Reject the Elk Management In Areas With Brucellosis 2014 Work Plan

August 8th is the FWP Commissioners mtg, where they will vote on the Elk Management In Areas With Brucellosis 2014 Proposed Work Plan. This plan is basically the same open ended, do whatever you want to benefit certain ranchers, to hell with the wildlife biology and Montana hunters plan that was submitted to the Commission this spring, with some "Cover My Ass" thrown in. This "management" has been a debacle in my opinion. Please contact the FWP Commissioners to not approve the Elk Management in Area With Brucellosis 2014 Proposed Work Plan. fwpcomm@mt.gov

I read something interesting in the Bison EA, pg. 49, I thought I would share, since this pertains to elk and the northern elk herd, specifically elk HD 313, an area that is of concern involving the elk brucellosis management. Take a look at information provided by FWP wildlife biologists. This is an area that kill permits were issued to ranchers this spring, as part of the elk brucellosis management. HD 317, just north of 313 is where the dispersal hunts occurred.

Northern Boundary (HD313):
Hunting District 313 encompasses winter range for the Northern Yellowstone elk herd, a migratory herd that summers primarily within Yellowstone National Park and the Absaroka- Beartooth Wilderness. This population peaked during the 1980’s and 1990’s with a 10-year average of 15,304 during 1986-1995 and has been in decline since the late 1990’s. The highest number of elk observed during aerial surveys was 19,054 elk in 1994. The winter 2013 count resulted in 3,915 observed elk, a decline of 74% from the population average at its peak. The herd is counted cooperatively by Montana and Yellowstone National Park, and the portion of the herd that winters in Montana is managed with an objective of 4,000 elk. The 2013 count resulted in 3,000 elk wintering in Montana. The highest count of elk wintering in Montana was 8,626 in 1996 with a 10-year average of 5,444 during 1989-1998. Within HD 313 from 2004-2012, there has been an average of 1,344 elk hunters and 7,302 elk hunter days annually. The average number of elk harvested declined from 1,590 (average 2000-2006) to 259 (average 2007-2012). Hunting season structure is restrictive with antlerless harvest limited to 30 brow-tined bull/antlerless youth-only permits and unlimited permits for brow-tined bulls."

Points concerning the Work Plan

• "To date, local working groups (which are supposed to have representation by Sportspersons, Wildlife enthusiasts, Landowners that do not raise livestock and Livestock Producers) have not been identified in all areas." Meetings have been set up, of primarily ranchers, in their homes, obstructing sportsmens groups and excluding the other stakeholders required by the Commission. Complaint letters have been ignored, Montana Annotated Code 2-3-101 - 107 open meeting has been obstructed and resulting FOIA's only partially filled, contrary to Dir. Hageners directions.

• Again, the "Unknown number of..." aspects to this plan is not really a plan, but an opened ended recipe for continuing the practices that have been occurring with little accountability or transparency.

• Why has FWP used sportspersons dollars to supply stackyard fencing, hazing, kill permits, etc. to ranchers that do not allow public access hunting during the established hunting season as the Game Damage Program requires (Landowners may be eligible for game damage assistance if they allow public hunting during established hunting seasons. Assistance may include hazing, repellants, temporary or permanent stackyard fencing, damage hunts, kill permits, or supplemental game damage licenses.)? When this question was brought up by one of the Elk Brucellosis Working Group members at the July 11th meeting in Bozeman, Quentin Kujala quickly replied to them that they, the Working Group, did not include it in their Proposed Recommendations that the FWP Commissioners approved. I have a number of questions with this. 1. Why did not Quentin Kujala, FWP's representative and manager of this program point this out to a “civilian” working group when they were compiling their proposed recommendations? 2. Why did no other FWP representative reviewing this document before presentation point this out? And if they did, why was it not presented to the Working Group? 3, Why did the FWP Commissioners not add this as an amendment to the Proposed Recommendations to protect Montana Sportsmen, their access and their dollars coming into FWP? 4. Why is this still not required in this work plan?

• "Hunters will be selected using mechanisms "comparable" (this kind of ambiguity is what has been causing concerns.) to those used for game damage hunts." This should read, "Hunters will be selected from the Hunt Roster ("There is only one Hunt Roster and hunters from this roster may be identified for 3 types of hunts: Game Damage, Management Season, and Dispersal." - FWP website)."

• "Dispersal hunts will be accomplished as early as possible in the risk season..." This whole section should lead with a statement that IF there is a concentration of elk in a commingling situation, then..., not the open ended objective of accomplishing dispersal hunts as early as possible. In effect, what this sounds like is a Montana elk hunt season from Sept. 7th through May 15th. also, Julie Cunningham, FWP's Region 3 wildlife biologist warned in an email, "Furthermore, I think of the Madison-Gallatin herd as an example here. Elk move out of the Gallatin into the Madison during winter. The more we hunt during winter, the more we are reducing a herd which spends summer on public lands and is publicly accessible through early hunting season, AND which is BELOW objective. We could be really hurting our Gallatin herd by allowing post-February hunting. I do have radio-collar data showing mid-winter migrations out of the Gallatin to back this up."

• Gut pile management is crucial, IF this whole process is really about minimizing the risk of brucellosis transmission with cattle and other elk. This seasons gut piles were not managed. Why did Quentin Kujala and other FWP personnel familiar with the biology of brucellosis not insist on gut pile management? The only way a bull can transmit brucellosis to cattle is if he is infected (not just seropositive, showing antibodies to exposure), you kill him and then expose his lymph nodes and sexual organs to cattle or other elk. Likewise, with cow elk, with the addition of the birthing materials. There was one pregnant cow that was killed in this years "dispersal" hunts. This would have been a sure fire way, if she was infected/infectious to expose cattle and other elk to brucellosis.

• Why is there nothing in this document about kill permits and dispersal hunts in areas under objective? The Northern Elk herd has been in an average decline of 6-8 % each year for the last decade. Kill permits were issued in HD 313, which is 25% below objective, with yearling bull counts of .56% (less than 1 percent). The dispersal hunt occurred in HD 317 which is 16% below objective, with yearling bull counts of .9% (less than 1 percent). There were no cow/calf counts in HD's 314, 315, 317, and 393. There should be some restrictions against kill permits and dispersal hunts in areas with such a decline, focusing on other means to achieve the dispersal.

• Kill permit requirements should follow those of the fencing mentioned above - required public hunting during established hunting seasons and consideration of population numbers.

• Local Working Groups - should be established based on the multi stakeholder representation. I called all the conservation and wildlife advocate groups from Gardiner over to Bozeman and not one even knew about this group and had not been asked to participate. GWA had asked repeatedly to participate and was denied.

• The educational presentation needs some serious work to not look like and be presented as a livestock advocacy presentation, instead of a FWP wildlife presentation. Why is Quentin Kujala stating the inflammatory transmission risk time, from an abortion or birthing materials of brucellosis is 81 days? This is based on a worst case scenario test conducted by Keith Aune, Tom Roffe and others, which restricted any predation, sunlight and temps from normally affecting the bacteria. This has never been replicated in a natural brucellosis scenario. In fact at the Elk Working Group meeting on July 11th, Neil Anderson stated it was a race against the birds to get to an abortion event (notified by a VIT) and generally he lost. This inflammatory 81 day statement is not being qualified and is being used by ranchers as a war cry to eliminate elk and brucellosis from wildlife, even being incorporated on film, which is being passed around to the livestock community. Dr. Marty Zaluski, in public meetings such as the IBMP, has stated 21 days for the transmission period from an abortion. If birthing materials later in the season, the transmission period is even shorter due to temperature and sunlight.

• "Explore potential habitat management adjustments on WMA's and other lands and hunting season recommendations designed to foster adjusted elk distribution." This section sounds like it is more concerned with elk population numbers, wanting to apply increased elk tag numbers, which has no bearing on brucellosis transmission risks from commingling, especially in areas, such as Park County, that are in a decline. As far as the hunting to affect elk distribution, a recent paper, Effects of Hunter Access and Habitat Security on Elk Habitat Selection in Landscapes With a Public and Private Land Matrix, published 2013, written by FWP's Kelly Proffitt, et al should be considered. They found that elk cow security was affected by threats such as public land hunting and motorized vehicles, causing them to congregate on private lands, which is reducing the public land herds available to the public hunters. "Focusing harvest pressure on private lands currently restricting hunter access while limiting harvests on public lands may be an effective strategy for redistributing elk onto public lands in areas where elk distribution is focused on private lands with limited public hunting access." (pg. 10) This goes back to my earlier point of hunter resources being used for private ranchers that do not allow this public hunter access - its a lose/lose for he Montana sportsmen. Increasing nearby hunting on WMA's will only increase the elk population densities on the very ranches that they are wanting less elk populations on, to reduce the possible spread of brucellosis, which is not a threat during the regular hunting season anyway. So why is this really here, unless the objective is population control or to really drive the elk to the private lands during hunting season?

• As to "effective communication, education and outreach" with this Commission, the general public and landowners. I feel the Montana sportspersons should be included in this. I wholeheartedly agree. Y'all should be given the numerous documents from FWP wildlife biologists that you have been excluded from. Educating yourselves on these issues is necessary to your making wise wildlife management policy.

Please contact the FWP Commissions and ask them to reject this 2014 Elk Work Plan and call for an audit.

Kathryn QannaYahu

Montana's Elk Management In Areas With Brucellosis

The following post is a complex and interwoven subject, dealing with Montana's Elk Management In Areas With Brucellosis; the original 12 member Elk Brucellosis Working Group; the FWP Commission's adoption of the Proposed Final Recommendations on Jan. 10, 2013; the subsequent implementation of this program by Quentin Kujala who led the Elk Brucellosis Working Group; and the obstruction, lack of accountability and transparency in what should be a scientifically managed, multi-stakeholder public process concerning our public trust elk in Montana with the local elk brucellosis working groups. I highly suggest eating large amounts of organic dark chocolate to help process, of which copious amounts were utilized in the researching, analyzing  and presenting of this data for over half a year.

This article or any other similar action was not my first choice. It is the result of being forced to this action by numerous situations with some FWP employees, concerning myself and other concerned conservation sportspeople here in FWP Region 3. When you are confronted with the rejection of responsible wildlife science, excluded from the public process, stonewalled by the officials when you repeatedly protest these occurrences, when you have exhausted due process, you are left with the court of public opinion. Which is where I am at now. The purpose of this article is to bring awareness and thereby, hopefully, accountability and transparency to this process according to Montana Statues and the FWP Commission approved Proposed Recommendations. 

To make it easier to deal with the data, I have converted many documents obtained into PDF's and PNG's (you may need to zoom the image for better viewing) for universal viewing and printing. I hope that readers will look into the research and verify my statements, for I never expect anyone to just take my word for it. Beyond the verification, my greater hope is that Montana's conservationist sportspeople, wildlife and habitat advocates and general concerned public citizens will utilize the email links and phone numbers provided at the bottom to comment, question, complain to those in charge and fight for our elk, so that they do not go the way of the wild bison in Montana - hazed, shot, subjected to brucellosis test and slaughter, such as Rep. Alan Redfield suggested in his HB 312 - the elk brucellosis test and slaughter bill during this last legislation.There is  bigger picture here, which will have to be covered in a post all its own - the fundamental objectives of APHIS, USAHA and the DOL of eliminating brucellosis from known reservoirs - which includes elk.

July 11, 2013 is the next original Elk Brucellosis Working Group Meeting, that will review process and compile a report to the FWP Commission in Aug. There is only 1/2 hour public comment scheduled for this meeting.

Basic Elk Management In Areas With Brucellosis and Events Timeline

•  Fall 2011 - FWP and Commission initiate the Elk Management Guidelines in Areas with Brucellosis Working Group
• 1/12/2012 - a 12 member Working Group, chosen from over 40 applicants by FWP Director Joe Maurier, are notified of their acceptance. Noland and Raths are also ag/livestock, making 8 of the 12 members with ag/livestock interests.
• 9/11/2012 - FWP Commission tentative adoption of Working Group Proposed Recommendations
• 10/31/2012 - 1st FWP wildlife biologist comments against draft Proposed Recommendations. This one is a large list of points and very pertinent, "There are some points here that take us down some very dangerous roads. They are playing interests against one another, and I really have to wonder where the sportsmen’s voice is in all this. We could be paying landowners to fence out elk? Paying for vaccination? All the while reducing elk populations and thusly elk opportunities for sportsmen? I really hope that SOMEONE in our agency stands up to some of the points presented in here, or we may face some major problems in the future.", 2nd wildlife biologist comments. "Are livestock producers and other constituents willing to stand by this when other members of the public , MOGA, etc cry foul on us?" Neither of these statements were provided to the Working Group members, nor the FWP Commissioners. Names or identifiers have been blocked out to protect the conscientious biologists. Additional Science - Dr. Mark Albrechts chart (collaborated with Dr. Thomas Roffe) on Brucellosis Transmission from Elk Populations, Brucellosis Science Workshop Summary chart by Dave Hallac (YNP). 2012 Brucellosis Designated Surveillance Area (DSA). Zoom charts for better resolution.
• 14/11/2012 - Dr. Mark Albrecht's (member of the Working Group) letter to FWP Commission asking them to reconsider their vote on the Proposed Recommendations. This letter was first sent to Quentin Kujala to see if it should be passed on to the Commission members.
• 1/10/2013 - FWP Commission vote to approve Proposed Final Recommendations with commissioner's amendments. Dan Vermillion suggests that implementations go through Regional Supervisor and Regional Commissioner for authorization. Dan Vermillion is the Regional Commissioner. Commission minutes (page 5) verifying amendments and vote approval. At this point Gallatin Wildlife Association notifies FWP that they would like to participate in the local working group process.
• Feb.-April 2013 elk dispersal hunts take place, $2000 stack Fencing paid to ranchers with sportsmen dollars (1st request before Final Recommendations were even voted on, more fencing in Feb., county commissioner has bigger stacks, wants more money (at least two documented cases of fencing showed the ranchers did not allow "public hunting access for wildlife distribution and population management". I do not have the forms, as I requested, for the other cases, nor a listing of all the cases as I requested.) , hazing - hunt details below
• 2/15/2013 - 1st local brucellosis working group meeting at a Mill Creek rancher, Jim Melin's ranch, Friday Meeting, where 2 Gallatin Wildlife Association members (MWF affiliates), one of which Glenn Hockett the president, were on their way to Livingston to participate and are called, told they cannot attend that it is private, by FWP employee, directed by Quentin Kujala, approved by FWP Commission Chair Dan Vermillion as a "smart move".
• 4/22/2013 - 2nd local brucellosis working group meeting at Park County Rod and Gun Club. Again, invitation from one of the Park County Rod and Gun Club members is rescinded and we are told it is a private meeting by Quentin Kujala. Kathryn QannaYahu receives clarification from Pat Flowers, Region 3 Supervisor, that according to Montana Statutes, this is a public meeting while the FWP employees are there and presenting. She takes Montana statues and goes to meeting anyway, despite Kujala's obstruction and is admitted to meeting. See email below for this verification. Kujala stated he checked with legal beforehand, but in a conversation with Dokter, not knowing Kujala stated this, she confirmed it was a public meeting while FWP was there. Montana Annotated Code
• 4/24/2013 - Kathryn QannaYahu, as a concerned member of the public,conservation hunter and wildlife advocate emails official complaint letter concerning local working group meeting's obstruction with Quentin Kujala, Ken McDonald, Pat Flowers and Dan Vermillion. Kujala replies to recipients, "to make no response." No response was ever made by these officials, which prompted the Information Request.
• 5/3/2013 - Kathryn QannaYahu files official Information Request Relating to Elk Management in Areas of Brucellosis with FWP Director Jeff Hagener. Hagener forwards request to Ken McDonald stating, "We need to comply with this request". Ken McDonald forwards to Quentin Kujala stating, "My first inclination is to send her to the website where the workgroup documents were placed. If she comes back for more..."
•  5/24/2013 - Kathryn QannaYahu receives a CD in the mail with 388 sporadic emails, a fraction of the requested documentation.
• 6/14/2013 - After trying to call FWP Dir. Jeff Hagener about obstruction and partial Information Request fulfillment, Kathryn QannaYahu is told Hagener will not be available until mid-July, call is forwarded to FWP attorney Rebecca Jakes Dockter, who advises to send Hagener another Information Request email outlining the missing documentation. Email is sent and according to return receipt, opened at 8:31 PM. This has not been fulfilled.
• 6/24/2013 - Realizing I forgot to include the hunt roster information request in the unfulfilled information request, I sent another.
• 7/1/2013 - Hunt Roster reply from Dokter, via Kujala.
  HD 317 (zoom to see clearly), HD 560 . Actually, anyone without a legal degree, reading my request will be able to see, once again, I have not received all of what I asked for - order the rosters were at, as of January 10th, which hunters were utilized on which dates since then - to current date, where they hunted, what the classification of the hunt was labeled (game damage, dispersal, etc.) and what they harvested.
• 7/4/2013 - Rest of documentation has still not been received, nor any response to obstruction process by Hagener.

 Dispersal Hunt partial details. Due to the fact that I only received a small portion of my Information Request, I do not have complete details of this process. Here is what I do have. But first, I would like to lay some groundwork on this subject. 

On March 8, 2013, Brett French wrote an article, Northern park elk population still dropping. Wolf biologist Doug Smith and FWP biologist Karen Loveless are quoted concerning the declining elk numbers in the northern elk herd. The numbers this year are listed as being a 6% decline. The average decline is 8% in recent years.

"FWP counted only 11 calves per 100 cows last year, said Karen Loveless, an FWP biologist based in Livingston.'That’s really poor,' she said. 'As long as we have calf survival that low, I’m still really concerned.' To maintain the elk population, she said, calf recruitment would have to double to about 20 percent. To increase the herd, the recruitment rate would have to rise to 30 percent. The northern herd has been below that 30 percent rate for more than a decade, she added. 'Our objective for northern range elk wintering in Montana is 3,000 to 5,000,' Loveless said."

As a result of this article, in conjunction with my working group research I requested this years elk survey. Karen Loveless had not finished the final survey report but sent her stats.   The Mill Creek hunt was in HD 317. MAP (zoom). Recommendation for dispersal hunt at Mill Creek. 317's objective was 900. The count was 756. In the previous years report from Karen, she writes of district 317, "In 2012, 651 elk were observed, compared to 908 elk observed in 2011, 636 elk observed in 2010, and 937 in 2009. This count is 28% below the Elk Management Plan objective of 900 elk." This years count of 756 is 16% below objective.

Elk Management update PDF's recently released by FWP Region 3, Region 5

So why if the herd is in decline and these districts are below objective, is FWP having elk dispersal hunts there? 

Email from Kujala, dated May 2, 2013, 

"Sirs—
I have heard from Rep. Redfield (Paradise Valley). He is complimentary of the current brucellosis-related efforts that include the late season dispersal hunts in Regions 3 and 5. I also understand he is interested in a summer meeting with landowners to talk about an extended cow hunt. Not really sure if this means the next iteration of dispersal hunts or an antlerless elk hunt that is defined more within the context of biennial season setting. Regardless, something we should visit on—for now I offer this as an FYI for you to contemplate and prepare for any next conversation we need to have. Please forward to your staff as you see fit. Obviously one possibility here is an interaction with the 5-week season discussion.
Thanks and sorry, Q"

This is the same Rep. Alan Redfield that sponsored the  HB 312 elk brucellosis test and slaughter bill this year. He is also one of the Paradise Valley ranchers contacted by FWP for the first rancher local working group meeting.
 

Recent (July 2, 2013) email from Dr. Bill Mealer, a member of the Safari Club, to other Safari Club members, adding FWP Commission Chairman Dan Vermillion (Livingston resident), complaining about the late dispersal hunts. Vermillion states that he authorized the Mill Creek hunts.


Elk Brucellosis Talking Points/Questions

Are after Feb 15 hunts a good idea?

What do the biologists think? (At least 2 commented negatively in internal letters)

Should hunts be implemented without open and transparent public discussion involving all 4 interest groups identified by the working group? (Hunters, livestock producers, wildlife enthusiasts, and non-livestock producing landowners) 

What was done with the gut piles? (leaving fetuses behind may actually increase the risk of transmission)

Since the game damage hunt format is being used did the landowners allow public hunting during the general season? ( What is public hunting?  Block management?  The neighbors?  Relatives?  This needs to be defined and checked)

Is there any conservation easement on the property by any organization that allows for winter range use? (If the landowner has previously been compensated for winter range use we question spending more sportsman dollars.)

Were other options tried first? – hazing, fencing?

Cost of implementation and if any of the cost was paid for with anything but sportsman dollars– biologist and staff time, fencing cost, hazing cost. (Fundamental objective #3 is cost effectiveness)  How many sportsman dollars are being spent?  And staff/biologist time counts,  as it appears they spend extensive time trying to appease livestock producers.

What license was used by those participating? – for the later hunts it appears the 2012 license would have expired so was a 2013 tag used?

Did the hunts keep the elk away?

Is the area at or below objective? ( if below should we be harvesting more elk?) HD 313 we are BELOW objective by 25% and HD 317 we are BELOW objective 16% (according to the local wildlife biologists statistics), yet hunts took place.

Were blood samples collected? 

What has been done to create an educational presentation for potential working groups utilizing responsible science and wildlife management, not politics?  ( Having good information that represents science is important if any group is to make headway on this problem) 

Is a rancher’s kitchen table the appropriate place to have meetings?  Will the result be equitable and fair?  Are all parties represented?  Is FWP seeking long term solutions or just hoping to give the rancher something? 

So are these working groups or deals between FWP and ranchers?  I think that needs to be clear.  Don’t call this a public process if it is not – remember members of the MWF affiliate Gallatin Wildlife Association were told on two occasions NOT to attend these meetings and complaints citing Montana Statutes public process were ignored by FWP officials.

Bottom line:

Open and transparent meetings and communication involving all interested user groups is the only way to achieve a long-term solution. (Numerous conservation/wildlife advocate groups were contacted to see if they were contacted, any time after Jan. 10, 2013, by FWP for their participation in this local working group process. All have stated they were not and were not even aware of what was going on here in FWP Region 3 and 5. They are becoming aware now.)

Since we are seeking to minimize transmission and not to eradicate, this will be a challenging process.  We must push to minimize transmission NOT to eradicate.  The first fundamental objective is minimize transmission.  HB 312, introduced by Rep. Alan Redfield, sought to eradicate. Several FWP e-mails seems to really focus on Rep. Redfield’s desires.  He needs education NOT appeasement.

Official Contacts for questions, comments and complaints
I would highly suggest carboning a witness for accountability, since obstruction has been seen in some cases.

Governor Steve Bullock - 406-444-3111   governor@mt.gov

Tim Baker, Policy Advisor for Natural Resources - 406-444-7857  tbaker@mt.gov

FWP Commissioners - (406) 444-7826   fwpcomm@mt.gov
District 1, Gary J. Wolfe - (406) 493-9189 
District 2, Dan Vermillion - (406) 222-0624 dan@sweetwatertravel.com
District 3,  Richard Stuker - (406) 357-3495
District 4, Lawrence “Larry” Wetsit - (406) 650-7071
District 5, Matthew Tourtlotte - (406) 698-9696

FWP Director Jeff Hagener - (406) 444-3186  jhagener@mt.gov
FWP Deputy Director Mike Volesky - 406) 444-4600  mvolesky@mt.gov

Ken McDonald, Bureau Chief - (406) 444-5645  kmcdonald@mt.gov

Quentin Kujala, Wildlife Mngmnt Section Chief - (406) 444-5672  qkujala@mt.gov

Pat Flowers, Region 3 Supervisor  -  (406) 994-4050  PFlowers@mt.gov



Main Elk Brucellosis Working Group Members

Mr. Mark R. Albrecht - mralbrecht62@gmail.com 
Mr. John C. Anderson - jck@3rivers.net
Mr. Ed Bukoskey - goosehaven@rangeweb.net 
Mr. Joe Cohenour - utopiamt@optimum.net 
Mr. Rick Douglass - RDouglass@mtech.edu 
Mr. Rick Gibson - rgrs@wispwest.net 
Mr. Lorents Grosfield - lorents@mcn.net 
Mr. Ken Hamlin - knphamlin@bresnan.net 
Mr. Raymond Marxer - ramarxer@gmail.com 
Mr. Charlie Noland - chrlsnoland@yahoo.com 
Mr. William Raths - dick.nancy.raths@gmail.com 
Mr. C. Thomas Rice - trice@beaverheadcounty.org



Here's to accountability and transparency in Montana's Elk Management In Areas With Brucellosis.




Kathryn QannaYahu, concerned member of the public, conservation naturalist hunter and fisher (I have done primitive net and basket fishing to learn how, so I cant just say angler), wildlife advocate with traditional ag/livestock background now converted to organics and sustainability. Did I leave anything out? Oh yeah, Gallatin Wildlife Association and Montana Wildlife Federation member (but not writing this post on their behalf).
katqanna@gmail.com