Here is some clarification on some of these things discussed yesterday with the BLM for anyone who would like to further inform any comment they plan on giving. To be clear, I have no negative feelings toward the outfitter nor any of the people involved with the BLM, and in fact my position is they are asked to do too much with too little. First, I will
steelman what I understood to be the BLM’s position based on what they told us.
Utilizing a Categorical Exclusion (CX) for this type of Special Recreation Permit (SRP) is standard operating practice. In fact, they typically would not even put this out for public comment. It is their position that this SRP would have little effect on the landscape, on wildlife, and on the public’s experience, but will benefit the area economically. There is already one other outfitter that is permitted in much of this country.
OK.
Here is some further information.
-This permit has no limit whatsoever on the amount of clients/hunter days this outfitter will be allowed to utilized.
-This outfitter guides for deer and elk in 380, but chiefly, this will likely be used for guiding predator hunts (cat and bear)
-When asked about whether the BLM’s position that extension of SRPs has a threshold where a CX would not be utilized (here we are going from 2 sq miles to nearly 80), the answer was no. They just use CX for these types of permit expansions, and permits in general.
-The assumption is that the BLM’s agency-wide position that “this kind” of permit will not have any negative landscape,wildlife, or social effects. Does that blanket assumption change from bioregion to bioregion? Does it change when it is ungulate vs predator hunting? Does it change when hounds are being utilized to hunt cats and bear in critical wintering ground across tens of thousands of acres of Areas of Critical Environmental Concern in the elk calving factory of the Elkhorns? These are unanswered questions.
-The Black Sage WSA will be taken out of the proposal. CX are not to be used in this type of SRP in Wilderness Study Areas. The
proposal map for this was changed yesterday after the meeting.
-When I asked if the BLM would entertaining extending the comment period, given that there is less than a week left for comments, there is significant public interest, and they have had erroneous information up on their eplanning website for the majority of the open comment period, I was told,”We encourage you to get your comments in by August, 31st.” I’ll take that as a no.
-The BLM did not inquire with other agencies on the current use on the landscape in terms of hunter days, potential conflicts, etc. It pretty much sounded like they hadn’t spoken to FWP bios at all. The USFS representative said she, "just found out about this a couple days ago."
The standard operating practice position of the BLM that this just won’t change much on the landscape is dubious. In fact, I’d say it is patently false. The question is to what degree will the potential negative effects exist, and I think an EA would help with that. There was a really knowledgeable lion-hunter on the meeting who had some really in-depth nuanced reasons why this would harm the cat hunting opportunity for the general public having to do with geography, exclusive access to certain gulches for looking for tracks, etc. I am not knowledgeable enough on the subject to speak on that.There was more, but this is my quick take.
Lastly, I think it more than past time for a “come to Jesus” moment for all of us. Use across the landscape of the west is skyrocketing. It’s out of control with little sign of slowing down. Whether it is FWP, USFS, or the BLM, perhaps the most meaningful question we should be asking ourselves is:
Are those tasked with managing our wildlife and the landscape, positioning their management for the benefit of not just this year or the next,or ten years down the road – but for decades? Things are changing so fast. This is a ten year permit.
My position. The public should push for a full EA. Push back against the idea that this is just SOP and not a big deal. Make them show their work.
