Laurie Shannon
Planning Team Leader
Charles M Russell National Wildlife Refuge
P.O. Box 25486
Denver, CO 80225-0486

We are responding to the draft CMR Comprehensive Conservation Plan and Environmental Impact Statement, and request our comments be entered into the official public record.

Backcountry Hunters and Anglers is a national organization dedicated to preserving our world-class outdoor traditions by protection and restoration of important wildlife habitat components and traditional non-motorized hunting and fishing opportunities.   Our Montana Chapter includes hunters and anglers who live in communities surrounding the CMR as well as many more that hunt and fish on the CMR from other places in Montana.  Many of our members hunt and fish on the CMR throughout the year.

The future direction provided by the commitments of the CCP is critical to meet the legal requirements and intent of the National Refuge System.   Our organization strongly believes that this planning effort must first prioritize protection and restoration of wildlife habitat.  After wildlife habitat for all species throughout the entire refuge have been secured, then human uses should be accommodated to the degree that the special values of the CMR are not compromised.  This prioritization is that conceptualized by enabling Refuge legislation.  One of our concerns is that domestic grazing as it is currently practiced is detrimentally affecting some important ecological components of vegetation including buffalo berry and chokecherry.  Reduction or modification of existing grazing where a full complement of native vegetative species are being adversely affected must be a keystone element of the new plan.  Modification of grazing to be designed to emulate the effects of past bison grazing could maintain some domestic grazing while benefiting wildlife habitat.  Restoring a full complement of vegetation can better assure  ecological viability and resilience, abundant wildlife populations and perhaps reduce undesired ungulate movement onto adjacent private lands.

CMR special values and role of large native ungulates must be clear throughout the CCP.  This must include minimal displacement of wildlife off the refuge due to human disturbance, which is now aggravated by excessive motorized routes or excessive reservoir motorboat access.  This means that the refuge CCP must designate large non-motorized refugia across the CMR in sufficient sizes that large ungulates, such as elk, are not displaced in large numbers to private lands.  Recent study results from USFS Starkey Experiment Station in eastern Oregon documented elk displacement from ATVs in excess of ½ mile away.  This means some non-essential motorized routes must be closed through this CCP process to create more secure elk habitat.  Secure areas should be at least 3 miles from the nearest open road which equates to a hour hike for an average hunter. 

The CMR has the opportunity to offer a unique prairie ecosystem and associated outdoor human experience that cannot be replicated anywhere else in our nation.  Protecting or enhancing this experience potential for both the recognition of its ecological importance as well as the opportunities for the next generation of recreationists should be decision criteria used in the CCP process.  These special values must include that the human outdoor experience is not dominated by the sounds and sights of man.  The experience should include experiencing native vegetation that is not dominated by domestic grazing systems, or intense fencing.  The human CMR  experience should be one not interrupted by the sounds and sights of high speed motorboats nor the passing of motor vehicles.    We note that the existing motorized condition provides an unacceptable 82% of the CMR within 1 mile of a motorized route or reservoir motorboat access.  We advocate substantially reducing road and water motor access to secure important ecological habitats and substantially improve non-motorized traditional hunting and fishing experiences.  Such non-motorized experience opportunities should apply to both archery and general hunting seasons.

We request that the CCP support allowing ecological processes to operate and be visible on the landscape including natural fire.  We believe noxious weeds are one of the most onerous threats to the prairie ecosystem and advocate containment of invasive vectors, as well as avoiding vegetative conditions favorable to invasive species such as overgrazing. The CCP must be aggressive in preventing and containing invasive species on the CMR.

Backcountry Hunters and Anglers supports the preferred alternative D with requested modifications as described below.

Alternative D only proposes to close 23 miles of the overly dense and extensive road system.  The minute reduction of road mileage does not recognize the noxious weed vector motorized use creates, nor the road’s impact on ecological integrity of the CMR.  Many of the roads identified for retention duplicate access to the same destination, an example being Roads 204 and 205.  One of these roads could be closed without taking away access to the destination at the end of the roads. As another example, we find that Road 327 borders a recommended Wilderness area and does not provide essential access to any feature or facility.  We request this road be closed in the final Plan and adjacent lands be added to the recommended Wilderness acreage.

We support the additional Wilderness recommendations identified in Alternative D. Wilderness reinforces the mission of the refuge by providing blocks of undisturbed land and quality habitat.  It also provides security for big game and helps to keep wildlife on the refuge.

At the same time, we find no valid reasons for eliminating the East and West Beauchamps as recommended Wilderness.  A single road (201) penetrates these East and West Beauchamp which we recommend be closed and motorized access, if essential, be rerouted on other roads.  However, both East and West Beauchamp are greater than 5,000 acres, so they meet the size criteria for Wilderness.   

We suspect the private inholding in East Hell Creek recommended wilderness is the rationale for eliminating this area as recommended Wilderness.  However, Wilderness can and does include private inholdings and should not be a compelling reason for elimination if wilderness attributes exist. Currently there is no public access to East Hell Creek, but that could change in the future. Regardless of the whether it does change, it  also should not be used as a rationale for eliminating recommended Wilderness.

Most important, the three areas you are proposing to eliminate in Alternative D were originally recommended for Wilderness because they fit the Wilderness criteria in terms of size, naturalness, primitive character, negligible human activities, and opportunities for solitude. Since the original wilderness inventory conducted in the 1970s, these areas have remained much as they were then. We are not aware of any substantive changes to the landscape which detract or diminish their Wilderness character, nor does the EIS identify any changes. These areas are just as worthy of consideration for Wilderness now as they were in the 1970s.

We request, as a minimum, that the net acreage of recommended Wilderness not be reduced from the current plan. The native prairie, badlands, and river bottoms found in the CMR are underrepresented in Montana and the National Wilderness Preservation System. There are 3.7 million acres in designated Wilderness in Montana, only 3.4 percent of land area, and almost all of it is in the Mountainous areas in the Western half of the state. There are only 32,000 acres of Wilderness in Eastern Montana. Preserving the option of Wilderness for all of the areas provides an opportunity to diversity Montana’s, and the nations, Wilderness portfolio.

To recommend less than the current plan would not support the emphasis on ecological processes on which Alternative D is developed. Further, these areas remain worthy of wilderness designation and should be better represented in the National Wilderness Preservation System.

We also request a substantial public road mileage be closed during archery and general hunting season to provide secure habitat for large ungulates, especially elk.  Since the last plan, the CMR has experienced a great increase in boat-equipped hunters accessing CMR lands from the reservoir, resulting in lower elk security.  Another current phenomenon is the reduction of adjacent private land available to the average elk hunter.  Leased or outfitted private lands become relatively secure elk habitat that CMR elk are attracted to because of limited secure habitat on the CMR.   Both of these changes in the last planning period have reduced elk security substantially.  This has reduced the yearlong ecological presence of elk for at least 3 months.  Modification of the Final Plan to include key seasonal road closures during hunting seasons can provide large blocks of secure habitat to encourage elk to stay on the CMR rather than be displaced to private lands where only the wealthy can hunt them.  An example is the closure of Road 848 could substantially increase secure habitat.  All road systems closed or left open should be coordinated with adjacent private and public land managers.  In addition, the road system should not provide privileged access to the CMR from adjacent lands that are not open to the public.

We recommend the final Plan be proactive in restoring bison to the CMR.  Not only would the CMR be more complete ecologically with bison present, but bison would offer a traditional hunting opportunity in a relatively natural environment.   Evaluation of bison based grazing compared to domestic cattle is an intriguing role for the CMR in cooperation with Montana Department of Fish Wildlife and Parks.  Experimental use of conservation herds of bison, such as those of the American Prairie Foundation, could provide real knowledge of how bison might use the CMR and its vegetation.

MT BHA advocates policy that favors natural population levels of all native wildlife.  MT BHA supports restoration of a natural age class of deer, elk, bighorn sheep and antelope, as part of the ecological process theme of Alternative D.  We believe a buck/doe ratio goal of 25-30 bucks per hundred doe mule deer does not emulate the desire for a natural age class of mule deer and recommend increasing this ratio. Elk age class objectives on the CMR should in either a big game hunting experience or wildlife viewing experience that reflects a full age class spectrum of big game.   Big game on the CMR should be managed to a higher numbers and age class objectives than other public lands in eastern MT to maintain a quality hunting experience, and to better reflect the result of natural ecological processes of Alternative D.

We also would request the final plan capture the opportunity and desirability of reintroducing and restoring bighorn sheep to the south side of the river which may have at least as good or perhaps better bighorn habitat as the north side presently supporting a healthy herd.

Sincerely,

Greg L Munther, Chairman
Montana Chapter Backcountry Hunters and Anglers