May 5, 2020

Montana Fish, Wildlife & Parks
Kris Tempel, Habitat Conservation Biologist
[email protected]
490 N. Meridian Road, Kalispell, MT 59901

The Montana Chapter of Backcountry Hunters & Anglers (MT BHA) offers the following points pertinent to the potential development of a conservation easement (CE) adjacent to Lost Trail National Wildlife Refuge. The land was recently acquired by Southern Pine Plantations Montana, LLC (SPP) near Marion, MT. Our Chapter is comprised of 3,000+ dues-paying Montana hunters and anglers, many of whom treasure and utilize both public and publicly accessible private lands near the proposed easement. We appreciate previous landowners who have traditionally allowed hunting and fishing access on these lands, and we certainly encourage consummation of such an easement.

To ensure an easement that recognizes private land rights while optimizing benefits to both wildlife and the public, we believe the following issues must be addressed, should the process move forward:

1) Easement must be perpetual. Given changing conditions and potential fluctuating interests of both owner and conservation easement administrative agency, any conservation easement must be perpetual.

2) Public access to public land inholdings. The CE should include appropriate assured public access to both the private land within the CE as well as all intermingled public land parcels.

3) Define sustainable forestry. While “sustainable” forest management is admirable, the term needs further definition. To achieve this goal, we believe key objectives must be included in the CE with measurable and temporal specificity. Key constructs to address in these objectives: a) an appropriate range of forest age structures in appropriate juxtaposition and responsive to naturally occurring patch sizes, 2) retention of existing old growth components for ecological values if the existing old growth component is considerably less than needed for ecological values and 3) recognition of and control of invasive plant species.

4) Motorized use. Public motorized use should be clearly defined by specifying open road densities and providing for seasonal restrictions that maintain both ecological big game wildlife habitat values and provide a range of hunting experience opportunities. The CE needs to define how motorized public use restrictions are to be enforced.

5) Partial sale or subdividing. Partial sale or any potential subdividing must be discouraged, or as a minimum, specifically defined geographically and kept at scale to retain big game habitat, ecological values and without blocking significant public access.

6) Conflicting uses. Any public or landowner uses conflicting with ecological values or degrading big game habitat need to be specifically identified and specified how such uses will be controlled or permitted.

7) CE Administration. The roles and responsibilities of both the landowner and administering agency need to be clearly articulated, as well as resolution process of potential disputes.

We recognize that the above components may contribute to taking private land rights from SPP, and there is economic compensation required for each of these components. We accept that some compromise may be needed to balance the public interests with available funding. We urge creativity in this regard.

Additionally, we perceive that some of the above requirements we have listed warrant further analysis of the proposed site and forest products in order for them to be addressed. We look forward to participating in public input process following the Environmental Analysis should the proposed project move forward, which we hope it does. We request to be notified of any updates at: [email protected].

Sincerely,

Greg Munther, Montana Chapter Conservation Director
Molly Elliott, Region 1 Montana BHA Chapter Leader