LETTER: Montana BHA comments on the Draft Supplemental Environmental Assessment at Northwest Montana Wetland Management District

*** Learn more and submit your own comments by April 3, 2024 ***


March 15, 2024


Ben Gilles, Project Leader
US Fish and Wildlife Service
53775 MT HWY 212
Charlo, MT 59824
[email protected]

Re: New Northwest Montana Wetland Management District Administrative Facilities 

On behalf of the Montana Chapter of Backcountry Hunters & Anglers and our roughly 3,000 dues-paying members, please consider the below comments outlining our opposition to the Proposed Action to construct a new residence and new administrative facilities for the NWMT WMD at one of the identified sites: all USFWS managed Waterfowl Production Areas.

Our organization and our members advocate to protect quality fish and wildlife habitat, public access and our fair-chase hunting and fishing heritage. It should come as no surprise that we continue to oppose any proposal that would unnecessarily develop a Waterfowl Production Area. Our concerns are consistent with our previous comments on this issue from October of 2021.

We encourage the USFWS to continue to pursue Alternative E from the original proposal - the acquisition of property not currently owned by the USFWS - and ask that the agency be patient and creative in finding an appropriate site for these new and necessary facilities. Surely there can be an appropriate building site identified that isn’t in a WPA, lands acquired with Federal Duck Stamp dollars “to conserve some of the most threatened and productive migratory bird habitat in the nation,” according to the USFWS’s website.

The proposed building site are lands currently open to hunting and provide native bunch grass and other valuable habitat for waterfowl and upland birds. This includes both non-game and game species alike including ducks, geese, Hungarian partridge, and pheasants.

This loss of huntable acreage would also be a loss of access for our members and the many other Montanans who hunt and recreate in the Mission Valley. It’s also worth noting that the huntable acres lost here are not limited to the build site alone; shooting is often prohibited - for good reason - 150 yards or more from any residence or building. This means the negative impact to hunters will far exceed the 12 acres noted in the Environmental Assessment.

Finally, it’s worth noting that it’s not only Montana BHA and our members opposed to this. When discussing previous public involvement, the Environmental Assessment states: “the comments were largely supportive of Alternative E since many of the commenters preferred that the WPA properties be preserved for wildlife habitat rather than be used to construct new infrastructure with additional traffic and air quality impacts. The removal of areas currently open to hunting was another concern.”

We remain convinced that either the acquisition of property not currently owned by the USFWS or utilizing USFWS lands that are already developed would be the best choices of action for both the resource and hunting opportunities, and we therefore oppose the Proposed Action.

Thank you for your time and consideration. 






Aaron Agosto, Bigfork, MT

Volunteer Flathead Valley Board Member

Montana Chapter of Backcountry Hunters & Anglers


*** Learn more and submit your own comments by April 3, 2024 ***

About Aaron Agosto

Carpenter. Hunter. Fly fisher. Montanan.

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