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WHY PUBLIC COMMENTS ARE IMPORTANT – MSGA encourages its members to engage in the public comment process. This is an opportunity for you to be involved in the decision-making process happening within federal and state agencies, to offer your thoughts on alternative ways for an agency to accomplish what it is proposing, to offer your comments on the agency’s analysis of the environmental effects of the proposed action, and possible mitigation of potential harmful effects of such actions.

Check below to view current public comment opportunities.

The Stream Gage Oversight Work Group is seeking public feedback on the Draft Report to the 2022 Montana Water Policy Interim Committee on Stream Gaging in Montana.

The Work Group was created by the 66th Montana Legislature in response to water users’ concerns over the shutdown of 10 USGS stream gages in Montana. The Work Group conducted a review of the USGS network and developed recommendations to improve network resilience and continuity considering decreased funding.

The report is available here

The broad recommendations of the report are:

  • The State of Montana should work with its elected representatives in Washington D.C. to encourage a significant and sustained federal investment in the nation’s stream gage network.
  • The Montana Legislature should consider an increase in state funding to maintain its current level of support to the USGS network in Montana.
  • The Montana Legislature should consider appropriating additional funding to complete the build-out of the DNRC state-based stream gage network called for in the 2015 State Water Plan.

Comments will be accepted until 5 p.m. August 12, 2022, and will be used to inform the Water Policy Interim Committee on Montanan’s support for stream gaging.

Or email [email protected]  if you need to send an attachment.

Or mail to:
Montana DNRC
Attn: Paul Azevedo
PO Box 201601
Helena, Montana 59620-1601

FWP seeks public input on local elk management issues

HELENA – Montana Fish, Wildlife & Parks will be hosting a series of public meetings this summer and fall to gather ideas about local elk management issues and population objectives. Meeting places, times and details are posted on the FWP website.

FWP began developing a revised statewide Elk Management Plan in 2020. The first step in the process was to convene a citizen’s group to develop guiding principles for revising the plan. The next step is to gather input on current elk population objectives and other local challenges that could be addressed in the revised Elk Management Plan.

“Revising the statewide Elk Management Plan is a critical step for improving elk management to meet both hunter and landowner expectations,” said FWP Wildlife Division Deer/Elk Coordinator Lindsey Parsons. “Public input from the beginning is critical and we’re hoping hunters and landowners alike will provide comment during this scoping period.”

A public comment period will be open from June 20 to Oct. 15. Beginning June 20, comments can be submitted online or emailed to [email protected].

Input gathered during the local process will be used with information obtained at the statewide scale to develop a draft Elk Management Plan.

Once the draft Elk Management Plan has been developed and released, there will be additional public comment opportunities offered.

The Montana Department of Natural Resources and Conservation (DNRC) is seeking nominations and applications for conservation district supervisors to serve on the newly formed Conservation Districts Advisory Council (CDAC). CDAC was created to replace the former Conservation Resources Advisory Council (RCAC).

Council’s Name and Agency 

Conservation Districts Advisory Council, Department of Natural Resources and Conservation

Council’s Composition 

The composition of the Council shall be seven (7) members with one (1) from western Montana, one (1) from south central Montana, one (1) from northwestern Montana, two (2) from eastern Montana and two (2) from north central Montana.

Council’s Purpose 

  1. Advise and assist the Conservation Districts Bureau on district operations and conservation-related issues including impending conservation matters.
  2. Facilitate communication between the Conservation Districts Bureau and districts.
  3. Advocate the importance of the work and value of the conservation districts to the public, partners, and stakeholders.

Council Member Responsibilities

The Council will meet at a minimum of 2 times per year. Members will be tasked with ensuring that the Conservation Districts Bureau is in alignment with its purpose of empowering conservation districts to meet their mission through legal and operational support, financial assistance, and professional development.

If interested, please complete the gubernatorial application and send to Stephanie Criswell. She is available for questions and nominations at 406-444-6669, [email protected].

PLC Seeks Information on Voluntary Grazing Adjustments

The Public Lands Council has been working with the BLM and Forest Service to ensure they’re directing their staff to use as much flexibility as possible during the upcoming grazing season. The agencies have asked PLC to help them encourage permittees to report actual use, or to help them demonstrate that permittees are already making grazing decisions that match the landscape needs. There are a variety of reasons a permittee may not report actual use, but in order to push the agencies to use more flexibility, we need your help. 

Please complete the two question survey below, and share with your neighbors, state PLC delegates, and friends. Personal identities are not collected as part of the survey unless you want to be contacted as an example of grazing changes.

WHAT DO YOU THINK ABOUT HISTORIC PRESERVATION IN MONTANA?

The Montana State Historic Preservation Office (SHPO) is revising the state’s five-year preservation plan, Preservation Montana, and we need your input on how SHPO and Montana’s preservation community can better promote and facilitate preservation across the state. Our 10-question survey provides you an opportunity to express your opinions and identify emerging preservation issues. SHPO will synthesize survey results and revise the current plan’s Issues, Goals, Objectives, and Strategies for a 2023 rollout.

Take the survey now:
Survey – Montana Preservation Plan Update 2023-2027 (surveymonkey.com)

SHPO appreciates you sharing your most valuable commodities: your time and thoughts!

The EPA and the Army Corps of Engineers have published the first of their two-phase rulemaking to repeal the Navigable Waters Protection Rule (NWPR). Following a recent court decision in Arizona that vacated the NWPR, the agencies have been implementing the 1986 regulation. Phase 1 of the rulemaking removes NWPR from the Code of Federal Regulations, so that the agency is able to implement the 1986 regulation, with revisions, while they work to revise the definition of “waters of the United States” through a second phase.

For question, please reach out to Raylee Honeycutt at ra[email protected]

Montana’s Livestock Loss Board is looking to revamp the loss prevention grant process and is requesting suggestions from Montana Ranchers to make the process easier for ranchers to apply. Give your ideas today!

In order to facilitate a new process, the board directed two of their members to come up with a new grant application. Elaine Allestad a rancher from Big Timber and Patty Quisno a rancher from Harlem have begun working on new grant requirements. Early thoughts in the process are lowering a cost share requirement for a grant match to make it more affordable. It’s not always a cash match for a cost share. It can be value for your labor such as installing an electric fence to help keep grizzly bears out of smaller pastures as just one example.

“The board’s philosophy has always been that a rancher will know what will work best for their own ranch. We will never tell you what you need to do to reduce predation. This is where you come in. If you have ideas that may help the board, we want to hear from you.” – George Edwards, Livestock Loss Board Executive Director

Ideas can be sent to [email protected]. Please keep in mind that our funding is restricted to non-lethal methods related to grizzly bears and wolves. 

The Livestock Loss board encourages public comment throughout their meetings and your input will help the board come up with better solutions In the future. 

A board meeting to discuss a new grant form will be held sometime during the week of October 11-15th. Meeting details can be found at www.llb.mt.gov.

ONGOING ISSUE: BLM’S DRAFT EA ON AMERICAN PRAIRIE RESERVE CHANGE APPLICATION FOR BISON

+ ABOUT THE ENVIRONMENTAL ASSESSMENT

American Prairie Reserve (APR) has submitted a proposal asking the BLM to modify their grazing permits. APR is seeking changes in the class of livestock from cattle to cattle and/or bison and modifications to their season-of-use and construction and/or removal of range improvement projects. The project also includes adjustments to allotments (such as combining pastures) and administrative actions (such as issuing ten-year grazing permits). Comments regarding this environmental assessment should address the APR proposed alternative, Alternative B.

+ IN ALTERNATIVE B, APR IS REQUESTING TO

  1. Change the class of livestock from cattle to bison
  2. Change in authorized seasons-of-use
  3. Change to remove interior fencing and manage their private lands along with the public lands as one common pasture. This includes construction, reconstruction and/or removal of some fences and adjustments to allotments.
  4. Action from BLM to issue a ten-year grazing permits

+ BACKGROUND

On Sept. 24, 2019, the American Prairie Reserve (APR) submitted a proposal (an update to their earlier proposal submitted on Nov. 20, 2017) to modify certain terms and conditions of seven BLM-administered grazing permits held by the APR. APR’s original proposal sought permit changes for 18 BLM grazing allotments located in four counties. The APR’s updated proposal reduced the number of BLM allotments involved and requested and is only in Phillips County. 

Based on APR’s amended proposal and public input received during the scoping period, the BLM prepared a draft EA and FONSI for the following seven BLM allotments managed by its Malta Field Office: Telegraph Creek, Box Elder, Flat Creek, White Rock, East Dry Fork, French Coulee and Garey Coulee.

The public comment period will run from July 1 through September 28, 2021. The BLM encourages public review and comment on the Draft EA and FONSI by visiting the BLM’s ePlanning website at https://eplanning.blm.gov. Search using the NEPA number: DOI-BLM-MT-L010-2018-0007-EA. 

+ POINTS TO CONSIDER

  1. Is BLM making a special exception for this application due to the animals being bison?
  2. Bison are not included in the definition of livestock allowed to graze on federal land (see 43 CFR 4100.05-5). The Federal Grazing Regulations permit bison to graze on federal land only with a more-limited Special Use Permit. Should bison be allowed under this current proposal?
  3. Should there be consideration that APR’s bison are a conservation herd and not a commercial herd.
  4. How would BLM treat an application requesting removal of fences and season long grazing for cattle or sheep?
  5. If BLM approves this application, this is a precedent for similar applications to approve cattle allotment requests.
  6. A range management principle in general is – increase fencing (cross fences) and you increase carrying capacity because you have more control over the livestock’s movements. So the reverse should be true – decrease or remove fences and you lose carrying capacity because the animals will concentrate in their favorite or the best areas. 
  7. How will range monitoring be completed and documented to meet range standards?
  8. APR states that it has implemented a wildlife-friendly bison fence that does not inhibit wildlife movements, so is there a need to remove interior fencing?
  9. Has BLM considered a comprehensive approach to APR’s plan for bison restoration?
  10. Is an EA adequate or should an EIS have been completed?
  11. What are the socioeconomic effects the alternative will have on the local community?
  12. APR pays Department of Livestock per capita fees on the bison they own, classifying them as domestic livestock.

+ TAKE ACTION

The public comment ended on September 28, 2021. 

For any other comments or questions, please contact Jay Bodner or Raylee Honeycutt at the MSGA office at 442-3420 or email at [email protected] or [email protected]

+ IN ALTERNATIVE B, APR IS REQUESTING TO

  1. Change the class of livestock from cattle to bison
  2. Change in authorized seasons-of-use
  3. Change to remove interior fencing and manage their private lands along with the public lands as one common pasture. This includes construction, reconstruction and/or removal of some fences and adjustments to allotments.
  4. Action from BLM to issue a ten-year grazing permits

+ BACKGROUND

On Sept. 24, 2019, the American Prairie Reserve (APR) submitted a proposal (an update to their earlier proposal submitted on Nov. 20, 2017) to modify certain terms and conditions of seven BLM-administered grazing permits held by the APR. APR’s original proposal sought permit changes for 18 BLM grazing allotments located in four counties. The APR’s updated proposal reduced the number of BLM allotments involved and requested and is only in Phillips County. 

Based on APR’s amended proposal and public input received during the scoping period, the BLM prepared a draft EA and FONSI for the following seven BLM allotments managed by its Malta Field Office: Telegraph Creek, Box Elder, Flat Creek, White Rock, East Dry Fork, French Coulee and Garey Coulee.

The public comment period will run from July 1 through September 28, 2021. The BLM encourages public review and comment on the Draft EA and FONSI by visiting the BLM’s ePlanning website at https://eplanning.blm.gov. Search using the NEPA number: DOI-BLM-MT-L010-2018-0007-EA. 

+ POINTS TO CONSIDER

  1. Is BLM making a special exception for this application due to the animals being bison?
  2. Bison are not included in the definition of livestock allowed to graze on federal land (see 43 CFR 4100.05-5). The Federal Grazing Regulations permit bison to graze on federal land only with a more-limited Special Use Permit. Should bison be allowed under this current proposal?
  3. Should there be consideration that APR’s bison are a conservation herd and not a commercial herd.
  4. How would BLM treat an application requesting removal of fences and season long grazing for cattle or sheep?
  5. If BLM approves this application, this is a precedent for similar applications to approve cattle allotment requests.
  6. A range management principle in general is – increase fencing (cross fences) and you increase carrying capacity because you have more control over the livestock’s movements. So the reverse should be true – decrease or remove fences and you lose carrying capacity because the animals will concentrate in their favorite or the best areas. 
  7. How will range monitoring be completed and documented to meet range standards?
  8. APR states that it has implemented a wildlife-friendly bison fence that does not inhibit wildlife movements, so is there a need to remove interior fencing?
  9. Has BLM considered a comprehensive approach to APR’s plan for bison restoration?
  10. Is an EA adequate or should an EIS have been completed?
  11. What are the socioeconomic effects the alternative will have on the local community?
  12. APR pays Department of Livestock per capita fees on the bison they own, classifying them as domestic livestock.

+ TAKE ACTION

The public comment ended on September 28, 2021. 

For any other comments or questions, please contact Jay Bodner or Raylee Honeycutt at the MSGA office at 442-3420 or email at [email protected] or [email protected]

+ ABOUT THE ENVIRONMENTAL ASSESSMENT

American Prairie Reserve (APR) has submitted a proposal asking the BLM to modify their grazing permits. APR is seeking changes in the class of livestock from cattle to cattle and/or bison and modifications to their season-of-use and construction and/or removal of range improvement projects. The project also includes adjustments to allotments (such as combining pastures) and administrative actions (such as issuing ten-year grazing permits). Comments regarding this environmental assessment should address the APR proposed alternative, Alternative B.

BLM Announces proposed decision for the APR Change Application for bison on seven grazing allotments

MSGA’s Statement
HELENA, Mont. (March 30, 2022) – Today, Montana Stockgrowers Association (MSGA) President Jim Steinbeisser issued the following statement regarding the Bureau of Land Management’s proposed decision for the American Prairie Reserve Change Application for bison on seven grazing allotments:
“Our organization and our members have consistently provided comments regarding our concerns with APR’s proposals. These include concerns over the impacts to the rangeland health, riparian areas, and socioeconomic impacts to the rural communities and the livestock industry. The proposed decision published today did not address the concerns brought forth by our association, as well as numerous other ranching families.” Read more >>

MPLC’s Statement
HELENA, Mont. (March 30, 2022) – The Montana Public Lands Council (MPLC) shared its disappointment today as the Bureau of Land Management’s (BLM) Malta Office issued its proposed decision regarding the American Prairie Reserve Change-of-Use.
“As the state’s largest organization representing individuals who graze on public lands, our members are very familiar with the permit processes and what processes should be followed. We feel this proposed decision did not take into account the additional vetting and analysis needed to make a decision. Our organization has brought forth in previous comments the legality of bison’s grazing eligibility under the Taylor Grazing Act as well as concerns regarding rangeland health and the protection of riparian areas.” Read more >>

THINGS TO KEEP IN MIND WHEN SUBMITTING COMMENTS:

  1. Craft a “Substantive” Comment – a substantive comment is one that: 
    • Questions the accuracy, methodology or assumptions used in the analysis;
    • Presents new information or reasonable alternatives not analyzed; or
    • Causes changes or revisions.
  1. Support Your Point – This can be personal observations, experience or cited sources. 
  2. Avoid Vague Statements – Specifics help the agency to consider and evaluate the issue you have identified. 
  3. Provide Detail – Describe the issue, what can be done, the specific location, what resources are involved, etc. 
  4. Present Solutions – Include a potential fix to the problem you have identified. 

ABOUT THE NATIONAL ENVIRONMENTAL POLICY ACT

The National Environmental Policy Act “… is intended to help public officials make decisions that are based on the understanding of environmental consequences…” (40 CFR 1501 (c).) To achieve this, the EIS considers the effects of agency actions on social, economic and natural resources within the planning area. Citizens, such as yourself, often have valuable information about places and resources they consider important and the potential effects proposed agency actions may have on those places and resources.

COMMENT EXAMPLES

Examples of Substantive Comments  Examples of Non-Substantive Comments
Example 1:
“While we understand the desire to increase access to public land for recreational opportunities, we feel it is important to work with agencies and recreation groups to find acceptable solutions for all stakeholders. Additional recreation use results in added operational expenses for permittees, including weed management or fence repair. We recommend the inclusion of a statement that the Council will foster collaborative efforts to address conflicts and help reduce the costs for permittees.”Example 2:
“In short, the description of a species’ habitat must not be used as justification for the Services to regulate themselves into a position of authority across broad swaths of lands and waters where the agencies would otherwise have no authority.”
Example 1:

Simply disagreeing with a proposed action.

“I do not support Alternative B.”

Example 2:

Simply stating an opinion.

“Protect our resources!”

Example 3:

Commenting on items outside the scope or proposal.

“Please extend your office hours for those who work between 8-5pm Monday-Friday.”