Mack Long, Regional Supervisor
Harper’s Bridge Fishing Access Site (FAS) Development email@example.com
Montana Fish, Wildlife & Parks Region 2 Headquarters
3201 Spurgin Road
Missoula, MT 59804
Subject: Harpers Bridge Fishing Access Development
From: Montana Chapter Backcountry Hunters and Anglers
Montana Chapter of Backcountry Hunters and Anglers is a conservation organization of hunters and fishermen from across the State who have joined for protection of wildlife and fisheries habitat as well as non-motorized fishing and hunting opportunities.
Our comments on the Harpers Bridge FAS Draft EA issued in June 2010 focuses on the document’s inadequate assessment of cumulative and connected actions and effects stemming from proposed development of another enhanced motorized boating opportunity. The EA fails to discuss or mitigate the impacts of such present and increased levels of motorized uses on wildlife habitat, water quality, adjacent landowners and non-motorized recreation uses. Wake erosion from high-speed craft is only example of an impact. In addition, the safety of non motorized users, which includes difficult-to-see tubers, families in canoes and small rafts, and small floating fishing craft, is at risk when this development encourages more motorized use on a thin river thread,.
We are not in opposition to some development of the site for fishing access if mitigation measures include meaningful, effective restrictions on motorized boat and jet ski use on waters potentially accessed by the planned facilities.
Motorized use must be addressed not only for specific adverse effects, but the scale of those effects. For comparison, a non-motorized floater may have some disturbance to wildlife during their travel, which may commonly be 5-10 miles for an entire day. On the other hand, a motorboat could easily run from Harpers Bridge to the Florence Bridge 15 miles up the Bitterroot in a single hour and then return creating the same level of disturbance on their return trip for the next hour. The effect of this scale of impact on non-motorized river users, noise to neighborhoods, wildlife, and shoreline erosion must be addressed.
We have noticed annually the substantially increased motorized boating and jet ski use originating from the recently enhanced launch facilities at Kona Bridge and the existing Kelly Island access and continuing along both the Clark Fork upstream and downstream as well as in the Bitterroot River. We acknowledge that primitive motorized access is now available near Harpers Bridge from the south bank of the river. However, the long dusty washboard road leading to the south bank discourages most users of trailered watercraft. The planned additional ramp at Harpers Bridge will undoubtedly increase river motorized use because of the easily accessed paved road and planned parking for up to 36 vehicle/boat trailer combinations, including motorized boats and jet skis. This facility will lead to increased congestion, conflict and liability of mixed recreational uses on the river. This unmitigated planned action substantially degrades fish and wildlife habitat, degrades non-motorized recreation opportunities, adds more noise for adjacent landowners and residents up and down the river, accelerates shoreline erosion and increases discharges of unburned hydrocarbons directly into the river. The ramp encourages increased use of motorized watercraft and consumption of hydrocarbon based energy while adversely affecting both habitat and non motorized uses.
Specifically, we ask that the EA address cumulative long-term impacts, both social and biological, of such infrastructure on uses and resources along the Clark Fork and Bitterroot rivers. We ask that the EA be revised to include a wider scope and include a more thoughtful discussion of the real river impacts and impacts to the human environment. The inadequacy of the draft EA is represented by the following specific examples:
Page 10 1a Soil - Fails to acknowledge or mitigate the increased shoreline erosion from large boat wakes at all river levels. Most of the Clark Fork and lower Bitterroot are unconsolidated deposits which are easily eroded with lateral wave action. Our members have witnessed the considerable sediment generated from the shoreline on the Bitterroot and Clark Fork with just a single pass of a large boat with lateral wakes. References on shoreline erosion from power boats include: Johnson, S. 1994. Many sources on boat wake erosion area are linked through the following web site: http://www.nanticokeriver.net/Boat_Wake_Damage_Links.html.
3h Surface Water Contamination- Up to 30% of hydrocarbons from two cycle engines are deposited directly into the river. Personal watercraft emit pollutants such as benzene, toluene, and xylene and other hydrocarbon pollution at a rate of 2-3 gallons per hour of operation. Johnson, M.L. 1998. Ecological risk of MTBE in surface waters. John Muir Institute of the Environment, University of California, Davis, California. http://tsrtp.ucdavis.edu/mtberpt/homepage.html
Tjärnlund, U., G. Ericson, E. Lindesjöö, I. Petterson, and L. Balk. 1995.Investigation of the Biological Effects of 2 -Cycle Outboard Engines’Exhaust on Fish. Marine Environmental Research 39: 313-316. Jüttner, F., D. Backhaus, U. Matthias, U. Essers, R. Greiner, and B. Mahr.
1995. Emissions of two- and four-stroke outboard engines-II. Impact on
water quality. Water Resources 29(8): 1983-1987.
Page 16 5g Wildlife- EA indicates no additional stress to wildlife, despite high speed, noisy and large wake motorboats operating at all seasons and water levels. No mitigation is offered. The document indicates quiet floaters are unlikely to disturb bald eagles, but omits effects of the increased in high speed, noisy motorized watercraft. Elk have been observed on multiple occasions along the river riparian area downstream from Harpers Bridge, and effect of increased motorized use on this riparian ungulate use should be discussed as part of the EA. Our observations are that most waterfowl, shorebirds and eagles are displaced on a regular basis with such watercraft. Elsewhere in the state, including portions of the Yellowstone River, rivers are closed by FWP in the fall to motorcraft to avoid displacing waterfowl off the river system. In the spring, broods of waterfowl on our rivers are forced to be separated from adults that can fly and flightless young that must endure the large wakes, noise and stress from large motorboats and jet skis. (Reference motorcraft literature includes: Rogers, J.A., and S.T. Schwikert. 2002. Buffer-zone distances to protect foraging and loafing waterbirds from disturbance by personal watercraft and outboard-powered boats. Conservation Biology 16(1): 216-224).
6 a, b- Noise- The EA does not acknowledge or mitigate the predictable increase in noise from large jetboats, motorboats and jetskis . Such craft are easily heard for over a half mile up to a mile or more, especially across water bodies. To residents and non-motorized river users, this noise level is a serious nuisance, especially when it is frequently repeated. Jet ski users are notorious for “performing” in front of people, who rarely appreciate their antics.
7d Residences- The EA does not acknowledge or mitigate for the motorboat and jetski noises which will disturb residences near the ramp, as well as up and down the river. Powerboats and jet skis rarely stay within close proximity of a Fishing Access Site. Currently, residences occupy one or more banks for much of the length of river easily accessed by such motorized watercraft. A thorough discussion of conflicts of powered watercraft on recreationists and residences can be found in “Personal Watercraft and Powerboat use on Big Payette Lake, McCall, Idaho” ( 2005).
9e Traffic Hazards- The EA states that the development will be beneficial to traffic hazards. The EA totally ignores the increased traffic hazards on the river resulting from increased density of mixed motorized and non motorized uses and it offers no mitigation of these impacts on user safety. Often motorized users are operating in low light conditions when seeing and avoiding non-motorized users is difficult. The result is a dangerous condition for which MDFWP is responsible and potentially liable if not mitigated. Personal watercraft (jetskis) represent around 7% of registered vessels, but account for 35% of all boating accidents. A United States Coast Guard (USCG) sponsored survey found that the exposure rate for non-fatal jetski accidents is 6.5 times higher than for traditional recreational powerboats. In 2008, the US Coast Guard statistics document Montana has one of the worst boating accident rates in the US, with over 10 deaths per 100,000 registered boats. Nationwide, in 2008 there were over 100 deaths from boats colliding with people in the water.
10d Energy- Without disclosure or mitigation, fostering additional motorized boat use for strictly recreation with enhanced motorboat launch is inconsistent with state energy conservation policy.
11c Opportunity- The EA seems to stress enhancement of non-motorized uses such as floating and fishing without acknowledging the greatest change in use will likely be expanded motorized uses. With the ramp, users from the Frenchtown and west Missoula area will have a much easier place to launch and use jet skis and motorboats. Increased opportunity, such as this development, encourages purchasing more motorized watercraft. However, there is no discussion of the negative impacts of additional motorized craft on the safety nor enjoyment of non-motorized users. The operators of a single powerboat or jetski can disrupt the enjoyment of many non-motorized bank and non-motorized boat users, and have to pass these people while both to and from to their entry point on the river. (Reference: 52p.http://bluewaternetwork.org/reports/rep_pwc_ACAreport.pdf)
Ultimately, MDFWP will need to react to serious boating accidents, some of which could result in fatalities. There is liability associated with providing facilities that encourage such obvious conflicts to both humans and the environment. Non-motorized users will become frustrated or displaced, residents along the river progressively more irritated, and wildlife will be displaced.
Instead, we urge proactive action commensurate with this FAS development to restrict motorized uses on the Clark Fork and tributaries. Montana BHA members appreciate the 20 mile long reach downstream of this site without improved access facilities that would encourage additional use. However the Harpers Bridge FAS site development will increase motorized use on this section unless legal restrictions are placed on this reach.
To fulfill the requirements as per Montana Code 23-1-110 we request a public meeting as per this code requirement: “opportunity for a public meeting and public comment (emphasis added) on the advisability and acceptability of the proposal.” To comply with this legislative direction, we request that this EA address “(c) environmental impacts associated with the improvement or development”, which includes those cumulative effects of providing additional motorized access and facilities which encourage such motorized use away from the site proper and the associated effects of such motorized use on safety, resources and current users.”
We refer MDFWP to Goal 1 of Montana Code 23-1-126” (1) The good neighbor policy of public land use, as applied to public recreational land, seeks a goal of no impact upon adjoining private and public land by preventing impact on the adjoining land from noxious weeds, trespass, litter, noise and light pollution, streambank erosion, and loss of privacy (emphasis added). It appears this proposal has not addressed the emphasized items in this goal in a meaningful way. By not preventing or addressing these cumulative effects of additional motorized use impacts resulting from this proposed development, it appears MDFWP has ignored legislative direction.
To fulfill the requirements of Montana Code 23-1-127, we request MDFWP address part 2(d) “implementation of safety and health measures required by law to protect the public” by taking commensurate action as part of this decision to restrict motorized use on the Clark Fork and Bitterroot Rivers potentially accessed by motorcraft launched at the proposed Harpers Bridge FAS development”.
With the recent development of the Kona Bridge FAS and now the proposed Harpers Bridge FAS, now is the time to revise motorized boating regulations on the middle Clark Fork and Bitterroot Rivers. The vast majority of current use is non-motorized. Delaying this much needed revision until resultant motorized use increases as a result of this planned development will only make the debate and controversy even more heated.
Montana State Chairman