August 6, 2021

Rick Northrup, Habitat Bureau Chief

Montana Fish, Wildlife & Parks

PO Box 200701

Helena, MT 59620

[email protected]

Re: EMERGENCY GRAZING AND HAYING LEASES ON SELECT FWP WILDLIFE MANAGEMENT AREAS DRAFT ENVIRONMENTAL ASSESSMENT

The Montana Chapter of Backcountry Hunters & Anglers (MT BHA) represents approximately 3,000 dues-paying Montana members who care deeply about fish and wildlife habitat, public access and fair-chase practices. We strive to protect large parcels of backcountry habitat, as well as the opportunity for fair-chase hunting and fishing experiences. We submit these comments in response to Montana Fish, Wildlife & Parks’ (FWP) proposal to implement emergency grazing and haying on portions of 14 Wildlife Management Areas (WMAs).

We have great sympathy for our ranching communities who are suffering from this drought. Additionally, it is incumbent upon us to note that according to FWP's website, hunter-funded WMAs, "are managed with wildlife and wildlife habitat conservation as the priority.”

We acknowledge that grazing and haying have been shown to provide benefit to some wildlife species, namely ungulates, under specific conditions. However, WMAs were created to conserve vital habitat for a broad range of species. Additionally, grazing and haying are already allowed on many WMAs across the state, carefully designated with location and temporality for the benefit of wildlife and to limit competition for habitat resources between domestic livestock and wildlife. During this extreme drought year where natural competition is fierce, we’re concerned that areas that were previously unfit for grazing and haying are now being considered to benefit privately owned non-native livestock. Additionally, wildlife displacement, loss of hunting opportunity, the potential spread of invasive weeds and degradation to riparian areas and the increased wildfire risks from motorized vehicles and machinery are all concerns that need thorough vetting.

In closing, Montana BHA feels for our ranching communities. We also firmly agree with FWP that WMAs should be managed with wildlife and wildlife habitat conservation as the clear priority. We respectfully ask that this emergency order include the following:

1. Implementation that universally improves winter feed for publicly owned wildlife, while taking into consideration the needs of other wildlife including upland game and ground-nesting birds who rely on plant growth for cover.
2. Grazing and haying priority be given to our neighbors who are currently enrolled in FWP's Block Management Program. Some 1,200 landowners are enrolled in Block Management and have generously opened their private lands for public hunting access; many of them could surely use the extra help, and if we’re opening hunter-funded public wildlife management areas for private use, we would like to reciprocate their goodwill first and foremost.

Sincerely,

John B. Sullivan III, Board Chair

The Montana Chapter of Backcountry Hunters & Anglers