August 6, 2019

Bureau of Land Management Missoula Field Office
Re: 2019 Resource Management Plan
3255 Fort Missoula Road
Missoula, MT 59804

To the dedicated staff at the Missoula BLM Field Office:

Thank you for the opportunity to comment on the Draft Missoula Resource Management Plan. The following comments are submitted by the Montana Chapter of Backcountry Hunters & Anglers (MTBHA). We represent more than 3,000 outdoorsmen and women who are avid public land users and advocates. We rely on public lands to hunt, hike, fish, boat, forage and explore. In return for those opportunities, we strive to protect and conserve these lands, its wildlife and waters.

As you know, the Federal Land Policy and Management Act (FLPMA) requires that the BLM manage public lands for multiple-use and sustained yield, including the conservation and management of lands recreation, water quality and wildlife. We believe that the preferred alternative that was released to the public in this draft plan can be improved to ensure protections for these important lands and waters.

We believe that alternative C is the best optionfor the BLM lands, wildlife, water and people in the Missoula Field Office area with a number of additions and changes we will outline below. Alternative C emphasizes the greatest degree of conservation of fish and wildlife habitat, and conservation of cultural and historic resources.

Here are aspects that we support in alternative C:

• We support Alternative C which would allocate the Lower Blackfoot River corridor to “Limited Motorized” use, thereby allowing opportunities at the site-specific travel planning, which alternative A does not document. We request that the motorized routes only extend to the routes that are currently permitted, not be expanded, and that walk-in hunting be the primarily access method to this corridor, outside the currently open roads. We look forward to continuing this conversation during a future travel planning comment period.
• We support that Alternative C would use bio-control to the extent possible rather than herbicide treatments when treating noxious weeds.
• Alternative C states that stricter requirements would be triggered if rangeland health standards were not met with the causal factor livestock grazing. This is common sense and ensures that this form of working lands management proceeds with care to keep out invasive weeds and does not result in habitat degradation for wildlife, including riparian areas.
• We support that alternative C - as well as the other alternatives - do not close the entire Missoula FO to grazing. Grazing is an important economic aspect of this area which supports many people’s livelihoods. If grazing were to be removed from this landscape entirely, working ranches and their private lands would be severely impacted. This would likely result in the selling of important private lands increasing the potential for subdivision and increased habitat fragmentation and the loss of private land hunting opportunities through block management and other means.
• We highly support that the BLM prohibits leases for domestic sheep or goats within bighorn sheep habitat to reduce the chance of disease transfer to these valuable herds. We encourage the BLM to proactively address any potential conflicts that could arise from domestic sheep or goats on adjacent private lands.
• We support the road density restrictions in all big game winter range habitat as proposed in alternative C, which is approximately 105,911 acres.
• Under Alternative C, we support the recommendation that 1,015 acres would be withdrawn from mineral entry and that the ACECs, Lewis and Clark National Historic Trail corridor and Garnet Ghost Town would be closed to mineral material extraction. For the Lewis and Clark trail, we support the elements of Alternative C to designate a 1-mile corridor on each side of the trail, excluded from rights-of-way and closed to salable minerals, and manage potential activities to be compatible with the trail objectives and values. This ensures that the surrounding fish and wildlife habitat would experience no additional degradation.
• Under alternative C, we highly support that the BLM would protect the wilderness characteristics in the five identified areas by maintaining that they are closed to mineral material sales, closed to motorized travel and closed to construction of new roads. We support the emphasis of prescribed fire and hand tools over mechanized equipment as well as the wildfire management approach with “light hand on the land suppression tactics.”
• Alternative C states that eight percent of the habitats in this FO’s area would be treated per decade and that this could vary slightly year to year. This treatment as structured by the bullets under the Forest Management Objective laid out on page 63-64 in the RMP Volume 1 are supported by MTBHA. In that so much of this RMP’s area is within the Wildland Urban Interface, this makes good management sense.

The following are general overarching comments that we would like to see reflected in the new Missoula BLM RMP regardless of what Alternative is selected. We urge inclusion of the following stipulations that are of particular importance to future well-being and public use of these lands:

• The lands within the Missoula BLM area are highly popular for recreators and include important headwaters that support significant watershed drainages. Conserving these areas and protecting them from degradation - i.e. being loved-to-death - is an important responsibility that we are asking the BLM to continue to carefully undertake. Specifically, preserving hunting access to walk-in only in the majority of instances is our request.
• We ask that the Blackfoot River is preserved to protect its outstanding natural, cultural and recreational values in a free-flowing condition for the enjoyment of current and future generations.
• We request that the BLM adopt Backcountry Conservation Areas in the final RMP. BCAs provide federal land managers the tools to conserve big-game habitat and critical unfragmented areas, prioritize active habitat restoration and enhancement, allow for traditional uses of these lands to continue and support important public access for hunting, hiking, fishing and foraging. BCAs strike a balance of conserving special places from development, providing access and providing management flexibility for habitat restoration and rangeland improvements. MTBHA supports that BCAs maintain functional blocks of security habitat for big game and emphasize the conservation corridors and linkages to provide for wildlife movement.
• We specifically support BCA’s as depicted on the Recreation Management Area map of Alternative C to include those lands in Chamberlain Mountain, Hoodoo,Marcum Mountain, Ram Mountain and Bear Creek Flats. This management approach conserves valuable areas and supports public access while providing multiple-use flexibility for active restoration, fire management and the continuation of traditional uses that are important to local communities. We believe the adoption of BCA’s would help the BLM implement Secretarial Orders 3347, 3356 and 3362.
• We support that the preferred alternative closes the WSAs to all motorized and mechanized use.
• There are significant wildlife corridors documented by the state game and fish agency that we request the BLM take into consideration in this planning effort to conserve and restore where possible as well as corridors that may be identified at a later time.
• There are a number of unique, sensitive and seasonal habitats that wildlife require in the Missoula BLM FO area that we request the BLM take into consideration in this planning effort to protect - particularly riparian corridors, winter range, waterways and grasslands.
• Alternative C sets the stage for step-down travel management focused on snowmobiles, mountain biking and hiking opportunities in the Lower Blackfoot and Garnet areas with the “Limited motorized travel” allocation. We would request continued and increased focus on walk-in recreation opportunities.
• The BLM Missoula Field Office is already making great strides to address checkerboarded landownership and establishing continuous blocks of public land with good access points. Specifically, we support common sense acquisitions by the BLM, particularly in the Blackfoot Watershed, currently owned by the Nature Conservancy (TNC). These lands were acquired by TNC for conservation purposes and for eventual public ownership.
• We understand and are sympathetic to the challenge of managing for scientific, scenic, historical and archeological values that contribute to the broader social values of western Montana. We ask that the BLM considers the latest science of climate change to predict where possible conservation challenges will arise due to warming temperatures, decreasing water supplies, increasing human demand for public land uses and changing weather regimes to help make this landscape more resilient and resistance to degradation. This is a hard ask but we rely on our public land managers to have the vision and foresight to do this responsibly.

Thank you sincerely for this opportunity to comment on the Missoula FO RMP,

The Montana Chapter of Backcountry Hunters & Anglers

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