November 26, 2018

Heather DeGeest
Helena District Ranger
Helena National Forest
280 Skyway Drive
Helena, MT 59620

Subject: Strawberry Butte Front-country Trails Project

Dear Ranger DeGeest:

I’m writing this letter on behalf of the Montana Chapter of Backcountry Hunters and Anglers (BHA), based in Missoula, Montana.

The Montana Chapter of BHA represents approximately 2,600 sportsmen and women across our state. Our mission is to ensure North America's outdoor heritage of hunting and fishing in a natural setting, through education and work on behalf of wild public lands and waters. 

The Elkhorn Range is a special place. It is the only part of the National Forest system where Congress has directed the Forest Service to implement a management strategy that favors the needs of wildlife above other standard public land considerations. The Elkhorns Wildlife Management Unit (EWMU) is absolutely unique in the Nation. It is home to one of the most revered and heavily hunted elk herds in Montana. The range is also home to a diverse suite of game and non-game wildlife. At least one grizzly has been documented using the Elkhorns in the last few years. The Strawberry Butte Front-country is some of the best low-elevation wildlife habitat in the Elkhorns, and is used by game and non-game wildlife year round. 

Montana BHA would like to believe that this proposal is simply a scoping document. As such, public comment will give the Forest some inkling of where to go from here. If the Helena National Forest (HNF) has put the proposal forward with the goal of simply adopting 39 miles of user-created and maintained routes, under the auspices of Categorical Exclusion, then we are adamantly opposed to the project as it stands. 

We believe that moving ahead with the adoption of the trail system as proposed, is pre-decisional, and smacks of a back room deal between the HNF and local trail advocates. We also believe it likely that the HNF will eventually turn the maintenance of the trail system over to some of the very trail advocates who have been involved in the construction, maintenance and promotion of the unauthorized trail system in the first place. This is out and out unethical policy that rewards illegal activity on public land. 

Montana BHA believes the Helena National Forest needs to take a time-out here. There is no question that the existing trail system in the project area is illegal and unsanctioned. That the HNF has failed in its duty to manage resources and recreation in the area is a given. Although bureaucratic inertia may have contributed to the existing situation, there is every reason for the HNF to slow down and think this through, rather than rush into the adoption of an outlaw trail network. The disposition of the on-the-ground unsanctioned trail network needs to be addressed via a public community discussion, in the light of day. What is the rush; especially as the Forest Plan Revision process is ongoing?

There is absolutely nothing wrong with trail projects or mountain biking in the Elkhorns. However, there is a growing body of scientific work regarding the impacts of intense recreational use on wildlife. What you have proposed is a destination recreation area, close to Helena, a city that is advertising itself as a trails tourism destination. The unauthorized trail network is already listed on Trailforks on the Internet. If this user-created trail system is sanctioned one can reasonably expect use of the trails in the Strawberry Butte Front-country to increase substantially over time. It is difficult to imagine how the project, as proposed, will benefit wildlife. The number of miles of trail, trailheads and parking areas is likely to create much more intense future recreational use and far greater wildlife impacts over time. Closing a few connector routes is unlikely to benefit wildlife more than increased use will negatively affect the area’s game and non-game species. 

Dispersing trail use out of the South Hills is not a valid reason to spread it to the Elkhorn WMU. 

Would the HNF allow a private entity to site a high-density recreational trail system (like the one you have proposed) in the EWMU without the thorough environmental review of an EA or EIS? I think not. 

Montana BHA is a strong advocate for access to our wonderful system of public lands. However, that does not mean that we believe every square section of public land needs a recreational trail through it. Wildlife needs refugia where they can get away from human use. 

Montana BHA’s suggestions:

1) This project has greater potential wildlife and social impacts than can be examined under the auspices of a Categorical Exclusion (CE). We ask that you do an Environmental Assessment (EA) or Environmental Impact Statement (EIS) that examines various alternatives and provides the public with a substantive analysis of current conditions in the area and potential effects of the various alternatives. Right now the USFS simply asserts that the trail project will improve conditions for wildlife without any science or justification. 

2) Please drop the “Corral Mountain loop” from further consideration. 

3) The public needs to see detailed maps of which existing routes you plan to close and which routes you believe should stay open. 

4) Given the Elkhorn Range’s unique status as a Wildlife Management Unit the HNF needs to take a hard look at the best available science regarding recreation and wildlife and present that information to the interested public.

5) The HNF must factor in the ever-improving technology of mountain bikes. Just as with snowmobiles, the technology and capabilities of mountain bikes continues to improve. The Forest should make an attempt to factor in ever-more-capable technology into its big-picture management of Elkhorn Range non-motorized trails. 

6) Please recognize and account for the importance of the Willard Creek drainage on the local moose herd, as it pertains to recreation trail use of the area. 

7) We see potential social conflicts between intensive recreational trail use and both archers and rifle hunters during the fall hunting seasons. The plethora of unauthorized routes in the area already provides too many easy conduits for hunters, which increases the pressure on elk and other game. Please address these social issues in your analysis. 

8) Because the Elkhorns are collectively managed by the Helena National Forest, Beaverhead-Deerlodge National Forest, Bureau of Land Management, Montana Department of Natural Resources and Conservation, and Montana Fish, Wildlife and Parks, we wonder how much coordination has been done among these various agencies regarding the proposed high-density trail system as currently proposed. Is there an overall recreation management plan or strategy for the Elkhorns? We believe there should be such a plan. 

9) We believe that any trail system in the project area needs to be engineered so as to limit speeds to levels compatible with foot and horse traffic. 

Ultimately, Montana BHA sees a place for a few miles of trails in the project area, open to foot, horse and bike traffic alike. 

Thank you for your consideration. 

Sincerely,

Steve Platt

Capital Board Member 

Montana Chapter of Backcountry Hunters and Anglers