August 18, 2018

Deb Entwhistle
Forest Plan Revision Team Leader
Helena/Lewis & Clark National Forest
2880 Skyway Drive
Helena, MT 59602

Subject: Helena/Lewis & Clark Forest Plan Revision

Dear Deb Entwhistle:

Montana Backcountry Hunters and Anglers: Who we are

I’m writing this comment letter on behalf of the Montana Chapter of Backcountry Hunters and Anglers (BHA), based in Missoula, Montana. We currently represent approximately 2,500 sportsmen and women across Montana. Our mission is 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, waters and wildlife. Wild landscapes that provide excellent big game security and the opportunity to hunt and fish in public land backcountry areas are our passion.

With regard to the Forest Service Plan Revision:

Thank you!
1) First and foremost BHA would like to sincerely thank the Helena Lewis and Clark National Forest (HLCNF) for including Alternative D in the Alternatives based on public support for more recommended wilderness. We deeply appreciate your considerable efforts to take public comments into account and act on them within the law.  

BHA’s strong support for Alternative D

We enthusiastically support Alternative D because it will help maintain the public lands that we consider the most secure, ecologically significant and wildlife-rich areas on the HLCNF.  Whether these areas ever become congressionally designated wilderness is irrelevant at this time. That the HLCNF maintains and manages these lands as suitable for wilderness is our goal.  That suitability precludes allowing motorized or mechanized use of these last wildest places.  Missing from the Alternative D list of recommended wilderness areas is the roadless core of the Elkhorn Range. Please add the roadless core of the Elkhorns to the list of recommended wilderness areas in Alternative D. It is important to note that when recommended wilderness areas are listed in Alternatives, B, C, and D, BHA strongly supports the added acreages for the areas as listed in Alternative D. We strongly oppose the HLCNF allowing ANY motorized or mechanized recreational use (ROS) in recommended wilderness lands or lands that still retain a primitive setting (such as Sweeny Creek, for example, in the Divide Geographic Area). To allow such use in recommended wilderness or primitive landscapes will inevitably degrade the wild character of these areas.  It will lead to a situation wherein allowed use must be “taken away” when and if congress acts on these areas via wilderness bills.

We support the fact that all Alternatives restrict mechanized use to designated trails. We submit that mechanized use is not suitable for any primitive areas regardless of whether or not they are designated recommended wilderness.  

Keep Elk and other Game on Public Lands

A relatively new issue is that of human activity (including motorized and mechanized vehicle use and hunting), pushing elk and other game off of public land onto private lands where non-outfitted hunters cannot pursue them. The roadless lands recommended for wilderness in Alternative D are the areas where public land elk are most secure. If these lands were roaded and developed it would only exacerbate the problem of big game seeking refuge on private lands where most BHA members have no access.

Long-term Hunter-Conservationist interest in maintaining Wild Places

It is important to remember that the areas listed for recommended wilderness in Alternative D are still wild because they constitute difficult terrain that has never been easily roaded and/or logged. These are the last scraps of wild country within much larger landscapes of managed forestlands. We note that the acres deemed suitable for timber production are relatively similar across all of the Alternatives. The other and most important reason that these roadless lands still remain wild is that Montana citizens have repeatedly fought planned forest management activity in these, their favorite hunting, hiking, and fishing, spots. From BHA’s perspective the hunter-conservationist interest in maintaining these public lands in their current primitive condition is high. These recommended wilderness areas are the places where we pursue our passion. 

Special Places to BHA Members

2) Of particular interest to Montana BHA members are the following roadless areas called out in Alternative D. These are areas where our members hunt, fish, hike and/or ride horses. 

a) The Scapegoat additions: Arrastra Creek, Red Mountain, and Dearborn Silverking. These areas will be well-deserved and appropriate additions to the Nationally significant Scapegoat Wilderness complex. Having personally spent significant time in the Dearborn Silverking area in the last few months I can attest to the wild character of the area, the ubiquitous presence of mule deer, elk and grizzly. This area is popular with BHA hunters and fishermen, is a much-used backcountry hiking area and yet is remarkably accessible to members in Missoula, Great Falls, Helena and Lincoln. Many of our families take their first backpack trip on the easy trail along the Dearborn. The Alice Creek Trailhead sees nearly daily use by summer hikers from across Montana and the nation.

b) In the Divide Landscape these areas include: Nevada Mountain, Little Blackfoot Meadows, and Colorado Mountain. All three areas act as important big game security habitat for elk, deer and bear in a highly fragmented landscape. These three areas offer significant benefits as travel corridors and refugia for dispersing grizzlies, wolverine and lynx making their way south from the Northern Continental Divide Ecosystem, as well as many other species. Nevada Mountain is a huge expanse (50,000 acres plus) of ecologically significant wild country, near and dear to the hearts of considerable numbers of backcountry elk hunters.  Local hunter-conservationists have been pushing for wilderness designation for this “Southern Crown of the Continent” roadless area for over forty years. Little Blackfoot Meadows contains superb elk summer range and security in almost 30,000 acres of parks and lodgepole timber. It also contains important moose habitat. The Colorado Mountain area offers the best elk security in Hunting District 335, contains important winter range, and is the primary habitat for Helena’s backyard elk herd. Local hunters and BHA members have been hunting this area and campaigning to make it wilderness since the late 1970s.  
c) The Big Belts Landscape includes the Big Log addition to the Gates of the Mountains Wilderness, and the Mount Baldy, and Camas Creek roadless areas. Big Log is heavily used by local mule deer and elk hunters. Likewise, the alpine lakes in the Birch Creek basin (Mount Baldy) are popular with backcountry fishermen. Mount Baldy and Camas Creek provide important security cover for elk and other big game in the heavily roaded and motorized Big Belt Range.  

d) In the Little Belts the Deep Creek and Tenderfoot areas are rugged and wild.  Tenderfoot Creek is an important Smith River tributary and rainbow trout spawning stream. BHA members hunt deer, elk and bear in these two roadless areas, and many of them float the Smith River along its western boundary. Deep Creek and Tenderfoot offer our members excellent hunting and fishing, and opportunities for deep solitude.  

e) Finally, we support recommended wilderness in the Big Snowies and the roadless core of the Elkhorns. The Big Snowies constitute Lewistown’s southern backyard. Our members hunt deer, elk and black bear in the range. They also backpack and hike the deep limestone canyons and interspersed ridges of the area. In the rather dry prairies of Central Montana the Snowies are well watered and full of game.

The Elkhorns Wildlife Management Unit is the only congressionally designated Forest Service land in the system where management of wildlife is meant to be top priority. The core of the Elkhorns meets the desired conditions for wilderness in every way.  Motorized and mechanized recreational use of the roadless core of the Elkhorns must be restricted in order to maintain this condition. This range is home to a Nationally known elk herd and the location of some of the most difficult to draw either-sex elk licenses in Montana. The Elkhorns are one of the most popular elk hunting units in the state and many BHA members hunt here or hope to one day. 

It is important to note that in 1998 the Helena National Forest Supervisor made the Elkhorn Wildlife Management Unit unavailable for oil and gas leasing. Please amend the Plan to reflect this settled decision.  

Science-based Big Game Security Standards-Missing

3) BHA believes strongly is science-based wildlife and habitat management.  

We note some proposed Forest Plan standards for the Western Toad and a few pertaining to the grizzly, but feel that the omission of big game security standards is a serious flaw in the proposed new plan. No new science is cited to refute the science behind the big game security standards adopted in the 1986 Plan. The Guidelines described on page 104 are general, vague, and for the most part, meaningless. Big Game security is THE most important variable in keeping elk and other big game on HLCNF lands during fall hunting seasons. Simply stating that security will be dealt with on a piecemeal basis in consultation with Montana Fish Wildlife and Parks is not enough. We strongly believe that “elk hunter days” are not a scientific basis for measuring big game security.  

We have serious doubts about the HLCNF’s ability to maintain healthy public land elk herds over the long term in the absence of big game security standards.  
When new forest management projects are proposed there will be nothing by way of peer-reviewed science to measure the new project against. What is your strategy for maintaining elk and other big game on the managed portion of the HLCNF without regard for hiding cover and other security measurements? We ask that the HLCNF work together with Montana Fish, Wildlife, and Parks to adopt a science based big game security standard that includes hiding cover.

No new Hunting/Fishing Outfitter Permits on HLCNF

4) BHA believes that there are already enough existing hunting and fishing outfitter permits on HLCNF (held at 68 since the 1986 Plan). We believe the Forest should adopt a standard stating that no additional hunting outfitter permits will be granted by the Forest.

Trails – No net gain in Trail miles without adequate maintenance budget

5) Because the HLCNF has a significant backlog of trail maintenance, we believe that the Plan should adopt a guideline that requires no net gain of trail miles unless the HLCNF can show that it has the resources to maintain the Forest’s full trail system. 

Wild and Scenic Rivers

6) BHA is a member of the Montana Healthy Rivers Coalition. We support and agree with the comments submitted by American Rivers, one of our Montana Healthy Rivers Coalition partners, in regard to recommendations for Wild and Scenic Rivers under the HLCNF Forest Plan Revision process.  

Importance of Fire on the HLCNF Landscape

7) The current progression and scale of disease killed trees and dead biomass across the HLCNF is likely unprecedented, due to a century of increasingly successful fire suppression. There are hundreds of thousands of acres of biomass consisting of largely dead, dying and down trees. The economics of logging such stands is extremely negative. There likely will never be funding to mechanically treat more than a small percentage of these dead stands over hundreds of thousands of acres. Ecologically these acres need fire. The Forest Plan should detail how wildfire under moderate summer or fall burning conditions could be accommodated to consume some of the dead biomass and stimulate a new, healthy and beneficial vegetative community. Wildlife of all forms would benefit from fire disturbance. Prescribed fire is a needed tool as well, but prescribed fire needs to be planned and programmed for activity at landscape level over longer burning periods, not merely small units with heavy confinement lines burned only under short duration ideal conditions. Due to limited suitable burning windows and limited manpower, conventional prescribed fire will not make a significant change in the scale of needed fire across the Forest. 

Aggressive Obliteration of Unnecessary Roads

8) The plan should clarify that mechanical and prescribed fire fuels treatments are appropriate to protect WUI structures, but are ineffective for structural protection as treatments are located further from structures. While some existing primary access roads are necessary, there remains a proliferation of single use and user created roads that are currently detrimental to both water quality and wildlife. Road maintenance costs exceed projected revenues. The Forest Plan must specify an aggressive program to remove unnecessary roads from the landscape, especially using road obliterations. Benefits include reduce the spread of invasive plants, reduce sedimentation of streams, and improve security of big game species. 

Enhancing the Quality of Headwater Streams

9) Climate change will continue to adversely change streamflow and water temperature conditions. Priority protection and restoration of Forest headwater streams will be essential to maintain stream-associated values both on the HLCNF and downstream. Cold water fish, amphibians and invertebrate species, including westslope cutthroat and Threatened bull trout, will find their last refugia on Forest streams, if these streams are properly managed. Deliberate Forest Plan direction to enhance streambank water storage and water retention can markedly improve late summer streamflows and retain low stream temperatures. Higher flows and colder temperatures will benefit both on-Forest fish as well as off-Forest downstream water uses. Encouraging beaver in all suitable habitat will dramatically lessen floods, store sediments, improve bank storage and late season streamflows resulting from dam storage. Beaver dams occupying all potential beaver habitat will keep water on the Forest longer during peak flows and will store sediment. Their enhancement of riparian areas and streams also improve and enlarge fish and wildlife habitats. Some riparian areas currently need much more protection from cattle to allow shrub and channel restoration that both shades streams and accommodates beaver reestablishment.

Thank you for your consideration. 

Sincerely,

Steve Platt
Capital Board Member 
Montana Chapter of Backcountry Hunters and Anglers