January 29, 2024
Bureau of Land Management
Upper Missouri River Breaks National Monument
920 NE Main St,
Lewistown, MT 59457
Rachel Miller, [email protected]
Re: Left Coulee Access Environmental Assessment
Dear Ms. Miller -
On behalf of the Montana Chapter of Backcountry Hunters & Anglers and our roughly 3,000 dues-paying members, please consider the below comments outlining our response to the Proposed Action and listed Alternatives regarding the creation and opening of the proposed Left Coulee Access Road, a 0.6-mile primitive route that would provide legal motorized access to a network of 51 miles of motorized roads. We’d like to ask that the Proposed Action is refined, though we are not weighing in with support of any of the current options at this time.
The 90,000-acre Bullwacker area at the heart of this issue is one of the wildest, undeveloped chunks of land in the Upper Missouri River Breaks National Monument. Our members care deeply about this area as it touts exceptional habitat for - and opportunities to hunt - a multitude of wild game, including elk, mule deer, pronghorn, sage grouse, and upland birds. It’s an area that’s both important to protect, and for our members to be able to get to.
We formally request that the Proposed Action maintain its seasonal (Dec. 1st - June 15th) closure element but is further refined in a way that better protects the wild lands of the area. Specifically, we ask the BLM to include considerations that would protect the integrity of the Ervin Ridge Wilderness Study Area and the ecological values of the Cow Creek Area of Critical Environmental Concern.
Additionally, we ask that the Proposed Action both require and define better signage and enforcement rather than just broadly allowing for these. Without increased enforcement, maps, physical barriers, and signage clearly stating where motorized use is and isn’t allowed - our fear is that legal motorized access into this landscape will quickly turn into widespread illegal motorized use, damaging the habitat, displacing wildlife, devaluing quiet recreation opportunities, and putting at risk the wilderness characteristics found within the region’s WSA. Opening the door to additional illegal motorized use is one of our biggest concerns with the Proposed Action. Further analysis and commitments from the BLM are needed to ensure that illegal motorized use is kept in check if this motorized road network were to be reopened.
Finally, we can’t help but notice we have a unique situation on our hands, where we don’t have to completely theorize what motorized access to this area would look like and what it would do to habitat and wildlife. Pre 2009 - though motorized and mechanized use and machinery are now more common, more easily attained, and more advanced than they were 15 years ago - this motorized access existed. And after 2009, that motorized use didn’t exist, at least not for the public. Included in this analysis should be monitoring and wildlife population and distribution data from pre- 2009 versus the same data collected post-2009, ideally current day. This information will help the public better understand the likely impacts of opening this route and will, at the very least, force the BLM to take base studies today, before any route is opened, to have to compare with terrestrial and water quality or wildlife population or distribution changes down the road if motorized access and public use is in fact altered.
In closing, we ask that Proposed Action is refined, and we refrain from taking a stance on any of the current options at this point in the EA scoping process.
Thank you for the opportunity to comment,
Jake Schwaller
Eastern Conservation Policy Leader (volunteer)
The Montana Chapter of Backcountry Hunters & Anglers
About Jake Schwaller
Hunter, fisher, lawyer, lover of my home state.