Triple the Outfitter/Guide Client Days on the Beaverhead-Deerlodge National Forest

[Flynarrow]

If you hunt, fish or otherwise recreate on the B-D, you may be interested to learn that the B-D has just released a draft Environmental Assessment offering opportunity to comment on their proposal:

Authorize a triple of outfitter/guide client days from 13,000 client days to over 33,000 client days. Convert temporary outfitter/guides to priority client days. This will be done without telling the public what type of recreation nor where these outfitter/guides will be authorized to operate. No additional public comment will be required.

If you presently have a special elk hunting drainage or fishing lake/stream and do not favor an outfitter being authorized to camp/hunt in this area you may want to weigh in on this proposal.

​

https://www.fs.usda.gov/project/bdnf/?project=56926

The format of the proposal is not easy to digest, but if you persevere you can get through it. Please send this to your B-D hunting/fishing friends. Comment now or weep later.

 

[Nameless Range]

Thanks for sharing. I will be looking into it.

I am at a point and would like our public land agencies to also be at a point, where if a commercial use does not serve the greater public, then it is should be viewed as unnecessary and unwarranted on public lands.

 

[Carnage2011]

There are several hunting outfitters fighting this. A large portion of this proposal is due to an inquiry to start backcountry skiing trips and horseback trips. I have some details on it but I’ll need to try and find it when I get back home.

 

[Flynarrow]

There are several hunting outfitters fighting this. A large portion of this proposal is due to an inquiry to start backcountry skiing trips and horseback trips. I have some details on it but I’ll need to try and find it when I get back home.

Wonder why the EA talks to negligible effects of additional hunting and fishing guiding then? Likely no opportunity for future public comment.....you walk in and want to be a B-D outfitter and walk out with a permit. Doesn't seem to recognize the potential impact on the current resident hunters/fishermen. Just says 4% of those using guided wont be an adverse effect on anybody. Also says negligible effects on Wilderness Study areas, Wilderness, etc.

 

[sapperJ24]

Here's the public project page: https://www.fs.usda.gov/project/bdnf/?project=56926

"Under the Proposed Action, the likelihood for an increase in competition or goal interference would be
highest in FWP’s general elk hunting units 211, 214, 216, 304, 318, and 350 which are located in the Big
Hole, Clark Fork-Flints, Upper Rock Creek, Boulder River, Jefferson River, Upper Clark Fork, and the
Madison landscapes. The special draw units, however, would be the most likely to experience goal
interference and based on the analysis, district 310-46 in the Madison landscape would be the most
affected as a result of the Proposed Action. Using total number of service days within hunting
concentrated use corridors to assess potential for displacement, the Jefferson River, Madison, Tobacco
Roots, and Upper Clark Fork landscapes were identified as the most likely to be affected."

 

[Salmonchaser]

I’ll go off half cocked. After 20 years guiding in Alaska and seeing what happened there, my gut reaction is to think this a bad idea. I am biased to hunting and fishing, seems like some of these areas I hunt in could use some rest during the year.
I will take a look at the proposal however before I go to full cocked.

 

[Flynarrow]

The Beaverhead Deerlodge NF is proposing to triple the outfitter/guide client days without specifying which recreation activity is to be permitted, where it would occur, and no further public notification or comment period required. You can easily comment though a form on the Comment Sidebar at:

https://www.fs.usda.gov/project/bdnf/?project=56926

 

[Nameless Range]

I commented in opposition. Looks like they want comments by the 18th of December.

Some great comments in the reading room. Even MT FWP wrote a good letter voicing concern back in 2022.

 

[MThuntr]

Email I just received

December 6, 2023

Dear Friends and Neighbors,

On November 18, 2023, the Beaverhead-Deerlodge National Forest (BDNF) released a revised Outfitter and Guide Project Draft Environmental Assessment (EA) starting a 30-day comment period. Comments must be received by December 18, 2023. We appreciate the interest and robust comments we have already received and wanted to send a note to project subscribers to provide clarification on some recurring concerns.

We are re-releasing the draft EA for comment because we updated it along with supporting analysis based on the extensive feedback we received from the public and stakeholders on our last draft, which was released in February 2022. As described in this revised version (see pages 4-5 of the EA), please take note of the list of changes from the preliminary EA released in 2022 to this current version. One of those changes is that the Proposed Action service day pool increased from 30,000 days to 33,416 days, in order to reflect existing special use permit allocations while responding to a need to provide for new and expanded authorizations.

Here is a summary of some comment themes expressed and the Forest’s response.

Concern 1: The BDNF is going to authorize all 33,416 days at once if the Proposed Action is selected.

Response: The revised EA aligns with agency special uses policy found in Forest Service Handbook 2709.14 Chapter 50 by establishing a service day pool from which to authorize existing and future outfitting and guiding activities. Currently, 13,175 service days are already authorized to existing permit holders. Under the proposed action, this would leave 20,241 days available in the pool. However, that pool is further subdivided by Forest Plan landscape. (See Tables 1 and 5 in the EA for the total service day allocation by Forest Plan landscape for a break-down of service days including how many days are remaining when accounting for what is already authorized in existing special use permits.) The intent behind establishing a service day pool is two-fold: one, it sets a cap on outfitting and guiding activities (which addresses capacity concerns); two, it allows land managers to respond to current and future use by providing opportunities for gradual growth and addressing changing visitor use patterns. It is the decision-maker’s intent that this service day pool is in place for decades and allows the Forest to manage existing and future outfitting and guiding use.

Concern 2: The bulk of the service days will be allocated to additional hunting and fishing permits, because those activities represent the primary uses.

Response: The table below was featured in the previous 2022 draft EA and displays the kinds of new proposals the BDNF has received for outfitting and guiding activities. Hunting and fishing represent a very small proportion of those requests. The bulk of activities being proposed highlights the change in visitor use demands described in the Purpose and Need as well as the Recreation analysis. As the table reveals, hunting and fishing are no longer the primary interest for new proponents in southwest Montana.

Table 1 New Proposals Considered for Priority Use Permits

District	Type of Use and Season	Landscape and Management Area (displayed in Appendix A)	Service Days*
Pintler	Spring-Summer-Fall: Day use horseback riding	Clark Fork Landscape: Flint Foothills MA	23
Pintler	Winter-Spring-Summer-Fall: Day use snowmobiling, cross country skiing, day and overnight hiking and fishing	Upper Rock Creek Landscape: West Fork, Ross Fork, and Middle Fork, and Sapphires WSA MAs Clark Fork Flint Landscape: Georgetown Lake and Warm Springs MAs	100
Dillon Madison Wisdom	Fall: Day-use game retrieval using stock	Entire Gravelly Landscape Entire Madison Landscape except the Lee Metcalf Wilderness MA Tobacco Root Landscape on the Madison District Clark Fork-Flint Landscape: South Fleecer MA. Entire Big Hole Landscape: except the Anaconda Pintler Wilderness MA Entire Lima-Tendoy Landscape Pioneer Landscape: Bryant Creek, Quartz Hill, West Pioneer WSA, Pioneer Mts Scenic Byway, East Face, Torrey Mt Recommended Wilderness	100
Dillon	Summer: Overnight backpacking and fishing Winter: Backcountry Skiing	Pioneer Landscape: East Face, Pioneer Mts Scenic Byway MAs for backcountry skiing. East Face and Torrey Mt Recommended Wilderness MAs for fishing mountain lakes.	116
Madison	Winter: Overnight backcountry skiing using snowmobiles to get to the yurt and backcountry skiing from the yurt.	Tobacco Root Landscape: Mill Creek Corridor Wisconsin Creek, Tobacco Root Peaks, Management Areas	400
Madison	Summer: Overnight hiking and horseback riding using drop camp service	Gravelly Landscape: Snowcrest Recommended Wilderness MA, Ruby-Centennial Corridor, and Centennial Foothills MA.	80
Madison	Summer: Horseback riding, and spring bear hunting Fall: Day use hunting and fishing, overnight big game hunting and game retrieval with 1 designated site in the Elk River drainage.	Entire Tobacco Roots Landscape - Madison District Entire Gravelly Landscape Entire Madison Landscape except the Lee Metcalf Wilderness MA	124
Madison	Summer: Overnight bike tours	Entire Tobacco Root Landscape - Madison District Gravelly Landscape: Idaho Creek, Greenhorn Mountains, Timber Creek, Ruby Centennial Corridor, Upper Ruby, Centennial Foothills, Lobo Mesa, West Fork Madison, Hellroaring, Chain of Lakes, Ruby Horse Creek, Wall Creek, Johnny Gulch, and Wigwam-Cherry MAs	40
Madison	Summer: Overnight backpacking, youth education	Entire Gravelly Landscape	72
Wisdom Dillon Madison	Summer: Day use and overnight backpacking, mountaineering for youth	Pioneer Landscape: East Face and Torrey Mountain Recommended Wilderness Area MAs. Entire Tobacco Root Landscape - Madison District Gravelly Landscape: Snowcrest Recommended Wilderness Area, Centennial Foothills and Ruby-Centennial Corridor MAs.	Wisdom 245 Madison 300
Wisdom Madison	Summer: Day use and overnight long distance, high altitude guided running trips.	Big Hole Landscape: West Big Hole and West Big Hole Flats MAs Entire Pioneer Landscape Entire Tobacco Root Landscape: on the Madison District	Wisdom 40 Madison 40
Wisdom	Fall: Overnight backpacking trips, educational field courses	Entire Pioneer Landscape	45
Wisdom	Summer: Day use and overnight llama trips and fishing trips. Fall: Day use and overnight big game hunting with one basecamp and two spike camps.	Pioneer Landscape: Torrey Mountain Recommended Wilderness Area	120

Concern 3: There are no sideboards for these activities; we do not know where these activities are going to occur.

Response: There are substantial sideboards included in the Proposed Action. These include an extensive list of design features outlined in Appendix B. In addition to design features, all proposals must be filtered through agency screening criteria (see Appendix E) as well as be consistent with all law, regulation, and policy, including the 2009 Forest Plan. As the Recreation analysis describes, the bulk of activity will occur along concentrated use corridors. Almost all commercial and non-commercial uses occur on the BDNF on or directly adjacent to roads and trails and frequently entail reaching a popular or scenic destination. The recreation analysis largely focuses on distance buffers from trailheads, staging areas, roads, trails, and destination lakes (individual lakes and basins). A quarter mile buffer around all roads, trails, staging areas, trailheads, and destination lakes was used to establish the spatial extent of concentrated use corridors by season of use (summer and winter per the 2009 Forest Plan allocations). Separate spatial extents were developed for backcountry skiing and hunting. A description of these are included in the Recreation analysis. These are the areas in which we know the use will occur. And all use is limited to the total number of service days by Forest Plan landscape.

 

[MThuntr]

Concern 4: There needs to be a limit on service days by activity (e.g., no more new hunting guides should be considered; or a very small proportion of service days should be allocated to additional hunting and fishing days).

Response: This is a reasonable suggestion and something that should be described in public comment during this 30-day public comment period. Limiting service days by activity or by location (Forest Plan landscape, or particular areas on the national forest, etc.) is within the scope of this decision and can be considered by the decision maker.

Concern 5: This project is commercializing the national forest.

Response: The decision maker is not interested in commercializing the BDNF at all. The intent of the project is quite the opposite as the agency wants to be thoughtful in how it considers future outfitting and guiding proposals and how to respond to those proposals in a sustainable manner. This EA allows the decision maker to look at outfitting and guiding as a whole (forest-wide) rather than on a case-by-case basis (i.e., individual categorical exclusion projects on each district, which do not account for capacity nor lend itself to coordinating decisions on outfitting and guiding authorizations across district boundaries in a larger, programmatic context). The decision maker wants to maintain the predominantly non-commercial recreation setting the BDNF is known for. This Proposed Action would result in changing the proportion that commercial outfitting and guiding represents of our overall recreation use from 1.8% to 4%.

Concern 5: The 2015 Needs Assessment and Capacity Analysis is outdated and should not be used for the basis of authorizing outfitting and guiding.

Response: Needs assessments and capacity analysis documents do not constitute an agency decision. They are long-term vision or planning tools that help inform decisions but are not meant to be used as a singular point of reference for decision making. They represent one factor of many when considering where and when to authorize outfitting and guiding activities. Visitor use patterns can change quickly, and it would be impossible for the Forest to update a needs assessment and capacity analysis in a timely enough manner to respond to the frequency of changing recreation demands. This EA is intended to provide the decision maker with sufficient flexibility in the administration of the BDNF’s outfitting and guiding program while also including site-specific analysis required by NEPA to allow the agency to respond more efficiently and effectively to incoming proposals. Proposals received in response to the Forest’s 2017 solicitation letter reflect a dramatic shift in visitor use preference. For example, hunting and fishing no longer represent the majority of new outfitting and guiding requests.

In summary, electronic means of communication allows us to send project correspondence to a wider audience and earlier this year the Beaverhead-Deerlodge National Forest transitioned to this method of sending project information. We continue to see success in increasing our public outreach with the public subscribing to their preferred projects or districts. Earlier communication for this project was done by mailings, which can be challenging with outdated mailing lists and short staffing. Please navigate to the following website for general Forest Service subscription management : https://public.govdelivery.com/accounts/USDAFS/subscriber/new

Once you enter your email, it takes you to a page where you can customize and save your subscription preferences, organized roughly by forest, district, and purpose.

On the Outfitter and Guide project website (https://www.fs.usda.gov/project/bdnf/?project=56926), there are three folders of information available for review:

Analysis – this folder has the revised draft environmental assessment, all of its appendices including a multitude of maps, and the specialist reports such as the revised recreation analysis.

Scoping- this folder has the cover letter announcing the new comment period and the legal notice that was posted in the newspaper of record.

Supporting- this folder has supporting documents, such as the 2015 Needs Assessment and Capacity Analysis.

We hope these clarifying points serve the information needs for this project. Thank you again for your interest in managing your public lands.

Sincerely,

Lisa Timchak, Forest Supervisor

Beaverhead-Deerlodge National Forest

 

[MThuntr]

Beaverhead-Deerlodge National Forest - Home

Beaverhead-Deerlodge National Forest - Home

www.fs.usda.gov

 

[Sytes]

Thanks for sharing @MThuntr .
Appreciate the alert @Flynarrow .

Bite felt a tad bit more when it knocks on your own hunting door.
Glad I caught onto this thread before close of public comment.

The decision maker wants to maintain the predominantly non-commercial recreation setting the BDNF is known for. This Proposed Action would result in changing the proportion that commercial outfitting and guiding represents of our overall recreation use from 1.8% to 4%.

Someone with more knowledge able to assist with more clarity for Joe hunter?

This enables over double current commercial "outfitting and guiding"?

Basically, 1 of every 25 people stepping onto BDNF? [4%]
How is this defined? Vague question... Example: I typically "scout" (fishing excuse) my hunt grounds around P-burg and Skalkaho a few / couple x's per year and one or two single week hunts. How is it calculated within the 96% non-commercial to project 4% commercial use?

 

[SixPoint]

Concern 4: There needs to be a limit on service days by activity (e.g., no more new hunting guides should be considered; or a very small proportion of service days should be allocated to additional hunting and fishing days).

Response: This is a reasonable suggestion and something that should be described in public comment during this 30-day public comment period. Limiting service days by activity or by location (Forest Plan landscape, or particular areas on the national forest, etc.) is within the scope of this decision and can be considered by the decision maker.

Concern 5: This project is commercializing the national forest.

Response: The decision maker is not interested in commercializing the BDNF at all. The intent of the project is quite the opposite as the agency wants to be thoughtful in how it considers future outfitting and guiding proposals and how to respond to those proposals in a sustainable manner. This EA allows the decision maker to look at outfitting and guiding as a whole (forest-wide) rather than on a case-by-case basis (i.e., individual categorical exclusion projects on each district, which do not account for capacity nor lend itself to coordinating decisions on outfitting and guiding authorizations across district boundaries in a larger, programmatic context). The decision maker wants to maintain the predominantly non-commercial recreation setting the BDNF is known for. This Proposed Action would result in changing the proportion that commercial outfitting and guiding represents of our overall recreation use from 1.8% to 4%.

Concern 5: The 2015 Needs Assessment and Capacity Analysis is outdated and should not be used for the basis of authorizing outfitting and guiding.

Response: Needs assessments and capacity analysis documents do not constitute an agency decision. They are long-term vision or planning tools that help inform decisions but are not meant to be used as a singular point of reference for decision making. They represent one factor of many when considering where and when to authorize outfitting and guiding activities. Visitor use patterns can change quickly, and it would be impossible for the Forest to update a needs assessment and capacity analysis in a timely enough manner to respond to the frequency of changing recreation demands. This EA is intended to provide the decision maker with sufficient flexibility in the administration of the BDNF’s outfitting and guiding program while also including site-specific analysis required by NEPA to allow the agency to respond more efficiently and effectively to incoming proposals. Proposals received in response to the Forest’s 2017 solicitation letter reflect a dramatic shift in visitor use preference. For example, hunting and fishing no longer represent the majority of new outfitting and guiding requests.

In summary, electronic means of communication allows us to send project correspondence to a wider audience and earlier this year the Beaverhead-Deerlodge National Forest transitioned to this method of sending project information. We continue to see success in increasing our public outreach with the public subscribing to their preferred projects or districts. Earlier communication for this project was done by mailings, which can be challenging with outdated mailing lists and short staffing. Please navigate to the following website for general Forest Service subscription management : https://public.govdelivery.com/accounts/USDAFS/subscriber/new

Once you enter your email, it takes you to a page where you can customize and save your subscription preferences, organized roughly by forest, district, and purpose.

On the Outfitter and Guide project website (https://www.fs.usda.gov/project/bdnf/?project=56926), there are three folders of information available for review:

Analysis – this folder has the revised draft environmental assessment, all of its appendices including a multitude of maps, and the specialist reports such as the revised recreation analysis.

Scoping- this folder has the cover letter announcing the new comment period and the legal notice that was posted in the newspaper of record.

Supporting- this folder has supporting documents, such as the 2015 Needs Assessment and Capacity Analysis.

We hope these clarifying points serve the information needs for this project. Thank you again for your interest in managing your public lands.

Sincerely,

Lisa Timchak, Forest Supervisor

Beaverhead-Deerlodge National Forest

Nope, I still don’t like it.

 

[44hunter45]

Might I suggest this will seriously hamper G-bear "recovery" in these regions. You cannot have that.
It might be time to team up with regional bear lovers.