February 14, 2022

US Army Corps of Engineers, Omaha District
Operations Division, Natural Resources Section
1616 Capitol Ave.
Omaha, NE 68102

RE: Scoping Comments Fort Peck Project Master Plan

Dear Fort Peck Master Plan Project Team:

Our organizations represent tens of thousands of Montana sportsmen and sportswomen who greatly value the fish and wildlife resources and hunting and fishing opportunities provided to the public by U.S. Army Corps of Engineers’ administered lands and waters at Fort Peck. This landscape provides an amazing fish and wildlife resource, and we offer the following scoping comments to be considered as part of the Fort Peck Master Plan revision process. Specifically, we request that the USACE take a hard look at expanding recreational hunting opportunities at The Pines and the Rock Creek Recreation Areas on the eastern side of Fort Peck.

As you know, USACE regulations in 36 C.F.R. §327, state that it is “the policy of the Secretary of the Army, acting through the Chief of Engineers, to manage the natural, cultural and developed resources of each project in the public interest, providing the public with safe and healthful recreational opportunities while protecting and enhancing these resources.” The regulations further specify that USACE lands are open to hunting “except in areas and during periods where prohibited by the District Commander,” and that “additional restrictions pertaining to these activities may be established by the District Commander.” We interpret additional restrictions as meaning the District Commander could impose area weapons restrictions and establish specific zones closed to hunting to eliminate and manage conflicts, while also maintaining zones with important public hunting opportunities open that would otherwise not be possible with broad-brushed area closures.

As such, we request that carefully crafted hunting opportunities be considered for adoption within The Pines and the Rock Creek Recreation Areas that protect the health and safety of the public and serve the public interest of providing safe and healthful recreational opportunities, while supporting Montana Fish, Wildlife and Parks in managing wildlife resources.

The Pines Recreation Area, at around 850 acres, is located on Fifth Ridge in Valley County on the north side of the reservoir. With its ponderosa pine forests, the area provides excellent habitat for Rocky Mountain elk, and is located in the limited-entry and sought-after Montana FWP Hunting District 630 (HD 632 up until 2022), which is known for world-class bull elk hunting. The area also provides quality mule deer habitat, and some waterfowl and upland bird habitat. During the state regulated hunting season, The Pines Recreation Area harbors considerable elk numbers, but because the entire recreation area is closed to hunting, these elk are unavailable to hunters and safe and healthful public recreation opportunities are lost.

The Rock Creek Recreation Area, at 2,800 acres, is located in McCone County on the far eastern edge of Fort Peck. An area of rolling grasslands and small coulees, Rock Creek has considerable numbers of mule deer in the only limited-entry and sought-after mule deer unit in Montana FWP’s Region 6: HD 652. It takes years of applying to draw this coveted permit. The Rock Creek area also has considerable ring-necked pheasant, sharp-tailed grouse, and waterfowl populations. Because the entire recreation area is closed to hunting, these wildlife resources are unavailable to hunters and safe and healthful public recreation opportunities are lost.

While these areas are managed as Intensive Use areas, intensive use is a relative term in this remote northeast corner of Montana, and other USACE managed intensive use areas within Fort Peck are open to public hunting. Recreational uses within The Pines and Rock Creek Recreation Areas are largely seasonal and concentrated in defined and very specific portions of the individual areas. For example, nearly all of the development in the Pines Recreation Area is located to the south of the Pines Access Road and to the southeast of the boat ramp. When the 2008 Fort Peck Master Plan was created, there was a Youth Camp north of the access road that has since been closed and removed. Nearly all of the development in the Rock Creek Recreation Area is located along the lakefront, primarily in clusters. Significant portions of these two recreation areas are undeveloped and may be suitable for public hunting.

The counties where these two recreation areas area located are both rural and of low population— Valley County has 7,471 residents and McCone County just 1,790—and hunting is a widely accepted activity and cultural pastime amongst the general public. Montana FWP estimates that in 2016, hunting contributed $3.73 million to the Valley County economy and $1.42 million to the McCone County economy, supporting local hotels, restaurants, and stores. The USACE 2008 Fort Peck Master Plan states that the predominate use of these recreation areas in the fall is hunting (we are assuming for camping and lodging to hunt neighboring USFWS and BLM administered lands), followed by fishing in the winter. Representatives from our organizations have visited and used these recreation areas within the past four years during the September to November season and have observed that human activity is relatively low, with some boat ramp use, and camping and lodging for hunters. We recognize that there are portions of these recreation areas where hunting is likely not appropriate for public safety and disturbance reasons, specifically those areas in close proximity to cabins, boat ramps and campgrounds. However, given the high wildlife resources present, general lack of non-consumptive recreation uses during the fall, substantial local support for hunting, and significant undeveloped areas within these recreation areas where hunting is likely compatible, we request that the USACE consider opening public hunting opportunities utilizing short range weapons within The Pines and Rock Creek Recreation Areas.

The use of short-range weapons—such as archery equipment, traditional muzzleloaders, and shotguns— is a common management tool to provide safe, effective hunting opportunities in areas where public safety is a concern. For instance, numerous Wildlife Management Areas and Fishing Access Sites managed by Montana Fish Wildlife and Parks are open for hunting with short-range weapons while restricting the use of rifles. For example, the Kelly Island Fishing Access site on the outskirts of Missoula is heavily used by non-consumptive recreationists and is bordered by numerous residences, yet hunting with shotguns and archery equipment has been allowed for over a decade with minimal conflict. In opening The Pines and Rock Creek Recreation Areas to limited hunting consistent with USACE regulations, we believe the District Commander could borrow from the approach the USACE used to develop the Fort Peck Area Hunting Map and regulations in cooperation with the U.S. Fish and Wildlife Service, and establish zones open to short-range weapons hunting, as well as zones that are closed to hunting for public safety reasons. To help in this analysis, we have included two maps below that identify in red cross hatch, areas that could potentially be suitable for public hunting within The Pines and Rock Creek recreation areas.

Finally, hunting within these recreation areas could help the State control deer and elk numbers and densities, a tactic that has been shown to help reduce the prevalence of Chronic Wasting Disease (CWD), a fatal neurological disease in cervids that has already been detected in HD 630 as well as neighboring hunting districts 650 and 700. According to Montana Fish, Wildlife and Parks, “keeping deer numbers down and dispersed, and reducing buck:doe ratios, may keep the prevalence low and manageable.” The agency further specifies “this may also mean keeping deer or elk numbers low to keep infection rates low.”2 Opening big game hunting opportunities could further assist with detection and prevalence monitoring for the department through additional CWD samples from these areas. Our organizations greatly appreciate your consideration of our comments, and we look forward to engaging further with the USACE as the Master Plan revision process advances.

Sincerely,

Joel Webster
Vice President of Western Conservation
Theodore Roosevelt Conservation Partnership
725 West Alder St. Suite 1
Missoula, MT 59802

Kevin Farron
Montana Chapter Coordinator
Backcountry Hunters & Anglers
725 West Alder St. Suite 11
Missoula, MT 59802

Alec Underwood
Senior Policy and Development Director
Montana Wildlife Federation
P.O. Box 1175
Helena, MT 59624