October 12, 2023
FWP Region 2 Supervisor
RE: Fish Creek Watershed Draft Recreation Strategy
Dear Mr. Arnold -
The Montana Chapter of Backcountry Hunters & Anglers is a grassroots conservation organization representing roughly 3,000 dues-paying members in the state. Our members value productive habitat, public access, and quiet recreational opportunities to hunt and fish. With many of our members (including myself) living and recreating near Missoula - which also happens to be the headquarters of our national organization - we take a keen interest in and appreciate the opportunity to comment on the future management decision of the Fish Creek watershed.
BHA supporters and board members were early and active participants in the multi-stakeholder planning process, and we appreciate the work that's already gone into this effort. We recognize the many uses and values that the users of the Fish Creek complex possess, and we're familiar with the history of the area, the goals of DNRC-owned state lands, the objectives of FWP's Wildlife Management Areas, and the challenges of balancing natural resource protections with recreational desires across a landscape managed by multiple agencies.
According to FWP, in 2022, more than 3 million people visited Montana state parks, a more than 50% increase compared to a decade ago. And while the user days have not been regularly tracked at Fish Creek since 2019, all indicators suggest an increase in popularity. With Montana’s second largest city and second busiest airport just down the road, we only expect recreational use and demands to increase further in this area.
Unique to this area is that this state park - typically managed for recreation - is surrounded by a wildlife management area - managed for wildlife habitat conservation. These management designations and goals aren't always compatible, so a thoughtful and landscape-level recreation strategy is greatly needed.
We’re happy to see the draft strategy include seasonal closures, a recognition that increased infrastructure could decrease per capita impacts but also increase overall impacts, and an emphasis on wildlife habitat, something we want to strongly reinforce.
Along those lines, “FWP's Wildlife Management Areas (WMAs) are managed with wildlife and wildlife habitat conservation as the priority,” as stated on FWP’s website. We encourage this ‘Recreation Strategy’ planning process to keep that declaration front and center when considering any changes or recommendations within the boundaries of the Fish Creek WMA. This WMA already sees year-round use, including motorized access, something that many WMAs in the state restrict on behalf of wildlife habitat considerations. In other words, accommodations have already been made for recreationists at this WMA, and we should not lose sight of the overarching goal of this property funded primarily with sportsmen’s dollars when it was purchased in 2010.
For the most part, Montana BHA is supportive of the proposed activities found in Phase 1. Specifically, we applaud the proposal to preserve existing motorized use loops and provide better signage marking them as such; we'd ask that the signage also include reminders for the punishments of illegal, off-route motorized use. Additionally, there are several roads that we think should be considered for full gated closures. For example, numerous road grades along the Williams Peak loop appear “open,” lead nowhere, and are mostly overgrown with vegetation. Left unchecked, these routes are ripe for off-road motorized abuse.
We also support clarifying which dispersed sites are suitable for camping, and rehabilitating others that have safety or resource concerns like erosion. Adding vault toilets near existing and non-problematic dispersed sites will have a minimal impact on the landscape and will likely lead to a reduction in human waste ending up where it doesn't belong.
We understand concerns of recreational floating discussed in Phase 1 actions. Fish Creek offers heralded opportunities to fish for native species such as Westslope cutthroat trout and bull trout, and wild species such as rainbow trout and brown trout. Most of these are walk-and-wade opportunities, though some anglers do float sections of the river. If possible, we ask that floating and seasonal fishing opportunities remain, though - once again, with an eye towards wildlife habitat - we ask that strict prohibitions are placed on cutting or removing woody debris and log jams from the river. We realize this will make stretches impossible, difficult, or dangerous to float, so if future restrictions of floating are needed, we would be supportive of those. Without question, motorized watercraft use should be prohibited on Fish Creek.
Looking at the proposed actions outlined in Phases 2 and 3, we have some reservations, including the plan to expand dispersed and developed campgrounds and build new trails; simply put, the area already offers ample opportunities for camping and there are hundreds of miles of existing roads and trails that currently intersect the landscape.
Speaking to the former, with more than 500 miles of USFS and timber roads intersecting the watershed, we do not see the need for any new trail or road building, and we’d encourage the recreation plan - with an eye towards the above stated wildlife and wildlife habitat conservation priority - to look closely at existing routes to decide which should be closed to motorized use (including e-bikes), which should allow mountain bikes, and which should allow horse and foot traffic only.
Due to the abundant motorized access and availability of existing routes, we ask that within the entirety of the project area, that no new motorized routes be created or sanctioned, while, like we mentioned above, we’re supportive of preserving the existing motorized routes that currently exist. We remain deeply concerned with illegally created routes and encourage aggressive decommissioning of any routes seeing illegal use and signing that explicitly states travel restrictions and punishments for breaking the rules.
Within the boundaries of the WMA, we also ask that no new bike trails are officially sanctioned; outside of the WMA, we ask that any bike trails stick to existing roadbeds where, according to the draft plan, “mountain bikers have near limitless opportunities for biking.” If new trails for mountain bikers are a must, we ask for careful considerations of trail densities to preserve big game security habitat, to avoid riparian areas, saddles, and ridge top trails which wildlife frequent, and to prevent stream crossings which will negatively impact water quality and aquatic habitats.
The proposal to expand designated campgrounds specifically and add amenities is one that has been met with mixed emotions by Montana BHA. While this could lead to fewer user-created dispersed camps, it could also lead to an increase in year-round recreational use. We ask that any expansion of designated campgrounds be done carefully with an emphasis on rustic, walk-in sites with pit toilets and no other amenities being offered (so without running water, electricity, or pavement), and we would be open to seasonal closures and restrictions to further acknowledge wildlife needs consistent with a wildlife management area.
Additionally, Phase 3 suggests the possibility of rehabbing the Williams Peak Lookout and opening it to public overnight use. This idea is intriguing to our members; however, Montana BHA asks that - should the lookout be restored for reservable overnight use - that public access to the lookout remain non-motorized to protect habitat and the quiet recreation opportunities currently offered. Many Forest Service lookouts offer walk-in access only, a popular way to experience these rustic and memorable excursions, and we encourage the State Parks to consider this approach. The existing road could remain gated and available to administrative use only for any rehabilitation and future maintenance needs. Additionally, we do not see the need for or compatibility of new mountain bike trails on Williams Peak.
Finally, when looking at some of the proposals outlined in Phases 2 and 3, it's important to note how and why this area was purchased (mentioned above), and, to a smaller extent, who is currently using it and for what purposes.
Thanks to the study facilitated by FWP and the University of Montana, we know that roughly 2/3 of respondents (65%) utilize the area for fishing, followed by camping (51%), hiking (44%) and hunting (28%). Only 1 in 5 (22%) noted that they use the area for mountain biking, and fewer yet, 1 in 10 (11%), noted that the main draw of the area was off-highway vehicle use. As such, a high emphasis should be placed on angling, water quality, and quiet recreational opportunities such as hiking, and hunting.
Relatedly, FWP has stated that expanding the existing elk herd in the area is a priority for the department, and motorized use, mechanical use, and foot traffic all, in that order, displace elk and reduce elk security habitat. We encourage recreation strategy decisions to be made with elk behavior in mind both in route/trail planning and seasonal closures.
We appreciate the opportunity to comment on the draft strategy and look forward to continuing to engage in this public process.
Corey Ellis, Board Member
Montana Chapter of Backcountry Hunters & Anglers