4.5.2.3. Detailed Analysis of Alternatives

Allowable uses and management actions that impact paleontological resources include all surface-disturbing activities, changes in ownership, visitor accessibility, motorized vehicle use, and proactive paleontological resource management actions.

Impacts Common to All Alternatives

Potential impacts to paleontological resources as a result of other resource management actions are similar, although the intensity varies across alternatives. For all alternatives, impacts may stem from any surface-disturbing activity in an area where fossils are known or found to be present.

Similarly, paleontological resources would experience beneficial impacts from proactive management actions common to all alternatives. Although the degree of protection may vary by alternative, the goals of such management are the same for each alternative. For example, positive interaction with the public to prevent illegal activities and project reviews to avoid scientifically important paleontological resource sites are management priorities that result in beneficial impacts. The latter action will allow the avoidance of surface-disturbing activities that could damage or destroy significant paleontological values on BLM-administered land, including resources listed in National Park Service inventories of possible National Natural Landmarks. Other proactive, beneficial impacts across all alternatives come from balancing restrictions on access to newly discovered paleontological resources with opportunities for the public to collect fossils in a limited, recreational manner. This is accomplished through the management of scientifically significant paleontological resources for scientific and public use.

The recently enacted PRPA provides a new level of protection for paleontological resources (see Section 3.5.2 Paleontological Resources in Chapter 3). The interface of this law with BLM guidance is under development, and it remains to be seen specifically how it will affect the management of paleontological resources under BLM jurisdiction.

Brown/Howe Dinosaur Area ACEC, which the BLM manages for its paleontological values, appears under all alternatives. The management of and impacts from the management of this and other ACECs that include paleontological resources is mentioned in this section, but discussed in detail in Section 4.7.1 Areas of Critical Environmental Concern.

Alternative A
Surface Disturbance

Under Alternative A, surface-disturbing activities may result in impacts to paleontological resources. The BLM anticipates that impacts to paleontological resources from surface disturbance under Alternative A (see Appendix T) would be primarily adverse. However, required resource identification through on-the-ground survey of PFYC 5 and case-by-case for PFYC 4 before surface-disturbing activity will identify resources, and may mitigate adverse impacts, possibly resulting in data collection or preservation of paleontological resources, which would result in a beneficial impact. Once a paleontological locality is identified, Alternative A requires a 50-foot-wide buffer to preclude any surface-disturbing activities from damaging the locality.

Restrictions on surface-disturbing activities for the protection of other resources (such as soil, water, biological resources, and special designations) under Alternative A may provide additional protection for paleontological resources, because management that limits the potential for disturbance would result in beneficial impacts.

Resource Uses

Exploration for and development of locatable minerals, leasable minerals, and mineral materials would result in adverse impacts. Impacts would be direct, if exploration for or development led to disturbance of the paleontological resource, or indirect, if a road or other associated activity improved access to an otherwise inaccessible locale. However, mineral exploration or development activity also would lead to beneficial impacts, because discovery, improved access, and avoidance would eventually result in the opportunity to study previously unknown fossils and to educate the public.

Management actions associated with lands and realty would result in adverse and beneficial impacts. The BLM anticipates potential beneficial impacts under Alternative A, wherein the acquisition and retention of lands with significant paleontological resources is to be considered, but is not pursued as an active management strategy. However, if lands with important paleontological resources are disposed of and leave federal management, there may be adverse impacts because these areas would no longer be subject to the PRPA and other federal laws and regulations designed to protect these resources.

Impacts from linear resource uses (e.g., ROWs, corridors, and road development) and renewable energy development are similar, and may result in direct adverse impacts from surface disturbance associated with development. Indirect impacts arise from increased accessibility and resulting increased recreation use provided by the corridors and associated development. These activities may result in beneficial impacts if the development results in the discovery of resources or research and educational opportunities.

Off-road motorized vehicle use on public lands has the potential to directly and indirectly affect paleontological resources. Direct impacts occur when vehicles run over exposed fossils on a trail; indirect impacts result from accelerated erosion and degradation due to exposure. In addition, off-road motorized vehicle use enables access to remote paleontological localities, and would increase opportunities for theft and vandalism. While there may be adverse impacts due to off-road or inappropriate use of motorized vehicles under any circumstances, restricting motorized vehicle use in certain areas would provide some protection for sensitive resources. The BLM anticipates that Alternative A would result in disturbance associated with motorized vehicle use, which would have the potential to adversely affect paleontological resources in areas such as the Bighorn Slope, Bridger, Owl Creek, and Absaroka foothills. Recreation would result in adverse and beneficial impacts to paleontological resources. Increased use of the Planning Area and an increase in the number of recreational collection permits would increase the potential for damage to paleontological resources; an increase in opportunities to improve education and paleontological interpretation would benefit the resources.

Special Designations

Under Alternative A, the BLM manages four ACECs, including the Brown/Howe Dinosaur Area ACEC, for their paleontological values. For the Little Mountain ACEC, management would emphasize avoidance of sensitive areas, provide some restrictions for mineral development, and pursue withdrawal from appropriation under the mining laws in limited areas within the ACEC. Under Alternative A, the BLM also manages the Red Gulch Dinosaur Tracksite and Big Cedar Ridge areas as ACECs, limiting surface disturbance and providing other protections to paleontological resources in these areas.

Resources

The BLM anticipates surface disturbance associated with prescribed fire and mechanical fuels treatment under Alternative A. Actions related to fire and fuels management may result in adverse impacts to paleontological resources. Construction of fire breaks can cause surface disturbance, which may damage or destroy important fossils. However, there may also be beneficial impacts if the disturbance exposes previously unknown resources or improves access for study. Surface disturbance related to fire and fuels management would result in fewer impacts to paleontological resources than other types of surface disturbance, because it is less likely to penetrate deeply into strata that contain important resources.

Proactive Management

Under Alternative A, management actions that aid in the identification and preservation of scientifically important fossils include attachment of standard Paleontological Resources Protection Stipulations to surface-disturbing activities on PFYC 3, 4, or 5; retention and acquisition of lands for significant paleontological resources (although this is on a case-by-case basis); and development of additional interpretive sites. Under Alternative A, development of interpretive sites at informational locations is on a case-by-case basis. Surface disturbance associated with development of the interpretive site may result in adverse impacts to the paleontological resources. However, the public would benefit from development of this educational exhibit. Potential impacts from this management illustrate the dichotomy between the adverse impacts of direct disturbance and increased access, and the beneficial impacts of education and discovery.

Alternative A also includes several management actions, all of which are applied on a case-by-case basis, designed to protect paleontological values from actions not related to resource use, such as theft and vandalism. These management actions include closing areas with vertebrate or other scientifically significant paleontological resources at risk for damage from illegal activities and implementing on-the-ground surveys before surface disturbance or land disposal actions for all PFYC 5 formations and PFYC 4 formations on a case-by-case basis.

Alternative B
Surface Disturbance

Alternative B includes the least acreage subject to surface-disturbing activities. Therefore, surface disturbance under this alternative would result in the least impact to paleontological resources. Similar to Alternative A, impacts to paleontological resources from surface disturbance projected for Alternative B may be primarily adverse. However, an increase in resource identification due to on-the-ground surveys of PFYC 3 through 5 before surface-disturbing activity would result in a beneficial impact because it would identify more resources, and may mitigate adverse impacts or result in data collection and preservation of paleontological resources. Alternative B also requires a 100-foot–wide buffer around paleontological localities to preclude any surface-disturbing activities, providing greater protection than the other alternatives.

Alternative B includes the most restrictions on surface-disturbing activities for the protection of other resources, thereby resulting in more beneficial impacts than the other alternatives.

Resource Uses

As with Alternative A, exploration for and development of locatable minerals, leasable minerals, and mineral materials are likely to result in direct and indirect adverse impacts from disturbance and improved access. However, because Alternative B would result in less surface disturbance associated with minerals development, it also would result in fewer impacts to paleontological resources compared to the other alternatives. Making greater sage-grouse Key Habitat Areas administratively unavailable to mineral leasing would result in indirect beneficial impacts by limiting the potential degradation of paleontological resources in these areas.

Management actions associated with lands and realty would result in adverse and beneficial impacts. The greatest benefit would result from alternatives B and D, under which the acquisition and retention of lands with significant paleontological resources is to be actively pursued. The least benefit would be under Alternative A, under which acquisition and retention of lands with significant paleontological resources is only considered and, lastly, under Alternative C, under which no acquisition of private lands is planned.

Impacts from ROW-related actions and renewable-energy resource development would be fewer under Alternative B than under the other alternatives. Impacts from trails management and recreation under Alternative B would be similar to those under Alternative A, but to a lesser degree. Alternative B is projected to result in more surface disturbance from cross-country motorized travel in small, localized areas (Appendix T), but limits motorized vehicle use to designated roads and trails and closes more area to motorized vehicle use in the Planning Area. Limiting motorized vehicle use to designated roads and trails in the Bighorn Slope, Bridger, Owl Creek, and Absaroka foothills, and the Absaroka Front Management Area (partially closed to motorized vehicle use) would reduce potential disturbance and restrict access, thus decreasing the risk of looting. As with the other alternatives, the potential for beneficial impacts through discovery and subsequent research and educational opportunities would remain.

Special Designations

Alternative B designates eight ACECs for paleontological values and increases the size of several existing ACECs. For the Little Mountain ACEC, management under Alternative B is similar to Alternative A, with the addition of an expansion area. The Brown/Howe Dinosaur Area ACEC is maintained across all alternatives, but under Alternative B it would be administratively unavailable for mineral leasing, managed as ROW avoidance/mitigation, and the BLM pursues a withdrawal from appropriations under the mining laws. For the Red Gulch Dinosaur Tracksite and Big Cedar Ridge ACECs, management under Alternative B would be the same as under Alternative A. Alternative B also would add four ACECs with paleontological values – Clarks Fork Basin/Polecat Bench West Paleontological Area, McCullough Peaks South Paleontological Area, Foster Gulch Paleontological Area, and Rainbow Canyon Paleontological Area. Section 4.7.1 Areas of Critical Environmental Concern further discusses the management of and impacts from ACECs.

Resources

Actions related to fire and fuels management are anticipated to have an adverse impact on paleontological resources. Projected impacts are less under Alternative B than under the other alternatives.

Proactive Management

Proactive management under Alternative B provides the most protection for paleontological resources of any alternative. This management includes protection for PFYC below 4 and 5, larger buffer zones around important paleontological discoveries and sites, and prohibitions on surface disturbance. Alternative B also provides more protection for vertebrate or other scientifically significant paleontological values from actions related to non-resource use (e.g., theft and vandalism) compared to the other alternatives through the use of measures such as increased law enforcement and resource specialist presence in areas of high resource values and posting additional signs warning against illegal collection. Alternative B also includes management actions requiring the BLM to pursue opportunities to acquire private lands with vertebrate or other scientifically significant paleontological resources, actively solicit paleontological research, and sponsor data sharing and symposia. While management under Alternative B designates areas for casual use and collection of certain fossil types, it also seeks to minimize the development of interpretive sites in the Planning Area.

Alternative C
Surface Disturbance

The BLM anticipates that Alternative C would result in the most short-term and long-term surface disturbance. Therefore, this alternative would result in the most adverse impacts to paleontological resources of any alternative. Projected impacts to paleontological resources from surface disturbance under Alternative C (Appendix T) are anticipated to be similar to those described for Alternative B, although to a greater extent and intensity. The BLM requires on-the-ground surveys before it approves surface-disturbing activities, and monitoring of surface-disturbing activities in PFYC 5 formations, which would provide some mitigation of adverse impacts and may result in beneficial data collection or the preservation of paleontological resources.

As with the other alternatives, restrictions on surface-disturbing activities for the protection of other resources (e.g., soil, water, biological resources, and special designations) would protect paleontological resources, although the more limited nature of these protections under Alternative C would result in the least additional protection of any alternative.

Resource Uses

Impact from the exploration for and development of locatable minerals, leasable minerals and mineral materials would be greater under Alternative C than the other alternatives due to more projected surface disturbance. Monitoring is only provided for actions in PFYC 5, and standard Paleontological Resources Protection Stipulations are only attached to surface-disturbing activities in PFYC 4 or 5. Once a paleontological locality is identified, Alternative C requires a 50-foot-wide buffer, as does Alternative A. As with the other alternatives, resource use may also have a beneficial impact if discovery, improved access, and avoidance lead to the opportunity to study previously unknown fossils and to educate the public.

Management actions associated with lands and realty would result in adverse and beneficial impacts. The potential beneficial impact is similar to that under Alternative B, under which the BLM retains lands with important paleontological values. However, under Alternative C, there would be no beneficial impacts from acquisition of lands with significant paleontological resources, as described for Alternative B.

Impacts from linear resource uses such as ROWs, corridors, and roads, and from renewable-energy resource development, would be greatest under Alternative C. Management under Alternative C includes relatively few restrictions on ROW development and associated surface-disturbing activities, increasing the chance of direct and indirect impacts to paleontological resources. However, although the area affected by this management is larger under Alternative C, it is not likely that the corresponding beneficial impact also would be larger, because the magnitude of the increased use would probably not be balanced by a corresponding beneficial gain in knowledge and resource discovery. A similar adverse-to-beneficial impact imbalance would occur in the management of recreation and motorized vehicle use, because the magnitude of the increase in visits and traffic may outweigh the increase in knowledge gained. Restricting motorized vehicle use to designated roads and trails in the Bighorn Slope, Bridger, Owl Creek, and Absaroka foothills and the Absaroka Front Management Area would result in similar impacts to those under Alternative B.

Special Designations

Special designations under Alternative C would result in the least overall beneficial impact to paleontological resources. Alternative C does not designate any ACECs with paleontological values other than the Brown/Howe Dinosaur ACEC, which is designated under all alternatives. Paleontological resources in the Little Mountain, Red Gulch Dinosaur Tracksite, Big Cedar Ridge and other areas designated as ACECs under the other alternatives would be at a higher risk of degradation under Alternative C.

Resources

The area potentially affect by management of fire and fuels under Alternative C is projected to be twice that of Alternative A, and therefore likely to result in more adverse impacts to paleontological resources. Although beneficial impacts also are possible, the increased potential for adverse impacts would outweigh the benefits.

Proactive Management

Under Alternative C, some current management practices would continue. However, focus would shift to reactive investigations, such as implementation of the PFYC system for permits exceeding 5 acres and survey and monitoring in PFYC 5 formations. The BLM attaches Standard Paleontological Resources Protection Stipulations to authorization of surface-disturbing activities only for PFYC 4 or 5. Protection of significant paleontological values from theft and vandalism would be the same as for Alternative A, resulting in similar beneficial impacts. As for alternatives B and D, under Alternative C the BLM retains public ownership of lands with important paleontological values, but does not seek to acquire additional lands with important fossils. Under Alternative C, the BLM actively develops paleontological interpretive sites, resulting in impacts similar to those described for Alternative A, although to a greater degree.

Alternative D
Surface Disturbance

The BLM anticipates that Alternative D would result in slightly more surface disturbance and associated adverse and beneficial impacts to paleontological resources than Alternative A. However, the amount of surface disturbance varies by resource use, and certain resource uses that adversely affect paleontological resources (e.g., mineral development) would be similar to or disturb less area than Alternative A. New roads and trails, primarily associated with user-pioneered routes in areas designated as open to cross-country motorized travel, are anticipated to result in the largest increase in surface disturbance under Alternative D. Before surface-disturbing activity, on-the-ground surveys of PFYC 3 through 5 will be performed on a case-by-case basis, which would identify resources and may mitigate adverse impacts. This management also may result in beneficial impacts to data collection or preservation of paleontological resources, which would result in a beneficial impact. Surface-disturbing activities are allowed within at least 100 feet of the outer edge of a paleontological locality if the impacts can be adequately mitigated, in contrast to the other alternatives, which prohibit surface-disturbing activity within a certain buffer width of a paleontological locality.

Resource Uses

Minerals development under Alternative D would result in impacts similar to but slightly less than Alternative A, resulting in fewer impacts to paleontological resources. Limitations on mineral leasing in Key Habitat Areas for species such as greater sage-grouse would result in indirect beneficial impacts by limiting potential degradation of paleontological resources in these areas.

Under Alternative D, management actions associated with lands and realty are the same as under Alternative B, including the retention of BLM-administered land with significant paleontological values and the pursuit of acquisition of private lands with such resources. Impacts from ROW-related actions and renewable-energy resource development would be similar to those described for Alternative A, though to a lesser degree.

Impacts from trails management and recreation under Alternative D would be more than under alternatives A and B, but less than under Alternative C. Alternative D is projected to result in more surface disturbance from cross-country motorized travel in small, localized areas than alternatives A and B (Appendix T). CTTM designations under Alternative D are similar to those under Alternative A, but limiting off-road travel for big-game retrieval to within 300 feet of roads would limit route proliferation and the associated impacts to paleontological resources. As with Alternative B, limiting motorized vehicle use to designated roads and trails in the Bighorn Slope, Bridger, Owl Creek, and Absaroka foothills, and the Absaroka Front Management Area (partially closed to motorized vehicle use) would limit potential disturbance and restrict access to decrease the risk of looting. As with the other alternatives, there would be a potential under Alternative D for beneficial impacts through discovery and subsequent research and educational opportunities.

Special Designations

Under Alternative D, the BLM would manage four areas as ACECs for paleontological values. For the Little Mountain ACEC, management is similar to Alternative A, but with portions managed as administratively unavailable to oil and gas leasing. The BLM would manage the Brown/Howe Dinosaur Area ACEC under all alternatives, but under Alternative D would manage it as VRM Class III, allow ROW authorizations and other surface-disturbing activities following on-the-ground surveys before approving such activities or land disposal activities, and monitor surface-disturbing activities for PFYC 3 through 5 formations. For the Red Gulch Dinosaur Tracksite and Big Cedar Ridge ACECs, management under Alternative D is the same as under Alternative A. The Rainbow Canyon Paleontological Area, proposed under Alternative B, is not managed under Alternative D, and the beneficial impacts from BLM management described for Alternative B would not occur. Three areas proposed under Alternative B – Clarks Fork Basin/Polecat Bench West Paleontological Area, Foster Gulch Paleontological Area, and McCullough Peaks South Paleontological Area – are not designated as ACECs, but part of all three of these areas lie within the proposed PETM ACEC, which is unique to Alternative D. Section 4.7.1 Areas of Critical Environmental Concern further discusses management of and impacts from these special designations.

Resources

Under Alternative D, actions related to fire and fuels management would result in similar adverse impacts to paleontological resources as for Alternative A.

Proactive Management

Proactive management under Alternative D most resembles Alternative A, with fewer proactive actions than Alternative B. Differences from Alternative A include requiring an on-the-ground survey before approving surface-disturbing activities for PFYC 3, 4, and 5 on a case-by-case basis; allowing surface-disturbing activities within at least a 100-foot-wide buffer of the outer edge of a paleontological locality as long as impacts can be adequately mitigated; encouraging research (in contrast to providing opportunities for research).