Protect the Wild and Scenic Forks of the Flathead River

We suggest you provide the following points as part of your comments.  For greatest effectiveness, personalize your comments and confine them to the proposed action:

• Support the proposed establishment of a mandatory permit system for all floaters - The Forest Service lacks solid data on how many people use the river and for what purposes. Consequently, their proposed user capacity numbers are educated guesses and negotiated compromises between experts, rather than based on actual use data and associated impacts. The proposed free, unlimited permit system would provide the Forest Service crucial user data to better inform effective management action.

• Support the proposed extended no-stopping order and prohibition on dogs around the Goat Lick - Extending the current no-stopping order to prohibit floaters from stopping between Staircase Rapid and Split Rock Rapid will reduce disturbance to mountain goats, as well the prohibition on dogs in this area. Monitoring indicates mountain goats use a wider stretch of the river here than previously known. This is the only area mountain goats consistently access and cross the Middle Fork of the Flathead River. Minimizing disturbance is crucial to goat conservation in both Glacier National Park and the Bob Marshall Wilderness complex.

• Additional monitoring provisions for wildlife trends and recreational impacts to wildlife are needed - Inexplicably, the plan contains almost no provisions to monitor wildlife trends in the corridor except for mountain goats. Monitoring should, at a minimum, record where wildlife commonly cross the the Middle Fork between the Bear Creek River Access site and West Glacier – as this would help inform the siting of future wildlife crossing structures on the highway and / or railway as well as other actions to improve wildlife connectivity – and whether recreational river use is harming or displacing certain species like bears or moose.

• The Forest Service should identify and evaluate potential strategies to limit recreational use while developing the plan – Limiting recreational use in certain stretches of river may be necessary now, or in the future, to protect fish and wildlife, other outstandingly remarkable values, or the recreational experience. In developing the plan, the Forest Service should identify and evaluate a range of different strategies by which it may limit recreational use, should monitoring indicate such limits are necessary. This will help the agency better understand their public acceptability of different strategies, as well as be better prepared to quickly adapt management to improve resource conditions without having to first initiate a new time intensive, full environmental review for certain actions.

• An equitable portion of priority use service days should be allocated to non-commercial outfitters who provide affordable, education-focused trips or who serve underrepresented  demographics, like Indigenous communities, veterans, youth, or people with disabilities – The proposed allocation at present would allow massive growth (from 35,713 authorized user days to 136,000 authorized user days on the Middle Fork below Bear Creek alone) for the four existing commercial outfitters, all of whom offer the same basic service – single or multi-day whitewater rafting or fly fishing trips – primarily to tourists. One measly, temporary permit for only 50 user days (yes, five zero) would be reserved for an educational program or provider for underserved communities. This inequitable allocation ratio is a totally unacceptable commercialization of the public’s river and needs to be better balanced.

Read the comments submitted by GTMA here.