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October 30th, 2023

Ben Gilles, Montana National Wildlife Refuge Complex Project Leader

U.S. Fish & Wildlife Service

922 Bootlegger Trail 

Great Falls, MT 59404

[email protected]

RE: Proposed Missouri Headwaters Conservation Area

Dear Mr. Gilles

The Montana Chapter of Backcountry Hunters & Anglers is a grassroots conservation organization representing roughly 3,000 dues-paying members in the state. Our members value productive habitat, public access, and quiet recreational opportunities to hunt and fish. With many of our members spending a great deal of time in the wildlife-rich SW corner of the state, we take a keen interest in and appreciate the opportunity to comment on the Proposed Missouri Headwaters Conservation Area.

While our organization often focuses on our wild public lands and waters - and we recognize that this proposal falls entirely on private lands - we certainly have great interest in this project as our public fish and wildlife see no property boundaries and not only benefit from - but rely on - the private lands habitat provided by our landowning neighbors. And this identified project area, spanning parts of five counties and including up to 250,000 private eligible acres, covers some of the most productive fish and wildlife habitat in the state.

The one thing we’d like to see included in this proposal is an optional public access component, to be met with higher rates of compensation. Public access should not be a requirement, but simply an option when and where it makes sense for the landowner.

Though we appreciate and encourage public access, our support for this proposal certainly does not rely on it; we fully recognize that any conservation easements would still be a significant achievement, benefiting fish and wildlife of all sorts - including bighorn sheep, pronghorn, and mule deer - but perhaps none more so than our cold-water fisheries and our elk.

The project area makes up a significant portion of Montana’s Region 3, which holds 42 percent of our state's elk herd according to 2022 population surveys. Fueling a robust hunting economy in the fall, these big game animals spend much of the year on private lands. Additionally, many of the crucial wintering grounds and big-game movement and migration corridors are also found on private lands. It is with that understanding that we encourage this conservation area to move forward so that there are federal funds available to landowners who wish to voluntarily conserve their working lands, much to the benefit of our public wildlife.

In recent years, two of the world-famous, Blue Ribbon trout streams of southwest Montana - the Big Hole and Beaverhead - have both been experiencing rapid degradation in fishing and/or water quality. Conserving the watersheds of these two rivers - the lifeblood for the area's outdoor recreation and agricultural economies - will only help to keep cold, clean water flowing where and when it's needed.

The area's rivers also hold the few remaining native fluvial populations of Arctic grayling in the Lower 48. Not only is this fishery worth protecting, but the area could also be threatened with an Endangered Species Act listing to protect the fish, which would have significant impacts on the region's agricultural communities. More cold, clean water - which these conservation easements can help with - will only assist in preventing any listing. 

A similar argument could be made for sage grouse and the benefits of conserving southwest Montana's sage steppe to prevent a listing decision for this imperiled bird.

Finally, we cannot ignore the growing pressures to develop the lands that make Montana, Montana. Property taxes are rising, changes to climate are making damaging weather events more common, and it's becoming more difficult for our farming and ranching neighbors to make a living and afford to live their preferred way of life. Conservation easements offer a voluntary tool in the toolbox for landowners to keep their lands, to keep them working, and to keep their businesses in the family.

As one of the leading organizations advocating for the full and permanent funding of the Land and Water Conservation Fund, Backcountry Hunters & Anglers and our Montana Chapter are pleased to see this funding source - made possible by offshore oil and gas revenues, not taxes - be identified to accomplish what would be large-scale and lasting conservation wins in Montana.

This is a win-win-win from every angle, and we encourage the USFWS to approve the use of LWCF monies for this project. This is exactly the kind of thing our members had in mind when fighting for years to save LWCF.

With that, we offer enthusiastic support of this thoughtful, forward-looking proposal that will benefit Montana's landowners, our wildlife, our rural economies, and our hunting and fishing heritage.

We appreciate the opportunity to comment and look forward to continuing to engage in this public process. 

Sincerely, 

Kevin Farron, Regional Policy Manager

Backcountry Hunters & Anglers 

Corey Ellis, Board Member

Montana Chapter of Backcountry Hunters & Anglers

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