Category Archives: Physical Environment

A Citizen/Adjacent Landowner Critique of the Billings Class II Landfill Expansion Project Draft Environmental Assessment

[Editor’s Note: The draft report referred to in this article is available at and Montana’s Department of Environmental Quality’s website is at Comments are being taking by the DEQ until January 30, 2017]


Presented January 10, 2017 @ Blue Creek School

By Ralph D. Scott, Field Biologist, retired

Billings, MT 59101


At the above stated meeting, I pointed out some important voids in the draft assessment relative to the land (known as the landfill “buffer”) regarding the lack of data of the 350 acres ecological features, vegetation, fauna, etc.  Therefore, my comments are focused upon Section 3 Affected Environment and Environmental Consequences by Resource in the EA.

My comments, however, will be limited to the biological and natural community—the flora and fauna aspects—of the site; for I do not claim to possess enough in-depth expertise to critique the hydrological, geological, and soil aspects of the ecosystem/project area in question.


The assessment states: The analysis methods included…research of the Natural Resource Heritage Program database to determine the presence of threatened, listed, and/or endangered plant and animal species.

Note:  I volunteer and work with the Montana Natural Heritage Program, providing data and images for their field guide website.  I am happy you have used the info, but it is generic and serves only as a guide to foster awareness and thinking for the public at large, and public and private agencies to take a closer look at any ecosystem under consideration for development, alteration, and new management paradigms.


Assessment statement: The tract is currently dominated by various grasses, sage and cacti…used by deer and antelope populations.  Large areas of similar vegetation are found adjacent to the proposed expansion area. The landscape is not unique and does not contain any specially designated or unique wildlife features.

Question/Critique:  How was this assessment determined?  It seems obvious that this is not based upon any qualitative/quantitative field work (no “boots-on-the-ground,” if you will) by ecologists, naturalists, botanists, etc. (for example: I and other surrounding landowners are not aware of antelope occurring is this area). It is obvious that there is no data in the draft assessment to support such a conclusion. It has simply been a literature/internet data search!

As for the statement, “Large areas of similar vegetation are found adjacent…” this is not basically true. How adjacent, and what is the adjacent land use—housing, ranching, farming, etc. compared to this present Landfill buffer. Any close examination of a Google Earth photo of the “adjacent areas” would reveal that there are numerous vegetation types/habitats within the holistic vegetation classification system identified as Big Sagebrush Steppe and Great Plains Mixed Prairie, as presented on page 46, under Vegetation 3.6.1.    

Relative to Wetlands & Streams: The expansion area is located in the Blue Creek Watershed…Seasonal flow occurs in Stream 1 when it exceeds the rate of infiltration…the resulting shallow, course-bedded intermittent streams with shallow flows, but high turbulence, do not provide fish habitat.

Critique:  In my random & infrequent samplings of Blue Creek, I have collected 3 fish species—of course all in the Minnow Family (Cyprinaidae)—admittedly not “sport fish,” but fish nevertheless, plus there are many aquatic insects and other invertebrates.  How can that draft assessment be true?

Further, no biological data accompanies this assessment.  That is, these streams, although intermittent, often pool water during the dry season.  Aquatic life can be found in these pools.  Therefore, there should be a seasonal biological sampling of these streams—within the site, and especially several points along Blue Creek to its terminus with the Yellowstone River to establish a base-line of “what is now” as a biological monitor for assessing any future changes in the biota should the “engineering safe-guards” not perform as predicted.  To me, such a study would seem crucial to the assessment’s statements relative to hydrology, soil engineering, etc. and proposed “safe guards.”


It is obvious that this DEQ Environmental Assessment is extremely inadequate, biologically/ecologically, for any Billings citizen to sanction the City of Billings’ Landfill Expansion Project.  Here are some basic reasons:

  1. There is no inventory/listing of plant and animal species observed in the 350 acre site, which needs to include four season observations—nesting, migration, permanent residence, blooming, etc.
  2. There is no data relative to Vegetation composition, density, basal area, or standard measurements and standard (there are many available) methods.
  3. There is no biological data relative to the aquatic organism diversity within the Blue Creek watershed, and this would include the sampling upstream and downstream of the expansion site’s watershed confluence with Blue Creek to the Yellowstone River.
  4. More substantial data/analysis is needed to support claims made regarding wildlife shifts, adjacent similar vegetation types/habitat types, etc.
  5. It is very clear, that the EA is currently inadequate and incomplete, and that a more comprehensive/complete Environmental Impact Statement  (EIS) is required for further review.

I will not list more. In the eyes and minds of those authoring/submitting this EA, my conclusions may seem excessive, even cost and time prohibitive.  

As I see in the EA, the City of Billings submitted this application/proposal to the DEQ on April 27, 2015—more than a year before its public hearing.  They certainly, and the DEQ, has had adequate time to put professional/consultant biologists/ecologist into the field to assess the parameters I have listed above.


Respectively submitted: Ralph D. Scott, January 20, 2017


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