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HomeMy WebLinkAbout09-04-24 Public Comment - J. Karjala, Footloose Montana - Ord 2166, Prohibiting Trapping On City LandsCustomer Submission #CS-24-776 Open Created on September 4, 2024 by Jessica Karjala Print Description Dear Members of the City Commission of Bozeman and Mayor Cunningham, Per the recommendations on page 10 of the attached commissioned by Footloose Montana, we respectfully ask the Bozeman City Commission close the entire city owned portion of the 34,000 acres of the Sourdough-Hyalite area year-round to all trapping, snaring and water sets at their meeting on September 10, 2024, or the earliest date possible. I have attached the Footloose Montana report on the Sourdough area conducted by Mike Bader, to allow you to gain a better understanding of the area and the dangers posed to people, dogs and wildlife by allowing trapping to continue. Due to the checkerboard pattern of ownership of the land, Footloose Montana is also working with the US Forest Service to develop similar/same policy to increase the safety of the area and prevent confusion of those using the area. Footloose Montana was instrumental in banning trapping in the Blue Mountain Recreational Area, the Rattlesnake National Recreation Area, Pattee Canyon and Blue Mountain Recreation Areas all on the Lolo National Forest surrounding Missoula and hope to achieve similar success in the Sourdough-Hyalite area. We are glad to support the City of Bozeman with as many resources as necessary to ban trapping in the Sourdough-Hyalite area starting with the attached report and continuing with any other materials you might request. We have spoken with Mayor Cunningham on the draing of proposed language to ban trapping in the Sourdough-Hyalite area and have spoken to Commissioner Bode and want to thank both of them for taking time to listen and work with us. Please feel free to reach out to me with any questions you may have about the attachedAssigned to Alex Newby Collaborator/s Mike Maas Due By 09/07/2024 Submission Age 0 Days Attachments 1 Customer Messages 0 Internal Comments 0 Tasks 0 Source Internal by Jessica Karjala Category Public Comment Department Clerk's Office Customer Name Jessica Karjala Customer Email jessica.karjala@footloosemontana.org Cell Phone - 9/4/24, 2:12 PM about:blank about:blank 1/3 study and/or the work of Footloose Montana to ban trapping on public land in Montana. My cell is 406 880-9594 and my email is jessica.karjala@footloosemontana.org Jessica Karjala Executive Director, Footloose Montana Location 314 West Main Street, Bozeman, MT 59715 Section 1: Assessor's Addresses Section 2: CDBG Information Customer Messages (1) Mike Maas 09/04/2024 02:11pm Email Street Address 314 West Main Street City Bozeman State MT Zip 59715 APN Owner Name - Owner's Mailing Address Flagged? No Assessor's Address CDBG Eligible? No CDBG Approved? No Census Tract 000800 Block Group 300310008002 LowModPct 53 9/4/24, 2:12 PM about:blank about:blank 2/3 Thank you for your public comment Good aernoon, Your public comment has been received and will be distributed to the City Commission and appropriate sta. Thank you, -- Mike Maas, MPA| City Clerk City of Bozeman | 121 N. Rouse Ave. | Bozeman, MT 59715 D: 406.582.2321 | C: 406.599.0804 This email is in reference to issue CS-24-776 (CRM-VhSNkGdDz). In case of any queries, you can respond to this email and we will get back to you as soon as we can. Bozeman, MT 121 North Rouse Avenue , Bozeman, MT 59715 Public Comment 9/4/24, 2:12 PM about:blank about:blank 3/3 1 Introduction The Bozeman Creek-Sourdough Canyon and Hyalite Creek-Canyon (Sourdough-Hyalite) areas near Bozeman are within the Greater Yellowstone Ecosystem and host nearly all of the native wildlife species that were here over 200 years ago. Much of the area is within the 155,000 acres of the Hyalite-Buffalo Horn-Porcupine Wilderness Study Area (S. 393, Montana Wilderness Study Area Act 1977). According to the Custer-Gallatin National Forest the Hyalite drainage is the most heavily used by recreationists in U.S. Forest Service Region 1 and the Sourdough Creek Trail also receives medium-heavy use in all seasons. Several checkerboard sections of land owned by the City of Bozeman are within the Bozeman Creek watershed and Bozeman Creek supplies 40% of the municipal water supply for the City of Bozeman. This report analyzes the recreational use in this area, the value the area has for connectivity or linkage habitat for wildlife and potential conflicts resulting from the Wolf-Furbearer Trapping Regulations authorized by the Montana Department of Fish, Wildlife & Parks (2022). A comparative analysis of consistency with management in other designated Recreation Areas on U.S. Forest Service managed lands in Region 1 is made. Finally, this report makes recommendations for potential deconfliction encompassing the Bozeman-Sourdough Creek Watershed and the Hyalite Recreation Area within the Custer Gallatin National Forest. Current Management Designations The Custer Gallatin National Forest Revised Forest Plan designated the Gallatin Linkage Area which includes the Sourdough Creek/Canyon and the Hyalite Recreation Emphasis Area (see Figure 2). Much of it is within the Congressionally designated Hyalite-Buffalo Horn-Porcupine Wilderness Study Area. Figure 1. Sourdough Creek has high water quality and supplies 40% of the municipal water supply for Bozeman, Montana. George Wuerthner photo. 2 Wildlife Resources This area has tremendous wildlife values. An analysis of the Gallatin Range found more than 98% of the species endemic to this area still exist here (Craighead 2015). According to the U.S. Fish & Wildlife Service (2022) this area is occupied grizzly bear (Ursus arctos) habitat and it has been documented to be a habitat connectivity area for grizzly bears between the Greater Yellowstone and Northern Continental Divide Ecosystems (Walker and Craighead 1997, Peck et al. 2017, Sells, et al. In Review). Due to this potential the Sourdough Creek watershed is included in the designated Gallatin Linkage Area. This area has also been identified as a connectivity area for lynx (Lynx canadensis) (U.S. Forest Service map). Recreation Use More than 3 million people visit the Custer Gallatin National Forest each year with heavy use in the Madison- Gallatin-Henry’s Lake region near and adjacent to Yellowstone National Park. This is approximate to the numbers that visit Grand Teton National Park. “Hiking and walking are the most popular dispersed recreation activities on the Custer Gallatin National Forest by quite a wide margin…” (CGNF). The Bozeman area continues to grow and attract more visitors. On Bozeman’s doorstep, Sourdough Canyon receives medium-heavy use in all seasons and in winter is groomed for both cross-country and skate skiing and there are ski events. Its proximity to Bozeman and an easy and wide grade at the lower end make it very popular with families with children, hikers, birdwatchers, photographers and bikers. Using an old roadbed the trail is wide enough that a mother walking her baby in a stroller is a common sight. It has a Trailhead and there is a rental cabin at Mystic Lake. This Trail is listed on all the trails and recreation web sites. Figure 2. Designations Made in the Custer Gallatin Revised National Forest Plan. 3 Figure 3. Mystic Lake and the Mystic Lake Cabin Are a Popular Destination in All Seasons. U.S. Forest Service photo. The Hyalite drainage is the most heavily used area in U.S. Forest Service Region 1. “In 2016 the canyon received more than 40,000 visitors monthly in the summer and over 20,000 visitors monthly in the winter. Current visitor monitoring indicate that use has increased over the last 5 years to more than 60,000 visitors monthly in the summer and over 30,000 visitors monthly in the winter. Use in the canyon was even higher this past year during the global pandemic.” (CGNF 2022). The Hyalite Recreation Area has vehicle access by road and has five developed campgrounds and several other signed campsites. There are two Fishing Access Sites, two Picnic Areas, two Trailheads and a rental cabin. In total there are 475 developed sites, 185 dispersed camping sites, about 70 miles of trail and 65 miles of roads within the Hyalite area. Hyalite is also a world-renowned ice climbing destination. According to the Custer Gallatin National Forest there are no leash requirements for dogs on any trails. Since these areas are designated as off-leash areas for dogs, recreation visitors are frequently accompanied by one or more dogs. Figure 5. Dogs Accompany Recreation Users in All Seasons. Phil Knight photo. Figure 4. Scenic Beauty and Easy Access Draws Hundreds of Thousands to the Sourdough-Hyalite areas each year. George Wuerthner photo. 4 Current Trapping Regulations The Sourdough-Hyalite area is within Montana Hunting District 301 and within the larger Trapping District 3. The area is within Unit 5 Lynx Critical Habitat (USFWS 2014) and within the Lynx Protection Zone (Montana Fish Wildlife & Parks 2022). By regulation, wolf (Canis lupus) trapping using snares is prohibited. Lethal ground sets and snares are prohibited within 1000 feet of a designated, signed trailhead and any public land campground accessible by highway vehicles. Wolf trapping using foothold traps is prohibited within 1000 feet from any public land trailhead (Montana Fish Wildlife & Parks 2022). According to the Custer Gallatin National Forest all main trails in the Sourdough and Hyalite drainages including the Mystic Lake Trail have a 500-foot setback from either side of the trail where trapping is prohibited (see Figure 6). The 500-foot setbacks cover just a fraction of the Sourdough-Hyalite areas. The status of numerous secondary trails is uncertain including Nordic skiing trails with heavy use. In the Sourdough and Hyalite drainages, water sets including those set for beaver (Castor canadensis), muskrat (Ondrata zibethicus) and otter (L. canadensis) are not included in the 500-foot setback (see Figure x). In fact, Montana trapping regulations allow water sets up to the high-water mark within 50 feet of fishing access sites, trailheads and other public facilities. Trapping for many non-game species including coyote (Canis latrans) is allowed year-round. While snares set for wolves are prohibited other types of traps and snares set for many other species are allowed. In Trap District 3, seasons for Otter, Muskrat and Mink (Neovison vison) runs from November 1-April 15 and for Marten (Martes americana) December 1-February 15. Beaver trapping is open November 1-April 15. According to the Montana Wolf-Furbearer Trapping Regulations the main trails in the Sourdough-Hyalite Area have 500-foot setbacks as shown in Figure 6: However, the Hyalite Road for the first 4 miles of the Canyon has a minimal setback of 50 feet. Figure 6. The 500-foot Trapping Setbacks in the Sourdough and Hyalite drainages. 5 Conflicting and Competing Uses The Custer Gallatin National Forest Recreation Report prepared for the Revised Forest Plan does not contain the word trapping. Yet there are many potential conflicts that arise from trapping activity within areas of high human use. Hidden and baited traps are indiscriminate and pose a safety risk to pets and risk of serious injury to small children. Most citizens are unaware of how to release the trap jaws and may panic, further elevating the situation. Between 2012-2022 there were at least 266 reports of domestic dogs caught in traps in Montana (Montana Fish Wildlife & Parks 2018, 2022). These records are very incomplete. For example, the annual Trap Bycatch Report for 2022 will not be available until perhaps October 2023 due to tardy and incomplete reports from Montana Fish Wildlife & Parks regions. Moreover, many incidents of pet captures are not reported. For example, the trapper is seldom nearby when a dog gets caught in a trap so the owner releases their dog. They either do not know they should report it, don’t want to take the time or fear retribution from the trapper. While trappers are required to report the capture of any domestic dog within 24 hours, this does not always happen. Trap injuries to pets can be gruesome and lethal (see Figure 8) and cause emotional trauma to their owners. Winter recreation use is rapidly increasingly on forest trails and there is also much off-trail use by skiers. The impacts go beyond the actual number of pets trapped and include the fear and anxiety pet owners have when using public trails, rivers and other areas where trapping is allowed. The prospect of their pet being trapped may result in people not using areas intended and designated for recreational use. Figure 7. This sign shows that water sets are not prohibited Within the Sourdough Creek Area. Footloose Montana photo. 6 Figure 8. These Dogs Have Suffered Gruesome Injuries Due to Traps. Footloose Montana photos. To the extent that trappers use the public transportation system of roads and recreational trails to access their trap lines means that there are traps in close proximity to people and pets. Most trappers use motorized vehicles to access their traplines and trap sites including trucks, All Terrain Vehicles and snowmobiles. In the Sourdough drainage where motorized use is prohibited this may concentrate trapping within the most heavily used portion of the Trail and canyon. Conflicts are not limited to hiking trails. The fact that the Custer Gallatin National Forest designated the Gallatin Linkage Area and the Hyalite area as a Recreation destination rather than Proposed Wilderness for the portion within the Wilderness Study Area will only draw more users and increase the potential for conflicts with trapping. Conflicts with Wildlife Connectivity The Gallatin Linkage Area was designated for the purpose of facilitating wildlife movements including for the threatened grizzly bear and lynx. This aligns with State and Federal policy and strategy. Several scientific studies have reached the same result: Sourdough-Hyalite is within a primary connectivity route for both male and female grizzly bears (Walker and Craighead 1997; Peck et al. 2017; Sells et al. In Review) connecting the isolated Greater Yellowstone population with the Northern Continental Divide Ecosystem population. These results are shown in Figure 9. Newmark, et al. (2023) found that linking Glacier and Yellowstone National Parks 7 would extend medium to large species persistence time up to 4.3 times as long as they would persist if they were not connected. On page 47 the Grizzly Bear Conservation Strategy states: Population Connectivity Connectivity among grizzly bear populations mitigates genetic erosion and increases resiliency to demographic and environmental variation. One way to mitigate potential impacts from climate change is through well-connected populations of grizzly bears in the lower-48 States and Canada. This Conservation Strategy envisions the NCDE serving as a “source population” for grizzly bear populations in the CYE, BE, and GYE. Attaining habitat connectivity between these areas would benefit multiple wildlife species and would be consistent with the USFWS Grizzly Bear Recovery Plan (USFWS 1993), the Grizzly Bear Management Plan for Western Montana (Dood et al. 2006), the Grizzly Bear Management Plan for Southwestern Montana (MFWP 2013), the interagency statement of support for the concept of linkage zones signed by the State wildlife agencies in Montana, Washington, Idaho, and Wyoming and the USFS, USFWS, USGS, NPS. Connectivity remains a goal within the Draft Montana Statewide Grizzly Bear Management Plan (2022). The Executive Office of the President, Council on Environmental Quality released a memorandum to all federal departments and agencies on March 21, 2023 titled Guidance for Federal Departments and Agencies on Ecological Connectivity and Wildlife Corridors. Among its many goals and guidance are: •Assessments that may indicate natural and human-induced risk or threat level to components of connectivity •Identification of existing barriers or blockages to connectivity that could be removed •Removing, modifying, or avoiding the installation of barriers to wildlife movement along migratory routes Wolf-Furbearer trapping represents a conflict with the Linkage management emphasis. Incidental, but illegal taking of migrating animals including grizzly bear and lynx have been documented throughout Montana. Grizzly bears have been documented to have been trapped, injured and killed by traps set for numerous species including marten, wolves, bobcat (Lynx rufus) and coyote (Montana Fish Wildlife & Parks 2022; Lamb et al. 2022; Bader et al. 2023) and lynx and wolverine bycatch has also been documented. These conflicts have arisen to the point that the State of Montana and the U.S. Fish and Wildlife Service have been notified they may be sued for Endangered Species Act violations for failing to prevent it (Flathead-Lolo-Bitterroot Citizen Task Force May 9, 2023). Figure 9. The Sourdough-Hyalite Areas Are Within a Primary Linkage Area for Both Male and Female Grizzly Bears. Sells, et al. 2023. In Review. 8 Comparative Analysis For comparative analysis, the Rattlesnake National Recreation Area on the Lolo National Forest on the edge of Missoula was found to be the most analogous to the Sourdough-Hyalite within U.S. Forest Service Region 1. They are similar in size, both have heavy public use and they access higher elevation congressionally designated Wilderness or Wilderness Study Area. Both are on the doorstep of a major urban area and outdoor recreation and tourism hub with a University and an active outdoors constituency. One difference is that the Hyalite Recreation Area has vehicle access by road and has five developed campgrounds and several other signed campsites. There are two Fishing Access Sites, two Picnic Areas, two Trailheads and a rental cabin. These all amplify the potential for conflicts with trapping. The less-developed Sourdough-Bozeman Creek also has heavy use and a former roadbed for a trail that accesses the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area and like the Rattlesnake, is part of a major linkage and habitat connectivity area for grizzly bears and lynx. There is a rental cabin at Mystic Lake and the Sourdough Creek Trail provides access to dispersed backcountry camping. By regulation the Rattlesnake National Recreation Area is closed year-round to all trapping and rifle shooting including rifle hunting while bow hunting is allowed. The Pattee Canyon and Blue Mountain Recreation Areas on the Lolo National Forest adjacent to Missoula are also closed to all trapping year-round as well as rifle hunting and recreational shooting. Specific to trapping management rules for the Rattlesnake National Recreation Area and adjacent Forest Service lands state: “The following are prohibited in the described areas: Predator (including but not limited to coyote, weasel, skunk and civet cat) and all non-game wildlife (including but not limited to badger, raccoon, rabbit and fox) trapping year-round in the Rattlesnake National Recreation Area and South Zone (36 CFR 261.58(b).” There were conflicts between trapping and cross-country skiers at the Lake Como Recreation Area on the Bitterroot National Forest where several dogs were caught in traps. As a reactionary measure this resulted in this Winter Recreation Area being closed to trapping by regulation. The Custer Gallatin National Forest has previously taken actions to reduce conflicts in the Hyalite that are analogous to the conflicts created by trapping. “In 2013, the Custer Gallatin National Forest implemented a ½ mile shooting restriction on either side of Hyalite Road. This restriction was established to address safety and resource management concerns. The density of people and infrastructure needed to accommodate diverse interests and uses, resulted in the drainage needing a closure to provide for the safety of all users in this part of the Custer Gallatin National Forest.” (CGNF) “The Forest is proposing a permanent closure to recreational shooting in the Hyalite drainage…The issuance of a yearlong closure is necessary to provide for public health and safety. The narrow geography of this glaciated valley, the density of roads, trails and developed and undeveloped sites, and the volume of people who recreate in this area make it unsafe for unmanaged recreational target shooting. The size of this closure has been reevaluated and determined to be the smallest necessary to protect the safety of users within this area and the infrastructure located in the Hyalite drainage.” (CGNF). 9 As the Custer Gallatin National Forest concluded with recreational shooting, even a half-mile setback was not sufficient to protect public safety and visitor enjoyment. A dog capture led to the establishment of the 500-foot setbacks from main trails in the Hyalite-Sourdough area but this is inadequate and leaves people and pets vulnerable while engaged in activities that are designated as off-leash areas for dogs. A dog can cover this distance very quickly. Very few if any trappers are able to accurately pace off 500 feet from a trail. The 500-foot setback for trapping is arbitrary and insufficient and as shown in Figure x covers a fraction of these heavily used areas. Montana regulations require a 1000-foot setback from all campgrounds, picnic areas and fishing access sites. The Sourdough-Hyalite area receives heavy day use outside of campgrounds, picnic areas and fishing sites and this use is dispersed over a large geographic area, is year-round and overlaps all trapping seasons. However, water sets can be placed just 50 feet from Fishing Access sites, trailheads and other public facilities and there are no setbacks from trails. Allowing water sets just feet away from major trails is irresponsible in an area where children and pets are commonly present. Figure 10. Allowing Water Sets Where Children and Pets Play is Irresponsible. Footloose Montana photos. Since Montana has no specific trap checking requirements, dead animals caught in traps could be submerged within Bozeman Creek for days, compromising the City of Bozeman municipal water supply. These precedents within Region 1, U.S. Forest Service identify potential courses of action for reducing conflicts in the Sourdough-Hyalite areas. Deconfliction With Recreational Use “Hiking and walking are the most popular dispersed recreation activities on the Custer Gallatin National Forest by quite a wide margin.” (CGNF). Deconfliction strategies should be weighted towards the vast majority of users as they were in the Rattlesnake National Recreation Area. By contrast, very few Montanans engage in trapping. The public has already shown preferences within Sourdough-Hyalite that protect themselves and their dogs. Public support led to the ban on recreational shooting. The sheer numbers and density of users throughout the entire Sourdough Canyon-Hyalite Recreation Emphasis Area require deconfliction with trapping. There are a few potential approaches to providing for public health and safety. 10 •Require dogs to be on leash in all areas. This is socially unacceptable. The Bozeman area is a very dog- friendly culture and the public has already voiced its support for off-leash rules for dogs and dogs accompany people in all seasons. Conflicts with dogs led to the current 500-foot setback from all main trails. •Within the Sourdough-Bozeman Creek the canyon channels use along the trail until the loop around Mystic Lake. This roadless area is within the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area and the Gallatin Linkage Area and management emphasis includes connectivity for movements of animals including grizzly bear and lynx. It is recommended that the Sourdough Canyon be closed to all trapping and snaring including water sets year round from the Trailhead to Mystic Lake. The closure area would extend to the top of the Canyon on either side of Bozeman Creek and completely around Mystic Lake. This comports with the precedent set in the Rattlesnake National Recreation Area and the Pattee Creek and Blue Mountain Recreation Areas on the Lolo National Forest. In all other areas within the Gallatin Linkage Area it is recommended that setbacks from all trails extend to 1000 feet on either side of the trail. •Within the Hyalite area expand the setbacks from all roads and trails to the ½ mile originally used for managing recreational shooting. This would prohibit trapping in a large portion of the Recreation Area and provide additional deconfliction, or, •As with the closure to recreational shooting the Custer Gallatin National Forest may find that the entire Hyalite area is “the smallest necessary to protect the safety of users within this area.” There is very high- density use and much off-trail use in all seasons including dispersed camping so that an alternative approach is to close the entire 34,000 acres year-round to all trapping, snaring and water sets. This is the precedent which was set in the Rattlesnake National Recreation Area and the Pattee Canyon and Blue Mountain Recreation Areas on the Lolo National Forest within Region 1. Deconfliction With Wildlife Connectivity Within the Gallatin Linkage Area including the Sourdough Creek watershed the following changes to trapping regulations are recommended to prevent bycatch of non-target wildlife species. • Body-gripping traps, especially those set for marten and weasel (Mustela), are a threat to grizzly bears causing serious injury including amputation of feet and toes, bone loss and death. A study in British Columbia (Lamb et al. 2022) found that ≈ 7% of all grizzlies in their study sample had missing toes on front paws. A major cause was bears sticking their feet into baited body-grabbing traps for marten. To prevent bears from having their feet caught in traps set for marten, Lamb et al. recommend that the elevated cubby boxes have openings large enough to pass a marten but too small for a bear to fit a whole foot through. In Montana, there are no regulations or recommendations specific to preventing bycatch of grizzly bears. All traps set for marten and other furbearers should be required to have a closed front and an opening no larger than 2.5 x 2.5 inches. 11 • In Montana, snares for most species are required to break loose with more than 350 pounds of dead pull strength) while for wolves this requirement is 1,000 pounds (Montana Fish Wildlife & Parks 2022). However, Lamb, et al. (2022) found that on average an adult grizzly bear has about 342 pounds of dead pull strength, not enough to break free. Cubs and sub- adults with less pull strength are particularly vulnerable. To prevent bycatch, injury and death, trap size and strength must be tailored to the target species and have no more hold strength than necessary for the target species. The largest traps including snares should be required to break free with no more than 300 pounds of dead pull strength to prevent holding grizzly bears. A significant amount of trap bycatch of grizzly bears, lynx and other wildlife is due to snares (Montana Fish Wildlife & Parks 2022). The use of snares should be prohibited on public lands. • Within lynx critical habitat or protection zones, use of fresh meat for bait is not allowed but tainted bait meat defined as being exposed to temperatures above freezing for 24 hours is allowed and these scents can be detected by grizzly bears from very long distances, even miles. The use of fresh and tainted meat as baits should be prohibited within grizzly bear habitats. •Conibear “body-gripping” traps are allowed in grizzly bear habitat if they have a jaw spread less than or equal to 5” and can be elevated at least 48” above the surface. These are well within the reach of even a subadult grizzly bear and wide enough to catch a front foot. The jaw spread of conibear traps within grizzly bear habitat should be less than 4”. • To prevent serious injury or death to a grizzly bear, it must be released within 24 hours (Cattett et al. 2008). Wolf traps are required to be checked every 48 hours but for all other species Montana Fish Wildlife & Parks only recommends checking traps at least once every 48 hours but does not require it. Montana is only one of three states in the U.S. that does not have mandatory trap check requirements. Many traplines are only checked once a week meaning grizzly bear and other species bycatch could go undetected for days causing extreme suffering and trauma before death. It is recommended that in all circumstances for all species it be required that traps be checked at least once every 24 hours. • With climate change, it is predicted that grizzly bears will enter the den later and emerge earlier (Pigeon et al. 2016). As recommended by Lamb et al. (2022) the opening of trapping seasons for furbearers should be delayed to avoid trapping grizzly bears as they prepare to den. Everywhere that grizzly bears may be present should be off-limits to wolf trapping using snares, traps and bait from March 16 to December 31 when Figure 11. Grizzly Bears With Their Feet Mangled by Traps Set for Other Wildlife. Lamb, et al. (2022) photo. 12 grizzly bears may be outside of their dens. Trapping seasons for otter, muskrat and mink currently run from November 1-April 15. To avoid attracting pre and post denning grizzly bears, these seasons should be adjusted to December 31-March 16. Recreation use is not without blame when it comes to conflicts with connectivity. A host of scientific studies have shown that recreational use, including by mountain bikers can displace grizzly bears and other wildlife from productive habitats. The Custer Gallatin National Forest has reached the false conclusion that high recreation use has no effects on migrating wildlife including wide-ranging species. Recreation use must be studied and limited if found to have substantial impacts on native wildlife. Conclusion As human population and recreation use increase, so will conflicts between recreation, wildlife connectivity and wolf/furbearer trapping unless actions are taken. Trapping is an inconsistent use in an area with very heavy use including off-trail use and where dogs are allowed off-leash. While the U.S. Forest Service has banned trapping within the three recreation areas on the doorstep of Missoula, they have not taken similar action in the recreation areas on the doorstep of Bozeman. Prohibiting trapping within the designated Hyalite Recreation Area and the Sourdough Canyon and restricting trap methods in the Gallatin Linkage Area will reduce the potential for conflicts with people, pets and migrating wildlife. A fundamental aspect of trapping is its indiscriminate nature which is exacerbated by the inadequate trapping regulations promulgated by the State of Montana. Traps set for marten and coyote catch bears, lynx, wolverine and other threatened and sensitive species. Failure to resolve these conflicts will result in more bycatch of pets, sensitive and threatened wildlife species leading to further loss of support for trapping on public lands and an increase in the number of states that ban or restrict this activity. The Sourdough-Hyalite landscape is ill-suited to furbearer trapping due to both the volume of recreational use and the nature of that use and the fact these are designated as off-leash areas for dogs. Wolf-furbearer trapping is inconsistent with the primary purposes for which the Hyalite Recreation Emphasis Area and Gallatin Linkage Areas were designated by the Custer Gallatin National Forest and inconsistent with the management of other designated Recreation Areas in U.S. Forest Service Region 1. Both the U.S. Forest Service and the State of Montana are legally liable for damages should a child or any member of the public be injured by a trap which they allowed to be there. The U.S. Forest Service and the State of Montana have a responsibility to resolve this ongoing threat. The Custer Gallatin National Forest has the authority to unilaterally close these areas to trapping pursuant to CFR 261.58 – Occupancy and Use. The recommended deconfliction strategies are necessary to ensure public health and safety, the life and safety of pets and visitor enjoyment. 13 Sources Used Bader, M. and 27 others. 2023. Comments on the Draft Montana Statewide Grizzly Bear Management Plan. 68p. Cattett M, G Stenhouse and T Bollinger. 2008. Exertional Myopathy in a Grizzly Bear (Ursus arctos) Captured by Leghold Snare. Journal of Wildlife Diseases 44(4):973-978. Craighead, F.L. 2015. Wilderness, Wildlife, and Ecological Values of the Hyalite-Porcupine Buffalo Horn Wilderness Study Area. A Report for the Lee and Donna Metcalf Foundation. Custer Gallatin National Forest. 2022. Land Management Plan. 247p. Custer Gallatin National Forest. 2017. Assessment Forest Plan Revision Final Recreation Settings, Opportunities, and Access Report. 54p. Custer Gallatin National Forest 2022. Hyalite Drainage Proposed Permanent Recreational Target Shooting Closure June 2, 2022. Lamb C, L Smit, B McLellan, LM Vander Vennen and M Proctor. 2022. Considerations for furbearer trapping regulations to prevent grizzly bear toe amputation and injury. Wildlife Society Bulletin e1344. Newmark WD, Halley JM, Beier P, Cushman SA, McNeally PB, Soule’ ME. 2023. Enhanced regional connectivity between western North American national parks will increase persistence of mammal species diversity. Scientific Reports (2023) 13:474. Peck, C. P., F. T. van Manen, C. M. Costello, M. A. Haroldson, L. A. Landenburger, L. L. Roberts, D. D. Bjornlie, and R. D. Mace. 2017. Potential paths for male-mediated gene flow to and from an isolated grizzly bear population. Ecosphere 8(10):e01969. 10.1002/ecs2.1969 Pigeon et al. 2016. Pigeon KE, G Stenhouse, SD CÔTÉ. 2016. Drivers of hibernation: linking food and weather to denning behaviour of Grizzly Bears. Behavioral Ecology and Sociobiology 70:1745–1754. Sells, et al. 2023. In Review. Biological Conservation. Walker, R. and L. Craighead. 1997. Analyzing wildlife movement corridors in Montana using GIS. In: Proceedings of the 1997 International ESRI Conference. U.S. Fish & Wildlife Service. 2018. NCDE Subcommittee. Conservation strategy for the grizzly bear in the Northern Continental Divide Ecosystem. 170p. + appendices. U.S. Fish & Wildlife Service. 2022. Grizzly Bear Occupied Habitat and May Be Present map. Grizzly Bear Recovery Office, Missoula, MT. White House Council on Environmental Quality. 2023. Guidance for Federal Departments and Agencies on Ecological Connectivity and Wildlife Corridors.