UPDATE: Tongue River Railroad Proposal—Still a Bad Idea

The Surface Transportation Board’s Office of Environmental Analysis (OEA) released a Draft Environmental Impact Statement (DEIS) on the proposed Tongue River Railroad. They claim the “proposed rail line may affect, but is not likely to adversely affect” wildlife in the area. However, the DEIS’s findings are based on inadequate wildlife surveys.

The Tongue River area in southeast Montana is special. It is broad, beautiful, undeveloped, and full of wildlife like black bears, pronghorn, elk, and mountain lions. The Tongue River, Otter Creek, Rosebud Creek and other small streams provide riparian oases on the plains and habitat for an abundance of songbirds and other wildlife. In short, the area in question regarding this railroad is an outdoor treasure.

One of the most significant issues with the DEIS is that the OEA did not do a complete survey. The OEA surveyed in a short time frame, between January and September of 2013, and only covered one-third of the ground projected to be impacted by the railroad. Although best management practices in the wildlife profession dictate that several years of four-season studies over the entire area are needed to properly document the wildlife resources.

To make matters worse, these surveys were completed after the most devastating wildfires that southeastern Montana has ever experienced burning hundreds of thousands of acres in the study area including the Ash Creek and the Chalky Fires. Those fires made many species of wildlife relocate since their habitat was destroyed and there was no winter feed in the burned areas.  It should go without saying that surveying after these fires does not give a complete picture of the wildlife resources in the region.

One good example of the shoddiness of the wildlife survey work involves the sage grouse.  The bulk of the sage grouse survey involved two OEA biologists flying 55 miles per hour 75 feet up in the air in a Jet Ranger Helicopter.  At this height and speed, it’s no wonder that they observed only two groups of sage grouse on the flight. The biologists did have the helicopter land, so that they could check out some possible grouse tracks. But the biologists couldn’t figure out whether they were sage grouse or sharp-tailed grouse tracks.

But that’s not the worst of it regarding the wildlife surveys. OEA didn’t conduct any fish surveys. Not one fish was touched in the preparation of the DEIS. They did a few fish habitat surveys, and that is all.

The OEA also states in the DEIS that the impacts associated with the railroad will not affect wildlife populations because the populations are “not vulnerable to decline”.  This is a faulty premise.

Let’s consider mule deer for example. While mule deer populations are relatively stable in eastern Montana, mule deer populations across the West have declined significantly over the past several decades. This is particularly true in areas that have undergone significant development—like in the Green River Valley in Wyoming with all of its oil and gas development. If the proposed new railroad line and a huge coal mine, the mule deer populations in southwest Montana could be just as depleted.

Another fault in the wildlife portion of the DEIS involves its analysis of habitat fragmentation and migration corridors, or rather the DEIS’s lack of analysis.  The study area currently has high level landscape connectivity. Wildlife rely on being able to freely move through their habitats to meet their biological needs. This connectivity is extremely important in southeastern Montana because of the arid landscape and the need for wildlife to have to travel to limited water sources.

Without question, the railroad and the miles and miles of fencing that are to go along with it would fragment the area in a myriad of ways.  Many of the ecological benefits associated with the current level of high habitat connectivity would be lost. Unfortunately, the DEIS gives only a cursory look at the impacts associated with fragmentation and the railroad, going so far as to say “big game populations do not migrate in the area.”  This statement completely minimizes the importance of the Tongue River and its tributaries for local migrations and wildlife’s ability to make it to the river for water and to move up and down the valley.

Lastly, it should be noted that the DEIS totally glosses over the impact that the changing climate will have on the area’s wildlife.  Scientists are predicting warmer temperatures, more intense storms, more frequent and intense droughts, less snowpack in the mountains, and earlier spring runoffs. While warming winters should provide some benefits to some wildlife species, on the whole, these climate trends are decidedly not good for wildlife. The railroad is only being proposed to be built to accommodate a large coal mining operation.  The burning of the coal from this proposed mine would only make the impacts of climate change worse on wildlife.

In short, the DEIS wildlife analysis is inadequate and needs to be overhauled.  The ecological value of the area is too great to let it be ruined by the Tongue River Railroad.

Urge the Surface Transportation Board to say NO to the proposed Tongue River Railroad. The deadline for commenting is August 24.