February 10, 2020

The Montana Chapter of Backcountry Hunters & Anglers
PO Box 9257 
Missoula, MT 59807

Carol Hatfield, District Ranger

Belt Creek- White Sulphur Springs Ranger District

204 West Folsom

P.O. Box A

White Sulphur Springs, MT 59645

Subject: Horsefly Vegetation Project

Dear Ranger Hatfield,

The Montana Chapter of Backcountry Hunters and Anglers (MT BHA) welcomes the opportunity to comment on the Horsefly Project. Our 3,250 Montana members rely heavily on public land hunting and fishing opportunities, including those on the Helena-Lewis and Clark National Forest (HLCNF). Because our members are primarily public land hunters, the outcome of projects that affect public land big game and big game habitat is vital to the future hunting opportunities of our members.

Our concern with this project is the foreseeable degradation of wildlife habitat and big game security. Montana BHA has a long-term interest in the HLCNF maintaining its current, scientifically based, big-game security standards rather than adopting inadequate guidelines. As per the direction of the long-standing Forest Plan, we expect the HLCNF to carry out projects that would not significantly degrade wildlife habitat.

We note that the existing open motorized route density is high (anywhere between 1.7 and 3.2 miles of road per square mile – depending upon which resource report is referenced) and that much of the project area does not meet the C-1(5) big-game security standard in the existing Forest Plan.

As we understand it, the HLCNF says it can’t meet big game security standards as they exist today, so the HLCNF is proposing to waive these Forest Plan habitat security standards.

Additionally, we feel it is inappropriate for the HLCNF to use FWP’s current “over objective” measure for elk populations in FWP Hunting Districts 416 and 454 to justify not maintaining big-game security on HLCNF lands. Citing state fish and game objectives – which change at least every other year and include far more variables than the habitat existing on lands managed by the USFS – in an effort to weaken federal land management agencies’ habitat standards is inappropriate and could lead to a myriad of problems. There are reasons these agencies are kept separate.

However, if the HLCNF thinks it appropriate to consider state fish and game management objectives in their Forest Plan objectives, there’s a very strong argument to be made that the elk on public landswithin Hunting Districts 416 and 454 – including the Horsefly project area – are not, in fact, in an “over objective” status for elk. Rather, because of the HLCNF’s past inability to reduce open motorized route density to meet its own scientific big-game security standards, a high percentage of public land elk have alreadybeen displaced from public to private lands, where the public land hunter does not have hunting access to the animals. Consequently, elk have multiplied in these hunting districts to a point exceeding the socially created “over objective” status as determined by Montana Fish Wildlife and Parks. With elk learning to thrive on the lands offering more security for them, the elk have developed a preference for private lands and moved away from HLCNF lands. Now, Montana FWP has very few management options for controlling elk numbers and it can be easily seen how reducing public land elk security even further - like how the Horsefly Project would do, as currently envisioned – would simply exacerbate this problem.

Furthermore, according to your analysis, there are no known elk calving areas within the 20,100-acre Horsefly project area. Given the size of the area and that it contains numerous spring seeps, wet drainage heads and other typical calving habitat, we wonder why elk are not known to drop calves across this large acreage in the southern Little Belts? If in fact calving does not take place in the project area, might the HLCNF failure to meet the Forest Plan big-game security standards in past travel management be playing a role here?

It is worth noting that very little information was available in the EA about mule deer numbers in the project area. Has the high density of open motorized routes contributed to the current mule deer decline?

To make this project more compatible with big-game and habitat security, we respectfully request that the HLCNF significantly scale back the number and size of treatment units, use more fire and less commercial timber harvest to manipulate vegetation, and build fewer miles of temporary road (vectors for both invasive weeds and reducing elk security even further). Furthermore, temporary roads should be required to be recontoured following existing logging routes to avoid new roads from becoming additional detriments to public land elk security habitat. And finally, to at least offset the quantity of new roads built in this highly degraded and fragmented landscape, we ask that the HLCNF identify routes which are currently open to motorized use and revisit their use restrictions in an effort to bolster elk security and combat animal displacement.

Thank you for the opportunity to comment.

Sincerely,

Doug Krings,

Region 4 Chapter Leader

Montana Chapter of Backcountry Hunters & Anglers

CC: Jay Kolbe, Montana FWP