLUMN 2 & 1 PARAGRAPH 7 & 1
QUOTE; "The Revised Universal Soil Loss Equation (Renard et al 1991) was used to estimate
gully and ,streambank".
"Erosion in the planning area is not limited to the sheet and rill erosion predicted by the
erosion would account for the remaining 75 percent".
COMMENT: When was the USOS "208 Water Quality Plan for the Big Horn Basin" done. The
dates should be presented so we have a better understanding on how to apply this information
towards alternatives if it is of recent date,
CHAPTER 3 PAGE 127 COLUMN 2 PARAGRAPH I
QUOTE: "The BLM has developed approximately 63 wells from formations including the Fort
Union, Mesa Verde, Lance, and Wilhwood. These formations yidd well water ranging
from 5 gallons per minute to more than 20 gallons per minute of suitable quality for
livestock and wildlife. Many wells are not functioning because of deterioration over
time".
COMMENT: How many wells are not functioning^ An if so why has the BIJvl not gone back to
re-hab the wells or develop others. If ranchers have access to these areas why hasn't the BLM
involve both the rancher and themselves in solving the problem
page 3
CHAPTER 3 PAGE 128 TO 131 "SURFACE WATER" THE WHOLE SECTION
COMMENT. Concerning data information is totally out of date or actually none is available
(1979tc 1086). Some ofthe conclusions are drawn on these limited facts. I'm not disagreeing
with some ofthe observations, what I disagree with is how the facts are drawn and how you come
to your conclusions. The last paragraph addressed various watershed treatments Why weren't
these maintained, and since most are not serving their original purpose, are they causing any
added problems in the area.
CHAPTER 3 PAGE 132 COLUMN 1 PARAGRAPH I
QUOTE: "Factors Affecting Forest Land Condition" "General Factors The forest land as a
whole is not producing up to capability because of stagnation, insect and disease
problems, old age and overall declining condition of stands".
COMMENT: Maybe one should re-look at this area as possibly being feasible to harvest and not
have it off limits, If one is concern about forest survival along with other environmental factors,
we should not allow this area to die because of in accessibility,
CHAPTER 3 PAGE 134 COLUMN 2 PARAGRAPH 2
QUOTE: "In 1976 an estimated SO acres were infested with noxious weeds Since that time
Russian knapweed has infested hundreds of acres along the Bighorn River and is
common along Gooseberry Creek, It is anticipated that other noxious weed species
and affected areas will be discovered".
COMMENT' Again data is being used that is out of date. What amount is infested with noxious
weeds and what are the different kinds'7
CHAPTER 3 PAGE 142 COLUMN 1 PARAGRAPH I
QUOTE: "Big Horn Sheep: Previously used habitate at Mudstone Ridge, Castle Rock, and the
Holy City is being studied to evaluate the potential for Big Horn Sheep rcintroduction"
COMMENT: Would that mean that this land would be token out of future use for production of
cattle and domesticated sheep What effect will this also have in hurting and other recreational
uses,
CHAPTER 3 PAGE 147 COLUMN 2 PARAGRAPH I
QUOTE "The planning area provides -nesting habitate for around 100 species of neo-tropical
migrant birds. The populations of most of these species are declining in part due to
habitat fragmentation on breeding grounds in the planning area"
559
COMMENT: what do you mean fragmentation on breeding grounds7 When statements like
these are made and sre not clarified or explained fingers start to poini in different directions on
who's fault it is.
CHAPTER 3 PAGE 147 COLUMN 2 PARAGRAPH!
QUOTE: "Raptor electrocution may still be a problem on $>
have been up graded to raptor-proof standards.
e of die older power lines but most
COMMENT How many power lines have not been up graded7 It has already been proven that
the old power lines were a major problem for raptors and that's why the up grading was being
done. Why has the BLM not given the power companies a mandatory time Until on the up grade
of power lines
CHAPTER 3 PAGE 149 COLUMN 2 PARAGRAPH 4
QUOTE: "Immediately upstream of Wardel Reservoir, imprison wildlife".
COMMENT The operation of this new reservoir, how much land will be taken out for public use
and for animal production What real effects will this have on the Wardel Reservoir and its fish
populations plus what effects to habitat down river .
CHAPTER 3 PAGE 150 COLUMN 1 & 2 PARAGRAPH 5 & 1
QUOTE: "With recovery of grizzly bear population .... increase'' -potential habitat for transient
bears would ... ..planning area"
COMMENTS: My concern is that the Grizzly Bear is moving into uncharted territory. What will
he the Bl.M's moves then, will it be in total favor of the Grizzly Bear, or on the side with the
Humans?
CHAPTER 3 PAGE ISO COLUMN 2 PARAGRAPH 2
QUOTE: "Northern Rocky-Mountain Gray Wolf During the past few years, evidence support-
ing the .. ... A recovery plan lor wolves in the Rocky Mountain planning
area".
COMMENT: There are two ways to look at this quote, one there are wolves in the area, and the
National Parks, and United States Forest Service really screwed up. Two the BLM wrote this
noting full well the wolves that are being reintroduced into the park will be leaving the area
(because the wolves haven't bothered to learn to read), and will be entering BLMs domain. So
what will happen to the ranchers with livestock in the area next door, will they be compensated if
damages have occurred. The big one is that they will now long be able to use the land because of
the endanger species in the area.
pageS
CHAPTER 3 PAGE 151 COLUMN 1 PARAGRAPH I &2
QUOTE: "Starting in the !950's, water control Big Horn River continues to be a major
concern" "Management actions should consider shed are interrelated". "The
variety of land uses respond in a cooperative way".
COMMENT: Why aren't these water control structures servicing there original purpose and since
they are not what effects have Ihey had on the areas that they are located7 When you say
"Management actions should are interrelated" are you going to take in the fact that the
BLM did not follow through with their obligation in raking care of the publics lands properly.
When you make a statement of "require individuals, organizations, and the BLM to respond in a
cooperative way" the only way I can honestly see this happen is when the BLM actually listens to
the people in the communities that are iD the vicinity of the public lands
CHAPTER 4 PAGE 151 COLUMN 1&2 PARAGRAPH 1, 1-4
QUOTE: "The inventory and protection inventories". "Many of Administration".
"These permits available to the public" "During the past 15 years,
management and recreational activities", "to activities of ,. analysis period"
COMMENT. When you talk about inventory and protection of cultural and palcontological
resources, and how "these inventories would be funded by oil companies, utility companies "
and then you go on to say how in the past it was 68 per cent were inventory because of gas & oil,
and mineral-related activities. Then the BLM goes on to state "Comparing the anticipated level of
future surface-disturbing activities to activities of the past 1 5 years, similar number of eligible sites
would be discovered during the analysis period" There seems to be a major conflict with the
statements presented by the BLM itself inside there own BLM Management Draft Plan that has
been presented to the public for comment. The plan is for total cut back on these activities, so
where is this funding coming from, and where are these discoveries going to occur when gas & oil
and related mineral activities are really no*» longer have access to these areas in the plan
^
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560
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Final Environmental Impact
Statement and Proposed Resource
Management Plan for Grass Creek
ELM LIBRARY
^ RS 150A BLDQ. 50
DENVER FEDERAL CENTER
P-O. BOX 25047
DENVER, CO 80225
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