LETTER: Montana BHA Comments on Sage Grouse Plan

Montana Sage Grouse Habitat Conservation Advisory Council:

Montana Backcountry Hunters and Anglers welcomes the opportunity to comment on the proposed Montana Sage Grouse Plan. Our members are grassroots Montana hunters and fishermen who cherish prairie habitats and their wildlife, as well as hunting opportunities within sage habitats on both public and private lands. Our members pursue game, but appreciate all the ecological aspects of wildlife habitats encountered while in the field.   It is the context of sage grouse and their habitats that we formulate these comments.

First, we appreciate the efforts for the State of Montana to retain authority to manage sage grouse, and the emphasis on landscape scale habitat needs of these birds.

We at Montana BHA urge the Council, The Governor and all other responsible parties to keep a firm grip on the fact that only an improvement in the health and sustainability of our native Sage Grouse will serve to keep this species from being listed as an endangered species under the federal Endangered Species Act. A plan that reflects stakeholder agreement but does not adequately support the needs of Sage Grouse will be a failure.

Montana BHA also understands that other Rocky Mountain States are now engaged in Sage Grouse planning activities. It is only logical for Montana to examine the proposals made in other states. We caution, however, against adopting elements of plans and management practices from other states without a detailed and scientifically validated understanding of how those proposals will actually affect Sage Grouse health and sustainability in Montana locales.

Plan Strengths BHA Supports As Drafted

One-Mile No Surface Occupancy (NSA)

The Plan recognizes the 1 mile no surface occupancy stipulation from leks in core areas which is scientifically justified, along with a maximum of 5% surface disturbance and no more than one well pad per section. These provisions are extremely important to reducing fragmentation and MT BHA urges inclusion of this provision in the final document without reduction of the NSA stipulation.

Private Land Incentive Fund

We applaud the recommendation to set up a Conservation fund to provide financial incentive for management of private land sage grouse habitat, and we recommend a prominent funding commitment and mechanism be included in the Plan.

Montana BHA Requests For Improvement of the Draft Sage Grouse Plan

Strong Statement of Plan Objective

 A stronger statement of plan objective would greatly improve this Montana Plan. BHA requests the addition of a goal statement contained in USFWS sage grouse planning documents:  

   "long-term conservation of sage-grouse and healthy sagebrush shrub and native perennial grass and forb communities by maintaining viable, connected, and well-distributed populations and habitats across their range, through threat amelioration, conservation of key habitats, and restoration activities”

(Conservation Objective Team’s Final report a federal-state collaborative effort).

 The final Plan needs an improved structure of population goals that stair-step from a general statewide goal down to specific, meaningful regional landscape or even smaller scale goals. This is especially important when populations are subject to fluctuations due to factors that variety among locales.

In addition, a statewide goal can mask a serious decline in one landscape that may be discontinuous to other populations. Why is the current population structure considered to be a baseline?   With documented declines in some landscapes, the Plan must provide for population recovery on those landscapes.

Grazing Managed to Support Sage Grouse

 We request strong Plan direction to not only assess grazing plans, but provide a fully funded and scientifically defensible monitoring strategy and monitoring funding mechanism to assure habitat goals are being met.

BHA understands that livestock grazing is an established land-use practice and will continue to occur. However, state regulated grazing plans and performance must assure perpetuation, cover density, and recruitment of sage plants and their plant community. All grazing must assure adequate residual cover, and forbs and other non-grass components to favor sage grouse survival and recruitment.   Special requirements are needed in riparian areas to protect habitat components because Sage Grouse use these areas disproportionately for brood rearing.

Habitat Fragmentation and Degradation

 With the exception of habitat restoration efforts, change and additional disturbance to the existing situation generally can be viewed as negative to sage grouse well-being until proven otherwise. We object to weak, hedging language such as “where feasible”, “where possible” and instead recommend decisive requirements instead of unenforceable guidance or suggestions.

Additive fragmentation by oil/gas development, prairie plant conversions, roads, and powerlines/towers/fences must be strongly constrained and their fragmentation effects discouraged throughout this plan. Only peer reviewed science should be used in developing stipulations appropriate to maintain habitats. We strongly remind you that, to be successful, this plan cannot maintain sage habitats only where convenient to existing and potential human uses and also preclude federal sage grouse ESA listing.

Strengthen Management Outside Core Areas

 We note that only 76% of sage grouse populations are protected by core habitat protective requirements. Much weaker management protections on the remaining sage grouse habitats could result in serious population declines outside of core areas. The Final Plan should either substantially increasing habitat protections outside of core areas, or expand the core habitat designations to cover substantially greater percentage of occupied sage grouse habitat.

Furthermore, BHA recommends re-assessing all landscapes with sage habitats as potential core habitats to maximize core habitat acreage. We suggest additional Core Area in Garfield-McCone County (about 500,000 acres) identified by other commenters in this process.

Specify Management Criteria Within Core Areas

 We did not find specifics of how core habitats will be monitored in the draft plan. A management practice schedule and descriptive criteria needs to be specified along with assurance that quantified monitoring will take place. How is monitoring information to be documented and stored and who/what will be responsible to responding to monitoring that suggests action is required to protect habitat?  

Decisive disciplinary triggers need to be in place to respond if monitoring is not funded or accomplished.   Without a strong monitoring plan, how can managers as well as the public be assured that damaging habitat activities will be prevented, stopped, or damaged habitats restored? While there is guidance offered, there are few requirements in this plan to assure habitat damage will not occur.

Core Area Stipulations (pp. 13 - 20).

 The document has a list of stipulations that are required for projects that will disturb sage-grouse habitat. Overall stipulations priority must be clearly stated to 1) Avoid any new disturbance, 2) minimize footprint of disturbance with fragmentation as the key measure, and 3) mitigation as last resort.

Core Area Stipulations (Monitoring/Adaptive Response, page 18-19).

 The Draft Plan offers only a vague “decline in affected leks” threshold for action.   Since leks can have fluctuations under the best of circumstances it will be difficult to rely on leks as a trigger for “adaptive management responses.” How many years of data would be needed in a naturally fluctuating population to detect human/management induced declines?

No Surface Occupancy (NSO)

 We object to the .25 mile NSO in general (non-core) sage grouse habitats as scientifically indefensible. We believe all stipulations need to have the preponderance of scientific findings to back them.

We also object to the amount of designated “Special Management Core Areas” established to allow some threatening activities to occur in otherwise core habitats. Permitted activities in these areas will lead to more fragmentation of sage grouse habitat.   How will mitigation assure that additional fragmentation will not occur?

How is “No Surface Occupancy” defined in this Plan? In our opinion, that definition must be written to permit no surface disturbance or surface activities within the specified distance.

Again, Thank You for the opportunity to comment.

Respectfully Submitted,
Greg Munther, Co-Chairman
Montana Backcountry Hunters and Anglers

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