NATIONAL WILDLIFE FEDERATION®
People and Nature: Our Future Is in the Balance

Northern Rockies Project Office
240 North Higgins, # 2 - Missoula, MT 59802
406-721-6705 - 406-721-6714 [fax] - www.nwf.org

August 21, 2002

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

Dear Mr. Slagel:

The National Wildlife Federation is pleased to submit the following scoping comments related to the management plan for the Upper Missouri River Breaks National Monument.

The National Wildlife Federation (NWF) is the nation’s largest member-supported conservation group, uniting individuals, organizations, businesses, and government to protect wildlife, wild places, and the environment upon which we all depend. Through our grass-roots members, affiliates, and field offices nationwide, we educate, assist, and inspire people from all walks of life to conserve wildlife and other natural resources. Our common sense approach to environmental protection balances the demands of a healthy economy with the need for a healthy environment, ensuring a brighter future for people and wildlife everywhere.

We commend the BLM for launching this very important planning process for one of the newest units of the National Landscape Conservation System (NLCS). The Upper Missouri River Breaks National Monument was designated to, first and foremost, protect and conserve the vast array of historic, biological, geological, paleontological, archeological, and scenic values for future generations to enjoy.

As you begin the planning process for this National Monument, we would like to highlight BLM’s vision for the NLCS units as “Great American Landscapes - healthy, wild and open.” The National Wildlife Federation firmly supports the mission of the NLCS, which is to “conserve, protect, and restore these nationally significant landscapes that have outstanding cultural, ecological, and scientific values for the benefit of current and future generations.” To this end we support this planning initiative and urge BLM to implement the vision and mission of the NLCS during the planning process.

“The hills and river Clifts which we passed today exhibit a most romantic appearance…As we passed on it seemed as if those seens of visionary inchantment would never have and [an] end; for here it is too that nature presents to the view of the traveler vast ranges of walls of tolerable workmanship, so perfect indeed are those walls that I should have thought that nature had attempted here to rival the human art of masonry…” -William Clark’s journal description of the magnificent White Cliffs area on the western side of the Upper Missouri River Breaks National Monument that he and Meriwether Lewis first encountered on their westward journey nearly 200 years ago.

Please incorporate the following comments into the public record, and address each concern in detail as part of your National Environmental Policy Act (NEPA) process:

Desired Outcome and Overall Vision:

• Fully implement the vision and mission of the NLCS and proclamation language in a management plan that protects and conserves the abundant cultural and natural resource values in the Monument.
• Preserve the primitive quality of the area to the greatest extent possible, consistent with the protection of the resources.

Wildlife and Habitat:

• Achieve and maintain natural populations, population dynamics, and population distributions of wildlife.
• Promote and adopt management actions necessary to protect the further conservation and restoration of the full suite of native wildlife including endangered species, at-risk species, and species experiencing sharp declines. As part of this analysis, BLM must consider the impacts that decades of intensive livestock grazing, road development, and off road motor vehicle (ORV) use have had on wildlife and wildlife habitat.
• Reintroduce extirpated native species to the area.
• Conduct studies on habitat manipulation on a case-by-case basis, whether for wildlife, weed control, sage grouse recovery, or fire rehabilitation. Any BLM proposed restoration activity within the Monument should be in compliance with NEPA.
• Conserve and restore Sage Grouse habitat within the Monument.
• Identify key wildlife areas such as leks, nesting, brood rearing, calving grounds, and winter ranges. Preserve their integrity by limiting developments within the Monument.
• Develop a monitoring plan to monitor the status of wildlife populations and to detect impacts to wildlife populations from various uses.
• Develop an inventory of all flora and fauna, including endangered, threatened, and sensitive species, to be made available to the public.
• Encourage the planning team to assess and evaluate the possibility of bison restoration in the Monument. However, it is critical that any bison restoration initiatives include professional wildlife management and hunting as a part of the management plan. In addition, it is imperative for the planning team to consult with the appropriate Native American Tribes to facilitate their involvement with bison restoration. A possibility exists to allow bison to range across landscapes that include both federal and tribal lands. Such opportunities for co-management of a restored bison herd should be fully explored. Grazing of privately owned bison in the Upper Missouri River Breaks National Monument is no substitute for wild and free ranging bison, managed as wildlife.

Energy Development:

• Specify that the Monument is withdrawn from all new forms of mining, geothermal and oil and gas development.

Private Property Rights:

• Recognize the Monument proclamation’s provision for continuation of existing land ownership and uses.
• Where appropriate, encourage pursuit of conservation easements for private properties to add to protection of surrounding resources.

Roads, Roadless Areas, and Wilderness:

• Preserve the roadless natural characteristics of the Monument by prohibiting the construction of new roads, and prohibit the upgrading of existing roads.
• Close existing roads that are determined to damage land or water resources, conflict with wildlife management, interfere with maintenance of wildlife habitat or which are determined to be inconsistent with the area’s overriding managerial purpose.
• Restrict ORV use from ecologically and culturally sensitive areas, and limit ORV use to suitable designated routes that will result in the least possible impact on the environment or impairment to other legitimate uses of public properties.
• Address additional designations of Wilderness Study Areas in the planning process.
• Review information submitted by the public in determining potential Wilderness Areas in the Monument.

Riparian and Watershed Restoration:

• Develop livestock grazing plans that fully protect and restore wetlands, riparian corridors, and rare ecological plant communities.
• Prohibit placing trails and recreation facilities in riparian areas.
• Develop a strategy to ensure that land management practices (grazing, recreation, etc) protect water resources.
• Develop and implement a plan that fully protects and restores Cottonwoods to wetlands, riparian corridors, and along the Missouri River.

Invasive and Noxious Weed Control:

• Develop regulations and procedures to prevent and reduce the spread and introduction of non-indigenous, invasive plants that have a negative impact on indigenous ecological communities.
• Evaluate livestock grazing as a vector for the spread of weeds.
• Evaluate roads and road construction as channels for the spread of weeds and motorized vehicle travel as the vector.

Cultural, Geological and Palentological Resources:

• Adopt measures to protect the cultural, geological, and paleontological resources from artifact collectors, looters, thieves, and vandals.
• Determine sites or areas that are most vulnerable to current and future impact and adopt management actions necessary to protect and restore these resources.
• Engage the Native American community to determine whether there are sites or specific areas in the Monument of particular concern.

Recreation:

• Provide opportunities for visitor exploration and discovery in an undeveloped, primitive setting.
• Clearly distinguish issues related to wildlife and hunting. Hunting, fishing, and trapping shall be recognized as historic and traditional uses in the Monument and shall be included in current and future management plans.
• Identify specific uses that will be acceptable/allowable; e.g., hiking may be allowed only on designated trails in certain areas of the Monument.
  Prohibit rock climbing where it would harm archeological, palentological, biological or other resources.

Informational Signing and Monitoring:

• Limit signing within the Monument boundaries to provide to the public a uniquely primitive experience where the visitor is informed via printed information outside the Monument.
• Identify suitable location(s) for visitor centers outside the boundaries of the Monument.
• Develop information other than maps, regulations, and safety precautions that are educational and serve to interpret the landscape of the Upper Missouri River Breaks region and help to put the emigrant journey across the land into perspective.
• Institute an on ground presence of BLM personnel, including rangers, specifically on weekends beginning in May and extending through October when the visitation is the greatest.

The Upper Missouri River Breaks National Monument is truly a “crown jewel” that was specifically established to protect and conserve the abundant natural and cultural values for all Americans to enjoy. Thank you in advance for your consideration of our comments and look forward to working with you throughout the planning process.

Sincerely,

Marc Smith
Legislative Representative
National Wildlife Federation

Tom France
Director, Northern Rockies Project Office
National Wildlife Federation

Enclosure: Proclamation of the Upper Missouri River Breaks National Monument