*** Submitted via email on February 9th. Learn more and submit your own comments by February 12th at 5pm. ***

February 9, 2024

Liz Bradley, Region 2 Wildlife Manager

Montana Fish, Wildlife and Parks

3201 Spurgin Road

Missoula, MT 59804

[email protected]

RE: Spotted Dog WMA Grazing and Water Development Plan Draft EA

Dear Ms. Bradley,

On behalf of the Montana Chapter of Backcountry Hunters & Anglers and our roughly 3,000 dues-paying members, please consider the comments below outlining our response to the Spotted Dog Wildlife Management Area Grazing and Water Development Plan Draft EA and the two alternatives offered. 

Our members value wild places, quality habitat, public access, and the fair-chase hunting and fishing opportunities these things provide. So, it comes as no surprise that we continue to engage in the management of Spotted Dog, one of our state’s most treasured wildlife management areas. In 2019, our chapter submitted comments on the first phase of this grazing treatment plan. More recently, in July of 2023, BHA staff joined FWP and others for a tour of Spotted Dog to see and hear firsthand how domestic cattle grazing treatments impact the SD WMA.

Our stance is that grazing on the SD WMA should continue only if shown to substantially increase the long-term value to a wide variety of game and nongame species. We are not convinced the proposed alternative does this.

Fully recognizing that the draft plan is not a prescriptive, pre-approved grazing agreement, but rather a framework for allowing grazing, we feel the proposed alternative falls short. The no action alternative also seems less than ideal and problematic. Therefore, we encourage FWP to develop and ultimately adopt a different alternative, one that clearly prioritizes wildlife and wildlife habitat, ensures that domestic cattle grazing remains a carefully managed tool used judiciously only if and where it makes sense, and looks for other ways to strengthen landowner elk tolerance. After all, “the primary purpose of the Spotted Dog WMA is to benefit wildlife and fish habitats, and natural resources on behalf of the public,” according to the EA prepared by FWP.

First, what we like about the proposed alternative. 

Requiring public review and Fish & Wildlife Commission approval for future grazing agreements is appreciated. The focus on regenerative rest and rotation grazing practices that have been shown to benefit wildlife is good. We’re also excited by the flexibility of virtual fencing technology both in how this can focus grazing needs at a finer scale, but also in how this could potentially rid the landscape of unnecessary and problematic fencing. We recognize FWP’s efforts to protect valuable riparian areas, aspen stands, and wetlands by exploring other water development options, though these too come with added concerns and questions (below). Finally, we appreciate the requirement that partner grazing producers on SD WMA must allow some level of access to their private lands for public hunters, though we feel this deserves closer scrutiny in terms of both its effectiveness to address problematic concentrations of elk and elk behavior and to provide equitable public hunting opportunity.

Now, what concerns us with the proposed alternative.

When acquired in 2010, the primary funding source for this property was the Natural Resource Damage Program. “The goals of the purchase, as listed in FWP’s grant application to NRDP, were to:

• Permanently protect priority fish and wildlife resources.
• Enhance critical winter habitat for elk and mule deer.
• Maintain migratory patterns to and from the National Forest for a regionally significant elk herd.
• Provide lasting public access to previously inaccessible lands.
• Maintain landscape connectivity between the Blackfoot and Clark Fork watersheds.
• Replace lost and injured natural resources that were the subject of Montana v. ARCO.”

There was no mention of providing domestic cattle grazing opportunities, nor prioritizing adjacent agricultural interests over wildlife resources. As proposed, we remain unconvinced that livestock grazing will provide a definite benefit to the stated goals of this property.

While grazing can benefit wildlife and wildlife habitat if carefully managed and monitored, it can also create a host of problems such as forage competition, diminishing water quality, and spreading of invasive species. Creating an annual reliance on grazing in a public wildlife management area makes it difficult to balance the expectations of neighboring commercial interests and the public resource, especially during times of stress and scarcity (drought, fires, floods, etc). The proposed alternative offers little flexibility in terms of prioritizing wildlife and wildlife habitat as needed. Montana BHA welcomes an alternative that requires flexibility in the grazing regime based on resource needs and current conditions rather than the needs of neighboring livestock producers.

Even during times of abundance, outcomes of grazing are often far from perfect. For example, FWP acknowledges in the EA that it failed to “achieve the desired wildlife habitat benefits” of the EOU agreement and experienced containment issues with both forms of fencing technology. FWP signals that they intend to graze more intensely to reach desired goals and is committed to working “with the manufacturer (Vence) to improve the efficacy of the technology,” but the recent performance does not instill the confidence needed for our organization to support the proposed alternative, at least not until further testing and analysis is complete.

Furthermore, the proposed alternative fails to consider the nearly century-long livestock grazing history and its impacts, and what might be needed to restore the area to a pre-cattle ecosystem. Additionally, FWP lists grazing as the leading contributor to degraded riparian health, range health, and the presence and spread of invasive species on the SD WMA. Exactly how this baseline study would be continued to ensure that future grazing practices are improving these critical areas of wildlife habitat, rather than continuing to harm them, remains unclear. We welcome a grazing alternative that includes a monitoring framework, outlines actions based on monitoring, and provides solid commitments by FWP to follow through.

The proposed alternative fails to mention prescribed fire or other beneficial rangeland habitat work. Prescribed fire, for example, could be applied to improve rangeland health with no additional infrastructure (therefore at a lower cost than domestic grazing) in a way that mirrors natural habitat improvements. Montana BHA welcomes a grazing alternative incorporating low-intensity prescribed fire and other treatments into the framework to benefit wildlife and wildlife habitat.

The proposed alternative needs more data on the relationship between elk and cattle distributions. With the virtual fencing technology and elk collaring data, we have a situation where we can potentially see this interplay in new ways. Montana BHA welcomes a grazing alternative that incorporates a more thorough research component of elk and cattle relations.

Like we said above, we are intrigued with the potential of virtual fencing technology but are also concerned with the persistent issue of trespass-cattle and how this problem could intensify with expanded grazing. We welcome a grazing alternative that holds neighboring cattle grazers accountable for damages, fence repairs, and compliance, clearly outlined in a written agreement.

While we appreciate the options to remove cattle from sensitive riparian areas, adding water infrastructure comes with concerns and costs. Namely, this leads to more of the SD WMA being eligible for grazing. Montana BHA welcomes an alternative that carefully evaluates added water infrastructure.

Relatedly, the existing and expanded grazing treatments have and will cost the department money and staff to manage and monitor. Montana BHA welcomes an alternative based on a true financial cost/benefit analysis (something that is missing in the current proposals) including alternative approaches for increasing neighboring landowner tolerance for elk while charging cattle producers the going state rate ($15-$20 per AUM) for any livestock grazing permitted.

It’s also worth noting that the current and future Exchange of Use (EOU) agreements require that “partner producers on SD WMA must allow sufficient access to their private lands for public hunters,” something Montana BHA appreciates. However, this fails to mention if those producers are still being (our would be) paid the impact payments associated with a program like Block Management, if they’re even enrolled in Block Management, if the Hunt Roster would be more effective at distributing elk, and if public, equitable permissions are needed for this ‘public hunters’ requirement or not (i.e., are friends and family enough to satisfy the ‘public hunters’ requirement?). In other words, are partner producers being paid for the public hunter access required for them to graze the SD WMA for free? And is that public access really public access? Montana BHA welcomes an alternative that requires the majority of public hunter days outlined in agreements be equitably allocated via FWP.

In closing, the current pilot project was scheduled for six years, and we just completed year five. During that time, FWP has failed to hit desirable habitat outcomes, has demonstrated an inability to provide the necessary staffing to measure impacts and contain trespass cattle, and the project has come with significant costs to the public with questionable returns. We ask for an alternative that addresses the above-mentioned concerns, continues to monitor and improve the virtual fencing applications, and conservatively explores watering infrastructure. If the comprehensive analysis shows a benefit to wildlife on the SD WMA, then an alternative could potentially allow FWP to expand these grazing practices cautiously to other areas of the SD WMA.

Until then, we kindly request that FWP not pursue the proposed alternative and instead generate alternatives that align more closely with the overall purpose of the WMA as a place for wildlife to thrive. If forced to support one or the other current Alternatives, Montana BHA favors Alternative 1: No Action as this is the least risky and most cost-effective way to achieve the stated goals of the property.

Thank you for the opportunity to comment, 

Dan Tracey, Missoula Valley Board Member 

Montana Chapter of Backcountry Hunters & Anglers

*** Submitted via email on February 9th. Learn more and submit your own comments by February 12th at 5pm. ***