Amber Kamps, District Ranger
Attn: Blackfoot Travel Plan
Lincoln Ranger District, 1569 Hwy 200,
Lincoln, MT 59639

Dear Ranger Kamps:

These comments pertain to the draft Blackfoot Travel Plan, and we request they be entered as part of the formal public record.
Backcountry Hunters and Anglers is a national organization dedicated to protection and restoration of important wildlife habitat and traditional non-motorized hunting and fishing opportunities. Our Montana Chapter has a number of members who dominantly hunt and fish on the Lincoln Ranger District. These members are acutely aware of how expanded motorized use has adversely affected both habitat and traditional non-motorized hunting opportunities.

The framework for the new Blackfoot Travel Plan must be to protect and restore large blocks of secure big game habitat, as well as maintain and restore large blocks of non-motorized hunting and angling opportunities. Northern Region Forest Service research has provided much supporting documentation of the diminishing wildlife value of lands as motorized route density increases. For example, elk habitat suitability is reduced by half with one open mile of motorized route per square mile. In addition, recent Forest Service research in Starkey Experimental Forest has documented that elk react negatively to the presence of ATVs more than 1000 yards away. In Montana, the issue of public elk being displaced to private lands is a growing and significant issue. For ranchers who do not want elk, this displacement can cause economic hardship with damage to hay crops. For public land hunters, this displacement also can cause loss of public access to public elk. For MDFWP, the ability to control elk numbers is hampered when elk have been driven to private lands and are generally unavailable. This issue is very prevalent in the Ovando-Helmville area.

The two issues of 1) providing large wildlife security areas in each major drainage as well as and 2) providing large blocks of non-motorized hunting and angling opportunity need to be addressed in the Blackfoot Travel Plan. We feel strongly that the travel plan framework must include multi-thousand acre non-motorized big game security areas across the travel plan area. These areas need to be secure for both the summer and fall periods. We suggest the logical foundation for providing these secure areas is to first manage all Inventoried Roadless Areas within the Blackfoot Travel Plan area as non motorized, at least during the spring through fall periods:

• Roadless tracts contiguous to Scapegoat Wilderness, from Lolo NF boundary (Arrastra Creek) east to Continental Divide at Rogers Pass
• Anaconda Hill Roadless Area (Rogers-Flesher Passes)
• Specimen Creek and Crater Mountain Roadless Areas (Flesher-Stemple Passes)
• Nevada Mountain Roadless Area (Poorman Creek- Dana Springs)

All route closures related to hunting security should commence no later than September 1 to avoid leaving these routes open during the archery season. Routes now closed with 3, 7, 9, and 12 closure designations should be changed to Sept 1 closures. Montana bowhunters numbers have grown to about 40,000 now and motorized easy access not only displaces elk and other wildlife, but diminishes the non-motorized hunting opportunity. Open routes during hunting seasons should be dominantly those available to all vehicles, and minimize those only open to just motorcycles or ATVs. Allowing different classes of vehicles on routes provides a privileged class of hunters who own such devices over those who are limited to the family full sized vehicle.
In October 2009 in response to scoping, Montana BHA previously requested consideration to modify the Travel Plan in the following areas and routes:

1. There are abundant undetermined unauthorized roads and trails adjacent to the Continental Divide Trail between Fletcher Pass and Rogers Pass that provide inappropriate access the Continental Divide Trail. These should be collectively closed and obliterated to prevent motor vehicles from traversing the Anaconda Hill Non-motorized (IRA) Area with its key grizzly feeding areas as well as the Continental Divide National Scenic Trail.
   The area of Anaconda Hill IRA is within a (Circle 5) non-motorized AREA, closed year-round to all wheeled vehicles for over 25 years to provide wildlife security. Yet the proposed action maps displays new forest road (FR 1980) originating on private lands and traversing miles within this long-standing Non-motorized Wildlife Area.
   BHA members are puzzled—how and when was a new forest road authorized within a Non-motorized Management Area ? Despite this, the proposed action fails to obliterate and effectively eliminate this route through the heart of Non-motorized (roadless) Wildlife Security Area along the Continental Divide.
2. The Trail 487 should be closed to all motorized use as it compromises the value of the Nevada Mountain Roadless Area as wildlife security.
3. The Trail 440 should be closed to all motorized use as well as it compromises the value of the Nevada Mountain Roadless area as wildlife security.
4. The Trail 485 now open to motorized uses between Beaver Cr Road and Copper Camp compromises the value of the Arrasta Mountain Roadless Area as wildlife security and should be closed to all motorized use.
5. In addition, please close and obliterate the Road 771-A1 to Copper Camp, and close Trail 417 to motorized use to protect goat poulations. The non-motorized nature of this basin would favor the Red Mountain mountain goat population, as well as provide a non-motorized experience in the upper Copper Creek Basin. Easy road access such as these motorized routes has led to eradicated mountain goat populations in other areas.
6. There are several areas on the District which have an unnecessarily high density of roads and trails open to motorized use that certainly precludes these areas from suitable habitat for more reclusive species such as elk and grizzly bears. These areas are without merit as non-motorized hunting opportunities. We request an analysis of the need for high open road density in areas of a) Rogers pass-Beartrap Cr drainages, b) Stemple Pass-Granite Butte-Virginia Cr vicinity, 3) Ogden Dalton vicinity, including Roads 1823 and 1163-E2 previously closed to public motorized use 4) Trapper Mtn to Nevada Lake face roads currently open during the archery season.

We reiterate the above six specific requests provided in previous scoping.

All proposed motorized routes should be compatible with soil, drainage, wetland, and noxious weed protections and within the anticipated budgets of the District to maintain these routes. National road policy dictates you must display a minimum road absolutely necessary as part of the process. We request display of this minimum road network. We also request site specific analysis of each route to be compatible with Forest Plan watershed, fish and wildlife direction and standards in the current Forest Plan. We encourage obliteration of roads and ORV trails no longer deemed needed to improve enforcement and provide resource restoration and protection. All Forest Plan standards and guidelines must be met in the selected alternative.
We reiterate the above issues, and are responding specifically to some of the actions or inaction advocated in your most recent scoping proposal.
We request reconsideration of “reclaiming” only 8 miles of road contained within the entire travel planning area. Obviously there are many old mining roads and outdated timber management roads that are good candidates for “reclaiming”. In many cases the management need for the roadbed no longer exists, and perpetuating these roadbeds invites unauthorized illegal use. In addition their perpetuation reduces wildlife habitat value and important security as they remain human conduits even if closed.

On those roads south of Highway 200 the proposal to “store” roads using gates must be reconsidered in light of the high cost and ineffectiveness of gates. From personal experience as former District Ranger, the cost of a single gate is about $1000 with required signing. Trying to close a road with simply a gate that has been open to public travel normally results in considerable vandalism and loss of one or two gates, plus creates enforcement issues and public frustration continually. Full obliteration is far preferable if an essential management need is not foreseen. If a road may be needed in the future, entrance obliteration and waterbarring can provide some options at less cost. “Entrance obliteration” by recontouring the road prism, if located and constructed properly costs far less (estimate $350) per closure and is more effective with lower enforcement issues. And in addition, such a closure sends a message that ALL traffic is prohibited, not just for those without a key to the gate. We would advocate for any stored road that aggressive waterbarring on the roadbed behind the closure be required to reduce residual erosion risk. The bottom line is road closures must be effective. The most effective are those fully obliterated, the next most effective are those entrance obliterated on steep lands unable to be circumvented, and least effective have proven to be gates.

The designation of 41 miles of new motorized routes is being proposed without justification or site specific analysis. In addition, designation of unauthorized user created routes sends the message that such unauthorized uses may well be legitimized by the Forest Service in the future. We request site specific analysis of all proposed routes to assess whether they meet Forest Plan wildlife, fish and watershed design standards, National Forest policy and direction and and can be effectively maintained and enforced with foreseeable budgets and manpower. We request before any route is included in this plan that each proposed new motorized route be site specifically assessed and documented by law enforcement personnel whether effective law enforcement and compliance is likely with each route proposal.

We request reconsideration of the proposal to continue to allow motorized use on the Long Gould-Hemville Trail in the Nevada Creek Roadless Area This is perhaps the largest potential elk security area south of Highway 200 and potentially provides a traditional hunting experience away from motors.
Montana BHA objects to providing 1l miles of motorized routes in the Speciman Creek Roadless Area along the CDNST. This motorized proposal dissects the roadless area into small pieces, thus destroying a traditional hunting opportunity. In addition, motorized use along ridgetops is the most disturbing to elk habitat security. It also promotes dropping hunters off a ridgetop to allow them to easily drop through the remaining elk habitat reducing its elk security value.

We look forward to continued participation with this important project on the Lincoln Ranger District.

Sincerely,

s/greg l. munther

Greg L. Munther, Chairman
Montana Chapter, Backcountry Hunters and Anglers