Montana BHA Issues

Montana BHA Scoping Comments on Lewiston Resource Management Plan

Greg-UplandBureau of Land Management

Lewistown Field Office

920 East Main St

Lewistown, MT 59457

The following serves as Scoping comments pertinent to the Lewistown Resource Management Plan (RMP) planning process.          

Montana Chapter Backcountry Hunters and Anglers is comprised of over 300 Montana sportsmen across the state who depend on management of public lands in Montana to support abundant fish and wildlife populations, as well as provide traditional, non-motorized hunting and fishing opportunities. The content and direction ultimately provided by the Lewistown Resource Management Plan (RMP) Revision will be critical to both the sustainable wildlife habitat and hunting opportunities.   

We request the following issues be addressed in the revision process through development and analysis of alternatives or specific management direction in the revised RMP.

Vegetation and Plant Community Health and Diversity

  1. Protection and restoration of woody draws.   These relatively uncommon plant community features are disproportionately used by wintering big game and are essential as wintering sharptail grouse habitat. Livestock grazing has led to reduction of this habitat feature or its health on the RMP landscapes. Plant components of this feature are in poor vigor and often lack sufficient regeneration. The RMP must resolve how this important vegetative component will be protected and restored.
  2. Protection and restoration of riparian areas.   These plant communities are disproportionately grazed by livestock and are often dramatically altered negatively as wildlife habitat. Most of the RMP hunted species depend substantially on riparian areas as habitat. Riparian areas comprise minor percentages of the RMP but are among the most abused from livestock grazing. The RMP must protect and restore all riparian areas. The RMP must resolve adverse effects of disproportionately heavy grazing occurring and the effects of that grazing on riparian vegetative health and vigor.
  3. Manage for vegetative health and diversity on upland sites.   Cattle grazing systems are commonly developed to, under the best of management, to improve the conditions of grasses as opposed to shrubs and forbs. The effect of these grass-oriented grazing systems is the reduction of shrubs and forbs important to wildlife as forage, cover, and nesting cover. Residual plant cover assures insect production and diversity as critical gamebird brood food source. We request the RMP address upland vegetative diversity and health through direction for grazing plan designs, monitoring and inventories.
  4. Ensure grazing and other uses do not facilitate noxious weed spread. Long term vegetative health and wildlife habitat is dependent on native plants that are dramatically adversely affected by invasions of noxious weeds. The RMP must prioritize vegetative health and preventing noxious weed spread higher than any other use that might facilitate noxious weed spread, including incompatible grazing and other surface disturbances such as road construction, oil and gas development, and native plant conversions .
  5. Protection of all sagebrush communities.   All sagebrush plant communities must have priority for protection. Any land uses must not further fragment, alter or lessen vigor and reproduction of sage communities. No uses should be permitted that contribute to fragmentation of sage communities.

    Get involved with Montana BHA's efforts to ensure public access to your public lands and to maintain high-quality non-motorized habitat.  Join BHA Today!

Comments on Grazing Plan for Robb Ledford Wildlife Management Area

32 Land TawneyMontana Fish and Game Commission:

Montana Backcountry Hunters and Anglers, consisting of over 300 Montana sportsmen dependent on well managed public lands , are appreciative of prior efforts to acquire and manage Wildlife Management Areas.   Although there are often particular species identified for management emphasis in a WMA, a Wildlife Management Area needs to be responsive to the habitats of all wildlife and fish species.

The current Environmental Analysis for the Robb Ledford grazing allotment details conflicts with current grazing and riparian/fishery resources, to wit:.

From page 8 EA:

Rock Creek

“extensive livestock-caused alterations to stream banks kept the riparian in the non-functional category. In 2011, riparian assessments demonstrated that Rock Creek health remained stable and was barely functional. Heavy browsing and lack of establishment of preferred woody species were the most consistent driving factors (Thomson et al. 2011. E.).”

Comments on Arrastra Creek Grazing Allotment

John W Thompson, Acting Field Manager

8 lb prarie rainbow resizedMissoula 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.

Defending Public Stream Access in Montana

26 Steven AvrilSince in the 1980’s Montana has been the “gold standard” in terms of protecting its citizen’s rights to recreational access of the waterways within its borders. In 1984 The Montana Supreme Court held that the streambed of any river or stream that allows for recreational use can be accessed by the public, from public land, regardless of whether the waterway is “navigable” or who owns the adjacent streambed property. The Montana Stream Access Law gives the public rights to access streams and rivers for recreational purposes, up to the ordinary high-water mark. The law does not allow access through posted lands bordering those streams or to cross private lands to gain access to streams.

No such stream access is available in many states. For example, in Wyoming boaters cannot even drop anchor in a river flowing through private land without being in trespass. Article IX, section 3 of the 1972 Montana Constitution gave the ownership of the state’s waterways to its citizens. It goes without saying that this law that must be protected from those individuals who would like to reverse our State Constitution to privatize Montana steams. This law protects access rights not only to current Montana citizens, but to future generations.

Montana BHA Member Frank Vitale Featured in Video on Protecting the North Fork

In this video, Montana BHA member and backcountry horseman Frank Vitale is among one of many local residents and public land users who explains why protecting Montana's North Fork is important to him.  Local sportsmen conservationists like Frank continue to work to protect the North Fork's wild waters and backcountry habitat.

Montana BHA Member Featured in Video on the Rocky Mountain Front

BHA member and rancher Roy Jacobs speaks-up on the need to protect the intact lands he depends on, in this video on the legacy of the Rocky Mountain Front.  Local BHA members like Roy are working towards ensuring these lands remain intact, so that sporting and ranching traditions can continue on as they have for decades.

Questions to Fish Wildlife and Parks on Management of Spotted Dog Wildlife Management Area

Dear Randy:

This is a follow up letter to the MT BHA letter we sent FWP a couple of months ago.

According to FWP website, Montana WMAs have the following direction…

“FWP’s Wildlife Management Areas (WMAs) are managed with wildlife and wildlife habitat conservation as the foremost concern. WMAs protect important wildlife habitat that might otherwise disappear from the Montana landscape. They provide vital habitat for bear, bighorn sheep, birds, deer, elk, furbearers, moose, mountain goats, wolves and an array of other game and nongame wildlife.”

“The primary goal of Montana's Wildlife Management Areas is to maintain vital wildlife habitat for the protection of species and the enjoyment of the public.”

Montana Chapter of Backcountry Hunters and Anglers believes there is ample room for improvement of in current management of Spotted Dog WMA to meet the vision emulated in the above statements. To better understand how Spotted Dog is and will be managed in the future, we request responses to the following questions.

Comments on Montana Sage Grouse Management Plan

Montana Sage Grouse Habitat Conservation Advisory Council:

Montana Backcountry Hunters and Anglers welcomes the opportunity to comment on the proposed Montana Sage Grouse Plan. Our members are grassroots Montana hunters and fishermen who cherish prairie habitats and their wildlife, as well as hunting opportunities within sage habitats on both public and private lands. Our members pursue game, but appreciate all the ecological aspects of wildlife habitats encountered while in the field.   It is the context of sage grouse and their habitats that we formulate these comments.

First, we appreciate the efforts for the State of Montana to retain authority to manage sage grouse, and the emphasis on landscape scale habitat needs of these birds.

Comments on Spotted Dog Wildlife Area

Jeff Hagener, Director

Montana Department Fish Wildlife and Parks

Dear Jeff:

abuseOn October 1, 2013 I had occasion to drive thru and hike parts of Spotted Dog Wildlife Management Area as part of a bowhunt in HD 215. I have attached a couple of photos to document grazing conditions that Montana Chapter Backcountry Hunters and Anglers do not feel are appropriate for a Wildlife Management Area managed by FWP.   We also are compelled to discuss the current motorized uses occurring on the WMA.

As background, I spent 32 years with the US Forest Service, both as fisheries biologist as well as District ranger for 10 years managing roughly 3330,000 acres of western Montana public lands. Both as fisheries biologist and District Ranger, I had extensive experience and exposure to management of livestock as well as the effects of poor management.

We fully understand the current grazing lease was imposed on the Department when the purchase of Spotted Dog lands was finalized. However, it is our understanding that this lease is expiring in the next year or two. The upcoming lease expiration will be an excellent opportunity to get it right next time.


As you can see from the photos, the stream channel condition and alteration by years of mismanagement of cattle has had a devastating effect on channel form, stability and function, and fisheries habitat values. Woody riparian plants expected to be on such a stream are largely gone, replaced by bluegrass and noxious weeds.   I would expect that any FWP fisheries biologist would collaborate my opinion on the extreme adverse effects of livestock. At one time I expect this stream had dominantly woody plants such as willow and alder and likely extensive beaver activity in the moderate and low gradient reaches of all the streams on the WMA.  

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Backcountry Hunters & Anglers seeks to ensure North America's outdoor heritage of hunting and fishing in a natural setting, through education and work on behalf of wild public lands and waters.

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