March 7, 2022
Amanda James, Field Manager
BLM Dillon Field Office
1005 Selway Drive
Dillon, MT 59725
Re: Comments on BLM Dillon FO 15-Year RMP Evaluation
Dear Ms. James:
On behalf of roughly 3,000 dues-paying members in the Big Sky state, please consider the below comments from the Montana Chapter of Backcountry Hunters & Anglers on the Dillon Field Office Resource Management Plan (RMP) 15-year evaluation. We encourage the Dillon FO to consider an RMP amendment to account for new information and policies specific to the conservation and restoration of big game migration corridors and winter range. Our members value wild places, public access, quality habitat and the fair-chase hunting and fishing opportunities these things provide.
Many of BHAs members recreate on lands managed by the Dillon Field Office. BHA cares deeply about these lands and our group has been a participant on the Beaverhead Recreation Working Group since its inception in 2018. We've engaged in boots-on-the-ground stewardship projects with the goal of improving hunter ethics, managing motorized use and providing better education and accountability among user groups. Much of this BRWG work has taken place on BLM lands managed by the Dillon Field Office.
In 2021, volunteers from our organization spent a weekend assisting the National Wildlife Federation and Montana Fish, Wildlife & Parks in removing dilapidated fencing on BLM lands that was shown to inhibit big game migration patterns. Our combined efforts resulted in 16 miles of fencing removed; wildlife-friendly fencing will follow. The need for this project was made clear due to improved technology and better understanding of the full extent of big game migration movements across the landscape. Data from Montana Fish, Wildlife and Parks' new Terrestrial Wildlife Movement and Migration Strategy, completed in 2020, adds even more useful insight that could help ensure careful resource planning that identifies and conservers important wintering grounds and migration habitat. The BLM is required to consult with state wildlife agencies and bureaus to ensure land use plans are consistent and complementary to one another along the entire wildlife corridor in common instances where winter range or migration corridors span jurisdictional boundaries, and an RMP amendment provides a great opportunity to do just that. Given the FWP strategy includes Action 5, which directs the agency to “Work collaboratively with local, multi-state, federal, and tribal governments to increase consideration and maintain functionality of wildlife movement and migration in land use, recreation, mining and energy, community and economic development, and transportation planning,” there seems to be an immediate opportunity to align state and federal habitat conservation priorities through a Dillon RMP amendment.
The fencing removals also aligned with 2018 signed Department of the Interior Secretarial Order 3362, which directs the BLM to work to enhance and improve big game winter range and migration corridors. More recently, the 2021 Conserving and Restoring America the Beautiful Report served to restate DOI’s commitment to this work through expanded “Collaborative Conservation of Fish and Wildlife Habitats and Corridors.” An amended Dillon RMP could help further achieve these goals and implement the directives outlined in SO 3362 to a) minimize development that may fragment winter range and primary migration corridors; b) limit disturbance of big game winter ranger; c) utilize other proven actions necessary to conserve and/or restore the vital big-game winter range and migration corridors across the West; d) update all existing regulations, orders, guidance documents, policies, instructions, manuals, directives, notices, implementing actions, and any other similar actions to be consistent with the requirements in this Order; and e) prioritize active habitat management projects and funding that contributes to achieving wildlife population objectives.
Additionally, recent studies have solidified the significant (and growing) economic value that hunting and fishing brings to the region; we ask that the BLM be conscious of this as the RMP is revisited and careful planning considerations are given to avoid user or development conflicts in SW Montana. For example, in Beaverhead County alone, outdoor recreation was found to contribute more than $167 million each year to Montana’s economy while creating more than 1,400 jobs.
And finally, with help from the Wild Sheep Foundation and other partners, Montana Fish Wildlife & Parks recently relocated 26 bighorn sheep in hopes of restoring the Tendoy's herd (another 34 are planned for relocation in the area in 2022). This work is not only biologically important, but it's expensive. Bighorn sheep do not respond well to pressure, motorized use or development, and we ask that the RMP revision take into account these restoration efforts when planning things like renewable energy development, seasonal motorized use restrictions, resource extraction or new roads and trails. The Big Sheep Creek area along with its tributaries where these sheep were released are especially critical wildlife habitat and offer some of the best of the best hunting and fishing opportunities; we hope that these are managed with natural values left intact with an updated RMP, and that future development in the area be avoided.
In closing, we thank the Dillon Field Office for considering an amendment to the RMP, and we encourage you to do so with the above taken into careful consideration.
Scott Desena, Butte, MT
Southwest Montana Board Member
Montana Chapter of Backcountry Hunters & Anglers