The following letter was submitted by MT BHA in regards to the Bureau of Land Management's (BLM) Miles City Resource Management Plan (RMP).
Miles City Field Office
111 Garryowen Road
Miles City, Montana 59301
The following are Montana Chapter Backcountry Hunters and Anglers (MT BHA) comments regarding the Miles City Resource Management Plan (RMP) Revision.
Montana Chapter Backcountry Hunters and Anglers are Montana sportsmen across the state that depend on management of public lands in Montana for management of habitat to support both fish and wildlife, as well as traditional non-motorized hunting and fishing opportunities. The Miles City Resource Management Plan (RMP) Revision is critical to both the wildlife habitat and hunting opportunities.
Of the insufficient range of Alternatives presented, our organization supports Alternative B for the following reasons:
-Recognizes the importance of sage grouse habitat on 1.1 million acres and proposes to restore habitat on 260,000 acres.
-Does not allow oil and gas leasing on 39% of these lands.
-Recognizes 22 areas as ACECs on 1,350,000 acres
-Recognizes Devils Creek protection of 5236 acres
-Does not allow grazing on 210,000 acres
Why did the range of alternatives not include one Alternative that protected all sagebrush habitats, while minimizing adverse effects of surface occupancy on wildlife habitat? We believe even Alternative B fails to meet the needs of wildlife habitat and Montana sportsmen and we request a wider range of alternatives. None of the Alternatives developed provide sufficient prioritization of wildlife habitat, or the recognition of impacts proposed and continuing resource uses have on that wildlife habitat.
We question the decision to not provide sage grouse prioritization on all potential sage grouse habitat in light of evidence that the species is a candidate for listing as threatened. We request an assessment of all sage grouse habitat in the Resource area. We also believe the BLM has a federal land management responsibility to protect and restore all potential sage grouse habitat given that adjacent private lands do not have the same habitat responsibilities that do the BLM lands. How is the RMP is addressing National and Regional sage grouse planning guidelines, and what assurances are in the RMP to assure on-the-ground positive actions are completed?
Vegetation and Plant Communities:
Vegetative health is key to maintenance or restoration of wildlife habitat. How does the Preferred Alternative assure that vegetative communities are managed for plant diversity and health? The EIS must provide quantified evidence that documents that vegetative communities within the RMP are within natural range of variability at both the micro and macro scale. We believe the BLM has legal mandates and custodial land management responsibility to insure all components and structure of all vegetative communities are maintained on all landscapes in the Resource Area. On this Resource area, those at-risk plant communities include assessing the extent and health of woody draws , riparian areas and sagebrush communities in context of their historical presence and condition . The plant community assessment must also address invasion of noxious weeds and address containment of mechanisms that accelerate noxious weed invasions such as grazing, off road vehicle use and surface disturbance by oil and gas development. We request the final RMP specify grazing system modifications to assure all vegetative components are measured for condition and trend , not just grass. We request the RMP insist all grazing allotment management plans assure health and vigor of both sagebrush and woody draws and riparian areas, and forbs and other native plants. What assurances are to be incorporated in both the RMP and subsequent allotment management plans to insure grazing usage does not exceed specified use levels regardless of budget shortfalls, drought, wildfire, or other perturbations? This RMP must be an action document that places resource condition and health before utilization and extractive industry activities.
What do the Alternatives contain to assure valuable habitats and plant communities such as riparian areas are protected or restored? Special management and emphasis must be placed on riparian areas health. These relatively rare habitats in the Resource Area have disproportionate importance to both native plant and animal communities, both aquatic and terrestrial. At present riparian communities in this Resource Area are among the most abused by livestock grazing. Without exclusionary fencing, these areas will continue to be the most intensively grazed in any allotment. The final RMP must specify immediate actions on all allotment management plans to assure grazing use is allowed only when riparian areas have been individually assessed and documented as in excellent condition. Key riparian species, including woody plants, must be restored where they historically occurred. Exclusion fencing, beaver restoration, other techniques and suspension of grazing permits must be evaluated and promoted in the final RMP. Simple rest rotation grazing has not proven to be successful in restoring many of the riparian vegetative and structural components of this plant community. The RMP must mandate specific procedures to assure significant riparian health improvement before any new allotment management plans are approved where riparian areas occur.
How will plant communities be protected and restored where surface disturbing activities are permitted? We request safeguards for protection or restoration of healthy vegetative communities be mandated on all surface activities to minimize surface disturbance, noxious weed invasions, topsoil protection, and plant utilization standards. Adequate safeguards using the best science and techniques must be mandated as requirements for all future surface disturbing activities in the final RMP.
Wildlife and Wildlife Habitat
How will the RMP assure the health and potential productivity of wildlife habitat is maintained or enhanced? The health of the wildlife community is dependent on how the BLM manages its surface activities and uses. We request documentation of the current health of all components of native wildlife communities. While big game are often the primary species evaluated and documented, we know that many other species may be more vulnerable to surface activities. We request documentation and quantified assessment of how the Alternatives affect all components of the native wildlife community. This would certainly include candidate listed or listed species including Greater Sage Grouse, Black Footed Ferret, Interior Least Tern, Pallid Sturgeon, Whooping Crane and Sprague’s Pipit. But it would also include Bald and Golden eagles. We request specific actions be identified for implementation in the revised RMP.
How will the RMP protect or restore woody draws and other vulnerable habitat types? No less important to our members is assuring the health of sharptail grouse habitat. Sharptail grouse populations and other wildlife species are likely limited by the past mismanagement of woody draws that are very susceptible to damage or elimination by domestic livestock grazing. In addition, short grass prairie health, including nesting cover and insect populations are essential to healthy sharptail populations. We request documentation of the historic distribution of woody draws in the RMP and condition and distribution of these habitats where they historically occurred. Where less than full potential, we request specific actions or standards in grazing plans to restore health and distribution of woody draws. We also request an assessment of wildlife species obligate to woody draws.
How will the RMP protect all existing and potential sagebrush communities and their obligate species? Sagebrush communities are vulnerable to grazing systems that are designed to focus and foster grass health at the expense of other vegetative components. In addition, sagebrush is vulnerable to noxious weed invasions, and other surface disturbing activities including oil and gas development. We request specific required actions be identified in the final RMP to assure grazing systems in sagebrush habitat types foster health and recruitment of younger sagebrush in such communities. In addition, minimal surface disturbance to sagebrush communities must be required in all surface disturbing activities, including road construction, drilling pads, pipeline installation and other such activities. Topsoil retention must be required, and immediate native plant community restoration completed once a site has been disturbed. All construction permitted must assure disturbed sites are restored as quickly as possible and noxious weed control measures be implemented throughout the project life. Native plant species must be mandated in all restoration efforts.
How will permitted infrastructure and grazing systems be modified to assure needs of sage grouse are protected or enhanced? Specific to sage grouse, overhead power lines must be minimized or prohibited or relocated outside sage grouse habitats. Fences should be designed to be sage grouse friendly. Residual ground cover must be assured in all grazing plans during nesting and rearing time periods.
How will the RMP insure habitat for big game species is managed to it biological potential? Habitat for big game species, including deer, bighorn sheep, elk and antelope, must be provided throughout the Resource Area where historically present. This includes all the plant communities used must be managed for viability and distribution where historically present. All fences must be wildlife friendly both for location and construction standards. Migration corridors must be identified in the RMP, and science based habitat modifications and human occupancy restrictions be required for any project within the RMP.
Travel Management and Recreation
How will motorized travel be managed to insure resources are protected, off road travel is prohibited and non-motorized recreation opportunities are enhanced and protected from motorized intrusions? All motorized travel must be restricted to designated routes, and enforcement mechanisms increased to assure compliance. Off road travel leaves tracks others may follow which often becomes another road. Game is displaced. Noxious weeds are spread.
We strongly object to any provisions for game retrieval off designated routes. Provisions are unnecessary as hunters must consider how they are to retrieve game before they shoot an animal. Any such provisions are ripe for abuse and cannot be administered effectively by existing BLM personnel and law enforcement. Such activities ruin the experience for nonmotorized hunters and others wanting to escape from sights and sounds of motorized vehicles. Big Game they may be seeking are displaced by game retrieval activities and therefore, the non-motorized hunter’s hunt is ruined. Motorized tracks encourage others to follow, and noxious weeds are spread into important habitats. Allowing game retrieval is unnecessary, expensive to administer, and ripe for abuse.
Has each motorized route been assessed as to its effect on wildlife and non-motorized recreation opportunities? We request an assessment of each and all motorized routes in the RMP, and their cumulative effect on wildlife displacement, noxious weed spread, and other resource damage.
How much of the Resource Area is designated and managed for non-motorized recreation, including hunting? We request designation of at least 25% of the area as no closer than one mile from a designated motorized route to provide a recreation opportunity spectrum that included opportunities for non-motorized recreation. We request such non-motorized areas be formally delineated
On a RMP map and surface disturbing activities be strongly discouraged from such lands. As part of such delineation, MT BHA supports retention of roadless and wilderness qualities and management of the seven WSA’s contained within the RMP. These areas, in addition to providing for non-motorized recreation opportunities, also provide additional security for many wildlife species.
How does the RMP address public hunting access to isolated BLM parcels? How does permitted outfitting on BLM lands affect public hunting access? We request the RMP balance the impacts of the outfitting industry and its adverse effects on non-guided Montana hunters. We believe the outfitter industry contributes to landlocking out non-guided hunters, particularly on isolated BLM parcels without public access. Options which must be evaluated in the final RMP are 1) obtain legal public access to all presently isolated BLM parcels, 2) prohibit outfitting on all BLM lands within the Resource Area to discourage locking out public hunters, and 3) restricting permitted outfitting to only those BLM lands which are landlocked, retaining the other accessible BLM lands for Montana non-guided hunters.
We request our comments be individually assessed and specific comments or response provided to each comment. We request being notified of any additional public comment opportunity on this RMP.
s/greg l munther
Greg L Munther, Chairman, Montana Chapter Backcountry Hunters and Anglers
(picture courtesy of USFWS)