October 28, 2018
Chuck Barone, Project Leader
Montana Department Natural Resources and Conservation
2273 Boot Hill Court Ste. 110
Bozeman, MT 59715
Attn: Timber Sale
Dear Chuck Barone:
The Montana Department of Natural Resources and Conservation (DNRC) has recently released their Limestone West Timber Sale Draft Environmental Impact Statement (DEIS). The Montana Department of Natural Resources and Conservation (DNRC), Bozeman Unit began working on developing this proposed Limestone West Timber Sale Project in March 2016. The agency has already held a series of public participation events, considering public comments, and conducted extensive field work and analysis. As a result, DNRC has developed three Action Alternatives and a No Action Alternative all of which are designed to meet the proposed project objectives and address issues and concerns raised by the public. Most of comments below will pertain to Alternative A and B as these alternatives will have the greatest and immediate impact upon the landscape.
The Gallatin Wildlife Association (GWA) is submitting comments to address this DEIS. GWA is a non-profit volunteer wildlife conservation organization representing hunters, anglers and other wildlife advocates in Southwest Montana and elsewhere. Our mission is to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy. We support the Montana constitution which states: “the opportunity to harvest wild game is a heritage that shall forever be preserved” and that “the legislature shall provide adequate remedies to prevent unreasonable depletion of natural resources.”
The Enabling Act of 1889:
GWA is commenting with the understanding and knowledge that the goal of the Montana DNRC Forested State Trust Lands Habitat Conservation Plan is to produce the largest measure of reasonable and legitimate return over the long run on lands held by the State of Montana for the purpose of supporting public education as detailed in the Enabling Act of February 22, 1889. These institutions are also declared the beneficiary as pertained in the 1972 Montana Constitution, Article X, Section 11; Montana Code Annotated [MCA] 77-1-202. The Board of Land Commissioners (Land Board) and DNRC are required by law to administer these trust lands.
According to what is stated on page one of the DEIS, “Management of the lands in the project area is guided by DNRC’s State Forest Land Management Plan (SFLMP), Forest Management Rules (Administrative Rules of Montana [ARM] 36.11.401 through 470), and the Montana DNRC Forested State Trust Lands Habitat Conservation Plan (HCP). The SFLMP has the following philosophy:”
Before we move into the merits of the DEIS or lack thereof, GWA would like to question the full applicability of a law which is 130 years old; a law which was formulated in the 19th century being applied today in the 21st century. It is obvious that the Enabling Act of 1889 is still active and has not been superseded, but the state legislature and Congress really do need to review the necessity and continuance of its existence. According to what we know, this legislation was originally designed to help Montana and the State of Washington to become states, a law which allowed the Dakota Territory to split into both North and South Dakota. The states were obligated to pay off debts while the federal government would provide education to its citizens. These forested public lands were set aside in a trust fund to aid in that funding and reimbursement of public-schools. This need to pay for education by setting aside state lands is no longer relevant and necessary today. The state of Montana has a large enough tax base in the 21st century to cover those costs without setting aside public lands to generate revenue. These lands have more value today by serving the public in other ways rather than fulfilling an obligation designed 130 years ago.
On page 11 of the DEIS, there is this statement.
We understand the requirement, but we dispute the need to maintain an antiquated policy.
In learning of the project, one of the first concerns of GWA was: to what end? We understand the willingness and mandate under the Enabling Act and the Constitution, but what were going to be the ramifications to the resources on the ground? How was this going to affect the forest ecology and the wildlife? Whenever man exploits a resource, there is a cost to be paid. In searching through the DEIS, nowhere could we find any analysis on the cost-benefit ratio. There was a sub-chapter entitled Economic Analysis on page 229 where an economic analysis was conducted, but nowhere did we find a value placed on wildlife lost, or habitat lost, or the environmental degradation which would likely occur. Which is why we ask; what is the value of our natural heritage? Many would say priceless. How do you (we) establish a dollar value on such intangibles? In spite of the difficulty, they do need to be valued, not ignored.
Eight out of the 279 pages (the main body of the DEIS) were devoted to analyzing the economic benefits of this project. It has been stated on page 234 of the DEIS that the revenue gained from Alternative A and Alternative B were estimated to be $189,600 and $130,478 respectively. We should say revenues gained is the net profit to the trust fund, the whole reason for this project. We recognize there would be more economic benefits than just those to the trust fund. The DEIS makes this statement on page 235.
But these economic benefits are temporary. In addition to that end, DNRC touts the economic benefits in the private sector from the logging scenario but should that even be considered if the sole goal is to generate income for the state? Outside of trust revenues, there is also expected to be an increase in state revenues. Those are estimated to be $462,438 or $318,240 for Alternative A and B respectively. It is obvious that these are minimal increases in state funding compared to the many actions which are available to state agencies and legislatures in order to increase state revenues. Greater savings could be accomplished by legislative action if politics wouldn’t get in the way. The same could be said for local job creation or for generation of local income. Decades of wildlife disruption, habitat loss and environmental degradation far outweighs a couple years of increased minimal job growth or income generation. We can also state without equivocation; wildlife habitat destruction and wildlife displacement would far exceed the minimal net revenue gained to the trust fund.
But this DEIS takes the economic benefits of this project a step further. It tries to justify the proposed project by touting improvements to forest health and productivity. There is this statement on page 234.
GWA challenges that statement. Where is the science on which this premise is based? That discussion is below.
But before we move on to the cost of this project and its impacts, GWA would like to raise an issue concerning DNRC’s ability or lack thereof to collect funds from those utilizing state lands. Since we are talking about benefits to the state, DNRC has the ability to raise revenues for the same if it saw fit. There is an access point in the project area that leads to the east side of Mt. Ellis. It is our understanding that all non-hunting recreational users of state land are supposed to have a state lands permit costing $10. Is this being enforced? This is a potential source of income for DNRC and for the trust fund if the funds were so directed. It is our understanding that Montana Fish Wildlife and Parks (MFWP) is the primary enforcement agency for permit compliance but they rarely target this problem. Is this the case? DNRC should be enforcing this permit system on the public who use DNRC’s lands. How many dollars across the state have been lost due to the ineffectiveness of state agencies to collect funds from the utilizing public? DNRC should have provided an estimated amount of those lost dollars in this discussion.
But this does bring up an interesting point. There are other ways to raise funds from state lands other than from exploitation or extraction. We suggest that DNRC look into these other sources of raising income.
Our Forests: The DEIS seems so determined to justify the commercial benefit to be gained, that it minimalizes the environmental cost. An example of this can be seen concerning the lack of discussion on forest health resulting from clearcutting. Appendix A on page 314 states that clearcutting was eliminated from further discussion because of what they determine to be limited use. We do not agree with this rationale that adverse impacts from clearcutting should be minimized just because of acreage size. Who determines what is limited use? Under Alternative A, nearly 14% of project area would be clear cut. The DEIS does not provide adequate discussion of the adverse impacts from clearcutting. Clearcutting affects the microclimate within a forest, drying out soil and organisms, changing the biome. This is the determining factor in what kind of ecosystem we have. Not to do a full analysis of this treatment is unprofessional and biases the DEIS.
The DEIS states on pages 79 and 80 that regeneration as proposed in Alternative A and B of Douglas-fir stands may be hampered by the growth of shade-tolerant species. In order to circumvent this action, it is stated that both alternatives may include additional planting of Douglas-fir and even brush control in order to obtain sufficient levels of Douglas-fir stocking levels. This tells GWA that these areas are not suitable to provide sustainability. What this would mean are additional intrusions upon the landscape to provide an otherwise unobtainable goal. All would mean more dollars spent, more footprints upon the landscape, more opportunity to transplant noxious weeds and invasive grasses.
GWA believes that regeneration most likely will far exceed the 30 years stated. This is highly optimistic especially in a warmer, drier biome with climate change and removal of canopy cover which is forecasted to occur.
But there are other rationale needing to be considered when analyzing the best way to make forests healthy. There is science which needs to be explored; other arguments which need to be heard. I would like to refer the DNRC to the link below.
We don’t see evidence within this DEIS stating the science and the danger of removing fire-resistant older trees. What is the danger or likelihood of fuel-reduction treatments increasing the probability of invasive weeds and non-native fire prone grasses? Where is the proof that fires avoid forests because of thinning? This last point brings us to the scientific reference listed below. We strongly urge the DNRC to read and address the issues as stated in The Open Forest Science Journal, 2008.
We would like to refer DNRC to quotes from both references as they corroborate each other. This first quote is from The Open Forest Science Journal introduction (pg. 1):
This additional quote from StopThinningForests.org/fire-prevention.html may state it more succinctly.
In this quote you can either replace Forest Service with DNRC or just add DNRC to the existing statement and it would be relevant. As stated in quote 1, fuels rebound and if fire does not reach treated areas on the landscape, then cost for prevention is not returned in benefit.
But one of the more important scientific questions which the DEIS did not address was the loss of genetic variability due to the practice of forest thinning. What are the costs of losing this genetic makeup of trees; trees that are more likely to be resistant to drought, fire or pestilence. Where is the science on this within the DEIS? GWA would like to refer DNRC to the following science journal; https://phys.org/news/2017-01-forest-thinning-sabotage-natural-climate.html.
Within that link, there is an article entitled Proposed forest thinning will sabotage natural forest climate adaptation, resistance to drought, fire, insect outbreaks by Derek E. Lee, Phd. Dated January 16, 2017 in Wild Nature Institute, there is this statement.
What are we doing to our natural forests? Do we really understand the method to our madness? What is the cost of our sacrificing the natural health of our forest for man’s interpretation of what that healthy forest should be?
Other Concerns: This leads us to the second quote from the introduction of The Open Forest Science Journal.
Note the mention of ecological cost and negative impacts on aquatic systems, etc. Even the DEIS verifies and acknowledges these impacts, but the report minimalizes them to the point of being of “no concern”. This is an example of what we meant when we say the DEIS is biased.
Introduction of Noxious Weeds:
It is unmistakable; an increased footprint of man upon the forest floor will lead to an intrusion of noxious weeds and non-native grasses. On page 95 of the DEIS there is this statement.
Two actions will happen as a result of this proposed project. There will be an opportunity of non-native grasses and noxious weeds to enter the landscape during and as a result of timber extraction, and they will have another opportunity to enter the landscape as the land is opened up for grazing and recreation. GWA would like to refer the DNRC to a U.S. Forest Service EIS on Noxious and Invasive Weed Treatment Project on the Gallatin National Forest of 2005. Even though this EIS is referencing lands on the Custer Gallatin National Forest, application to DNRC lands which border Forest Service lands can be made. On Chapter 1, under “Ecological Impacts Of Invasive Plants”, page 1-4; it states.
Further on, on page 1, there is this statement under “Soil”.
GWA would also like to refer DNRC to another document by the U.S. Forest Service, the FINAL Supplemental Final Environmental Impact Statement Bozeman Municipal Watershed Project of 2011. On page 179, it states the issue of weeds this way.
It is interesting the U.S. Forest Service includes the phrase “may cause” as they describe the relationship between aggressive actions of forest harvesting and the establishment of noxious weed populations. But we firmly believe the issue is stated so for a reason, and that reason is because they do. To those who believe that the spread of noxious weeds is not a serious issue, we urge those to read further on page 179.
Noxious weeds cause a number of potentially significant problems. According to Sheley et. al. 2005 noxious weeds:
displace native plants,
affect threatened and endangered species,
alter normal ecological processes (e.g., nutrient cycling, water cycling)
decrease wildlife habitat,
reduce recreational value,
increase soil erosion and stream sedimentation
cause major economic losses.”
If all of this is true, which we believe it is, then we ask the question. Why do government agencies insist in actions that magnify the problem, actions that aggravate the negative rather than solve the problem? Mitigation is not a solution, but it seems to be the answer that is used to enable and justify proposed actions. If this is true, then the Forest Service and all other government agencies who practice resource management needs to rethink their actions, budgets and proposed actions.
Geology and Soils, Road Building and Sedimentation and Erosion:
These three topics laid out in the DEIS, road building, sedimentation and erosion, and geology and soils are topics which are all inter-related. Water-quality issues resulting from land and soil disturbance should be included in this relationship as well. Natural resources of soils, water and vegetation are all impacted by the ability of these resources to repair and heal themselves. And much of that depends upon the severity of the damage, slope conditions, climate and the nutrients and the biota of the soil itself. These issues and concerns are not new to projects which have been proposed along the Gallatin Front south of Bozeman. The DEIS makes the following declarations.
On New Road Building,
On Sedimentation and Erosion,
And for Geology and Soils, there is this.
These are documented givens within the DEIS. We are especially concerned that effects from skid trails are forecasted to remain for at least 10-30 years. We are concerned because we believe the DEIS is minimalizing the degree and length of negative impacts over time. Evidence of soil and land disturbance, visual and biological, will most likely remain on the landscape longer than expected. The DEIS references the SINMAP model forecasting impacts to soil productivity as low to moderate. We know that models are only a tool to be used in analysis. They are only good as the data inputted into them.
After having said that, GWA would like to refer DNRC to their own report, Bear Canyon Management Plan and Draft Environmental Impact Statement of 1980 (BCMP). This report was written as a result of increased demand for recreation, grazing and forest products within the DNRC, Bear Canyon Planning unit. This is an area by the way, which incorporates much of the current Limestone West Project area. Even though the DEIS of the BCMP is nearly 40 years old, the geology remains the same.
In connection with that report, on page 12 there are these bullet points.
How can these concerns, these geologic and hydrologic likelihood of events be ignored? When you look at these geologic characteristics of the area and then look at the map on page 109 in Appendix II of the current DEIS, Map LW-2 Limestone West Project Slope Stability Index pictures much of the area with moderate to quasi stable slopes at best. We feel the DEIS falsely depicts the reality on the ground; thereby minimizing the danger of slope stability of the area. The organization Save Our Gallatin Front states that the Limestone West area is unsuitable for logging due to its steep slopes and unstable soils. We concur.
Aesthetics and Climate Change:
There are many reasons to oppose the timber sale of Limestone West. We’ve already listed some of them here. We anxiously want to get to the discussion of wildlife, our primary concern, but just a sentence or two on aesthetics and the unknowns of climate change. As a wildlife advocacy organization, the negative impact on the aesthetics may not be our foremost concern, but as a citizen-based organization in the Bozeman community, we do care how are community appears to those of us who live here and to those visiting from the outside world. And to that end on page 66 of the DEIS, it states the following.
This would be a blight on the landscape of Bozeman and would be so for a considerable time despite some views to the contrary. This proves a point as to why people should have a stake and a say in how public lands are used. The use of public lands is not just for those who have a vested interest in making profit. State and federal lands belong to all the people and the people should have a voice in their health, appearance and purpose. But the people should also be educated in all facets of their history and their purpose. They should be educated in the ecological processes at work and accept those processes even though they may not see a benefit at the time. It is up to organizations, state and federal entities to educate the public to the overriding benefit of our forests instead of feeding the politicization of them.
Climate change is addressed in the DEIS, but not perhaps to the detail necessary or required. Climate change is going to have an impact upon our natural resources and our heritage. The question is then, not if or when, but how severe? We know that climate change will not only affect our weather, but it will affect our hydrology, our forests and flora. It will affect our wildlife and their migration patterns, species existence, agriculture and our economics. There may be a lot we don’t know, but there is also a lot in what we do know. On page 126-127, there are these statements.
What we should know is forests mitigate climate change. They do so by taking in CO2 gases. According to the Climate Institute, “it is estimated that 25% of the world’s total greenhouse gas production comes from deforestation alone.” So why are we cutting down more trees? Man is enabling the climate to get warmer and drier by applying varying degrees of deforestation. That in turn enhances climate change which allows forests to become warmer and drier. That in turn, enhances pestilence to occur providing us an excuse to cut more trees. We are the problem and we are enabling a vicious cycle to occur.
Phil Whitmer along with the science team at Sciencing.com wrote an article entitled Negative Effects of Clear-Cutting dated April 25, 2017. Under the paragraph entitled Forest Biome, they go on to state this scientific fact.
Climate change only aggravates this scenario by making it harder to restore balance back to a clear-cut or thinned area of a forest. The forests floor will become open allowing for a warmer, drier microclimate destroying the delicate balance was present. And then there is this statement in the DEIS found on page 127, a disappointing statement to say the least, on climate change.
We see public land management agencies being the front lines in applying the most recent science to the ecosystems charged to them. It is their responsibility to understand and to apply this science. Managing biodiversity under the SFLMP is the problem. Time and time again we see various land management agencies succumb to political pressures and the whims of special interests’ groups knowing that the proposed actions would be harmful to the resource, but we do them anyway. Why? In this case we propose them because of an antiquated law that will net the trust fund just under $190,000 (alternative A)? We should manage the biodiversity with the science as we understand it, not to go blindly forth following bad policy just because it is policy. Agencies need to be more progressive in interpreting good policy on public lands and help change the laws in order to utilize the science. Take the politics out of it. We know this may be too idealistic, but that is what needs to be accomplished.
We’ve said all of this to show the costs of this project far outweigh the benefits. There is a cost to be had, but the DEIS does not emphasize the cost upon those values lost. In other words, the DEIS seems so hard to justify the commercial benefit to be gained, that it minimalizes the environmental cost. And that environmental cost is no more prevalent than as it pertains to wildlife, our primary concern.
The Cost to Our Wildlife:
Nowhere within the DEIS is our concern greater than what this project will inflict on wildlife. And we have these concerns for good reason. It will be the wildlife which will likely suffer the greatest loss along the Gallatin Front, perhaps even more so than the loss to the forest integrity itself. GWA recognizes when man interferes or manipulates the forest biome, it will benefit some wildlife species and harm others. That is a given. But the question becomes, does that benefit or harm upset the ecological balance? It is that point which is not discussed within the DEIS. The DEIS spent 106 pages analyzing the effect this project would have on wildlife. But there is more to forest integrity than how we affect it. A greater question would be how does our actions (for example: this project) effect the relationship of species with each other or to those intricate parts of the forest biome? Do we completely understand the intricacies we are dealing with?
We find it interesting that the greatest majority of the DEIS is spent discussing the analysis of wildlife. Perhaps this is because the importance the Bozeman community places on wildlife; or perhaps it is because of the acknowledgement of the obvious. Both are true. And with that, we begin.
The DEIS correctly states our concern over the integrity of wildlife corridors. GWA views this project as adding to the fragmentation of the Gallatin Bridger Big Belt Corridor, an action which would make this connectivity corridor less effective. These “nickel and dime” projects, although small scale in nature, tend to have significant adverse impacts on overall connectivity. But because of their size, many of the harmful effects are down played or ignored. Comments in the DEIS on page 127 acknowledge this impact.
The DEIS admits that this project area is home to elk, mule deer, white-tailed deer, black bears and grizzly bears, moose and other species. These are fairly significant species proving that this is a critical habitat area for wildlife. Another passage out of the DEIS is found on page 131. This paragraph fairly and accurately describes the current conditions along the Gallatin Bridger Big Belt Wildlife Corridor near Bozeman. But what the paragraph seems to be saying is concerning. The DEIS seems to be implying that since these conditions are not ideal for a corridor, somewhat limited (is the term used), one more fragmentation will do no harm. Since this disruption will be temporary, wildlife will adjust and return back to their old migratory routes and behavior. Is this proper science in use? Is this proper resource management? Please rethink what you are saying as you read this again.
Security- It is widely known that various species inhabit and utilize this specific wildlife corridor. GWA would like to refer DNRC to a letter which they should have received in April of 2016 from Region 3 of the Montana Fish, Wildlife and Parks (MFWP). In that letter they state the following.
Further on, they state.
One of several main functions of wildlife corridors is providing security. Without that security, wildlife will feel threatened introducing fragmentation and inefficiency to wildlife habitat and to the connectivity corridor potential. We find it interesting that hunters complain about the lack of hunting potential, saying that elk have been displaced. But here we have a project (as well as other past projects) which will displace elk and we are supposed to accept this rationale because it provides a few dollars in the pockets of special interest.
Road Density – One of the greatest actions that this project will have on wildlife is that of roads, road construction, road positioning and road densities. The location of roads is one of the greatest impediments to wildlife connectivity, and one of the more irreconcilable actions that can have detrimental effects to wildlife habitat. On page 155 of the DEIS, under the heading of the Affected Environment, there is this statement.
Even the DEIS seems to recognize the impact that roads can have on wildlife. But the troubling facet of this is the extent that the DEIS seems to go to downplay the effects of this proposed action, whether it be Alternative A or B. One more reference to the above letter from MFWP of 2016, further on in that same letter, it states the following.
This reference to road densities, verifies what is already known that roads and wildlife don’t mix. GWA would like to refer DNRC to a U.S. Forest Service Report, Forest Roads: A Synthesis of Scientific Information, a General Technical Report, PNW-GTR-509 of May 2001. On page 22 under Habitat Fragmentation, it states this.
Habitat fragmentation is a major culprit in lack of security for wildlife. Road densities are part of that fragmentation. Obviously the greater the density, the more fragmentation and the more inefficient the habitat becomes. The more inefficient the connectivity corridor becomes. The subject of road densities is explained in the DEIS, but in confusing fashion. We understand that this is a moving number depending upon what location is being referred to and to what timeframe of the project is being discussed. We’ve seen numbers based upon different scenarios ranging from only a .1 increase in change as a result of project operation to a density of 4.2 miles of roads/sq mile (table T-4, page 249). Let us refer you again to the MFWP letter stated above.
But in either regard, the road density is going to have impact, potentially a significant impact depending upon the knowledge that state and federal agencies know. We do know a lot; the problem is that we choose not to utilize the knowledge that we do have. We go through with projects knowing that they are risky and that they aggravate already existing problems.
Effects of Winter Recreation on Wildlife:
GWA would like to go back and refer to the April 2016 letter from Region 3 of MFWP. In that letter, there was this quote in reference to road densities.
This leads into a discussion concerning an issue which was sparsely covered in the DEIS, the effects of winter recreation on wildlife. Those two words “winter recreation” were mentioned 5 times, but 4 of those 5 in the DEIS were repetitional with no new additional thought. And it was only done in a way that raises more questions than answers. On page 216 under Direct and Indirect Effects of Action Alternative A, there is this statement listed as line item 6.
The DEIS provides next to little information about the increase in winter recreational use by the public although it states that is expected to rise. This is a use by the public that could cause additional stress on elk and other wintering ungulates. MFWP addresses this concern, but it seems it was not a concern that DNRC took seriously. It should have been discussed in greater detail in the DEIS. Would it have been possible for DNRC to provide solid data about the number of users?
Before we move on, GWA would like the DNRC to review the work done by Greater Yellowstone Winter Wildlife Working Group, a coordinated effort between the U.S. Forest Service and the National Park Service. In their report dated October of 1999, they published a paper entitled “Effects of Winter Recreation on Wildlife of the Greater Yellowstone Area: A Literature Review and Assessment”. There is too much information to go into detail here, but we would recommend that DNRC read, listen and adhere to the many recommendations made by this team of wildlife experts. This document could be used as a management tool, where applicable, on DNRC lands baring any new research stating the best available science. For an example, we will show excerpts here as they pertain to the recommended management guidelines for elk, as found on page 26 in the document.
These are just three of the recommendations on how to best manage elk during winter. The reason? All of that and more can be found in the document. An excerpt found on page 23 of the document states part of that reason.
Let’s ask the question first. Can habitat fragmentation and biodiversity exist on the same landscape? The next question would be, if so, would it be a natural occurrence or one that has been manipulated or altered by man? And if that be the case, would that be a true biodiverse landscape? Perhaps that is the real question. That question is not answered in this DEIS. Biodiversity is mentioned 27 times in the DEIS, but only in terms of it being a goal within the project objectives. But the DEIS never does state what that objective would look like. What does biodiversity look like here? How will that be achieved and when? You can’t achieve biodiversity when you are changing wildlife behavior; or when you are pushing certain species out of an area only to favor others. That is what is happening here in the Limestone West Project Area. The next several quotes are from the DEIS, quotes which prove that point.
On page 130 and 134 respectively, there are these statements.
On page 156 and 157 respectively, there are these statements.
GWA does not believe this is what biodiversity looks like. This shows the effects of habitat fragmentation not biodiversity. The proposed alternatives of A and B are the opposite effect of a biodiverse landscape. Just because we state that a biodiverse landscape is a goal, doesn’t mean the actions will achieve objective. If we use the most prominent scientific definition, it is the following.
How do the expected results meet the definition of biodiversity? Biodiversity is perhaps the most overused word in today’s lexicon concerning resource management. It is a word bandied about to show concern for environmental integrity, but in many cases as in the Limestone West Project, actions speak louder than words. Along this regard, there is this statement on page 131.
GWA challenges the acceptance of this assumption. It is true that some species such as deer may find advantages in this broken landscape, but for all species we strongly feel this would not be the case. On page 174 under the heading of Direct and Indirect Effects of Action Alternative A, there is this statement which counters the previous assumption for bears.
Endangered and Threatened Species:
Since the writing of these comments, the grizzly bear was replaced back on the Endangered Species List as of late September, 2018. We find this good news for the future of the bear and hopefully for other species where special interests try to delist parts of an overall population. But having said that, it is obvious now that this project very well could have effects on the overall populations of grizzly bears, especially those bears who may tend to travel or roam within the Gallatin Bridger Big Belt Wildlife Corridor and/or those bears along the southern face of the Gallatin Range. We would once again like to refer to the letter from MFWP dated April 2016.
We are repeating this to prove the point that this area is rich in wildlife and it is rich in species of concern (SOC), endangered and threatened species, all of which is important to show how biodiverse this section of the forest already is. Several species mentioned here in the MFWP’s letter are either listed or should be listed under the Endangered Species Act (ESA). The richness of the area’s wildlife is verified by Steve Gehman of Wild Things Unlimited from his update of Wildlife Surveys in the Limestone West Area of March 7, 2017. On that list of surveys, he reported the following tracks, visual sightings and wildlife captured on film via wildlife cameras.
Moose, elk, deer, pine martens, red fox, mountain lion and bobcat, and weasels.
Canadian Lynx – The DEIS accurately states our many concerns over habitat removal and fragmentation of habitat of the Canadian Lynx. On page 164, it states the following.
On page 166 under Direct and Indirect Effects of Action Alternative A
The DEIS goes on to state slightly less disturbance facts in Alternative B. But the DEIS admits that they are removing slightly over 20% of lynx habitat from the project area if Alternative A is chosen. Is this a price too high to pay? We have to remember that we are talking about our natural heritage. Can we safely assume that the lynx or any other species will come back over time when we as a society are constantly making further and further inroads into their habitat? Over time that line is pushed further and further back to where what is now habitat to that being permanently lost.
Wolverine - The DEIS is correct when it said the wolverine is proposed for federal listing under the Endangered Species Act. Without analyzing each species listed or those proposed to be listed under the ESA, GWA would like to discuss the wolverine. The DEIS reported results from Steve Gehman’s Wild Things Unlimited of observed wolverine tracks in the project area from 2017 and those found in the Hyalite Reservoir area from 2010. The DEIS also refers to a 33,422-acre cumulative effects analysis area. The purpose of utilizing this unit was to find zones of persistent snowpack above 7,200 ft in elevation, the elevation where it is believed the snowpack can provide potential denning habitat for female wolverines. The DEIS states on page 182 the following.
Further on in the paragraph, the DEIS states this.
Even though it is true the acreage of potential denning habitat within the project area is small, what we should not forget is that last sentence. Eighty per-cent of the wolverines denning habitat in the cumulative effect’s analysis area is greater than one mile from the project area. If we understand anything about wolverines, we know that this species is very mobile and can travel great distances in short periods of time. One mile is no distance at all for a wolverine. The same could be said of 5-10 miles. The fact that these species have potential habitat, denning habitat at that, near, extremely near and in the project area; this should be reason enough to suspend or cancel this project. Even though the DEIS acknowledges the situation on the ground, once again it seems the DEIS seems to downplay the seriousness of the potential result, another piece of habitat lost.
The same arguments could be made for other species located in the project area, species which are listed under the Endangered Species Act. This is at the heart of the argument for establishing wildlife corridors and maintaining biodiversity. This area is rich in wildlife. The area is rich in its biodiversity and has great significance to maintain a wildlife corridor. Should we put asunder what nature has communally brought together?
The Project’s Wildlife Legacy:
The DEIS has tried to lay claim to the Montana citizen that this is a temporary project. Two to three years tops, and it is over and done, except for some continued mitigation and monitoring. And we can’t forget about the recreational aspect of this, as new roads and openings into the forests will bring more people through the years. But we at GWA believe that the impact will be more long-lasting than this. Some of the excerpts from the DEIS even admit to this fact. These statements found within the DEIS admit to the projects negative impact on the area’s wildlife legacy.
And finally, the clincher statements which are found on Page 157, under the heading Direct and Indirect Effects of Action Alternative A.
This will be the project’s legacy. We believe that these affects will be long-lasting. And deep in the text of the DEIS, it states this as well. These proposed actions of Alternative A and B will be with us for decades. But we won’t feel the effects of such action nearly as much as the wildlife.
We began this discussion with the context this project has a cost and has a benefit. We wanted to know what would be the value gained or lost to the community if this project were to move forward. But more specifically, we want to know what would be the ecological harm, if any to our backyard. The DEIS seems to read that this project is a “cure all” for all of this forest’s ills. Not only would DNRC manage vegetative treatments in order to “restore health” to DNRC forests, but they could harvest the timber on these lands in order to meet the demand placed upon them by an antiquated law. A law written to divert funds to a trust fund of the State of Montana. “DNRC kills two birds with one stone” – pardon the pun. We disagree with this premise as written in the DEIS. There is a value to be had as the ecology exists right now. It is hard to place a dollar amount on something that is priceless, but also on something that people take for granted. Right before our own eyes, we are sacrificing a greater value for one of minimal, temporary, monetary gain. This is GWA’s position. When we look at the long-term damage to be done to the flora and fauna of our forest, who pays a price for that? It is the natural world itself. Who speaks for them? The DEIS does not seem to place a value on these resources; it only sees the monetary resource from a timber harvest. There is so much more before our eyes; once again are we taking this resource for granted?
The DEIS presented 4 alternatives. Alternative A and B are nearly the same with Alternative B being a slightly less aggressive form of Alternative A. Comments made in this format are directed to both Alternatives. We do not support Alternatives A and B in any way as they both are considered intrusive on the landscape causing long-term ecological damage to the local biome. The revenues gained from Alternative A and Alternative B were estimated to be $189,600 and $130,478 respectively. GWA believes the ecological damage done by either alternative far outweighs the economic benefit. There is a “No Action” Alternative, one mandated by the National Environmental Policy Act of 1969 (enacted Jan. 1, 1970). Although this alternative may seem acceptable to some, we’re afraid the choice of the No Action Alternative will not decide the matter. What is to prevent this action from being proposed again. As long as there is a mandate in state law, we see very little to be gained from supporting this alternative.
GWA prefers Alternative C, although even this choice has a drawback. For a description of Alternative C, it is quoted here from page 16 from the DEIS.
Alternative C provides a conservation license in lieu of a timber sale. Conservation license applicants can bid against the timber sale purchasers. That would provide funds for the school trust fund. This would be an acceptable and no-nonsense way to achieve the goals desired yet protect our heritage from unwanted exploitation at the same time. Our fault with this alternative is the term of 10 years used for the purpose of deferral of forest management. Why 10 years? Conservation is much more long term than 10 years. The actual length of the term can be debated at another time and we look forward to that debate. In the meantime, that would mean our forest could breath for another day.
There is a phrase which has caught on in our society, that being “It is time to search for our better angels.” We know the science is out there. We need to be judicious and recognize the science that has been manipulated by special interest groups to support their ulterior motives from the science that serves and protects the planet. Our better angels will hopefully help us choose the science which makes us be the better stewards we are called to be.
We want to thank DNRC for the opportunity to comment on the Limestone West Timber Sale Draft Environmental Impact Statement. We hope DNRC will give serious consideration to our thoughts and thought process. We urge DNRC to look into these sources for advice and consult.
Clinton Nagel, Board Member
Gallatin Wildlife Association
Stop Thinning Forests. Fire Prevention?, http://stopthinningforests.org/fire-prevention.html
Rhodes, J. Jonathan; Baker, L. William. 2008, Fire Probability, Fuel Treatment Effectiveness and Ecological Tradeoffs in Western U.S. Public Forests. The Open Forest Science Journal. http://www.energyjustice.net/files/biomass/library/Rhodes-Baker.pdf
Lee, E. Derek, Phd. Wild Nature Institute, January 16, 2017, Proposed forest thinning will sabotage natural forest climate adaptation, resistance to drought, fire, insect outbreaks,
Noxious and Invasive Weed Treatment Project, Gallatin National Forest, June 2005. Final Environmental Impact Statement. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3823802.pdf
Bozeman Municipal Watershed Project, November 2011. U.S. Forest Service. FINAL Supplemental Final Environmental Impact Statement. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5301349.pdf
Bear Canyon Management Plan and Draft Environmental Impact Statement. October 1980. Department of Natural Resources and Conservation. https://leg.mt.gov/content/Publications/MEPA/1980/dnrc1208_1980001.pdf
Whitmer, Phil. April 25, 2017. Negative Effects of Clear-Cutting. https://sciencing.com/negative-effects-clearcutting-8194063.html
Greater Yellowstone Winter Wildlife Working Group. October of 1999. Effects of Winter Recreation on Wildlife of the Greater Yellowstone Area: A Literature Review and Assessment. http://www.snowmobileinfo.org/snowmobile-access-docs/Effects-of-Winter-Recreation-on-Mountain-Goats_1999.pdf
Sheppard, B. Sam. April 22, 2016. Letter from Region 3 of the Montana Fish, Wildlife and Parks
U.S. Forest Service Report PNW-GTR-509. May 2001. Forest Roads: A Synthesis of Scientific Information, a General Technical Report.
Gehman, Steve. Wild Things Unlimited. March 7, 2017. Wildlife Surveys in the Limestone West Area