Dear Governor Bullock
Re Montana Sage Grouse Habitat Conservation Strategy
The 350 members of Montana Backcountry Hunter and Anglers include many well informed hunters who are concerned about the sustainability of sage grouse populations and their habitats. As an organization we have previously commented on the importance of a science based strategy in this planning process and suggested a number of habitat considerations to the Advisory council.
In Montana, many of us have witnessed dramatic reductions in both sage grouse habitats and thus populations. We are at a point where we can no longer afford to lose more habitat, nor see the remaining habitat degraded. In the end nobody wins if this Strategy is not clear and decisive in assuring sage grouse protection and leads to listing of the species as a Threatened or Endangered. If in doubt, the Strategy should error on the side of maintaining sage grouse populations and their habitat.
While the draft strategy is a good start, some of the proposed Strategy provisions are not supported by the best available science. We urge you to make the following changes to assure this strategy is acceptable to the Fish and Wildlife Service, as well as eliminating the loopholes that could be used by special interests to further degrade sage grouse habitat, which would result in further declines in sage grouse populations. The integrity test must be use of the best available science. At this stage we cannot risk the future of sage grouse with a weak Strategy.
We request that your office intervene in the process to assure the following:
1) Clarification that activities in Core Areas that do not meet recommended stipulations shall require compensatory mitigation, not just “may”.
2) In Core Areas, if project impacts are unavoidable, their size has been minimized, Core Area stipulations have been followed, and project impacts are expected to remain after reclamation, mitigation shall also be required following the Mitigation Framework outlined in Section IX. We do not believe Mitigation should be merely enhanced reclamation.
3) In General Habitats, if project impacts are unavoidable and their size has been minimized, it should be clearly stated that mitigation may also be required following the Mitigation Framework outlined in Section IX.
4) Noise decibel stipulations be imposed without having to evaluate and consider ambient noise levels as has been suggested in the current version of the Plan. We do not believe the best available science supports such an ambient noise modified noise stipulation, and implementation would be difficult.
5) In General Sage Grouse Habitats, a one mile no surface occupancy (NSO) stipulation be applied, which is supported by best available science. There is simply no basis in sage grouse science for the .25 mile NSO stipulation as proposed.
6) In depth scrutiny for the proposed stipulations related to bentonite, peat, scoria as well as sand and gravel. We believe any such proposals need to be fully evaluated and concurred with by the scientists in the Committee.
The importance of a Montana Sage Grouse Habitat Conservation Strategy that is clear, uses the best available science, and minimizes loopholes to best assure a bright future for sage grouse and their habitat cannot be stressed enough.
Co-chairman, Montana Chapter, Backcountry Hunters and Anglers