by Greg Munther, Nov 11, 2012

To: Kevin Riordan
Forest Supervisor, Helena National Forest
2880 Skyway Drive
Helena Montana 59601

And

Amber Kamps, District Ranger
Lincoln Ranger District
Lincoln, MT 59804

The Montana Chapter of Backcountry Hunters and Anglers is composed of Montana hunters and anglers who value and seek quality big game habitat and traditional non-motorized hunting and fishing opportunities. Many of our members both hunt and fish on the Helena National Forest, particularly hunting for elk.

As you are aware, the Helena has some quality backcountry such as the Scapegoat and parts of the Elkhorn mountains. However, most of the few remaining secure, undeveloped parts of the Helena are unroaded simply because they are overly steep, rocky and otherwise unproductive for both timber and elk. Studies of elk habitat selection document that elk, like people, select for gentler terrain and spend little time on terrain over 30% slopes. However, much of the lower, gentler, and often most productive elk habitats of the Helena have been roaded, have been laced by ORV routes, or both. In the last 25 years the problem has been exacerbated by a proliferation of off road vehicle routes, both authorized and unauthorized renegade routes. In addition the frequent and extensive violations of existing motorized restrictions render much of the Helena’s most productive elk habitats seriously compromised, particularly as they need to serve as secure habitats during the hunting seasons.

The Helena’s elk habitat condition now is largely fragmented and often marginally or insufficiently small during both the archery and general hunting seasons. This deteriorated condition has adverse impacts on elk security now and likely will have even worse effects in the future. Hunters on the Helena are already experiencing major displacement of elk from public lands onto private lands, where general hunter access is most often denied. This is a problem not unique to the Helena, as it is already a phenomenon on the Beaverhead-Deerlodge, the Gallatin and the Lewis and Clark Forests. The behavioral response of elk to human disturbance was well documented in Montana by Grigg (2007), who documented elk moving from the roaded Taylor Fork to the private Sun Ranch early in the archery season. In addition, mature bulls, a favorite hunter pursuit, are increasingly a smaller percentage of the herd due to lack of security on public lands. A mature bull component is important to breeding and breeding timing that results in calves mature enough to survive their first winter. Without protecting and enhancing hunting security, the existing 5 week general season will trend toward more permits-only hunting or shortened seasons, or both. The Elkhorns area, for example, has mature bulls, but also a very limited number of permits.

The response by responsible land managers to these elk related issues must be to enhance, rather than lessen the quantity and quality of secure elk habitat. Elk security is a relatively simple relationship of distance (enhanced by broken topography) from motorized routes. It is fortunate that Helena land managers can indeed restore elk security if the number of motorized routes can be reduced.

The importance of elk security during archery seasons cannot be understated. Often public land elk have been displaced to private lands even before general elk seasons have begun as documented on the MDFWP studies on the Gallatin National Forest (Grigg, 2007). Furthermore, Forest Service studies of elk in the Blue Mountains of Oregon (Wisdom, et al, 2005) have documented by telemetry under carefully controlled conditions that elk are displaced as far as .93 miles by the presence of motorized vehicles.

Despite our repeated phone requests we have not been told what the Helena NF is considering as a new elk security standard. According to rumor, the Helena may want to focus on the Hillis Paradigm as guidance to managing elk security on the Forest in the future. However, the values used and its application to the Helena is unvalidated and lacks scientific scrutiny. This concept lacks any scientific validation as to the adequacy of the patch size (250 acres) or the distance from motorized routes (1/2 mile). The Hillis Paradigm, never validated, was developed for Westside Forest conditions, primarily the Lolo. The Lolo consists of largely heavily forested landscapes with often dense understories which are far different that most of the Helena, which has numerous and extensive natural openings. Another major weakness of this concept is that it, without validation, discounts that significant numbers of elk hunters do indeed walk more than ½ mile from a road (a 10 minute walk on easy terrain) and would displace from a 250 acre patch ( about 1/3 square mile) in less than an hour. We believe if you tell a serious elk hunter there is a 250 acre patch of unbroken timber habitat only ½ mile from a road, many, if not most, would willingly walk to such “secure” elk habitat. The Hillis Paradigm also fails to consider the presence of old roadbeds, trails or gentle terrain common to the Helena which facilitate easier and quicker travel to a cover patch. In summary, we conclude the Hillis Paradigm is overly simplistic, unvalidated and inappropriate for the Helena and would be ineffective as a elk security standard.

Most knowledgeable elk hunters know where the remaining elk security is on the Helena. Any patch of timber less than a mile from a road or ATV trail will have hunters in that habitat nearly every day during the season. It is our estimate that a solo hunter can hunt thru a 250 acre patch of cover (1/3 square mile) in less than an hour and likely move most or all elk from this cover patch. How many times and at what frequency is an elk herd disturbed before it seeks private land? Based on the eastside forest Griggs study, this threshold occurred in the Taylor Fork during the archery season and before general season even began.

The measure of successful elk security on the Helena is whether the majority of elk stay on the Forest thru the general hunting season, or until driven to private land due to snow depth on the Forest. Simply, there are far too many motorized routes open on Helena, with little attention to insuring there are sufficient numbers of large blocks of secure elk habitat on productive lands within the Helena. The open nature of the Helena National Forest strongly suggests that the Forest should manage for non-motorized landscapes, rather than patches of cover.

Backcountry Hunters and Anglers advocates the Helena establish 25,000-50,000 acre blocks of good elk habitat free of motorized routes during both the archery and general hunting seasons. This size of block of secure habitat is necessary to assure the center of such a block is at least 3 miles from a motorized route. Three miles distance can be walked on a closed road system or trail in about an hour, depending on topography. Such blocks of elk security should be established across the Helena, in each elk habitat unit, as determined by FWP.

Given the high demand for elk hunting in Montana, the high rate of participation by Montana citizens, the importance of elk hunting as a driver to the Montana economy, we feel strongly that elk hunting economic values can compete with any timber harvest or motorized recreation that would detract from elk security.

We question the catalyst for proposing to modify the definition of elk security. Is it to make it easier to keep motorized routes on the Helena? We question why a Forest Standard would be proposed for only for two travel plan areas on the Forest rather than Forestwide. The Blackfoot Travel Plan and the High Divide Travel Plans are still in the draft stage and can be modified to close motorized routes for large blocks of land. Any elk security proposal to modify the Forest Plan must be supported by the best available science including all current elk research results, including that on the Gallatin and Starkey Experiment Station. There are also comprehensive discussions of elk security variables are discussed in:

Hershey, Terry. 2011. Implications of Back-country travel on key big game summer range in the Bighorn-Weitas Roadless Area, Clearwater NF.

Backcountry Hunters and Anglers. 2011 Cumulative and Universal: ATV Impacts on the Landscape and Wildlife.

Proffitt, K.M., JL Grigg, K.L. Hamlin, RA Garrott. 2009. Contrasting effects of wolves and hunters on elk behavioral responses to predation risk. Journal of Wildlife Management 73(3) 345-356.

Gucinski, H,, M. Furniss, R Ziemer, and M. Brooke. 2001. Forest Roads: A Synthesis of Scientific Information. USDA PNW-GTR-509.

Grigg, Jamin L. 2007. Gradients of predation risk affect distribution and migration of a large herbivore. MS Thesis, Montana State University.

Wisdom, M.J. 2007. Shift in spatial distribution of elk away from trails used by all-terrain vehicles. Report 1, USDA Forest Service, Pacific Northwest Res. Sta., 1401, Gekeler land, La Grande, OR 97805.

The issue of inconsistent elk security direction between eastside Forest Plans was cited by the Lincoln District Ranger as a reason to change from current elk security standards. If consistency between eastside Forests is an objective, we question why the Helena is proposing to move forward with some new Forest-specific standard well ahead of other eastside Forests? We also are concerned that the three MDFWP biologists with responsibility for elk on the Helena contacted had no knowledge of specifically what the Helena was proposing as an elk security standard, despite a Notice of Intent to change the standard being already published in the Federal Register. This appears to be a serious deficiency in a process where the Helena asserts MDFWP has been fully involved throughout the process.

We request the Helena Forest adhere to the existing elk security definition in the Helena Forest Plan, unless and until all the elements of the following process and outcome can be assured.

A) Begin a new open, public process incorporating all pertinent science with full participation and equal partnership by FWP field biologists representing the areas considered for standard revision.

B) Full agreement and consistency with all 4 eastside forests and FWP of any new proposed standard.

C ) Outside peer review of the standard by scientists and biologists experienced in elk security in context with Helena vegetative conditions..

D) Any measure of Elk security for the Helena must assure 1) that condition of and quantity of elk security results in the majority of public land elk on any landscape will remain on public land during the hunting season, or until winter conditions force them to lower lands, and 2) the age distribution of male elk meets the goals of FWP following the hunting season .

E) The elk security standard must be applied equally to all elk hunting seasons, including archery only season, as well as general season.

F) ORV and motor travel regulations must result in nearly full public compliance, and be a measured, quantitative variable assessed in the effectiveness of any new elk security standard.

G) The trend toward reduced density of forest canopy must be addressed and compensated for by the reduction of motorized access route density.

H) The location of motorized routes selected on the landscape must be selected to favor those routes with the topographical position on the landscape least impactive to elk security.

Elk security areas also serve as grizzly bear and lynx habitat as well as travel corridors, which should be considered as any new standard is being considered.

Montana Chapter Backcountry Hunters and Anglers requests full participation as this process moves forward. We request we, as well as all other interested parties be immediately informed of any elk security standard proposal being considered . We also believe it appropriate that the public wildlife and hunting interest groups meet with your leadership immediately on this issue.

Sincerely,
Greg L Munther
Chairman, Montana Chapter

Cc: Faye Krueger, Regional Forester, Northern Region