Recreation Management Use on the Madison River

 

Recreation Management Use on the Madison River

Dear FWP Commissioners:

The Montana Sportsmen Alliance (MSA) submits the following specific to the Environment Assessment (EA) for Recreation Management Use on the Madison River. 

MSA believes this process has taken far too long to complete and FWP continues to “kick-the-can” down the road. It is time FWP and the Commission adopt rulemaking which supports the Madison River Recreation Goal. MSA supports the three components of the goal, but believes all actions must first and foremost support long‐term health and sustainability of the fisheries. FWP data documents large fish are declining and angler satisfaction continues to deteriorate. Fish mortality resulting from hooking, angler satisfaction, impacts of commercial and non-commercial use, and changes in fish populations have been studied for many years. Data is abundant to move forward and make an informed decision.

Specific to the EA presented, we offer the following:

The GGTU proposal provides the greatest potential for meeting the goal for Recreation Management of the Madison River. If only one of the three alternatives is selected for adoption, we support the GGTU alternative. MSA believes additional and new actions not identified in the EA should be considered and proposed management actions modified, including:

Utilizing 2019 or 2020 client use days as a base is proposed by both FOAM and the GGTU. FWP’s own data suggests this level of use will not sustain the fisheries in the Madison River. A much lower base should be utilized. For example, consider averaging the number of client use days from 2010-2015 as a base level. The litmus test for whatever level of use is allowed, must be whether the fisheries can be maintained or improved.

MSA opposes the creation of “flex trips” that would allow outfitters to exceed their caps in two of any three years.

It has been stated commercial use accounts for only 15% of the overall angler use on the Madison River. While this may be true, in the months of July/August commercial use accounts for over 90% of the total use on some reaches. This information needs to be clearly displayed.

The use of a No Cost/No Limit Madison River Use Stamp may provide data useful to FWP in making future decisions. MSA questions the need to wait until after two years of data has been collected and analyzed before making a decision on future management. In addition, trigger points and the associated resulting management should be identified prior to adopting a “use stamp”.

We question the need to limit development of additional FAS acquisitions below Greycliff. Wouldn’t additional FAS’ help to distribute angler use? Development of additional FAS’ on the lower portion of the Madison River, if coupled with limiting commercial and potentially non-commercial use may help to achieve the goal for recreational use on the Madison River.


If use by commercial outfitters and their clients is in conflict with non-commercial user, please consider eliminating or greatly reducing the permitted outfitters who reside outside of Montana. On any given day there is a steady stream of vehicles pulling drift boats coming from Idaho to fish the Madison River. We believe these outfitters and their clients spend few dollars in Montana, except for the fishing licenses purchased. Client use days should be prioritized for Montana outfitters. This will help protect Montana outfitter and guides and support those communities dependent on commercial fishing use.


If sustainability of the fisheries cannot or will likely not be achieved through limiting commercial use, the EA must address placing limits on non-commercial use as well. This has been adopted on other rivers in Montana and non-commercial fishermen would adapt. FWP limits the number of big game permits issued in an effort to maintain populations and hunter satisfaction; why should fishing on the Madison River be different?

The walk and wade section should be just that. There should be no allowance for floaters to transect these sections of the Madison River ever. If their clients want to fish this section, do what many others do, hike into the areas.


If realistic reductions were placed on the number of client use days allowed, there would not be a need for rest-rotation. Rest-rotation places a burden on many outfitters and if other management actions were put into play, this simply is not needed. In addition, rest-rotation may simply shift a significant number of those client use days to other stretches of the Madison or other rivers, further exacerbating over use on those areas.


We do not support the need for FWP to hire “Rangers” for the traffic control of FAS’. There are too many FAS’ currently to adequately patrol and public education is a better and cheaper tool, and quite simply we do not believe FWP can afford this expenditure.


More clarification is needed related to the monetization of client use days and how this would be determined. MSA is strongly opposed to any such value and “right” placed on client use days. Monetization of these client use days, would make for sale a public resource, which MSA is opposed. Monetization would essentially would make it extremely difficult for a new outfitter to enter the business. These client use days were not purchased by current outfitters and as stated previously, we are opposed to the monetization of a public resource. FWP must require of transfer of any outfitter permit comply with current state law 47-37-310(4)MCA.


In summary, MSA appreciates the opportunity to comment on this proposed rulemaking. We ask you to consider points identified above and other ideas received in the final rulemaking. MSA welcomes the opportunity to assist and will continue to comment as opportunities are provided.

Sincerely;

MSA Leadership

John Borgreen
Joe Perry
Jeff Herbert
Don Thomas
Laura Lundquist
JW Westman
Steve Schindler
Robert Wood
Sam Milodragovich
Doug Krings
Dale Tribby