Forest Supervisor
Bitterroot National Forest
1801 North 1^st Street
Hamilton, MT 59840

The following comments are in response to the Draft Bitterroot Travel Plan and we request each comment be entered into the public record, and be specifically addressed in the FEIS.

Backcountry Hunters and Anglers is a national organization dedicated to preserving our world-class outdoor traditions by protection and restoration of important wildlife habitat components and traditional non-motorized hunting and fishing opportunities. Our Montana Chapter includes hunters and anglers who live in the Bitterroot Valley as well as many more who hunt and fish on the Bitterroot National Forest. Many of our members hunt and fish in the Bitterroot Forest throughout the year. While we believe there is a place for ORVs on our public lands, and understand they are popular and powerful tools, we are also aware of how expanded, poorly controlled motorized use has adversely affected both habitat and traditional non-motorized hunting and angling opportunities.

Backcountry Hunters and Anglers prefers adoption of Alternative 4. We believe it best meets the intent of protecting the resources of the Bitterroot National Forest. It best matches the agency's resource maintenance responsibility with available and foreseeable road and trail maintenance budget. It best protects hunted wildlife by providing enough security so long, unrestricted hunting seasons can be maintained on the Forest. It best provides large security areas and low open road density that will reduce relentless human pressure that drives elk onto private land where they are unavailable to public land hunters. It best provides for high elevation species such as mountain goat and wolverine. It substantially benefits fisheries resources by minimizing sediment delivery to streams resulting from motorized use of poorly maintained motorized routes. It also best meets INFISH objectives as well as reduces by half the stream miles potentially affected by camping along streams by motorized users. It best meets the Secretary of Agriculture's August 2009 (Missoulian 8/15/09) new direction to emphasize improvement and protection of national forest watersheds. It would best provide for maintenance of traditional non-motorized hunting and fishing opportunities across the Forest. It retains ample motorized opportunities with over 1450 miles of open roads and about 450 miles of motorized trails, as well as 540, 000 acres open to snowmobiles.

We wish to express our appreciation to the Bitterroot Travel Plan team for both the huge collective effort in a time of reduced budgets as well as recognizing many emerging issues important to our members, including:

We appreciate your display of specific route by route analysis and your treatment of each in each alternative considered. This made the effect of each alternative easy to track.

Ending motorized use in most of the Bitterroot Forest Wilderness Study Areas. Areas such as the Sapphire and Blue Joint WSAs are the core of both fish and wildlife refugia. It will maintain fair consideration of these areas as Wilderness without a legacy of motorized use. However, we request you include all of the Blue Joint WSA, not just that recommended for Wilderness by the Forest Plan. We also request snowmobiling in WSAs be curtailed at this time to better protect mountain goat and wolverine habitat. Not only would better meet the intent of protecting WSA's attributes, but it insures high quality fish and wildlife habitat as well as important large scale big game security areas and traditional hunting and fishing experiences.

Acknowledgement that elk hunting opportunity is enhanced by providing large secure areas that keep animals on the Forest, rather than being displaced to private lands.

Acknowledgement that bowhunting is an increasingly popular Bitterroot activity, and that secure hunting areas are as important to bowhunters during the archery season as they are to general season hunters. We acknowledge your identification of some routes that will be closed to motorized use seasonally beginning August 31 each year. Specifically we concur and SUPPORT Aug 31 closures of the following routes:

1334 mileage 2.9-7.2
1370-7.47
1392 0-8.5
5635 3.6-5.8
13102 0-1.6
13202 0-0.2
13203 0-2.9
13231 0-1.1
132590-1
13260 0-0.31
13261 0-2.8
62605 0-1.4
62669 0-1.2
62754 0-.39
62966 0-0.8
Tr 105 0-11.5
Tr 159 0-2.8
Tr 160- 0-2.8
Tr 161 0-7.5
Tr 182- 5.038-8.12
Tr 248 0-4.4
Tr 288 0-2
Tr 500 0-0.7
Tr 510 6.2-10.8
Tr 84 0-6.55
Tr 313.1 4.07-19.1

We SUPPORT closure of motorized use as proposed in Alternative 1 on the following routes:

Trails 168, 40, and 139 in the Moose Cr, Sign Cr and Martin Cr areas. Together, these closures will provide important security and traditional hunting opportunities.

Trails 178 and 203 in the Diggins and Wallace Cr area. These closures in combination create a significant non-motorized hunting opportunity and improve wildlife security.

Trail 170 in the Swift Creek area. Important wildlife security and traditional hunting opportunity will be enhanced.

Trail 73076 in Martin Trib 9.1. This single closure positively enhances a large portion of the Martin Creek drainage for wildlife habitat and traditional hunting opportunity.

We SUPPORT all of the motorized winter use closures in areas known to be currently or formerly occupied by mountain goats, as recommended by MDFWP.

We concur that the basis for providing quiet areas for non-motorized recreation, including non-motorized hunting and fishing, is most easily accommodated in Inventoried Roadless Areas, as well as Wilderness Study Areas.

We request, as a minimum, that the final version of the travel plan be modified to be more responsive to both resource conflicts as well as recreational conflicts in the following manner:

A) We believe the Bitterroot Forest has the responsibility to modify human uses that adversely affect sustainability of the Bitterroot's resources, whether motorized or non-motorized where adverse resource effects occur. The DEIS table of specific routes has identified many resource conflicts that need to be resolved in the final EIS and travel plan. Specifically we request the following routes be closed to motorized use based on the Forest's acknowledgement and documented significant resource conflicts in the DEIS:

62067 Identified as steep and sediment concerns. Forest Plan Goal 2.c.5 clearly intends such routes to be closed, by stating "Off road vehicle use will be controlled to prevent soil degradation".

62613 Identified as having wetland damage and sensitive plants. The Forest plan states "Provide a safe trail system that protects soil and water resource".

73211, 73212. 73213, 73214, 73215, OHV1-05, OHV2-08, OHV2-02 All identified as high resource concerns and weed spread. The Forest Plan states "Roads will be closed to public use if adequate road maintenance funds are not available" (Forest Plan Standard 2.j.2)

74788 Identified as having existing resource damages. The Forest Plan states "Roads will be closed to public use if adequate road maintenance funds are not available" (Forest Plan Standard 2.j.2)

Trail 313.1 Should closed to motorized use yearlong to be consistant with Lolo Forest Elk Management as well as eliminate this ridgetop route that has particularly adverse effects on elk habitat. This trail also conflicts with Wilderness management and the Wilderness setting.

Trail 313.5 should be closed yearlong to motorized use because of stated effect on mountain goats and elk

Tr SURD 03, 04, 05 should be closed yearlong due to identified weed spread issue. Weeds are one of the largest threats to our mountain ecosystem. In particular, the Forest Service should be implementing direct steps on currently motorized routes within bib game winter range in to contain such weeds as leafy spurge, sulphur cinquefoil, spotted and Russian knapweed. Even in wet mountain meadows, spread of oxeye daisy threatens productivity and plant communities of of these meadows.

2) We request reanalysis of elk security during the archery season to be using methodology consistant with the analysis of elk security analysis displayed for the rifle season. The DEIS contends : "Elk are therefore not very vulnerable to archery hunters in open situations where hunters are relatively conspicuous and easy to avoid, whereas elk in open situations are very vulnerable to rifle hunters capable of shooting effectively from long range. Instead, elk are more vulnerable to archery hunters in denser cover because archers can get closer to elk without being detected." We disagree with the premise that cover is not important to elk during the archery season to avoid archers. We ask for peer-reviewed biological documentation for this assertion. We have found that, once elk are detected, most bowhunters readily pursue elk wherever they are found, causing displacement from their preferred habitat. Areas with more cover reduces the likelihood that elk will be discovered and pursued as frequently during the archery season, therefore higher elk security. Displacement, rather than hunter mortality, is the archery season issue that must be assessed in a travel plan context. Elk that are detected and pursued during archery season behave similarly to elk during the rifle season. Enough pressure and they are displaced, often eventually to private land. Grigg (2007) documented that many elk in his study area were no longer available to public land hunters by the end of archery season because they had been displaced to private land. (Grigg, J. L. 2007. Gradients of predation risk affect distribution and migration of a large herbivore. MS Thesis,. Montana State University. Bozeman).

We believe inappropriate logic was used in the EHE analysis: According to the DEIS "The EHE model (Lyon 1983) did not account for motorized use on trails, so they are not included in these calculations to determine compliance with the EHE standard. Motorized trails are included in the EHE Index calculations in the next section.". Lyons project was spurred by conflict with open logging roads and elk. Motorized trails have essentially the same effect on EHE as an open road as substantiated by recent avoidance documentation by the Forest Service in eastern Oregon (Wisdom, M. J., H. K. Preisler, N. J. Cimon, B. K. Johnson. 2004. Effects of Off-Road Recreation on Mule Deer and Elk. Transactions of the North American Wildlife and Natural Resource Conference 69 and Naylor, L.M., M. J. Wisdom, R.G. Anthony. 2009. Behavioral Responses of North American Elk to Recreational Activity The Journal of Wildlife Management 73(3):328–338 ). Elk avoidance of ATVs in excess of one-half mile as documented in these studies must be acknowledged occur regardless of what kind of or whether a weapon accompanies these machines. In personal communication with Lyon, he has expressed that motorized trails indeed have the same effect on elk as an open road. Other Forest Service biologists contacted concur that there is no difference between an ORV route and a full sized route on elk disturbance. We request compliance with the Forest Plan Standard 2.e.14. using EHE by third order drainages across the Forest including motorized routes of all kinds.

3) We request that ALL motorized routes that are currently closed in mid October for wildlife security be modified in the new Travel Plan to be closed August 31. As stated above, the effect of archery hunters on elk and other big game is similar to general season hunters and should be regulated the same way. In addition, general season hunters are shortchanged in opportunity when insufficient wildlife security in archery season fosters large scale movement of elk to private lands where they are not available to public land hunters. In addition, leaving roads open to ATVs and motorcycles but closed to full scale vehicles during the hunting seasons is basically encouraging more hunters to buy and use ATVs and motorcycles, and creates a caste system favoring those who own and use these machines.

4) We have analyzed the Alternative 1 maps and found several routes that, if closed, would significantly improve wildlife security and traditional non-motorized hunting opportunities. Most of these are single track routes that enable motorcycle riders to penetrate some otherwise large scale wildlife habitat at the expense of security and non-motorized hunters. We request closure of the following routes to all motorized use, at least beginning Aug 31.

Trail 205 and 177 Overwhich and Porcupine

Tr 673, 606, 650, 17. Together these single track trail closures would significantly enhance wildlife habitat security and traditional non-motorized hunting opportunities.

Tr 171 and 172 in Upper Meadow Cr

Tr 223 (Razorback Ridge), 138 (Chicken Cr), and 139 (Deer Cr) Trail 138 is especially egregious because it is located on the same ridge that forms the boundary of the Blue Joint WSA.

Tr 650 Upper Hughes and Straight Cr.

Tr 103 and 205 Upper Warm Springs Cr

5) We believe the Forest has a responsibility to take action to bring open motorized use in balance with existing road and trail maintenance budgets. We note in the Soils portion of the DEIS: "Erosion of roads and trails will continue, especially at the current level of maintenance, which is not adequate to fully address erosion concerns on all designated travel routes on the Forest. ". We note that, according to the Forest Plan FEIS, over 60% of the non-Wilderness portion of the Forest is on erosive decomposed granitic soils. Decomposed granitic soils are among the most erosive in the West, and the most expensive to construct and maintain mitigated motorized routes. Increased gradients exasperate erosion problems and downcut routes collect surface runoff that perpetuates this erosion.

In addition, the DEIS does not adequately project the increase in motorized use levels adverse environmental effects logically anticipated over the life the Travel Plan. We have noted that the DEIS references the existing light use on some motorized trails without identifying what the resource effects of increased use will be from these lightly used trails as motorized use levels increase. We request the FEIS acknowledge the erosive effects of increased use over the expected life of the Travel Plan, and take specific actions to address the anticipated adverse fisheries effects of these anticipated sediment increases.

Useful references include: Ayala RD, Srivastava P, Brodbeck CJ, Carter EA, McDonald TP (2005) Modeling sediment transport from an off-road vehicle trail stream crossing using WEPP model. Paper Number 052017, Proceedings of the American Society of Agricultural and Biological Engineers Annual International Meeting, St. Joseph, MI ; Coe D, Hartzell M (2009) Assessment of sediment delivery from the Rubicon Jeep Trail. Report to the Central Valley Regional Water Quality Control Board, Rancho Cordova, CA.;Chin A, Rohrer DM, Marion DA, Clingenpeel JA (2004) Effects of all terrain vehicles on stream dynamics. In: Guldin, JM (ed), Ovachita and Ozark Mountains Symposium: Ecosystem Management Research. General Technical Report SRS-74, USDA Forest Service, Southern Research Station, Ashville, NC pp 292-296;Newcombe CP, MacDonald DD (1991) Effects of suspended sediments on aquatic ecosystems. North American Journal of Fisheries Management 11:72-82; Trombulak SC, Frissell CA (2000) Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14:18-30; Welsh MJ (2008) Sediment production and delivery from forest roads and off-road vehicle trails in the Upper South Platte River watershed, Colorado. MS Thesis: Colorado State University, Fort Collins, CO

6) We believe the Bitterroot Forest must consult with USFWS under ESA regarding the effect of the Travel Plan on bull trout as a threatened species, including the effects of continued use of motorized routes for in areas of sensitive soils and steep slopes(see above references), as well as on routes crossing streams or within riparian areas that have no or inadequate in-place mitigation for such crossings on fisheries, including bull trout. It must also analyze and consult on the effect of permitting motorized camping off the trail for up to 300 feet in riparian and streamside areas, authorization of motorized use on user created trails. We believe a site specific analysis is warranted on all those motorized routes that are within 400 feet of a stream, cross streams or active channels, and those without site specific analysis of condition of the trail and sediment reduction effectiveness. If a biological evaluation was provided the FWS, we believe it was appropriate to include the document to the public when the draft was issued.

7) Poor enforcement of the Travel Plan is one of the most important and frustrating issues to our Montana BHA members. Simply, the Bitterroot has not provided adequate nor effective enforcement to discourage illegal and inappropriate behavior by some motorized users. Currently (according to the Forest Monitoring Report) two or three hundred formal complaints are registered with the Bitterroot each year yet the number of illegal use convictions are far less than ten each year. We believe this poor enforcement record reflects badly on the agency and does not encourage responsible and accountable behavior. Our hunting members plan and anticipate hunting in a non-motorized secure environment have their experience ruined when rogue ORV use is encountered. This new travel plan must incorporate meaningful enforcement procedures and well thought out trailhead locations, as well as analyze motorized routes for violation potentials to better assure a high level of compliance by Forest users. Motorized routes that change to non-motorized by merely a sign far into the Forest are usually the easiest to violate and hardest to enforce. We request each motorized route be analyzed as to whether enforcement can be effective and eliminate those routes where enforcement effectiveness is judged to be low.

We believe implementation of the above recommendations would make the plan substantially improved over the current preferred Alternative 1 as described in the DEIS.

Sincerely,

s/greg l munther

Greg L. Munther, Chairman
Montana Chapter
Backcountry Hunters and Anglers