USDA United States Department of Agriculture

Forest Service Intermountain Region

DRAFT RECORD OF DECISION Long Term Special Use Authorization for the Wyoming Game and Fish Commission to Use National Forest System Land for their Winter Elk Management Activities at Alkali Creek Feedground

January 23, 2015

Responsible Official Kathryn J. Conant Acting Forest Supervisor

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— -, _7I-’ Kathryn J. Conant Date Acting Forest Supervisor Record of Decision WinterElk Management Activities Supplement to the EJS

Background On July 15, 2008, the Forest Supervisor of the Bridger-Teton National Forest issued a Final Environmental Impact Statement (hereafter 2008 EIS) and signed a Record of Decision (ROD) concerning a Long Term Special Use Authorization for the Wyoming Game and Fish Commission (hereinafter “the Commission”) to use National Forest System land for their winter elk management activities. The 2008 EIS included analysis related to six existing feedgrounds and two new areas adjacent to a feedground on land owned by the Commission. In the 2008 ROD, the Forest Supervisor decided to authorize use of five of the existing feedgrounds but postponed the decision concerning authorization for Alkali Creek Feedground to allow for additional analysis. The Forest Supervisor directed the Jackson District Ranger to survey the Gros Ventre Wilderness boundary adjacent to this feedground and to cooperate with the Commission to perform a more detailed survey of vegetative effects inside the wilderness. This draft Record of Decision displays the draft decision for the Alkali Creek Feedground. A Final Supplemental Environmental Impact Statement (hereafter 2015 Final SETS),documenting the additional analysis performed for the Alkali Creek Feedground is being issued together with this draft ROD. The FSEIS can be found at http://www,fs.usda.gov/goto/btni7projects. Supplemental feeding of elk (Cervus elaphus) has been conducted in northwestern Wyoming since the early 1900s. The initiation of providing supplemental feed to elk was in response to large-scale winter die-offs, which were due in part to the loss of migration routes to suitable winter range and the direct loss of winter range due to rural development and fencing (Taylor 2001). Emergency feeding was documented as early as 1907 when a Pinedale game warden provided feed for 200 snowbound elk on Willow Creek; the Supervisor of the Teton National Forest secured funds to purchase the hay (Sheldon 1927; Brown 1947). A 1939 Wyoming statute designates the Commission’ liable for damages caused by big game animals. Many feedgrounds were established in the 1940s and 1950s to prevent elk from entering private lands and damaging stored crops. They have become an effective tool in reducing damage to haystack yards and winter pastures on private lands, and in reducing potential for transmission of brucellosis to livestock (Wyoming Game and Fish (WGFD) 2004). Elk feeding sites have been strategically placed on and near National Forest System lands with the intent of preventing elk migration through private lands that are located in historic big game winter ranges. Alkali Creek Feedground is situated such that it is critical for holding elk in the Gros Ventre River drainage that otherwise would end up overwintering on adjoining private agricultural lands or the National Elk Refuge. The U.S. Department of the Interior’s 2007 Bison and Elk Management Plan for Grand TetonNational Park and the National Elk Refuge sets an objective for having about 5,000 elk on feed on the National Elk Refuge, which at current herd populations cannot be met if substantial numbers of elk leave the Gros Ventre drainage. The Commission’s supplemental elk feeding activities occur during the winter months at 21 feedgrounds and one staging area. Attachment 1 displays a map of the 21 Commission managed feedgrounds, the staging area (North Piney) and the National Elk Refuge. Eight of the 21 feedgrounds are on National Forest System lands: Alkali Creek, Dell Creek, Dog Creek, Fall

A note on terminology: The Wyoming Game and Fish Commission is the policy making board of the Wyoming Game and Fish Department (WGFD) and is responsible for the direction and supervison of the Director of WGFD. The Commission, through efforts of WGFD provides a system of control, propagation, management, protection, and regulation of all wildlfe in Wyoming. Thus, the Commission is the entity that is currently authorized to use and occupy National Forest System land for feedground use on the Bridger-Teton National Forest, while WGFD is the State agency that implements the Commission’s management direction, including the acts of feeding, vaccinating and testing elk at feedgrounds.

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Creek, Fish Creek, Forest Park, Muddy Creek, and Upper Green River. Forest Service regulations require authorization for use and occupancy of National Forest System lands. The feedground that is the subject of this decision is located near Alkali Creek on the Jackson Ranger District, see Attachment 2. Alkali Creek Feedground is located within the Gros Ventre drainage northeast of the Town of Jackson within the Jackson Elk Herd Unit along with two other feedgrounds at Patrol Cabin and Fish Creek. The first special use permit for feeding in this area was issued to the Commission in 1947 for use of one acre of land east of the current Alkali Creek Feedground to construct and maintain a hay shed. Daily feeding at Alkali Creek, Patrol Cabin, and Fish Creek Feedgrounds started in the mid 1960’s (WGFD 2007). Alkali Creek Feedground was moved to its current location in 1976. Facilities and feeding areas at Alkali Creek and Fish Creek feedgrounds are located on National Forest System lands. Patrol Cabin Feedground is operated on land owned by the Wyoming Fish and Game Commission. Historically these feedgrounds were operated relatively independently of each other with little interchange of elk among the three feedgrounds. Feeding at Alkali Creek, Fish Creek, and Patrol Cabin prior to 1998 saw an average of 497, 764, and 490 elk at each feedground respectively. The average length of feeding was 98 days at Alkali and Fish Creek and 89 days at Patrol Cabin. Since that time, wolf activity has influenced elk distribution in the Gros Ventre, resulting in elk aggregating into one large group of up to 2,845 animals. These elk now have a propensity to congregate on one feedground, and move to another feedground in the drainage in response to wolf pressure. It should be noted though, that some groups of elk persist on native winter range in the Gros Ventre independent of the feeding operations. Decision and Reasons for the Decision Decision I am selecting Alternative 2 as described on pages 14 to 16 of the 2015 Final SETSwith the addition of required design feature 8. I am deciding to authorize the use of 91 acres of National Forest System land for the Commission elk management activities at Alkali Creek Feedground. Specifically, the WGFD, at the behest of the Commission, will maintain and operate one elk tagging corral, one horse corral, one tack shed, one haystack yard containing two hay sheds, spring and trough developments including protective fencing and piping, and a feeding ground associated with their ongoing winter elk management program. My decision means that the existing special use authorization issued to the Commission for use OfNational Forest System land for elk management activities at Dog Creek, Fall Creek, Fish Creek, Muddy Creek and Upper Green River Feedgrounds will be amended to add authorization for use at Alkali Creek Feedground. Attachment 2 displays the location and boundary of Alkali Creek Feedground. Required design features and monitoring that are part of my decision include: 1) Any hay or straw used in association with this permit will be certified and tagged as noxious weed or noxious weed seed free (Orders #04-00-056, and #02-96-02). The WGFD will use certified weed free hay to minimize the potential introduction of noxious weeds. The operation will comply with county ordinance where applicable.

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2) The WGFD will be responsible for monitoring and treating of noxious and invasive weeds within the permit area. Monitoring will occur annually. 3) In areas adjacent to the permitted area, WGFD will treat cheat grass invasions with integrated pest management techniques and reseed areas with native grass adjacent to the feedground where cheat grass is prevalent. Monitoring will occur annually. 4) Forest Service monitoring of soil disturbance class and percent detrimental soil disturbance will occur about every five years. 5) Feeding is not authorized to take place on the mapped wetland areas or within 100 feet of the outer edge of the wetlands and the channel that connects them. The WGFD will monitor the condition of the aquatic resources and vegetative conditions within the 100- foot buffer area approximately every five years, using monitoring protocols approved by the U.S. Forest Service. If the desired conditions are not achieved, additional measures will be considered and conducted consistent with requirements of the National Environmental Policy Act. 6) Feeding operations will be conducted over 18 inches of snow or frozen ground as much as possible to reduce the potential for soil compaction from feeding sleds and hoofed animals. 7) Operations of the WGFD must comply with the Bridger-Teton National Forest Food Storage Special Order (#04-00-104) year-round within the permit area. Forest Service staff will periodically (at least once/year) inspect the operation in the winter to ensure compliance with the order. 8) If chronic wasting disease is detected in Wyoming west of the Continental Divide the provisions of the WGFD Chronic Wasting Disease Management Plan will be implemented and the Bridger-Teton will intensify coordination with the WGFD and surrounding federal and state land management agencies concerning disease management actions.

Reasons for My Decision This decision relies upon environmental analyses and public involvement as documented in the 2015 Final Supplement to the Environmental Impact Statement (FSETS) which tiers to the original 2008 Final Environmental Impact Statement for Long Term Special Use Authorization for the Commission to Use National Forest System Lands for their Winter Elk Management Activities (2008 EIS). Changed circumstances and new information considered in the 2015 Final SETS include changes in species listed as Threatened or Sensitive, designation of Wild and Scenic Rivers, impacts to the Gros Ventre Wilderness, issuance of the Pronghorn Forest Plan Amendment, effects related to recent fire activity, current information related to wildlife diseases, and effects of changes in the Commission regulations. The 2015 Final SETS also includes updated environmental effects analyses based on updated specialist’s reports and more recent public comments that I have considered in this decision. Where there are discrepancies between information presented in the 2008 EIS and the 2015 SEIS, I relied upon the information presented in the 2015 FSETS because it incorporates changed conditions and newer scientific findings. Throughout this process the Forest Service has relied on best available science and in large measure there is not disagreement or opposing views about the basic scientific findings.

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The complications and disagreements arise from the application of this science to a complex landscape with multiple and often conflicting managerial, social, and political objectives. My decision meets the purpose and need by responding to the Commission’s request to continue to use facilities on National Forest System lands to conduct their winter elk management activities. Under 36 CFR 251.50, an authorization is required for all uses of National Forest System lands. This action is needed because the existing authorization will expire on December 31, 2015.

This decision is difficult and complicated, and is one that I have not taken lightly. Feeding as part of winter elk management in western Wyoming is an emotive and controversial issue, and for good reason. The management of elk in and around Jackson is set in our community’s history as well as in the ecology of Jackson Hole. Elk are an iconic species that represents both the wildness of Wyoming and the role that humans have taken in managing that wildness. No alternative, with or without feedgrounds, is without tradeoffs and consequences to wildlife, resources, and people. In spite of the impacts and tradeoffs, I make this decision knowing that there is a concerted effort among local, state, and federal agencies and the public they serve to restore historic migration routes, ensure the production and availability of natural winter range, protect private land from elk damage, and to address current and emerging wildlife disease issues.

I have the discretion to authorize or not authorize the use and occupancy of National Forest System lands for the purpose of winter elk management. I decided that continuing to authorize use of National Forest System lands for this feedground while encouraging and supporting the Commission in exploration of alternative ways to manage elk populations in northwest Wyoming is the prudent course of action. One of the Bridger-Teton National Forest Land and Resources Management Plan (Forest Plan) goals is to help communities continue or gain greater prosperity by helping to re-establish historic elk migration routes to provide increased viewing and hunting opportunities for outfitters and clients (page 112, Forest Plan 1990). I remain committed to this goal in the long term. Reestablishing historical elk migration routes will take the combined effort and cooperation of state and local agencies as well as private organizations and citizens. In some cases this may not be possible with the development pressure that has occurred since our Forest Plan was signed. Through efforts such as the Jackson Interagency Habitat Initiative and coordination with the National Elk Refuge, Grand Teton National Park, and the WGFD on development of the Adaptive Management Plan for the 2007 Bison and Elk Management Plan and the National Elk Refuge Comprehensive Conservation Plan, the Bridger-Teton National Forest continues to work with interagency partners on ways to reduce reliance on supplemental feeding and management of feedgrounds. My decision concerning Alkali Creek Feedground does not foreclose the options for seeking long-term alternatives to winter feeding, and those efforts will continue. As a part of this decision, I am directing my staff to review the management practices of all feedgrounds on the Bridger-Teton National Forest every five years and prepare a report recommending any needed changes. The first report should be filed no later than January 1, 2020. The reviewers should invite participation by personnel from the National Elk Refuge, Grand Teton National Park, and Yellowstone National Park, Bureau of Land Management, and the WGFD and the Commission Such a review should focus on identifying changing conditions, emerging and known threats, and recommending corresponding feedground management changes to ensure interagency cohesion with regard to the elk herds that use the feedgrounds on the Bridger-Teton National

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Forestand adjacent state, federal, and private lands. If chronic wasting disease is found in a herd unit west of the Continental Divide in Wyoming, reviews will be held more frequently and reports filed at least annually as the disease spreads through the Bridger-Teton National Forest. I clearly understand and acknowledge that the Commission’s action of feeding results in artificially high concentrations of elk during winter and early spring which increases risk of disease transmission (Johnson, 2014; Appendix 7; and Appendix 3 in the 2015 Final SETS).The Forest Service is working in cooperation with the Commission and other federal agencies to support brucellosis and other disease management efforts. It is the responsibility of the Commission to direct the management of wildlife populations, including studying and managing the potential for disease transmission and determining acceptable levels of disease prevalence and risk. I have reviewed the WGFD Brucellosis Management Action Plan for the Jackson elk herd (Project Record) and Chronic Wasting Disease Management Plan (2015 Final SEIS Appendix 3), in determining the potential effect of feedgrounds on disease transmission and prevalence. Feedgrounds on National Forest System lands reduce damage to haystack yards and winter pastures on private lands, maintain elk population numbers, and reduce commingling of elk and livestock that can lead to brucellosis transmission. The Alkali Creek Feedground is strategically placed to effectively gather elk as they transition from summer ranges down to lower elevations in the winter. Use of National Forest System land at Alkali Creek allows for lower numbers of overwintering elk at the National Elk Refuge and more effective management of elk movements to prevent commingling with livestock and damage to agricultural lands. If and when chronic wasting disease becomes established on the Bridger-Teton National Forest, there is a moderate to strong likelihood that the population limiting effects of chronic wasting disease to elk, mule deer, and moose may be hastened by supplemental feeding, which is why the Forest Service requested that WGFD convene an interagency working group to update contingency plans for the feedground portion of the WGFD Chronic Wasting Disease Management Plan. WGFD did convene such a group and it consists of staff from WGFD, Bridger-Teton National Forest, Grand Teton National Park, and the National Elk Refuge. The results of this group effort are expected to be released in July, 2015. As described in Appendix 7 of the 2015 Final SETS, the presence of feedgrounds, as a whole, is likely to increase the frequency and duration of contacts that may transmit chronic wasting disease from elk to elk, from elk to the environment and from the environment to other ungulate species. While the influence of feedgrounds as a whole on the transmission of chronic wasting disease is fairly evident, the influence of a single feedground is more difficult to discern. Recent literature indicates that population-level impacts to elk are likely with the arrival of chronic wasting disease in elk in western Wyoming; although there may be a time-lag between arrival and population-level impacts. Confounding factors, including the influence of feedgrounds and the presence and abundance of top predators make predicting the outcome of the arrival of chronic wasting disease in western Wyoming less clear. Elk in western Wyoming reside within a complex mosaic of lands that are managed in an interagency manner. It is important that chronic wasting disease be similarly managed in an interagency fashion. The nature of the pathology of chronic wasting disease, the biology and ecology of the landscapes involved, and the arrangement of different land jurisdictions with differing agency missions and management objectives require that solutions be collaborative and integrated in a holistic and adaptive fashion. Thus, as with feedgrounds, chronic wasting disease mitigations will require an even greater collaborative interagency effort to manage. I decided it would be inappropriate to act unilaterally on this issue, for example by selecting the No Action Alternative, given the potential

5 Record of Decision Winter Elk Management Activities Supplement to the EIS to displace impacts and conflicts and potential for unintended consequences to other state, private and federal jurisdictions. I recognize that authorization of feedgrounds results in browsing and mechanical damage that over the course of time has reduced historical distributions of aspen, sagebrush and willows, the effects of which are most apparent on the immediate environs of the feedground, but that can be measured in some locations to as far as 1 mile from the feedground. 1decided that the benefits of allowing WGFD to reduce wildlife conflicts on private lands and help achieve National Elk Refuge management plan objectives outweighs the limited vegetative impacts on National Forest System lands. Nonetheless, I am requiring management actions aimed at reducing impacts to wetlands and other resources in the vicinity of the feedground. These management actions include requirements to use weed-free hay and proper food storage, monitor and treat noxious and invasive plants, monitor soil disturbance, and a requirement that feeding only take place over frozen or snow covered ground and not within 100 feet of wetlands. I am requiring associated monitoring to ensure compliance with these actions.

I considered the potential effects to all wildlife, as described in Chapter 3 of the 2015 Final SEIS and find that with the exception of elk and other cervids susceptible to chronic wasting disease, the impacts from allowing use and occupancy of the feedgrounds is nominal. I reviewed the potential for soil compaction and erosion and find this disturbance is within acceptable limits as determined by the soils specialist using the best available science (Chapter 3, 2015 Final SEIS). Several of the management actions described above are intended to minimize future soil compaction and disturbance. Alkali Creek Feedground is located immediately north of the Gros Ventre Wilderness boundary. Although no feeding occurs in the Wilderness, the presence of the feedground does result in elk congregating in large groups within the Wilderness, especially in the forested north-facing stands that provide shade on warmer days and protection from wind and driving snow during blizzards. This concentration of elk does impact vegetation within the Wilderness. Wilderness is partly defined as an area retaining its primeval character and influence, which is protected and managed so as to preserve its natural conditions and which generally appears to have been affected primarily by the forces of nature (Wilderness Act of 1964, Section 2c). The use of the words “generally appears” and “affected primarily” recognizes that, while managers must constantly strive to minimize human interference with natural processes, the requirement to do so is not absolute. I carefully reviewed and considered the current and expected future effects on vegetation and wildlife on Wilderness character (as described in the FSEIS and the Project Record) and find that those effects are within acceptable limits. Notably, the overall composition, structure, and function of plant communities and natural processes are expected to be maintained within the Gros Ventre Wilderness. Forest Service managers have authorized and reauthorized the use of Alkali Creek Feedground for the past thirty years since the passage of the Wyoming WildernessAct (WWA) and the past twenty-five years since the Forest Plan was established. My decision to continue to authorize Alkali Creek Feedground uses current information to reaffirm that feedground operation at this location is in compliance with WWA and the Forest Plan. Please see further discussion concerning this topic in the “Compliance with Applicable Laws” section of this ROD.

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Public Involvement The Notice of Intent (NOl) to supplement the 2008 Environmental Impact Statement to provide additional information concerning Alkali Creek Feedground was published in the Federal Register on April 23, 2012. A news release concerning the NOT was provided to the Bridger Teton National Forest news release mailing list. Letters or email messages were sent to the parties expressing interest in this project and who received notice of the 2008 Record of Decision. During the subsequent 30 day comment period, 40 comment letters were received from individuals, businesses, organizations and agencies. My staff reviewed these comment letters used them to assist me in determining the appropriate scope of analysis. The scoping letter, mailing list, scoping comments received, and summary of comments are in the project file. A Notice of Availability (NOA) of the Draft SEIS was published in the Federal Register on April 19, 2013, and a legal notice of this availability was published in the Casper Star-Tribune April 24, 2013. A news release was published in the Jackson Hole News & Guide on April 16, 2013, describing the proposed use and inviting public comment. Letters or email messages were sent to parties who received notice of the 2008 Record of Decision and to those who responded to the project NOT.Public comment was accepted on the proposal from April 20, 2013 to June 3, 2013. Overall over 461 letters and other forms of correspondence were received from the public as well as state and federal agencies. Several of these letters contained supplemental reference material for consideration. Forest Service specialists reviewed this literature for its relevance to this decision and documented their determinations in responses to comments and in the project file. From these letters, 646 individual comments were identified. Some comments led the agency to supplement or change information that was displayed in the 2013 draft SETS. The potential environmental effects described in the comments were thoroughly analyzed and considered in the 2015 Final SETS. Agencies, organizations, or persons raising issues or asserting viewpoints in response to the NOT and NOA included other federal agencies such as the Environmental Protection Agency and the Department of the Interior, state agencies including the WGFD, and environmental conservation organizations including Western Watersheds Project, Wilderness Watch, Greater Yellowstone Coalition, and the Sierra Club. We also received comments and issues from outfitters and guides as well as landowners in the Gros Ventre area. Finally we received comments and issues from nearly 450 individual persons who provided addresses from across the United States and several foreign countries. From the scoping comments received in 2013 as well as in 2008, the project interdisciplinary team identified the following list of issues which helped determine the scope of the analysis. Issue #1. High concentrations of elk on Alkali Creek Feedground during certain soil conditions

could cause soil compaction and/or,increased erosion. ., Issue #2. Use of Alkali Creek Feedground concentrates the elk, which could result in impacts to vegetation from browsing and trampling causing changes in vegetation type and condition, especially in sagebrush, aspen, and willow stands associated with riparian/wetlands. These vegetaIion impacts could affect wilderness character in the Gros Ventre Wilderness, outstandingly remarkable values in the Gros Ventre Wild and Scenic River corridor, and/or pronghorn migration.

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Issue #3. Use of Alkali Creek Feedground concentrates the elk, which could reduce stream bank stability and result in impacts to stream channel function. Surface water quality and fish habitat may also be affected by bank instability via sediment delivery and increased water temperatures. Issue #4. Use of Alkali Creek Feedground could impact elk, wolves, scavengers, Canada lynx, grizzly bears, greater sage-grouse, and other wildlife species that utilize sagebrush and riparian habitat.

Public comments received supporting the No Action Alternative suggested that; 1) feeding is not needed, 2) artificially high elk populations are undesirable, 3) fencing and other methods of protecting private land and livestock are alternatives to feedgrounds, 4) the Forest Service could act independently of other state and federal agencies, 5) feeding should be gradually phased out, and 6) asked that the most current and relevant science be used in this decision. These viewpoints were considered and addressed in the Response to Comments (Appendix 8, FSEIS) and supplementary analysis or edits were included in the Final SETSwhere appropriate. The function of the feedground at Alkali Creek is not to simply feed the elk; rather the function is to prevent the elk from traveling downstream to the National Elk Refuge, Grand Teton National Park, and private lands. While winter feeding invariably increases elk populations, those population objectives are set by the Commission and agreed to by the Forest Service, as well as other federal agencies. Consideration of fencing and other alternatives to feedgrounds or phasing feedgrounds out indicated that those actions, particularly fencing around private land, would cause unacceptable impacts to other resources, and would fail to meet WGFD’s desired function of holding elk in the Gros Ventre area. The complex mosaic of land ownership in western Wyoming makes unilateral decision making with regard to elk impractical. This is why I am requiring my staff to continue and expand interagency coordination with regard to elk and their habitat as discussed in the Reasons for my Decision section of this ROD. With regard to the use of the most current and relevant science, a significant update to the chronic wasting disease section of the SETS was made in the final version. A much more thorough and nuanced disclosure of the interaction of feedgrounds and chronic wasting disease is included in the Final SETS and Response to Comments. Much of the additional literature considered regarding disease came as suggested reading from the Greater Yellowstone Coalition, the Western Watersheds Project. This analysis support helped my staff make a more complete and useful disclosure of impacts. In responding to comments and analyzing other issues a few themes were evident. Analysis by the Interdisciplinary Team confirmed that concentrated elk use and the feeding operation does compact the soil. Design features were included in the decision that are specifically designed to minimize soil compaction and erosion, such as requiring that feeding only take place over frozen or snow-covered ground. The impacts to aspen, shrubs, and other vegetation from concentrated elk were a concern, as were impacts to wetlands and water quality. Analysis by the Interdisciplinary Team indicated that while these impacts occur, those changes are within the limits of acceptable change for each resource and are largely operating under a status quo. Some comments pointed out possible interactions of the feedground with other wildlife, including pronghorn, wolves, and sage-grouse. Impacts to wildlife were analyzed and found to be within acceptable limits largely because impacts from Alkali Creek Feedground are localized. Public and internal scoping indicated that this decision should be consistent with the management of special areas including Wilderness and Wild and Scenic River corridors. As with impacts to vegetation elsewhere, the Interdisciplinary Team described impacts to natural conditions within

8 Record of Decision Winter Elk Management Activities Supplement to the EIS the Gros Ventre Wilderness associated with the Alkali Creek Feedground. Analysis of these changes indicates that they are within acceptable limits of change and the presence of Alkali Creek Feedground does not change the Wilderness character of the Gros Ventre Wilderness. The operation and impacts from Alkali Creek Feedground are a part of the baseline condition of the Gros Ventre Wild and Scenic River corridor at the time of designation and, as such, the decision to re-issue this permit does not represent a change in those conditions, particularly because current impacts are not expected to increase. By far the most common type of comment had to do with the role that feedgrounds play in the arrival and spread of wildlife disease. Comments indicated that brucellosis and chronic wasting disease were of particular concern and this concern led the Interdisciplinary Team to further analyze the interaction of feedgrounds and diseases of elk. This additional analysis, with particular emphasis on chronic wasting disease, describes how concentrating elk at feedgrounds increases the frequency and duration of potentially infectious contacts among elk and between elk and the environment. The arrival and spread of chronic wasting disease in elk in western Wyoming is likely to have population level impacts, after a time-lag, and the presence. of feedgrounds as a whole is likely to accelerate the spread of the disease. As mentioned previously, there are confounding factors that make the outcome of chronic wasting disease arrival and spread at Alkali Creek Feedground less clear, including the presence and abundance of top predators as well as the role of the feedgrounds as a whole. Alternatives Considered

Two alternatives were analyzed in detail in the 2015 Final SEIS. Alternative 1 is the environmentally preferred alternative.

• Alternative 1 — No Action - No Special Use Authorization: Under this alternative, use of National Forest System lands for WGFC winter elk management activities would not be permitted at Alkali Creek Feedground. WGFC would remove the existing facilities and re-habilitate impacts at this location. The WGFC has informed the Forest Service that under this alternative, they would continue to implement their winter elk management activities in the Gros Ventre with facilities and feedgrounds at Patrol Cabin and Fish Creek. U.S. Fish and Wildlife Service would also conduct winter elk management activities at the National Elk Refuge. • Alternative 2 - Proposed Action: Under the Proposed Action, the existing Special Use Authorization issued to the Commission for use of National Forest System lands for elk management activities at Dog Creek, Fall Creek, Fish Creek, Muddy Creek, and Upper Green River Feedgrounds would be amended for continuation of use of 91 acres of National Forest System lands for the Commission winter elk management activities at Alkali Creek Feedground. Specifically, WGFD would maintain and operate one elk tagging corral, one horse corral, one tack shed, one haystack yard containing two hay sheds, spring and trough developments including protective fencing and piping, and a feeding ground associated with their ongoing winter elk management program. Attachment 2 displays the location and boundary of Alkali Creek Feedground. Winter elk management activities include, but are not limited to feeding, capturing, vaccinating and testing elk, and removing seral positive elk from the population, traveling to and from the feedground, and delivering hay to storage sheds, and maintaining constructed facilities.

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• Alternatives considered but dismissed from further analysis: In addition to the alternatives analyzed in detail in the 2015 Final SETS,the Forest Service considered a larger range of alternatives, but eliminated them from detailed analysis because they did not meet the Purpose and Need of responding to the Commission’s request, fell within the range of alternatives analyzed in detail, or other reasons as specified below. This discussion is also contained in the Alternatives Considered but Dismissed section of the 2015 Final SETS. One of the alternatives considered but dismissed included reissuance of the Alkali Creek permit without modifications or additional design features. This alternative falls within the range of impacts analyzed in detail. In addition, the assessments conducted for changed conditions since 2008 as well as public scoping revealed that additional measures could be put in place to further minimize the potential for environmental impacts. Some commenters asked the Forest Service to develop an alternative that would improve winter range on the Bridger-Teton National Forest and then eliminate all elk feeding while restoring historical migration routes. Bridger-Teton National Forest managers have implemented and continue to improve summer and winter big game habitat through habitat improvement projects, use of wild land fire, improved travel management and reduction of motorized routes in critical habitat, removal of fencing hazards, and protection of migration corridors. However, the Forest Service does not have the authority to direct the Commission to stop all elk feeding outright. The Commission has informed the Forest Service they intend to continue to feed elk on private, state, or other federal lands, even if authorization is not issued for Alkali Creek Feedground on National Forest System lands. Because this activity would continue, my decision cannot affect several of the impacts associated with Commission’s winter elk management activities, including prevalence of disease or disruption of elk migration and other movements. Winter feeding, test and removal, and brucellosis vaccination of elk are management activities directed by the Commission who has jurisdiction over state wildlife. Under various authorities and departments, the state of Wyoming is also responsible for authorization of the taking of elk, whether it be for sport hunting, disease control for wildlife or agricultural purposes, or to reduce agricultural conflicts and other damage to private property. Some commenters recommended that, if I decide to issue an authorization for Alkali Creek Feedground, I should limit the term of the authorization to five years. The length of term of an authorization is an administrative decision that is not subject to the requirements of the National Environmental Policy Act (NEPA). I considered this recommendation, but decided instead to not change the term of the existing master special use permit that I intend to amend to add the Alkali Creek Feedground authorization. The master permit expires on 10/1/2028. I decided this because it would be more financially and administratively efficient for the Forest Service to use the longer term length. A new environmental analysis would be required in five years instead of thirteen years if I followed the commenter’s advice. The analysis performed for this effort has been very thorough and has involved a substantial investment of agency personnel time. A new environmental analysis is not needed within five years because the master permit includes the following provision which enables the Forest Service to make changes annually as needed to the feedground operations:

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• The Operating Plan will be reviewed annually, and the amendments to the Operating Plan would document those changes. • Changes will be considered which may be necessary to improve the ability of the WGFC to improve feeding operations or for the Forest Service to meet management objectives and direction. • Forest Service’s NEPA implementation guidance requires periodic reanalysis of decisions concerning ongoing projects and environmental documents. If new information or changed circumstances relating to environmental impacts of a proposed action come to our attention at any time during project implementation, we must consider and decide whether or not a correction, supplement, or revision to an environmental document is necessary. • Periodic review of the feedground operations on the Bridger-Teton National Forest will result in reanalysis of this decision if/when it is appropriate between now and 10/1/2028. An alternative to construct elk-proof fencing around private lands in the Gros Ventre drainage was dismissed due to its cost and impacts to other resources. This alternative is not supported by the private land owners that would be affected and I am not willing to unilaterally surround or isolate private lands within the confines of an elk proof fence. Such an alternative would not meet the function of preventing downstream movement of elk to the National Elk Refuge, Grand Teton National Park, or private lands. Further, such an alternative would potentially result in unnecessary environmental harm including impacts to wildlife other than elk and other natural resources. Fencing around private land as proposed during public scoping would be inconsistent with the Pronghorn Amendment and the Wild and Scenic Amendment to the Forest Plan. These amendments require the perpetuation of migration routes and maintenance of scenic qualities in the Gros Ventre River corridor. Fencing around private lands would not comply with development regulations of Teton County, Wyoming. The cost of constructing and maintaining this amount of fencing would be well above predicted future budget allocations. The Forest Service also considered and dismissed from detailed consideration the alternative of moving Alkali Creek Feedground to an alternate location to reduce effects in the Gros Ventre Wilderness. Alkali Creek Feedground was established in 1947 and moved to its current location in 1976 to reduce damage to haystack yards and winter pastures on private land and to reduce commingling of elk and cattle that could result in brucellosis transmission. Selection of the final site incorporated lessons learned over a period of decades of feeding at alternate locations within the Gros Ventre and was made in response to increasing human activity, snowmobiling in particular, along the Gros Ventre Road (WGFD 2006). The feedground is strategically located in the proximity of Alkali Creek to spatially contain elk before they move down the valley and onto private land in an area that is isolated from immediate disturbance from the Gros Ventre Road. Alkali Creek sits at a topographic bottleneck in the Gros Ventre River drainage and moving the feedground up or down stream would lessen its effectiveness in spatially containing elk and would thus be less likely to meet the feedground function. There is no alternate location in the near vicinity suitable for elk management activities that would reduce impacts on the Wilderness because the Gros Ventre Wilderness is located near any other feasible location which would meet the feedground function. Some of the alternate sites have perched water tables supporting vegetation that is not resilient to impacts and some are subject to direct disturbance from winter human activity along the Gros Ventre Road.

11 Record of Decision WinterElk Management Activities Supplement to the EIS

Compliance with Applicable Laws My decision is in compliance with the National Environmental Policy Act (Public Law 91-190). I considered all public comments on the Draft 2008 EIS and the Draft 2015 SETSregarding the analysis of potential environmental effects. I reviewed the scoping notice published in the Federal Register, the Project Record, the purpose and need for action, the list of issues, the range of alternatives, the quality and findings of the scientific analyses, and the projections made in the No Action Alternative. The 2015 Final SETSand this ROD are in compliance with NEPA per the Council on Environmental Quality regulations (40 CFRs 1500-1508) and direction in the Forest Service Handbook (FSH 1909.15). All practicable means to avoid or minimize environmental harm from the alternative selected have been built into this decision. Those means are discussed on pages 2 and 3 of this document.

My decision is in compliance with the Administrative Procedures Act (Public Law 89-554). I considered and responded to all public comments on the Draft 2008 EIS and Draft 2015 SETS.I have documented the rationale for my decision, alternatives considered, and compliance with applicable laws in this ROD. I reviewed the Project Record, including consideration of best available science, and believe that my decision is neither arbitrary nor capricious. My decision is in compliance with the National Forest Management Act (Public Law 94-588). The project was designed in conformance with Forest Plan standards and incorporates appropriate land use and resource management plan guidelines. My decision is consistent with forest-wide and specific management prescriptions, standards and guides in the Forest Plan associated with Desired Future Conditions 3C, 6A, 6B, 6C, 6D, and 12, that fall within the various cumulative effects areas as documented in the 2015 Final SETSand analyses by resource specialists (see the project file). The Bridger-Teton Forest Plan identifies four zones with differing management prescriptions for Wilderness; 6A through 6D. Management emphasis in 6A areas is for the protection and perpetuation of pristine biological conditions (Forest Plan, page 191). In 6B areas, management emphasis is to provide for the protection and perpetuation of natural biophysical conditions (Forest Plan, page 192). Management emphasis in both 6C and 6D areas is to provide for the protection and perpetuation of essentially natural biophysical conditions (Forest Plan, page 193 and 195). The area immediately south of Alkali Creek Feedground in the Gros Ventre Wilderness where vegetation is affected by large congregations of elk is located within a Forest Plan 6C management area. The resulting biophysical conditions are essentially natural, as described in the Project Record. My decision is in compliance with the National Historic Preservation Act (Public Law 89-665). A cultural resource survey for the Alkali Creek Feedground has been performed and the report has been reviewed by the Wyoming State Historic Preservation Office. A determination of “no historic properties affected” has been made and no further survey or mitigation is required. My decision is in compliance with the Endangered Species Act (Public Law 93-205). A Biological Assessment (BA) was prepared and is incorporated into the Wildlife Report as part of the analysis of the alternatives. Tn2013, my staff informally consulted with the U.S. Fish and Wildlife Service (USFWS) with regards to effects on three federally listed species. Findings of “may affect, not likely to adversely affect” were made for Canada lynx, Designated Critical Habitat for Canada lynx, and grizzly bear. As of September 2014, the experimental, non essential status of gray wolves in Wyoming on National Forests was re-instated. The short term effects of feedground management favor wolf predation because feedgrounds concentrate elk and make them readily accessible and predictable in location. However, the long term effects 12 Record of Decision WinterElk Management Activities Supplement to the EIS may include a reduction of elk numbers due to disease factors that will reduce prey availability for wolves. The Forest Service project biologist determined that the selected alternative “will not jeopardize the continued existence of the species” for gray wolf. My staff prepared and submitted a supplemental BA that describes effects on gray wolves to USFWS and is awaiting U.S. Fish and Wildlife concurrence on their determination. On October 3, 2014 the yellow-billed cuckoo was listed a Threatened species by the USFWS. A critical habitat designation for this species is also proposed, but does not overlap the Gros Ventre watershed. The project biologist analyzed the effects of the selected action on this recently listed species and determined that the project “may affect, not likely to adversely affect” the yellow-billed cuckoo, and would have no effect on its proposed Critical Habitat. This conclusion is based on (1) the absence of current or historic use of the Gros Ventre watershed by the species, (2) naturally-limited woodland nesting habitat in the area, and (3) spatially-limited effects of feedground elk on cottonwood and willow habitats that might also serve to support foraging or movement of migratory cuckoos. A description of effects to yellow-billed cuckoo is included in the supplemental BA submitted to USFWS. My decision is in compliance with the National WildernessSystemPreservation Act (Wilderness Act, Public Law 88-577) and the WyomingWildernessAct (WWA, Public Law 98-550). Alkali Creek Feedground is not within a designated Wilderness. The structures ued at Alkali Creek Feedground were constructed in the mid- to late-1970’s. The Gros Ventre Wilderness was formally designated in 1984 with the passage of the WWA. In the 2008 feedground decision, the Forest Supervisor postponed the decision concerning authorization for Alkali Creek Feedground to allow for additional analysis. The Forest Supervisor directed the Jackson District Ranger to order a survey of the Gros Ventre Wilderness boundary adjacent to this feedground and to cooperate with WGFC to perform a more detailed survey of vegetative effects inside the wilderness. The cadastral survey revealed that the Wilderness boundary was north Of the previously posted location. This resulted in the reduction of the then-existing Alkali Creek Feedground permit area by 14 acres, relocation of a motorized trailhead, and installation of a gate to better regulate unauthorized motorized travel. The vegetative effects survey indicated that aspen impacts in the Wilderness were less than assumed in the 2008 feedground analysis. The Wilderness Act and the WWA do not affect the jurisdiction or responsibilities of states with respect to wildlife and fish in the National Forests (Section 4(d) (7), Wilderness Act and Section 503 WWA). Section 504 of the WWA states that Congress does not intend designation of Wilderness areas to lead to the creation of protective perimeters or buffer zones around each Wilderness area. The fact that non-Wilderness activities can be seen or heard from within any Wilderness should not preclude such activities or uses up to the boundary of the Wilderness area (WWA, Section 504). FSH 2320.3(5) states that buffer strips of undeveloped wildland should not be maintained outside of wilderness to provide an informal extension of wilderness. As described in the Special Areas Report and 2015 Final SETS(pages 160 to 164), there are localized impacts to vegetation within the Gros Ventre Wilderness, but those impacts are within acceptable limits of change to maintain the composition, structure, and function of plant communities and natural processes within the Wilderness. My decision is in compliance with the Wildand Scenic Rivers Act (WSR, Public Law 90-542) and the Craig Thomas Snake Headwaters Legacy Act of 2008 (Public Law 111-11). The WSR Act does not affect the jurisdiction or responsibilities of the states with respect to fish and wildlife (Section 13, WSR Act). The Special Areas Report and 2015 Final SETS(pagesl6o to 164) documents that the alternatives considered would not affect water quality, conditions of free

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Record of Decision WinterElk Management Activities Supplement to the EIS flow, or the established outstandingly remarkable values of the designated Wild and Scenic Rivers in the Gros Ventre. The operation and impacts from the Gros Ventre feedgrounds, including Alkali Creek Feedground, were part of the 2009 baseline condition for the Wild and Scenic Designation under the Craig Thomas Snake Headwaters Legacy Act of 2008. Impacts to water quality from natural and induced trailing associated with Alkali Creek Feedground are thus part of the baseline condition for the Gros Ventre Wild and Scenic River designation. Findings Required by Other Laws and Regulations My decision is consistent with the following key laws, regulations, and requirements: Clean Water Act of 1977: This decision is consistent with the Clean Water Act and amendments. My decision will not affect the existing high quality water flowing through the area. Feeding activities occur over snow or frozen ground thus reducing potential for soil and vegetation impacts. No construction or ground disturbing activities within wetlands are involved and therefore no permit is required from the U.S. Army Corps of Engineers. No state permit for streambed alteration is required because no streambed alteration is involved in the project. Consistency with the 2005 Travel Rule: As a permitted activity, this decision complies with 36 CFR Parts 212, 251, 261, and 295 Travel Management; Designated Routes and Areas for Motor Vehicle Use. Based on the effects analysis, requirement to consider effects on soil, watershed, vegetation, wildlife and wildlife habitat “with the objective of minimizing” them is being met. The effects to these resources have been analyzed throughout the Final SETS.The road system accessing Alkali Creek Feedground and the surrounding area in the Gros Ventre drainage was analyzed in the 2009 FEIS for the Off-highway Vehicle Route Designation project, which is incorporated by reference. Executive Order 11988 of May 1977 (Floodplains): This order requires the Forest Service to provide leadership and to take action to (1) minimize adverse impacts associated with occupancy and modification of floodplains and reduce risks of flood loss, (2) minimize impacts of floods on human safety, health, and welfare, and (3) restore and preserve the natural and beneficial values served by flood plains. Based on discussions in Chapter 3 of the 2015 Final SETS,the 2014 Hydrology Report, and the Project Record concerning floodplains, the decision complies with EO 11998 by maintaining floodplain integrity. (Simon 2014) Executive Order 11990 of May 1977 (Wetlands): This order requires the Forest Service to take action to minimize destruction, loss, or degradation of wetlands and to preserve and enhance the natural and beneficial values of wetlands. In compliance with this order, Forest Service direction requires that an analysis be completed to determine whether adverse impacts will result. Based on discussions in Chapter 3 of the 2015 Final SETS,the 2014 Hydrology Report, and the Project Record concerning wetlands, the decision complies with EO 11990 by maintaining and restoring riparian conditions (Simon 2014). Additionally, the analysis states that the two wetlands within the Alkali Creek Feedground will not be destroyed, lost, or permanently degraded by my decision. Executive Order 13186 of January 2001 (Migratory Bird Treaty Act): This Act requires the Forest Service to provide for the protection of migratory birds. High priority migratory bird species breeding habitats are analyzed and discussed in the effects analysis chapter of the 2015 Final SETS.Based on discussions in Chapter 3 of the SETSand the Project Record, my decision complies with EO 13186 by providing for protection of migratory birds.

14 Record of Decision Winter Elk Management Activities Supplement to the EIS

Executive Order 13112: This decision incorporates the implementation of a weed management plan. My decision will therefore not increase the spread of invasive plant species. Prime Farmland, Ran geland and Forest Land: There is no prime, farmland affected by the project. This project is located in the Upper Gros Ventre grazing allotment. There is no conflict between the Commission’s use and the livestock permittee’s use of these National Forest System lands because they occur in different seasons of the year.

Civil Rights Act of 1964 — There would be no adverse effects to groups or individuals protected under the federal Civil Rights Act. Executive Order 12898 (Environmental Justice): This decision was assessed to determine whether it would disproportionately impact minority or low-income populations, in accordance with Executive Order 12898. No minorities or low-income populations were identified during public involvement activities that would be affected by this decision. Violating Federal, State and Local Laws: My decision does not violate any federal, state or local laws or requirements for the protection of the environment. Treaty Rights: This decision does not conflict nor affect any Treaty Rights. The relationship of the U.S. Government with American Indian tribes is based on legal agreements between sovereign nations. In June 1867, an Executive Order established the Fort Hall Indian Reservation, as a collective place to consolidate the various bands of Shoshones and Bannocks from their aboriginal lands. The United States then signed the Fort Bridger Treaty of 1868 with Shoshone and Bannock Chiefs and Headmen. Today, descendants of the Lemhi, Boise Valley, Bruneau, Weiser and other bands of Shoshoni and Bannock reside on the Fort Hall Indian Reservation. Tribal members continue to exercise off reservation treaty rights, and return to aboriginal lands to practice their unique culture and traditions. The 1868 Fort Bridger Treaty reserves the right to continue traditional activities on all unoccupied lands of the United States for hunting, fishing, and gathering of resources for subsistence purposes. Opportunity to Object This draft decision is subject to the objection process pursuant to 36 CFR 218 subparts A and B. Objections will be accepted only from persons who have previously submitted specific written comments regarding the proposed project either during scoping or during other designated opportunities for public comment (36 CFR 218.5). Issues raised in objections must be based on previously submitted timely, specific written comments regarding the proposed project unless based on new information arising after designated opportunities. Individual members of organizations must have submitted their own comments to meet the requirements of eligibility as an individual, objections received on behalf of an organization are considered as those of the organization only. If an objection is submitted on behalf of a number of individuals or organizations, each individual or organization listed must meet the eligibility requirement of having previously submitted comments on the project (36 CFR 218.7). Names and addresses of objectors will become part of the public record. Incorporation of documents by reference in the objection is permitted only as provided for at 36 CFR 218.8(b). Minimum content requirements of an objection are identified in 36 CFR 218.8(d) and include:

15 Record of Decision WinterElk Management Activities Supplement to the EIS

• Objector’s name and address with a telephone number if available; with signature or other verification of authorship supplied upon request; • Identification of the lead objector when multiple names are listed, along with verification upon request; • Name of project, name and title of the responsible official, National Forest/Ranger District of project, and • Sufficient narrative description of those aspects of the proposed decision objected to, specific issues related to the project, how environmental law, regulation, or policy would be violated, and suggested remedies which would resolve the objection. • Statement demonstrating the connection between prior specific written comments on this project and the content of the objection, unless the objection issue arose after the designated opportunities for comment. Written objections, including any attachments, must be sent via regular mail, fax, email, hand- delivery, or express delivery within 45 days following the publication date of this legal notice in the Casper Star-Tribune to: Objection Reviewing Officer, USDA-Forest Service Intermountain Region, 324 25th Street, Ogden, UT 84401 (36 CFR 218.7)

The office business hours for those submitting hand-delivered objections are: 8 a.m. to 4:30 p.m., Monday through Friday, excluding holidays. Electronic objections must be submitted in a format such as an email message, pdf, plain text (.txt), rich text format (.rtf), and Word (.doc or .docx) to: objection-intermtn-regional-officefs.fed.us. Faxed appeals should be sent to (801) 625- 5277. Objectors are responsible for ensuring that their objection is received in a timely manner (36 CFR 218.9). The publication date in the Casper Star-Tribune, which is the newspaper of record, is the exclusive means for calculating the time to file an objection of this draft decision. Persons wishing to object to this draft decision should not rely upon dates or timeframe information provided by any other source. Extensions of the objection period are not permitted (36 CFR 218.9). When the objection filing period has ended and responses have been made to all objections by the reviewing officer, the responsible official may make a final decision on the proposed project. The reviewing officer shall issue a written response to objectors within 45 days following the end of this objection-filing period (this may also be extended by the reviewing officer up to 30 days) (36 CFR 218.26). Implementation Date If no timely objections are filed, a decision can be made on the 5th business day following the close of the filling period. Implementation may begin immediately after the decision is made (36 CFR 218.12). Contact Person For additional information concerning this draft decision or the objections process, contact District Ranger Dale Deiter at the JacksOnRanger District Office, P0 Box 1689, 25 Rosencrans Lane, Jackson, Wyoming, 83001 or by phone or email at 307-739-5410 or ddeiter(iIfs.fed.us.

16 Record of Decision Winter Elk Management Activities Supplement to the ElS

References Cited

Brown, R.C. 1947. The Jackson Hole Elk Herd. Wyoming Wildlife XI (12):4-l 1, 29-32 Johnson, T. 2014. Chronic Wasting Disease Literature Review Technical Report. Appendix # of Final Supplement to the Environmental Impact Statement Long Term Special Use Authorization for Wyoming Game and Fish Commission to Use National Forest System Lands for their Winter Elk Management Activities at Alkali Creek Feedground. Sheldon C. 1927. The Conservation of the Elk of Jackson Hole, Wyoming: A Report to Hon. Dwight F. Davis, the Secretary of War, Chairman of the President’s Committee on Outdoor Recreation, and Hon. Frank C. Emerson, Governor of Wyoming. Washington, D.C.: National Conference on Outdoor Recreation. Simon, R. 2014. Alkali Feedground Hydrology Resource Report. Taylor, M. 2001. Project Seedskadee. Prepared for Wyoming Wildlife Federation, 38 pages. U. S. Forest Service. 1990. Bridger-Teton National Forest Land and Resource Management Plan. U.S. Department of Agriculture, Region 4 Bridger-Teton National Forest, Jackson, Wyoming. 396 pages. Wyoming Game and Fish Department. 2004. Elk Feedgrounds in Wyoming. Wyoming Game and Fish Department, Pinedale, Wyoming. 25 pages. Wyoming Game and Fish Department. 2006. Evaluation of a Proposal from the Wyoming Outdoor Council, Greater Yellowstone Coalition and Jackson Hole Conservation Alliance for a Phase Out of Elk Feeding in the Gros Ventre, Pinedale, Wyoming. 37 pages. Wyoming Game and Fish Department. 2007. A Technical Report on Elk Feedground Vegetation Effects. Unpublished report. November 26, 2007. Report on file, Pinedale, Wyoming.

The U.S. WGFD of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color; national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisa or because all or part of an individual’s income is derived from any public assistance. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large prini audiotape, etc.) should contact USDA’s TARGET Center at 202-720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director; Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC 20250-9410 or call toll free (866) 632- 9992 (voice). TDD users can contact USDA through local relay or the Federal relay at (800) 877-8339 (TDD) or (866) 377-8642 (relay voice). USDA is an equal opportunity provider and employer.

17 Record of Decision Winter Elk Management Activities Supplement to the EIS

Attachment 1. Elk Feedground Locations

WYOMING FEEDGROUND LOCATIONS

ALKALI BENCH CORRAL BLPCK BUTTE CAMP CREEK DELL CREEK DOGCREEK FALLCREEK FlN’E GAN FiSH CREEK FORESTPARK FRPi.JZ GREYS RIVER PATROL CABIN HORSE CREEK J EWETT MCNEEL MUDDYCREEK NADONAL ELK REFUGE NORTH PINEY SCAB CREEK SODA LAKE SOUTH PARK UPPER GREEN RIVER

18 Record of Decision Winter Elk Management Activities Supplement to the EIS

Attachment 2. Map of the Alkali Creek Feedground and Associated Structures Alkali Creek Feedground

Gros Ventre.

J.

Water I elopment\

. Shed— ed s

Legend

AlkaliCreek Feedground Gros Ventre Wilderness

0 500 1.000 2000

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