Idaho BHA recently commented on a draft Environmental Assessment for the Upper Snake East Travel Management Plan. Read the full comments here. 

General Comments: 

• Human population increases across the entirety of the BLM Travel Management Area (TMA) have worsened recreational impacts on wildlife in recent years. Some of the most significant impacts involve losses of big game security habitat arising from fragmentation due to trail development and density. These impacts have contributed to lost or degraded hunting and fishing opportunities. For example, in Teton County, where recreational impacts are particularly high, we have lost our general rifle elk season. We recognize that recreation is not the sole cause for this decline but that it plays a major role in habitat degradation and depressed elk numbers. Adopting still more trails, especially along the Teton Front will not help this situation.
• Alternative B provides the best safeguards for wildlife of the Alternatives analyzed but we suggest in the most sensitive wildlife habitats it doesn’t go far enough to conserve big game populations and that BLM should analyze removal and rerouting of trails to conserve habitat integrity and minimize further fragmentation.
• ID BHA does not support the adoption of unplanned and illegal user created trails as part of the travel management process because we have seen it contribute to the explosive proliferation of new trails on other public lands in the TMA. Illegal trail construction should be handled by increased enforcement and penalties to offenders and illegal segments should be reclaimed to preserve habitat integrity. As a further deterrent we encourage the adoption of a policy making user created trails ineligible for future consideration and adoption into travel management plans.
• The TMP does not adequately address cumulative impacts to wildlife arising from existing trails on adjacent forest and private lands within the TMA.
• Conceptually BHA supports winter closures for wildlife to mitigate the impacts of recreation on wildlife during sensitive times, but we remain very skeptical that closures will be effective within the TMA because of a general lack of enforcement presence. If closures are implemented, we recommend that BLM bolster its own enforcement staff, work with user groups on self-policing strategies, and enter into agreements with the Idaho Department of Fish and Game (IDFG) for enforcement support across all BLM parcels within the TMA.
• BLM has limited capacity for enforcement; therefore BLM should be wary of creating new recreational areas that will require significant enforcement to maintain resource integrity. An important example is Teton Front in Victor, Idaho. This area is vital for big game during winter and through the calving/fawning season. The current preferred alternative proposes enhanced mountain biking trails. The trail plan for this landscape was largely developed by mountain biking trail activists. Since the start of the TMP process, most of the proposed trails have been illegally constructed. BHA is very concerned about process integrity and future management of such an important area for hunters and wildlife enthusiasts.