January 2, 2020
The Montana Chapter of BHA
PO Box 9257
Missoula, MT 59808
Dave Lefevre, Field Manager
Jennifer Alexander, Outdoor Recreation Planner
BLM Billings Field Office
5001 Southgate Drive
Billings, MT 59101
Re: Pryor Draft Travel Management Plan EA (DOI-BLM-MT-C010-2019-0029-EA)
Dear Ms. Alexander and Mr. Lefevre:
The Montana Chapter of Backcountry Hunters & Anglers recently commented on the Pryor draft travel plan with emphasis on the effects of the top-down direction to include e-bikes as non-motorized. We requested the site-specific analysis of proposed e-bike routes and, due to expected substantial adverse effects, the completion of an Environmental Impact Statement.
Additionally, on behalf of our 3,000+ dues-paying Montana members, we would like to stress that, while e-bikes in the Pryors would have serious adverse effects on the resources and traditional uses of the Pryors, the broad-based authorization of any non-motorized mechanized transport (i.e. mountain bikes) on virtually all designated routes will have widespread adverse consequences as well. Mountain bike use allows users to travel many more miles of any designated routes in any time period relative to non-mechanized users. Therefore, this increase in miles traveled at greater speed expands the adverse resource consequences, as well as adverse encounters with non-mechanized users.
Mountain bike usage can be expected to increase given the Pryors’ proximity to Billings and the relative ease of mountain bike travel. We urge you to consider the increase in use levels during the life of this plan, and not just evaluate the current use levels. We support designating some routes for mountain bike use in the Pryors, but believe this travel planning process should ensure balance for other non-mechanized users’ opportunities by limiting mechanized transport to a limited number of specific routes. We believe some of those routes designated as “non-mechanized use only” should, as a minimum, include all occupied and potential bighorn habitat, as well as both priority and general sage grouse habitat. Due to human disturbance resulting from increases in mechanized travel, habitat occupancy by both bighorn and sage grouse will be certainly be adversely affected by bikers, motorized or not.
We also note in table 3-9 that a total of 16.3 miles of new “non-motorized” routes will be authorized for public use in sage grouse habitat, routes that were previously limited to administrative use or use by permit. Not only would this decision allow mechanized travel on these routes, but under the top-down decision, motorized e-bike use would be authorized as well. Given the need for undisturbed sage grouse habitat as well as the risk of listing the sage grouse as Threatened, we request that mechanized travel be eliminated from sage grouse habitats except for the historic county or state roads currently in place.
Furthermore, looped routes are recognized as dramatically increasing recreational use. We request looped routes be avoided in occupied and potential bighorn habitat as well as in identified sage grouse habitats, particularly if mechanized travel would be authorized.
We urge you to develop the Pryor Travel Plan to respect both the current – and likely increase in – mechanized use and its impacts on wildlife, habitat and minimizing conflicts with traditional non-mechanized user groups.
Volunteer Board Conservation Director
The Montana Chapter of Backcountry Hunters & Anglers