December 19, 2019

The Montana Chapter of BHA

PO Box 9257

Missoula, MT 59808

Jennifer Alexander

Outdoor Recreation Planner

[email protected]

BLM Billings Field Office
5001 Southgate Drive
Billings, MT 59101

Re: Pryors Draft Travel Management Plan EA (DOI-BLM-MT-C010-2019-0029-EA)

Dear Ms. Alexander:

The Montana Chapter Backcountry Hunters & Anglers provides the following comments on the Draft EA re: Pryor Mountains Travel Management. Our membership of more than 3,250 Montana hunters and anglers use the Pryors, as well as other Montana public lands, and are committed to protecting both natural resource values, as well as traditional recreational uses of the Pryors.

We appreciate the effort of the local BLM office to designate specific routes in the Pryors. We request strong enforcement of illegal use where it may occur to protect both natural resources, as well as reduce conflicts with other recreational users.

We have serious concerns regarding the Department of Interior’s top-down direction to local BLM offices that includes regulating e-bikes as “non-motorized,” as this direction will negatively affect resources and traditional uses in landscapes such as the Pryors.

The Pryors are appealing to recreationists due to their unique features and their location adjacent to a large urban population of Billings. Due to the proximity of Montana’s largest city, the implications of any travel management decision are magnified due to the expected growth of recreational uses beyond the current recreation level of 17,496 users. The logical expansion of recreational use and its impact is not recognized in the EA. In addition to normal projected recreation use, the addition of e-bikes onto “non-motorized” trails will greatly accelerate use levels, user conflicts, trail erosion, impacts to wildlife and spread of noxious/invasive plant species.

We contend that e-bikes are indeed motorized. They have electric motors. Some are currently able to achieve speeds of 28 miles per hour, and we can expect technology will increase both speed and range of these vehicles. Confidently, we expect the number of e-bikes to dramatically increase as they allow relatively effortless travel into previously remote areas.

E-bike’s ranges allow users to many more miles in a day of use than a hiker or even a mountain biker. The existing bike routes were not designed for the level of use that will likely be generated. If e-bikes are allowed, we expect more trail erosion, an increase in user conflicts and a greater level of wildlife disturbance to occur.

For both bighorn sheep and sage grouse, more human disturbance is negative and causes both stress and displacement from their preferred habitat. Bighorn sheep are an iconic species whose populations are in difficulty statewide and are likely occupying far less habitat in the Pryors than they did historically. Sage grouse are struggling in the Pryors as well as across the state. With human infrastructure and disturbance a major factor in their decline, sage grouse are discussed and proposed for potential listing as a threatened species under the ESA.

The EA lists 42.6 miles of e-bike routes to be allowed in Areas of Environmental Concern (ACEC). We find this to be insensitive to the resources leading to such a designation. We also find that proposed addition of e-bikes into the three Wilderness Study Areas would eliminate the future potential of Wilderness designations for these areas.

Appropriate site-specific analysis of the resources, resource capability and resource risk of e-bikes is appropriate and necessary before any route segment is selected for e-bike use. Due to irreversible risk to resources and impact to the human environment including traditional uses, we request site-specific analysis for each route segment, as well as preparation of an Environmental Impact Statement before moving forward with a final Pryors Travel Management Plan.

Sincerely,

s/greg munther

Greg Munther
Board Conservation Director
The Montana Chapter of Backcountry Hunters & Anglers