Montana BHA Draft Lewistown RMP Comments

July 17, 2019

Draft Lewistown RMP Comments


Bureau of Land Management - Lewistown Field Office
920 NE Main Street
Lewistown, MT 59457


To the dedicated staff at the Lewistown BLM Field Office:


The Montana Chapter of Backcountry Hunters & Anglers (MT BHA) welcomes the opportunity to comment on the Draft Lewistown Resource Management Plan. Our organization is composed of more than 3,000 Montana hunters and anglers, many of whom hunt, fish and/or explore our public lands covered by the Lewistown Resource Management Plan.


Less than 30% of Montana is public land, meaning most Montana hunters and anglers, including our members, greatly depend on the current public land opportunities. Our members and other Montanans have stayed in Montana – or even made sacrifices to move to Montana – for these outdoor opportunities. Some have started businesses in Montana or kept their businesses in Montana because of these public land opportunities. Thus, our members take the decisions to be made in this planning process very seriously.


Our organization believes that Alternative B is best for Montana in the long term.


MT BHA has a high percentage of young adult participants (68% of us are age 45 or younger) who will have to live with the resource consequences of this decision for the rest of their lives. Alternative B best provides for maintenance of long-term resource productivity, and best protects remaining unique and best-preserved portions of the planning area. Alternative B recognizes and protects those areas identified with wilderness characteristics. It maintains the productivity and ecological characteristics of existing ACECs and maintains eligibility of stream segments eligible for classification under the Wild and Scenic Rivers Act. Most importantly, Alternative B maintains most of the land in near current use status, while not risking the degradation of those areas most valued by Montana citizens.


Without doubt, Preferred Alternative C puts significant acreage at risk of loss of long-term biological productivity, including wildlife habitat. Alternative C certainly reduces the quality of experiences that Montanans expect and rely on when they visit their public lands. Alternative C virtually eliminates constraints on energy-related surface disturbances and human uses, regardless of impacts to biological resources, or the quality of the environment. Alternative C plans to manage for narrowly defined commodity-oriented, short-term economic potential over broad-based long-term social andeconomic value of these lands. Alternative C understates the biological risk and long-term adverse economic consequences to local communities and to current uses if sage grouse are listed as Threatened or Endangered. Alternative C dismisses the BLM’s own sage-grouse plan for the area which identified protective measures for about 233,000 acres of core sage-grouse habitat along with another 112,000 acres of other areas used seasonally or year-round by the prairie birds. Alternative C also eliminates any protections for areas with Wilderness characteristics.


According to the BLM’s mission statement, “The Bureau of Land Management’s multiple-use mission is to sustain the health and productivity of the public lands for the use and enjoyment of present and future generations. The Bureau accomplishes this by managing such activities as outdoor recreation, livestock grazing, mineral development, and energy production, and by conserving natural, historical, cultural, and other resources on public lands (emphasis added).


After careful evaluation of this Draft, Montana BHA does not believe Alternative C meets the multiple use mission of the BLM stated above. It is apparent throughout the assessment of Alternative C that commitment to perceive short-term economic possibilities would be sacrificing common-sense protections and fails to protect key and unique areas within the planning area desired by present and future generations.


Montana BHA evaluated the Purpose and Need (ES.2) that were identified by the BLM which prompted the need for this RMP revision; our responses are as follows:


  • How can the BLM manage public land uses while maintaining and improving terrestrial and aquatic habitats?


MT BHA Response: Simply put, the preferred Alt C fails to “maintain and improve terrestrial and aquatic habitats.” Opening 91% of the area to energy development fails to “maintain and improve terrestrial and aquatic habitats.” Pumping and discharging ground water during energy development – water that is critical to sustaining springs in this arid environment – does not “maintain and improve terrestrial and aquatic habitats.” Disregarding existing protections for sage grouse “fails to maintain and improve terrestrial and aquatic habitats.” Disregarding protection afforded ACECs “fails to maintain and improve terrestrial and aquatic habitats.” Therefore, Preferred Alternative C should be dismissed as not meeting the intent for this revision.


Instead, Alternative B best meets the intent of this revision issue.


Regardless of Alternative selected, it is important that this revision adopt Backcountry Conservation Areas in the final RMP to conserve important big-game habitat and other critical unfragmented areas, to prioritize active habitat restoration and enhancement, to allow for and protect traditional values and uses of these lands to continue and to support important public access for hunting and other forms of recreation. Montana BHA suggests that, at a minimum, both the Arrow Creek Breaks and Crooked Creek landscape be designated as Backcountry Conservation Areas. Hunting Districts 410, 471 and 426 are extremely important to Montanans seeking public-land hunting opportunities in central Montana. Antelope, elk and deer are sought by big-game hunters, while sage grouse and sharptails are native birds pursued by many upland bird hunters.


  • Which areas should be open to mineral and energy development, and how should the BLM manage such development, while protecting human health and natural and cultural resources?


MT BHA response: Allowing mineral and energy development on 91% of the area does not protect human health nor cultural resources. We believe the “irretrievable commitment” (4-214) of water related to energy development in an arid area will adversely affect human health, as well as adversely impacting springs and seeps which are both critically important to wildlife. These wildlife resources are culturally important resources to Montanans. Therefore, we believe Preferred Alternative C fails to meet the stated intent for this revision, while Alternative B does assure a much better protection of such human health and culturally important resources.


  • How can the BLM manage areas that contain unique or sensitive resources?


MT BHA Response: Certainly, dismissal of the protections currently afforded to existing ACECs in Preferred Alternative C does not fit the intent of managing unique and sensitive resources. Nor does the removal of protection of wilderness characteristics with lands found to have such characteristics. Alternative B, however, does an adequate job of managing unique and sensitive resources. Also, we advocate that recognizing Backcountry Conservation Areas in any selected Alternative would be appropriate to meet this issue that is dictating this Revision.


  • How can the BLM manage increased conflicts between competing resource values and land uses, while accommodating increased demand for resources and activities?


MT BHA Response:  Preferred Alternative C is certain to increase conflicts of resource values and land uses. The current allocation or Alternative B will best manage conflicting uses. 


In summary, Alternative C fails to meet the Purpose and Need for this Decision and therefore must be discarded. In contrast, Alternative B best meets the Purpose and Need related to this decision.

Discussion of Alternatives


“Alternative C consists of a mix of uses on BLM-administered land and mineral estate based on making the most of resources that target social and economic outcomes, while protecting land health.”


MT BHA Response: It is outdated to frame “social and economic outcomes” as commodity outputs primarily. To the contrary, the rapid increase of outdoor recreation presently adds more than $7 billion annually to Montana’s economy and outstrips many other measures of economic wellbeing. In addition, the management of our public lands for wildlife, recreation and wilderness, including Lewistown Resource area, will continue to make Montana attractive to existing and new businesses across Montana. Protecting wilderness characteristics and establishing Backcountry Conservation Areas assures recreation diversity and abundant wildlife, both of which bring economic benefits to surrounding communities. In contrast, allowing habitat degradation through wide-open energy development that Alternative C encourages will certainly contribute to listing sage grouse as a Threatened Species. As stated, “This plan considers changes from the 2015 Greater Sage-Grouse Approved RMP Amendment related to mineral materials and does not carry forward the recommended mineral withdrawal for Sagebrush Focal Areas.” Such listing will be averse to the existing grazing-related portion of the economy, as well as many other land uses. In addition, the adverse effect of not protecting Sagebrush Focal Areas will negatively affect the hunting economy related to all species dependent on sagebrush focal areas, including antelope, mule deer and elk, as well as many game bird species.


Alt B emphasizes improving, rehabilitating, and restoring resources and sustaining the ecological integrity of habitats for all priority plant, wildlife, and fish species, while allowing appropriate development scenarios for allowable uses.


MT BHA Response: MT BHA believes Alternative B best addresses the issues identified as Purpose and Need (ES.2) driving the revision of this RMP. Alternative B recognizes that both outdoor recreation and wildlife values are important to Montanans both in the short- and long-term. Alternative B recognizes that 31 units with 202,000 acres including wilderness characteristics should be managed to protect those characteristics, which assure ecological health and continued recreational diversity. Alternative B protects quality of habitat on ten existing ACEC areas, which, by definition, are extremely important ecological areas. Alt B protects 32% of the resource area from uncontrolled off-road vehicles, thus providing a range of recreational experiences while protecting wildlife habitat values of those selected areas. Alternative B recognizes and protects sage-grouse habitats that are essential to maintain the future of sage grouse on the landscape and to forgo the need for listing as a Threatened Species.  Alternative B establishes 228,800 acres of Backcountry Conservation Areas, which assure continued uses while protecting wildlife and recreational values.


We must note that while we agree that lands having wilderness characteristics certainly provide “emotional connection people have with undeveloped and publicly accessible lands,” they provide much more. Lands with wilderness characteristics are largely unfragmented lands. Unfragmented lands are the best at providing habitat characteristics for species such as sage grouse, mule deer, elk and antelope. Such unfragmented lands provide some habitat security during hunting seasons to allow some animals to reach maturity which are the most-sought by some hunters. Unfragmented lands allow long, liberal hunting seasons without depleting hunted wildlife populations. Unfragmented lands provide solitude and remote experiences.


Irreversible Commitment of Resources


Depletion of surface water from watersheds may result in an irretrievable commitment of water that would otherwise have contributed to major river systems, including the Missouri River. Produced water from oil and gas wells in the planning area may be an irretrievable commitment of groundwater, depending on its use, once it reaches the surface. Increases in sediment, salinity, and nonpoint source pollution that result from surface disturbing activities could result in degradation of water quality and a Biological and Transportation and Access Stipulations pages (2-238 thru 247). MT BHA believes that depletion of surface and ground waters will be devastating to arid environments. Given the unpredictability of precipitation with present and future climate change, any decisions related to this plan should be framed to minimize or avoid any depletion of surface or ground water.


In addition, irreversible commitment of resources must acknowledge that fragmentation of intact portions of the sagebrush-steppe environments is an irreversible commitment along with associated environmental impacts of such planned actions.


Management Stipulations (2-7)


With one major exception (Stipulation 323)MT BHA supports and urges adoption of many Alternative B stipulations (which apply to other Alternatives in some cases) and restrictions for biological resources and special travel, transportation management and Access. Regardless of what Alternative is selected, we urge inclusion of the following stipulations into the final Plan that are of particular importance to future well-being and public use of these lands:

43. Objective: Maintain functioning hydrologic systems and provide a scientific, landscape approach to natural and human-influenced water systems. Increase the percentage of lotic riparian-wetland miles in the potential natural community, or at their capability, from approximately 63 percent to 80 percent by 2038 on all streams, including those streams listed as water quality impaired.

65. Objective: Minimize fragmentation of large intact blocks of sagebrush/grasslands. The necessary habitat, biological processes, and disturbance regimes would be allowed to maintain, enhance, or restore sagebrush/grassland species

88. Objective: Increase the percent of lotic riparian-wetland miles in potential natural community, or at their capability, to 80 percent by 2038. Increase the percent of lentic riparian-wetland acres in potential natural community, or at their capability, to 80 percent by 2038.

90. Allowable Use: Manage riparian wetland areas as ROW exclusion areas for roads and utility corridors, except for existing ROW corridors

109. Objective: Necessary habitat, biological processes, and disturbance regimes are present to maintain, enhance, or restore priority wildlife habitat and populations of special status species. Land use maintains habitat quality and large intact blocks of habitat. Habitat quality and land use allow wildlife species movement between large blocks of habitat and between seasonal habitats on a localized- and landscape-scale.

118. Action: Improve or maintain woody vegetation. Short-term treatment effects may be allowed if long-term benefits are expected.

128. Objective: Protect or enhance areas of ecological importance for special status species. Manage for no net loss of habitat for special status species.

232. Objective: Identify lands with wilderness characteristics and manage lands with wilderness characteristics to maintain: a high degree of naturalness; outstanding opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation.

235. Allowable Use: NO LEASING NL Lands with Wilderness Characteristics

278. Meet the forage demands of livestock operations based on current permitted use (AUMs), with an emphasis on other resources for forage demand (e.g., wildlife)

280. Action: Manage 30,000 acres as unavailable for livestock grazing, which includes portions of allotments and un-allotted land. All parcels not currently authorized for grazing use and certain other tracts similarly unauthorized for grazing use would be unavailable.

281. Action: Establish allotment stocking rates for watershed function and cover/forage by wildlife. This action corresponds with a light (21 to 40percent) forage level.

289. Action: No new sheep or goat allotments or conversions would be allowed in occupied wild bighorn sheep habitat. New sheep/goat allotments or conversion from cows to sheep/goats would not be allowed within 20 miles of occupied wild bighorn sheep habitat. Exact distances between domestic sheep and bighorn sheep would be based on habitat and movement potential.

300. Action: Designate four ERMAs (Figure 2-38, Alternative B: Recreation Management Areas [Appendix A]): • Arrow Creek backcountry conservation area ([BCA]; 12,800 acres) • Cemetery Road BCA (13,400 acres) • Crooked Creek BCA (183,500 acres) • Judith Mountains BCA (19,100 acres).

307. Objective: Maintain and improve land health while promoting responsible use through active travel management. Within each travel management area, designate a comprehensive travel management system that achieves resource management objectives; provides appropriate, sustainable public and administrative access; communicates with the public about opportunities; and monitors the effects of use.

308. Action: Manage specific areas to protect resource values in special designations, preserve and protect wilderness characteristics, protect vegetation and soils to maintain watersheds and water quality, reduce user conflicts, and reduce harassment of wildlife and provide habitat security. In areas designated as limited, restrict public cross-country OHV use on BLM-administered land yearlong or seasonally to existing routes.

310. Action: The BLM would emphasize management of the transportation system to reduce effects on natural resources from authorized roads, primitive roads, and trails. The BLM would also consider, through travel management planning, closing and restoring unauthorized routes to prevent resource damage.

316. Action: Manage 209,000 acres as closed to motorized travel* (Figure 2-42, Alternative B: Travel, Transportation Management, and Access – Motorized and OHV

318. Action: Manage 413,500 acres as limited to designated routes yearlong for OHV travel.

319. Action: Seasonally limit OHV travel and promote nonmotorized travel in the Chain Buttes and East Indian Butte Block Management Areas (BMAs; 28,700 acres*).

321. Action: Prohibit motorized cross-country OSV travel in the following locations (220,200 acres; Figure 2- 48, Alternative B: Over-Snow Vehicle Travel [Appendix A]): • Lands managed to protect wilderness characteristics • WSAs • ACECs: o Blind Horse o Chute Mountain o Deep Creek/Battle Creek o Ear Mountain • Areas with winter restrictions • Crucial wildlife winter range.

323. We have strong objections to Alternative B stipulation for the Durfee Hills. Without a land-based public ROW accessing the Durfees through private land (one currently does not exist), recreationists – including hunters – would be unable to access or use the Durfees under Alt B stipulation, “Action: Manage the Durfee Hills area as closed to motorized travel. Instead, it is only reasonable to allow aerial access to the Durfee Hills as per the stipulation for Alternative D Action: Manage the Durfee Hills SRMA to support recreational opportunities (primarily big-game hunting) for fixed-wing aircraft and helicopters.

325. Action: Where private landowners have demonstrated willingness to provide public access across their lands, the BLM would manage for public access from BLM-administered lands across such private lands in travel plans. Exceptions include routes that the BLM has proposed as closed or are known to be posted or otherwise closed to the public by private property owners. The BLM has no control over private road traveling through private land onto BLM-administered lands. Access across private land is subject to change. Where public motorized access is contingent upon the governing consent of adjoining landowner(s), the BLM would exercise a reciprocal “All or None” road use policy. This means that as long as the public is allowed access to these roads, no changes in travel management would occur; however, should the adjacent landowner refuse public access, then the BLM would reciprocate by closing its roads to their use as well.

326. Action: Obtain legal public or administrative access over nonfederal lands from willing landowners or state or other federal agencies, as appropriate, on a case-by-case basis as the need or as the opportunity arises and using criteria and direction in the Land Tenure alternatives (see Land Tenure section below). Methods used to acquire access include easements acquired through purchase, exchange, or donation; reciprocal ROWs; land exchanges; fee title purchase; cooperative agreements; reservations; permits; donation of fee land; covenant language in patents or deeds; or long-term land use agreements.

407. Action: Determine that the 27 stream segments are suitable for inclusion in the National Wild and Scenic Rivers System.

419. Action: If Congress releases Square Butte WSA from wilderness consideration manage as the Square Butte ACEC

In conclusion, MT BHA believes that the Final Plan must provide for long term protection and proper function of the natural resource base, while providing for the present and future public use of the area that is compatible with natural resource needs.






s/ doug krings

Doug Krings, Montana BHA Chapter Board Member (Lewistown)



s/greg munther

Greg Munther, Montana BHA Chapter Conservation Director (Missoula)


About Greg Munther

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