July 1, 2019

Tim Egan
Manager DNRC Dillon Unit
840 N. Montana Street 
Dillon, MT 59725 

Mr. Egan – 

The Montana Chapter of Backcountry Hunters & Anglers (MTBHA), representing more than 3,000 sportsmen and women in Montana, applauds the development of renewable energy sources in Montana and across the country. We also fully understand and appreciate the mandate requirements of School Trust Lands. At the same time, we are concerned about the continued loss of quality wildlife habitat, public access and great hunting and recreational opportunities for Montana sportsmen and women on – or accessed through - Montana State School Trust Lands.
 
With the commercial development of School Trust Lands in the Flathead Valley, and now the Apex Solar Installation as examples - more and more pressure will be put on School Trust Lands to be taken out of traditional ranching/grazing, recreational and wildlife paradigms, and put into commercial/industrial use. It is our hope that in the future, Montana DNRC works with the Montana Legislature to require financial mitigation within the School Trust mandate when there is a definitive loss of habitat, public access, grazing or hunting opportunity as a result of development on Montana State School Trust Lands. Fees collected could be channeled towards programs that increase and improve public access and hunting opportunity – such as the MTPLAN, Habitat Montana or Block Management – or tools that improve wildlife habitat like grass banking programs.
 
In the context of the Apex Solar proposal, MTBHA has identified the following issues and potential alternatives:
 
 1) Montana DNRC and the Lessee have not identified any means to financially mitigate loss of habitat, grazing, public access and hunting opportunity. A potential alternative would be establishing a mitigation fund where fees collected could be channeled towards programs that increase and improve public access and hunting opportunity – such as the MTPLAN, Habitat Montana or Block Management – or tools that improve wildlife habitat like grass banking programs.    

2) Montana DNRC and the Lessee have not considered alternative solar installation options that do not eliminate public access and hunting opportunity and destroy wildlife habitat. Alternative installations could include adding solar panels to existing state-owned structures or adding to areas with existing fencing where wildlife is not present, or to state-owned properties where public access is not currently allowed or feasible.

Thank you for your consideration,

John B. Sullivan III

Chairman
Montana Chapter of Backcountry Hunters & Anglers