April 19, 2018

BLM – Butte Field Office
Attention: Brad Colin
106 N. Parkmont
Butte, MT 59701

Subject: Scratchgravel Hills Recreation Area Management Plan (RAMP)

Dear Brad:

I’m writing this letter on behalf of the Montana Chapter of Backcountry Hunters and Anglers (BHA), based in Missoula, Montana.

The Montana Chapter of BHA represents approximately 1,500 sportsmen and women across our state. Our mission is to ensure North America's outdoor heritage of hunting and fishing in a natural setting, through education and work on behalf of wild public lands and waters.

The Scratchgravels are an island of public land surrounded by private lands on the west edge of the Helena Valley.  BHA acknowledges that the Scratchgravels make a good recreation area and support the BLM in the creation of a Recreation Area Management Plan (RAMP). We are particularly pleased that the BLM has chosen to close the area to motorized use.

BHA notes that unlike other BLM and National Forest lands around Helena, the Scratchgravels are a place where a higher density of recreational trails is appropriate.  However, there are currently over 40 miles of mostly user-created routes on BLM land in the Scratchgravels.  BHA encourages the BLM to created a sustainable trail system in the Scratchgravels, open to foot, horse and bike traffic, but we believe the 40 miles of inventoried “routes” are too many trail miles.  We believe many of these user-created routes can and must be reclaimed.  Once the trail system is established it is imperative that bikes be restricted to constructed trails.  Cross-country bike travel needs to be restricted.   

The Scratchgravels lie within the weapons restriction zone of Tenmile-Prickly Pear Valley Hunting District 388. The area supports huntable populations of game birds, whitetailed deer, mule deer and elk.  We currently support and will continue to advocate for the continuation of these hunting opportunities.  The western portion of BLM lands in the Scratchgravels is more open and is an area where a higher density of recreational trails will have the least impact on the resident deer and elk herd.  Maintaining security cover, such as beetle-killed pine deadfall, and some stands of young douglas fir, especially in the higher elevation areas, is a must.

BHA believes that the BLM should manage the Scratchgravels for recreational trails, but we urge you to recognize the importance of the area as wildlife habitat and a place for non-motorized hunting, as well.  We believe a well-designed trail system, when paired with reclamation of user-created routes, will be a win for both recreational trail users and wildlife. 

Thank you for the opportunity to comment.

Sincerely,

Steve Platt

Capital Board Member

Montana Chapter of Backcountry Hunters and Anglers