Thursday, September 5, 2013

Public Comments Needed For 2014 Work Plan for Elk Management Guidelines in Areas with Brucellosis

The open ended, "unlimited number of..." 2014 Work Plan for Elk Management Guidelines in Areas with Brucellosis (actually an outline - not a plan) was accepted by the FWP Commission on August 8th. If the hunter / conservationists of Montana do not speak up and protest this "plan", it will become the default plan and will be used as the same open ended plan that was used this year. The elk work plan can be found on pdf at the link below, but I suggest sending your comments to   rather than using the electronic form, which does not give you a copy of what you submit. The deadline for comments is Friday, Sept. 13th, 2013, at 5PM.

A work plan was supposed to be created by a local elk brucellosis working group, but due to the fact that the administrator of this program bypassed the Jan. 10th, 2013 Commission approved Proposed Recommendations, concerning the establishment of local working groups, no local working group work plan could be submitted to the FWP Commission. This is what they got instead - an outline. A "plan" is generally defined as a program or method with a stated goal and objectives to meet that goal, not the "unlimited number of...". 

Background information on what took place in 2013:

Points concerning this plan can be found below.

2014 Work Plan for Elk Management Guidelines in Areas with Brucellosis

  1. Local Working Groups: It is crucial that there be implementation of the Elk Management Guidelines In Areas With Brucellosis Working Group Proposed Final Recommendations: Fundamental Objective # 2 - local working groups (collaboration of diverse representation - Sportspersons, Wildlife Enthusiasts, Landowners, Livestock Producers and other resource or land management agencies). "All would be open meetings." Montana Annotated Code 2-3-101-107
  2. Fundamental Objective # 3: Maximize Cost Effectiveness: These so called Dispersal "Hunts", hazing and rancher stackyard fencing efforts all utilize Game Damage forms and models, yet do not have the requirements of the Game Damage program Montana Annotated Code 87-1-225: "Regulation of wild animals, damaging property ---public hunting requirements. Landowner is only eligible for game damage if...allows public hunting during established hunting seasons..." This is not cost effective for sportsmen if they are not receiving public hunting access in exchange for these services. 
  3. Fundamental Objective #1: Minimize Transmission from elk to livestock - needs to focus on Habitat, increasing vegetation on WMA's and public lands to attract and retain elk (elk security to restore public herd), look at reducing grazing on FWP WMA's to provide more forage for wildlife, as well as evaluate later release dates to not interfere with elk calving.
  4. Dispersal Hunts: the word "hunt" should not be used. This is not a fair chase hunt situation, it is not ethical hunting, it is a removal. No dispersal removal activity should occur after Feb. 15th, the time period established for ethical hunting considering the gestation period of the cows. Also, no removals should occur in areas that are in decline/under objective. Removals should not be a first choice, but rather a last resort, if that.
  5.  Brucellosis: While capture, test and slaughter was added to the draft Proposed Recommendations in 2012, by the FWP editor, it was objected to by the original Working Group and removed for the Final Recommendations. This needs to be adamantly maintained, in light of the ranching community calling for capture test and slaughter, as well as legislative efforts to make it law. Dispersal hunts should not mimic this policy under another name. Gut piles from removals should be managed so that if an elk was infected, any possible brucella in birthing materials, lymph nodes and sexual organs does not present a mode of transmission to cattle or other elk, which would be counter productive to this program (gut piles were not managed in 2013). In addition, FWP is signed on to the IBMP 9 objectives, point 4 being "Commit to the eventual elimination of brucellosis in bison and other wildlife." The only other wildlife in Montana that carry Brucella abortus are our elk. FWP needs to remove themselves from this objective. In addition, USDA and its subsidaries such as APHIS, as well as the MTDoL are promoting and pushing the immunocontraceptive sterilization of our wildlife. This elk brucellosis management plan needs to reject any efforts by the ag/livestock interests in promoting immunocontraceptives or vaccines as a means of minimizing transmission of brucellosis to livestock. "Humans have rarely (if ever) eliminated a disease from a wildlife population without eliminating the wildlife population of concern."
  6. Managing for Wildlife: A number of FWP wildlife biologist and peer agency papers and comments concerning the elk brucellosis management plan stated repeatedly that FWP should not be managing elk like livestock, but as wildlife. 
  7. Education: There needs to be a concerted effort to produce wildlife management supported educational materials for the public, not this worst case scenario study quote of 81 days (last time I heard the presentation to the FWP Commissioners it was up to 100 days, which has never been duplicated in natural conditions) that brucella remains on the landscape. Even the MtDoL states 21-26 days. 81 or more days is inflammatory and counter productive to the goal of maximizing acceptability of the disease in wildlife and the elk populations. Also, much of the current presentation is advocating the business of the livestock industry and their interests. FWP is in the business of managing Fish, Wildlife and Parks, not livestock.  

Please contact  with public comments on this 2014 Work Plan For Elk Managment. The deadline for comments is Friday, Sept. 13th, 2013, at 5PM.

Kathryn QannaYahu

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