PO Box 1175 (5530 North Montana) • Helena, MT 59624
406-458-0227 (phone) • 406-458-0373 (fax) • www.montanawildlife.com

August 20, 2002

Gary Slagel, Monument Manager
Bureau of Land Management
P O Box 1160
Lewistown, MT 59457-1160

RE: UPPER MISSOURI RIVER BREAKS NATIONAL MONUMENT SCOPING

Dear Mr. Slagel:

I am writing you on behalf of Montana Wildlife Federation (MWF), Montana’s oldest and largest conservation organization. The MWF is an advocate for sound conservation principles that enhance and sustain secure, non-fragmented, healthy habitats necessary for the perpetuation of diverse fish and wildlife species. MWF is this states lead citizen-based proponent for public hunting, angling, and wildlife related recreational opportunities. MWF formally submits the following comments to you to be included during the scoping phase of management planning for the Upper Missouri River Breaks National Monument.

In January 2001, when former President Bill Clinton proclaimed this last block of wild land where Lewis and Clark traversed 200 years ago, a national monument, he preserved an unsung national treasure for all Americans. The high prairie plateaus, sandstone canyons, cliffs and river bottoms epitomize the best of our country, a natural glory, a wildlife paradise. An overwhelming majority of Montanans supported this designation putting the highest value on those rough broken landscapes untamed by man’s desire to exploit nature’s bounty. The character of this land has remained little changed since Lewis and Clark, thanks to the careful stewardship of private and public lands. We are optimistic that within the ensuing management plan, steps will be taken to perpetuate and celebrate this character.

MWF requests that the following points be included in the management plan scoping process for the Upper Missouri River Breaks National Monument:

HUNTING AND PUBLIC ACCESS

“The monument boasts the most viable elk herd in Montana and one of the premier big horn sheep herd in the continental United States…Arrow Creek, originally called the Slaughter River, contains the largest concentration of antelope and mule deer in the monument…” from Monument Proclamation.
Hunting has been a prominent historical use of this region, first documented in the Lewis and Clark Journals during the Voyage of Discovery. In 2001, 1455 individuals applied for the 198 available general season elk permits and 2482 individuals applied for 3025 antelope permits available in the Montana Fish, Wildlife and Parks districts that include the UMRBNM. Add 537 archers to that figure who are all awarded permits provided they applied for those permits as their first choice (MFWP 2002 Tentative Big-Game Hunting Regulations).

Economic and cultural benefits derived from hunting and other outdoor recreation activities is substantial. A report from the Montana Chapter of the Wildlife Society documents 1.2 million hunter/days for deer, 900,000 hunter/days for elk translating into $360 million in economic benefits for the entire state of Montana. FWP figures quote $58,533,640 in license fees associated with big-game hunting, bird hunting, and fishing statewide. The monument supports a healthy game herd, and is highly utilized for the purpose of hunting. The entire Upper Missouri Breaks area is world famous for its elk herds. A reputable elk harvest does occur within the Monument area with equal or better hunter success on the adjacent Charles M. Russell National Wildlife Refuge (conversation with Michael Hedrick, Refuge Manager.) The UMRBNM is essential mule deer habitat with hunter success rated high (Stivers, FWP Biologist conversation) but the shining star is the growing Bighorn sheep herd. Common to the Ervin Ridge, Dog Creek, Bullwhacker Coulee and significant other habitat on the monument, hunter success on the either sex permits is 100 per cent of the issued permits (Stivers, Rossgaard FWP biologists conversation, 2002.) Biologists consistently observe 600 sheep during annual aerial population surveys. Upland game birds are sought within the monument. The uplands are highly suited for sharptail grouse production, the islands and riparian area associated with the Missouri River as well as the interface with agricultural crops produce ring-necked pheasant in good quantities. Historic evidence of Sage Grouse suggests that it has a high potential for a huntable population. Gray partridge also are common to the area’s uplands. Hunters also prize the river for its bounty of ducks and geese. With this data we can presume that the UMRBNM contributes prime opportunities for hunting recreation that need to be given high priority.

HUNTED SPECIES WITHIN UMRBNM

Big Game

• Elk
• Rocky Mountain bighorn sheep
• Mule deer
• Whitetail deer
• Pronghorn antelope

Upland Birds

• Sharp-tailed grouse
• Sage grouse
• Gray partridge
• Ring-necked pheasant
• Migratory birds
• Mourning dove
• Common snipe
• Lesser sandhill crane

Waterfowl

• Tundra swan
• Canada goose
• Snow goose
• Ross' goose
• White-fronted goose
• Mallard
• Pintail
• Northern shoveler
• American widgeon
• Gadwall
• Blue-wing teal
• G reen-wing teal
• Lesser scaup
• Common goldeneye
• Barrow’s goldeneye
• Canvasback
• Redhead
• Ring-neck
• Bufflehead

Include the following items into the list of concerns for scoping:

• Hunting and fishing shall be recognized as historic and traditional uses in the Monument and shall be included in current and future management plans. “Hunting and fishing shall be recognized as historic and traditional uses in the Expanded UMNWSR (now UMRBNM) These legitimate recreational activities (in compliance with state and federal law) shall be included in current and future management plans” RAC recommendation to Secretary Bruce Babbitt, December 1999.
• Hunting outfitting on Public Land within the monument shall ONLY be permitted on those public lands that have EQUIVALENT public access. Establish a management program that provides for EQUITABLE access for hunting and other purposes. Discontinue permits that contribute to EXCLUSIVE use of public land by commercial outfitters. In short, consideration for the public as a whole cannot be sacrificed for the benefit of commercial venues. These provisions are within BLM discretionary powers when developing an RMP for the UMRBNM, courts have affirmed the BLM’s discretionary authority to deny permission for certain uses. (Conservation on America’s Public Lands, October 2001)

WILDLIFE MANAGEMENT CONSIDERATIONS

Many passages in the Journals of Lewis and Clark refer to the bounty of the upper Great Plains and the area we know as the Upper Missouri Breaks. Many of the wildlife species remain from the time of the Voyage of Discovery, minus grizzly bears, bison, wolves and Audubon’s Bighorn Sheep. On May 25, 1805, shortly after entering the tall cliffs that characterize the Breaks, a description of the first specimen of Bighorn sheep was entered into Captain Lewis’s journal. This sheep, the Audubon sheep has since become extinct, Rocky Mountain Bighorn sheep have been successfully introduced to the area to fill the niche left by the loss of this unique species. To date, inventories of wildlife species within the monument have identified a great abundance and diversity of species. Two-hundred and thirty-three species of birds, 60 species of mammals, 20 species of amphibians and reptiles; every game species hunted in the state except for moose, mountain goats, chukar, blue and Franklin’s (spruce) grouse can be found in some quantity on the monument. Because the proclamation dictates that all objects listed shall receive full protection, we submit the following scoping comments in regards to wildlife considerations:

• Pursue and maintain healthy, natural populations, population dynamics and population distribution for wildlife species, both game and non-game species, warm-blooded and cold-blooded.
• Adopt high priority management actions necessary to protect the further conservation and restoration of native wildlife and wildlife habitat with no net-loss of wildlife species.
• Maintain up-to-date inventories of flora and fauna; pursue expanding the breadth of the present database.
• Determine and promote suitable habitat for sensitive species such as sage grouse and protect those resources with Area of Critical Environmental Concern (ACEC) protection.
• Re-establish sage grouse to its historic range within the monument.
• Encourage regrowth of Big-sage habitat types for expansion and repopulation by sage grouse. Recognize that parameters call for seven-inch stubble height to ensure successful sage grouse brood survival and manage livestock grazing to meet this end in suitable sage grouse habitat.
• Discourage wildfires in potential sage regrowth areas, as wildfires are counterproductive to recovering sage grouse populations.

LAND USE AND WATERSHED PLANNING

The Monument Proclamation requires that traditional uses of the area continue. Such uses require sound management decisions based on best use of the resource. We submit the following comments to be included in scoping regarding land-use and watershed planning:

• Recognize the proclamation’s provision for continuation of existing land ownership and use.
• Pursue conservation easements for private properties to add to protection of surrounding resources. (Excerpted from RAC recommendation to Interior Secretary Bruce Babbitt)
• Recognize that the BLM has the tools to effectively manage cattle use of the monument. Institute active monitoring and enforcement of grazing allotments to insure that lessees are adhering to management plans and respecting wildlife population priorities. Implement rest-rotation grazing plans that improves wildlife habitat.
• Ensure that new and existing livestock fences comply with legal parameters as directed in BLM Manual H-1741-1 that do not inhibit free movement of wildlife. Those standards for domestic fence requirements as quoted, “…3-wire, 38-inch height, with bottom wire 16 inches of the ground…” fences constructed as such comply to the Unlawful Inclosures(sic) of Public Lands Act of 1885 (43, USC, 1061-1064; 23 Stat. L. 321, ch.149).

NOXIOUS WEED CONTROL

Noxious weeds become more widely distributed each year. Many factors influence the establishment and spread of invasive plant species. The following points should be incorporated into the RMP:

• Give high priority to noxious weed control by aggressively seeking funds to achieve this goal. Use biological controls whenever possible, chemical control when needed to restore natural environments, techniques that fit the “integrated pest management” guidelines. USDA- CSREES (Cooperative State Research Education and Extension Service) defines Integrated Pest Management (IPM) as “a sustainable approach to managing pest species by combining biological, cultural, physical and chemical tools in a way that minimizes economic, health, and environmental risks.” Incorporate some or all of the following techniques.
• Biological controls such as differing various insects are known to control Leafy Spurge, Knapweed, Canada Thistle and Hounds tongue. Leafy spurge flea beetles have proven high success in the Lewistown area as bio-vector of leafy spurge. (Conversation with Craig Roberts, MT DNRC)
• Study the suitability of domestic goats as a bio-agent to control Russian and Spotted knapweed and domestic sheep for leafy spurge. Grazing contracts could concentrate these species, if suitable, in areas of infestation using small enclosures to minimize grazing on desirable species.
• Disturbed ground is prime substrata for noxious weeds to become established. Plans must emphasize reclamation begin very quickly in those activities that produce this condition: gas wells, drill pads, pipeline system and roads etc. should be reclaimed within 90 days of work completed; Avoid overgrazing by domestic livestock to reduce a disturbed ground situation.
• Minimize use of herbicides in big-sage habitat types to minimize negative impacts to potential sage grouse expansion within the refuge.

RIVER USE AND RIPARIAN REGENERATION

Regulations were already established for the Wild and Scenic River sections of the Missouri River Breaks previous to monument designation. Increasing river use is anticipated with the Lewis and Clark Bicentennial as the popularity of the new monuments increases. The following items are to be included for scoping:

• Manage motorized use of the river corridor to emphasize a natural experience using recommendations by the Central RAC as a guide.
• “All motorized use will be ‘no wake’ from Saturday before Memorial Day to the Sunday after Labor Day. (Current Management Policy)”RAC recommendation.
• Allow for controlled motorized use of river corridor during hunting season provided such use does not compromise riparian health objectives or other aquatic resource health issues. Restrictions to minimize high-powered boat use, in an objectionable manner must be considered to ensure a high quality experience for all visitors to the monument.
• Disallow the use of “jet-skis” (personal watercraft) throughout the UMRBNM corridor.
• Adjust river management plans to reflect consistency throughout, eliminate unrestricted motorized boating use areas presently in place.
• Limit commercial, motorized tourist operations so that commercial ventures are not given preferential treatment or conflict with non-commercial public use. If allocation is needed in the future to deal with crowding or issues of overuse, allocation/use must be given to the public.
• Establish aggressive management plans that will encourage restoration of a properly functioning riparian habitat wherever the potential exists through management of livestock, people, wildlife and weed control and other vegetation manipulation.
• Negotiate with administrations that control water release from upstream dams to restore historical seasonal flow dynamics to the river corridor thus encouraging riparian regrowth and a return to historic riverine aquatic-habitat dynamics.
• Use supplemental planting of typical riparian trees like river willow and cottonwood to restore a vibrant riparian ecosystem.
• Minimize use of herbicides in riparian areas (refer to IPM techniques in above section.)

TRAVEL MANAGEMENT AND SOCIAL ISSUES

Studies have been done that document the correlation between road density and habitat security. The Montana Elk Management Plan, a document developed by biologists and hunters to provide for guidance to federal land managers, states that the Montana Fish, Wildlife and Parks should “promote maintenance of key unroaded areas that provide important elk security.” An Idaho study data determined that bull elk can live in excess of 10 years of age in unroaded areas and more than 30 percent of bull elk lived to maturity. In contrast, individual elk have a 61 per cent chance of being killed by a hunter in highly roaded areas as compared to a 31 per cent chance in roadless areas. (Leptich & Zager.) In light of these studies, determinations in these studies indicate that excessive roads will impact the nature of the monument. For the benefit of providing non-fragmented habitat for elk, bighorn sheep, mule deer and antelope, MWF requests the following factors be included in the planning process:

• Reduce habitat fragmentation by eliminating non-essential and user made roads.
• Eliminate user-made roads within Wilderness Study Areas (WSAs) to comply with Department of Interior directives regarding WSAs.
• Travel Planning should aggressively ensure that the integrity of the resource be left intact; Primitive travel corridors should not be replaced by high-speed roads, motorcycle, or ATV trails. Corridors built to facilitate Oil and Gas drilling should not be included in the travel infrastructure and will be reclaimed as soon as feasible. Travel corridors and pad locations contribute to a “disturbed land” condition that encourages noxious weed infestation (USDA-CSREES report, 1999)
• OHV use is to be limited to existing designated open trails and roads; Post signs and distribute brochures outlining available open trails to minimize abuse of this restriction. Recreational vehicles introduce and encourage weed growth (Montana TWS report, 1999.)
• When developing plans for people management: The integrity of the resource must be given priority in planning and construction of any trails; Visitors must assume responsibility for their actions; Adequate sanitation facilities should be located and constructed in the least intrusive manner; It is assumed that facilities will be upgraded to match needs of the recreating public but follow previously stated guidelines.
• Identify sensitive biological and geological formations that could be adversely affected by foot-travel and set restrictions to protect these areas.

MONITORING AND FOLLOW-UP

• Establish monitoring programs to insure adherence to management plans for wildlife habitat enhancement, grazing, travel, river travel, weed control, and other people use controls; Establish enforcement measures to respond to related problems.
• Establish communication protocol with local civilian advisory groups.

In conclusion, this area in central Montana was set aside to preserve the Upper Missouri River Breaks for the benefit of all Americans. For their benefit, the plan must include components that ensure the future of sustainable fish and wildlife populations, non-fragmented habitats (priority), and public hunting and fishing opportunities. Please recognize the cultural values of hunting, fishing and sustainable fish and wildlife and the need for maximum measures to ensure their future.

“…It must be clearly borne in mind that all land is to be devoted to its most productive use for the permanent good of the whole people and not for the temporary benefit of individuals or companies… and where conflicting interests must be reconciled: the question will always be decided from the standpoint of the greatest good of the greatest number in the long run…” (From the Gifford Pinchot letter, 1905)

The Montana Wildlife Federation’s 7000 plus members appreciate the opportunity to offer comment on the development of a management plan which recognizes and maximizes the ecosystem integrity of the Upper Missouri River Breaks National Monument. All efforts must be pursued to preserve and enhance this irreplaceable legacy of the historic American West for present and future generations. I remain

Respectfully yours,

John R. Gibson, President