Montana 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:
“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.).”
From page 9 EA:
The 2011 assessment showed that Swamp Creek health had declined since 2006 and was in the nonfunctional category with the worst conditions present at the stream’s upper reaches. The primary factors driving the poor rating were a lack of adequate total vegetation cover of the floodplain and a shortage of preferred woody species establishment.”
From page 21 EA:
“Challenges remain along lower Robb Creek and within the Rock/Swamp Creek pasture where livestock pressures continue to show impacted riparian vegetation.”
These assessments document that grazing is dramatically affecting resources of both Rock Creek and Swamp Creek, as well as riparian areas associated with each. As you well know, riparian areas support a disproportionate density and diversity of wildlife as well. A nearly genetically pure westslope cutthroat trout population is adversely affected.
We request you intervene in approval of the grazing plan. We request for the next 6 year period of the grazing plan, no grazing should be permitted in the pastures containing Swamp and Rock Creeks. Riparian and stream conditions can improve with complete rest, but future grazing in the near term will perpetuate these conditions unworthy of a Wildlife Management Area.
Greg L Munther, co-chairman
Montana Backcountry Hunters and Anglers
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