Superior Ranger District
Lolo National Forest
September 8th, 2019

Subject: Redd Bull Project

To the Redd Bull Project Leader:

The Montana Chapter of Backcountry Hunters & Anglers thanks the U.S. Forest Service for considering our comments on the Redd Bull Project.

Our chapter represents 3,000 Montanans who are avid public land advocates. We rely on publically accessible lands to hunt, hike, fish, boat, forage, and explore. In return for the opportunities, we strive to protect and conserve the wildlife and wildlands within as well as the access to those lands.

We see the fisheries impacts as our most serious concern for this project with: a)     The failure to remove two miles of the South Fork of the Little Joe Road.b)     Allowing road building in the headwaters of important fisheries.c)     Not requiring the decommission all non-system roads in upper Ward Creek after timber harvest units are completed.

It is our understanding that this project was conceived with one of the primary objectives being to remove a two-mile portion of South Fork Little Joe Road. While hardening the surface has some sediment reduction benefits, it does not provide space for streambank revegetation. With stream temperatures foreseeable to increase with climate change, taking every effort to remove this man-induced temperature impact should be a principle retained in the decision process. In addition, removal will eliminate stream impacts from normal road maintenance, and will provide more space for the hydrological/geomorphic stream process to work which improves native fish habitat and stream function.

While we appreciate the need to manage forest vegetation in the developed portion of the Forest, we believe other alternatives in identified Roadless areas, including prescribed fire and/or modified wildfire suppression tactics be prescribed in lieu of mechanical treatments within roadless areas.

There are many parts of this proposal which are unfunded. To consider the overall cumulative benefits or costs, it is imperative that the resource protection/restoration portion of the overall project be completed with or before the extractive (road building and timber harvest) commence. All too often the Forest Service makes a public decision but fails to complete all the ingredients to a balanced project.

We request an interagency (FWP and FS) biological evaluation by seasoned big game biologists of the proposed open road/motorized trail network in the landscape following the project as it affects both big game productivity and security. We request roads/trails to be closed to motorized travel be effective in minimizing unauthorized uses. We have found that obliterating a short portion of the road prism in steeper terrain can be an effective cost efficient closure. 

On this specific project, we advocate for:

• Providing alternatives for the public to weigh in on that include the following:
  • Removing South Fork of Little Joe Road to protect the critical and healthy bull trout habitat of Little Joe Creek and its forks.
  • Identifying an alternative route into Moore Lake so as to not continue degrading the habitat in the South Fork of the Little Joe River.
• Limiting new road building in the headwaters of bull trout streams as well as limiting treatments detrimental to this habitat where roads might be reroute, i.e. surface hardening.
• Decommissioning of all non-system roads in upper Ward Creek after the units are completed.
• Incorporating a full-landscape approach to this project’s implementation to take into consideration the many users of this area, primarily the wildlife and vegetative communities of all forms proceeded by the recreators as secondary users. Those doing the watershed analysis of this project and its implementation must think of the long-term impacts on this landscape beyond a timber operation due to the length and scope of this project and the many impacts it will have into the future.
• When considering that the Roadless Area Conservation Rule, we ask the agency to proceed according to ensure the project does not infringe or become non-compliant with the Roadless Rule.
• Establishing a long-term monitoring plan to frequently measure and monitor the streams impacted by this project’s activities to document temperatures, sediment, and fish before, during, and for 10 years after to show the impacts (or hopefully the lack thereof) of logging, road hardening, road removal, etc.
• Increasing the collaborative efforts surrounding this large, long-term project and identifying the sequence of actions on this project to keep the public abreast of what is taking place on these treasured public lands.

Thank you for working to restore native fish habitat, improve vegetation resiliency; reduce forest fuels; improve elk habitat; provide diverse recreation opportunities; and support the economic structure of local communities. We support these activities and request that you consider our comments in doing so.

Thank you sincerely,

Hannah Nikonow, Region 2 Board Member

Montana Chapter of Backcountry Hunters & Anglers

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