John W Thompson, Acting Field Manager

Missoula Field Office

3255 Fort Missoula Road

Missoula, MT 59804

Re Arrastra Creek Allotment EA DOI-BLM-B010-2013-009-EA

Our 350 member organization is comprised of Montana hunters and anglers, many of whom hunt and fish in the Blackfoot drainage. Observations of livestock damage by our members were documented in our November, 2011 letter and photos to your office. We have reviewed the EA and have had phone conversations with your Range, fisheries and hydrologist specialists and have the following comments.

We found the EA to include a good discussion of the current fisheries, streambank and riparian vegetative conditions and past livestock damage.   We found the maps associated with big game and listed species ranges to be clear and readable. We are pleased that the BLM is assessing grazing on lands acquired through TNC, as well as previously publicly owned land in the Arrastra Creek drainage.

Unfortunately, the condition of this allotment is deplorable. Heavy grazing of virtually all the available palatable forage every year, season long has resulted in noxious weeds increasing, low vigor grasslands and water and riparian degradation.

Our concerns with Alternative B as the preferred Alternative are listed below.

• Based on the preponderance of range and plant physiology science, we object this allotment, as well as any other public lands being grazed under a season-long grazing system without rest. The plant physiology of a healthy native plant community demands regular one or more seasons of complete rest to establish strong root systems, plant vigor and formation of seedheads. In addition, the documented presence of, and potential spread and adverse effect of noxious weeds on the allotment is another reason for restoring plant vigor of native grazed plant species. We find range and riparian literature strongly supports short duration or rest systems over season long grazing systems, especially hot season grazing. The more palatable native plants will remain under extreme stress due to season long, hot season grazing. In addition, the EA recommended minimum 4 inch stubble height retention in riparian areas is an average measurement, and does not reflect disproportionate grazing on the most palatable species and preferred locations.     While there are some utilization parameters regarding riparian species, there are apparently no such parameters for upland species.
• Due to the apparent organizational resistance to evaluating or considering a rest rotation system within the allotment, we believe a viable alternative for this allotment could be integration with other public and private grazing lands under the lease by or ownership of the leasee to provide one or more years of rest across the entire allotment every 3 years. Another option that should be evaluated is to use the allotment only as a grassbank. This could lessen impacts on the allotment without significant investments and offer some grazing options on other BLM lands. Certainly the 23 cattle can be accommodated elsewhere in the valley.
• We object to the EA authorization an additional 1700 acres (p 22) to the grazing allotment under Alternative B of and commensurate expansion of AUMs associated with those additional acres. This decision ignores the potential impacts of grazing to those acres and there no apparent mitigation or controls associated with grazing those additional acres.   On those additional acres, there is apparently no inventory of, nor description of, stream or riparian conditions, nor potential assessment of impact on winter range preferred browse species. Often springs or seeps that likely occur on those acres have extreme importance to grouse and localized big game. There is no discussion of the adverse effect of livestock on those recreationists who choose to bird or big game hunt on those acres. We request those acres not be included in the allotment and commensurate AUMs not be permitted.
• Alternative B is a very expensive and personnel-intensive Alternative. Arrastra Creek has been documented as the most important spawning tributary of genetically pure strain of westslope cutthroat in the middle of the Blackfoot drainage, as well as the only bull trout tributary in that Blackfoot River reach.   And this Alternative and EA seems to downplay the significance of Arrastra Creek drainage being as a listed 303d drainage. Simply, we believe grazing should be permanently eliminated from the riparian or stream portions on this allotment that has been documented to be important to westslope cutthroat and bull trout.   The investments necessary to continue to graze riparian areas such as section 17 seems extreme to us to provide minimal livestock grazing capacity.   Are these investments coming from limited aquatic funding allocations? In addition, the EA commits to extensive monitoring by fisheries and hydrologist personnel that could be spent on other BLM lands/projects.  
• We question both the cost/benefit of the specified investments and whether all the investments and monitoring can/will be accomplished.   Page 78 lists at least $40,000 in public-funded investments to improve grazing compatibility for 23 cattle.   Grazing receipts for this use will be about $325/year. We question whether the average taxpayer would approve. We question whether such investments are prudent for such a small number of livestock.   Alternative C would be some improvement, but also has poor cost/benefit.
• Is the $40,000 presently available? Is the funding coming from fisheries/hydrology funding or from range improvement funding?   Because livestock caused the riparian damages to require these investments, only range funding should be used to prevent further damage.   There should be stipulations that any future grazing on this allotment be dependent on completion of indicated riparian fencing. Unfortunately, in our experience, grazing will continue even if the fencing is not completed nor all the monitoring is accomplished. In addition to the capital outlay in fencing, there are considerable implied costly obligations of BLM personnel to monitor. These are additional expenses that add to the overall disparity of cost/benefit of retaining this allotment, and selection of Alternative B. Fire season commonly drains personnel needed for monitoring and directly conflicts with monitoring requirements during the hot portion of the grazing season and therefore required monitoring may not occur. For example, each year BLM personnel will be required to measure stubble height and percentage weight utilization, shrub utilization, fence maintenance and searching for any bull trout spawning activity. All for 23 cows grazing for 4 months.

• We agree with the EA that Alternative B will affect big game winter forage (page 9) availability. On an allotment with overlapping moose, deer, elk winter range, we find the permitted use of 50% of riparian shrubs by livestock to be unacceptable. We also find lacking in the EA the importance of forest grouse as a recreational hunted species and the effect of riparian grazing on those species. The 50% utilization on woody riparian plants is again an average and does not reflect the preferential palatability of species such as red osier dogwood or willow over less palatable species such as alder.   And site specific location of some shrub communities makes them more likely to be grazed, and therefore more vulnerable than an “average” plant. In other words, individual plants or particular shrub clumps will suffer more than a 50% overall utilization. Also, the occasional high runoff years create point bars that provide excellent seedbeds for new riparian shrubs. However, season-long hot season grazing season almost assures that these new seedlings will be eliminated from the plant community by livestock grazing. These infrequent runoff events are critically important to recognize in the colonization of new riparian shrub communities.   The grazing plan does not provide for protection of seedlings except in the proposed exclosures.

Of the Alternatives presented, we urge adoption of Alternative C. However, while we find Alternative C preferable to Preferred Alternative B, we request expansion of alternatives to combine the Arrastra Creek allotment with other grazing lands in the Blackfoot drainage belonging to the leasee or other BLM lands to provide an extended rest followed by a rest rotation system combined with exclusion of riparian grazing in Section 17.

Public lands are increasingly important to Montana sportsmen as private lands are increasingly unavailable to sportsmen. Without well cared for wildlife and fisheries public land habitat, our members will find public land such as in Arrastra creek drainage has fewer wildlife and fish   We are dependent on public land managers to care for the land such as Arrastra Creek drainage in such a way to insure abundant populations of both wildlife and fish for the present, as well as future generations.

We request we be informed of your final decision on this allotment.

Sincerely,

Greg L Munther, Co-chairman,Montana Chapter Backcountry Hunters and Anglers