Bureau of Land Management

Lewistown Field Office

920 East Main St

Lewistown, MT 59457

The following serves as Scoping comments pertinent to the Lewistown Resource Management Plan (RMP) planning process.          

Montana Chapter Backcountry Hunters and Anglers is comprised of over 300 Montana sportsmen across the state who depend on management of public lands in Montana to support abundant fish and wildlife populations, as well as provide traditional, non-motorized hunting and fishing opportunities. The content and direction ultimately provided by the Lewistown Resource Management Plan (RMP) Revision will be critical to both the sustainable wildlife habitat and hunting opportunities.   

We request the following issues be addressed in the revision process through development and analysis of alternatives or specific management direction in the revised RMP.

Vegetation and Plant Community Health and Diversity

1. 
   Protection and restoration of woody draws.   These relatively uncommon plant community features are disproportionately used by wintering big game and are essential as wintering sharptail grouse habitat. Livestock grazing has led to reduction of this habitat feature or its health on the RMP landscapes. Plant components of this feature are in poor vigor and often lack sufficient regeneration. The RMP must resolve how this important vegetative component will be protected and restored.


2. 
   Protection and restoration of riparian areas.   These plant communities are disproportionately grazed by livestock and are often dramatically altered negatively as wildlife habitat. Most of the RMP hunted species depend substantially on riparian areas as habitat. Riparian areas comprise minor percentages of the RMP but are among the most abused from livestock grazing. The RMP must protect and restore all riparian areas. The RMP must resolve adverse effects of disproportionately heavy grazing occurring and the effects of that grazing on riparian vegetative health and vigor.


3. 
   Manage for vegetative health and diversity on upland sites.   Cattle grazing systems are commonly developed to, under the best of management, to improve the conditions of grasses as opposed to shrubs and forbs. The effect of these grass-oriented grazing systems is the reduction of shrubs and forbs important to wildlife as forage, cover, and nesting cover. Residual plant cover assures insect production and diversity as critical gamebird brood food source. We request the RMP address upland vegetative diversity and health through direction for grazing plan designs, monitoring and inventories.


4. 
   Ensure grazing and other uses do not facilitate noxious weed spread. Long term vegetative health and wildlife habitat is dependent on native plants that are dramatically adversely affected by invasions of noxious weeds. The RMP must prioritize vegetative health and preventing noxious weed spread higher than any other use that might facilitate noxious weed spread, including incompatible grazing and other surface disturbances such as road construction, oil and gas development, and native plant conversions .


5. 
   Protection of all sagebrush communities.   All sagebrush plant communities must have priority for protection. Any land uses must not further fragment, alter or lessen vigor and reproduction of sage communities. No uses should be permitted that contribute to fragmentation of sage communities.
   

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Travel Management and Recreation

1) Prioritize Travel Management Planning.   The RMP must prioritize travel management planning on all BLM acres in the Lewistown RMP.   Motorized travel can adversely fragment habitat, adversely affect wildlife security, can force wildlife to move to private lands, can spread noxious weeds, and can change hunting opportunities. Game retrieval provisions, if allowed, must be sensitive to facilitation off road travel and creation of new routes, the intent of ROS designation as well as big game disturbance.

2) Use Recreational Opportunity Spectrum.   We request the RMP utilize the ROS system to address balance of recreational opportunities. We request allocations which assure primitive and semi-primitive classes are well represented across the area.

Access to and equal use of landlocked parcels

1. Acquisition of Access to landlocked parcels. Acquiring public access to the boundaries of large BLM holdings where no such access currently exists must become the top travel priority for BLM management.
2. Proceed with no land exchange transactions that will negatively impact future public access to hunting and fishing opportunities in the area of the proposed exchange. Coordinate with FWP in evaluating wildlife management outcomes of completed exchanges.
3. Identify parcels without legal public access and direct efforts to improve legal public access.
4. Prohibit hunting outfitting on BLM lands where the general public does not have legal access.

Protections of all Greater Sagegrouse habitats

1. Any future oil and gas development must be restricted with No Surface Occupancy restrictions on all occupied sage grouse habitats, especially near leks and nesting habitat.
2. Strong direction to avoid sagebrush fragmentation by additional roads or construction of overhead powerlines, wind farms, energy development or other uses contributing to fragmentation of sagebrush communities.

Identify and manage Backcountry Conservation Areas

We ask that you identify areas of lands that are generally intact and undeveloped and that provide high quality fish and wildlife habitat. We ask that you allocate or designate these lands as “backcountry conservation areas” (BCAs) to conserve unfragmented fish and wildlife habitat and dispersed hunting and fishing opportunities.

BHA is working with other hunting and fishing based organizations to identify specific intact and undeveloped lands within the BLM Lewistown District that are appropriate for BCA management, and we will follow up with supplemental recommendations that nominate specific areas as backcountry conservation areas.

The following provides specific examples of the appropriate allocations or management approaches that should be applied in the Lewistown RMP when adopting BCAs.

BCA Resource Decisions

Fish and Wildlife Habitat and Noxious Weeds - Establish objectives for management activities that conserve, restore, maintain and enhance fish and wildlife habitat, control and manage noxious weeds, and restore forests and rangelands.

Recreation Opportunity Spectrum (ROS) - The following ROS classes would be available within BCAs:

• Primitive
• Semi-Primitive Nonmotorized
• Semi-Primitive Motorized

Off-Highway Vehicles - Designated as limited or closed. Existing routes would generally be retained, but travel would be limited to existing roads, primitive roads and trails.

Fluid MineralsLands - would be open to new leasing subject to No Surface Occupancy (NSO) stipulations.

Rights of Way - BCAs would be exclusion areas for new linear rights-of-way.

Renewable Energy Resources - BCAs would be exclusion areas for renewable energy development, such as wind and solar.

Grazing - The BCA has no effect on authorized rangeland health, standards, capacity (animal unit months - AUMs) or livestock grazing management actions and tools (e.g. fencing and watering).

Locatable Minerals - BCA lands are generally not intended to be withdrawn from operation of the general mining laws. Reasonable efforts will be made to reduce and reclaim surface disturbances from exploration and mining activities and prevent the fragmentation of intact habitats within BCAs, while allowing for existing rights to be exercised.

We look forward to working with you in the development of the RMP, and request you keep us informed of the process as it moves forward.

Sincerely,

Greg L Munther, Co-Chairman

Montana Backcountry Hunters and Anglers