Is Governor Bullock sanctioning test and slaughter of Montana's elk, bison, moose and deer?

At the Interagency Bison Management Program on November 21, 2013, MT DOL's State Veterinarian stated, during the Brucellosis Seroprevalence discussion, that they would be conducting a capture, test, slaughter and vaccination program with the wild bison exiting Yellowstone National Park, beginning this February. Familiar with the academic papers on the unrealistic and uneconomical subject, as well as the 0.0-0.3% risk that wild bison could possibly transmit the livestock disease brucellosis, back to domestic cattle (no documented case of wild bison to domestic cattle transmission has ever occurred in the wild), I emailed Governor Bullock, to share the science with him, in hopes that he would stop the DOL's 2014 slaughtering of thousands of bison as they exited the Park, as they did in the winter of 2005/2006 and again in 2008. The reply I received, which turned out to be canned, was such a factual, politicized disappointment involving elk and bison, I had to write a rebuttal to correct all the literal bullshit. Below is my reply, with Governor Bullocks email following. I have also included my original bison vaccination citations email below his. So if you like to read in chronological order, start at the bottom. I have received no reply from the Governor's office from this Dec. 26th rebuttal email.

Additional notes, I have repeatedly requested Montana's official position on brucellosis in wildlife, including the Governor's office, and received no such policy statement. I have also researched and uncovered documents that show the State has signed onto USDA APHIS's Brucellosis Management Plan (posted soon) with APHIS, whose current mission statement is the eradication of brucellosis in wildlife - the elk and bison (as well as other cervids) of the the GYA. 

Governor Steve Bullock's Email on Elk and Bison Brucellosis

Montanan's public and our public trust wildlife deserve better!

Please contact Governor Steve Bullock and voice your concern that test and slaughter/vaccine programs are not efficient, economical, nor socially acceptable management tools for our treasured and public trust wildlife.

Governor Steve Bullock
406-444-3111
Toll Free: 855-318-1330
FAX: 406-444-5529
Email: governor@mt.gov
Mail: Office of the Governor
PO Box 200801
Helena MT 59620-0801 

I guess he is anxious to stick it to Montana hunters in 2015, science be damned!

Sen. John Brenden, owner of Scobey Farms, from Scobey, MT, appears anxious to beat the rush to stick it to Montana hunters in the 2015 legislative session. He has already filed (drafting in process) LC0023 - Prohibit sage grouse hunting in Montana.
So heres some back story.  "Sage grouse With the U.S. Fish and Wildlife Service ordered to decide whether to list the sage grouse as an endangered species by 2015, Western states have been working to establish their own management plans. 'If you think the wolf was a big issue for Montana, it’s a piker compared to sage grouse,' said Sen. Bradley Hamlett, D-Cascade, who sits on the council and the governor’s advisory committee. The governor has appointed a sage grouse advisory committee which has scheduled 10 meetings between now and October. The plan is to have a draft out in October with a final report recommended by late November. Gov. Steve Bullock would then have until early January to make any adjustments with a plan finalized by the end of January, said Jeff Hagener, director of Montana Fish, Wildlife and Parks. Council member Sen. John Brenden, R-Scobey, suggested that halting the state’s hunting season for sage grouse may satisfy concerns expressed by some of the state’s partners. Hagener noted that, scientifically, hunting hasn’t been seen as affecting the bird’s population, but the perception is that if oil and gas leasing may be disallowed in certain areas because the birds are few, then hunting shouldn’t be allowed."


Let's not let science get in the way of wildlife management, by any means.

"In their March 2010 listing decision, the USFWS concluded that the key threats to the continued survival of sage - grouse are 1) habitat loss, fragmentation, and modification and 2) inadequacy of existing regulatory mechanisms, particularly in relation to energy and other development. The USFWS also evaluated the 'utilization' (e.g. hunting) of sage-grouse and concluded that 'the greater sage-grouse is not threatened by overutilization for commercial, recreational, scientific, or educational purposes now or in the foreseeable future' "

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 Greater Sage Grouse Conservation Strategy Page

American Plains Bison:Rewilding An Icon by James Bailey

For many, plains bison are the embodiment of wildness and the pre-settlement American West. After millenia of evolution through natural selection, however, the species was nearly exterminated, only to be subjected to domestication for more than 100 years. Domestication alters the bison genome through inbreeding, crossing with cattle genes, shrinking genetic diversity and artificial selection. These forces continue to replace natural selection and valued wild characteristics of bison. Does the future hold only continued domestication for plains bison in the United States?
 
With a view from over 50 years in the profession of wildlife biology, Bailey probes this and other questions in his original analysis of 44 conservation bison herds on native range in the United States. He focuses upon the gray area between wildness and domestication and sheds light on domesticating practices of Native American and government agencies, as well as commercial producers. He challenges the profession of wildlife management to expand its views of opportunities for manipulating wildlife populations. For bison, Bailey makes a strong case for creating large reserves to restore wild bison and their natural contributions to our grassland ecosystems.

Jim Bailey was professor of wildlife biology at Colorado State University for 20 years, teaching big-game management and wildlife nutrition. His first book was Principles of Wildlife Management. In retirement, he became interested in the management of bison in Yellowstone National Park. This led to his survey of the conservation status of bison in the United States and reassessment of wildlife management's influences upon the future evolution of large wild mammals.

You can purchase a copy of American Plains Bison, Rewilding An Icon,
at the following locations:

Bozeman - Country Bookshelf, 28 W. Main, Bozeman, MT 406-587-0166
Helena - Montana Book & Toy Co., 331 N. Last Chance Gulch, Helena, MT 406-443-0260
Missoula - Fact & Fiction Downtown, 220 N Higgins, Missoula, MT 406-721-2881; University Center, 5 Campus Drive, Missoula, MT (in The Bookstore at UM) 406-243-1234
Missoula - The Book Exchange, 2335 Brooks St., Missoula, MT 406-728-6342
Check with your local book seller, you can ask them to contact Farcountry Press at
1-800-821-3874, or order from them directly.
Amazon.com

MT Department of Livestock & Livestock Association Brucellosis Statements

Below is a link to the EMWH webpage dealing with the Sept. 10th testimony that Montana's DoL, Dr. Marty Zaluski gave before the Texas Animal Health Commission concerning their brucellosis rule change on cattle imports from Montana, Idah and Wyoming, the 2 GYA states affected by the brucellosis issue. There are a number of statements that we dont normally hear here in Montana on this subject, from the DoL on brucellosis. When I requested the written public comments from TAHC, I received a 72 page pdf file which not only included Zaluski's 50 pages, but statements from the Montana Stockgrowers Association, Montana Cattlemen's Association, some Montana ranchers. The pdf file is broken up by submitter for easier viewing. Also available are the audio files of the testimony. I really hate transcribing, so I have only done the main testimony from Dr. Marty Zalusky, not all the questions and his answers that followed yet. Mr. Palmers testimony on audio file 10 is also pertinent.
http://www.emwh.org/issues/brucellosis/livestock%20tahc.htm

DoL, "Montana's DSA includes 282 operations with 73,200 cattle and domestic bison. This fiscal year, 42,025 of the 73,200 animals have been tested to achieve a 99% confidence that the disease (if it exists) is present at a rate of less that 0.008%. The chance that any one Montana animal is brucellosis positive is 0.00024%." "In comparison, the state of Montana has an annual infection rate of 0.007% with five affected herds over six years since 2007." "There is no documented case of bulls spreading brucellosis." "So what happens is you have cattle properties that are typically on the flats, the river bottoms and the prairies, and then you have the elk ground that is alot of time in the forest. So its not like those elk are on private property typically, and in fact often times those elk are on BLM or Forest Service land," "So there are practices, its not like they come down on the flats, then spread out five fetuses and they take off."
Heres a really good one - no mention of bison, "So really the DSA in the state of Montana is in southwest Montana. And it is designed to identify the cattle at risk from brucellosis positive elk. So we know that brucellosis positive elk are in southwest Montana, they can potentially expose cattle and so the key to identifying the cattle at risk is to identify where the brucellosis positive elk are."

MSA, "There is an extremely low risk of brucellosis transfer posed by cattle coming out of Montana. While a small area of Montana in the Greater Yellowstone Area (GYA) is affected by rare transfers of brucellosis from wildlife, the state of Montana has proven highly effective in its efforts to mitigate the spread of brucellosis."
Mr. Palmers testimony (audio file 10) on behalf of the Matador Cattle Company (Koch Industries), the owner of the Beaverhead Ranch in southwestern Montana, discussing how little of an issue this is, "the majority of those times those elk are not calving in the same location as the cows."
Darrel Stevenson, Stevenson Angus Ranch, "As you can see the rate of incidence is extraordinarily low and our policing system has proven to manage with superb efficiency....Why isnt the science trusted? As reviewed in the attached, incident rate in Montana is low and imported cattle to Texas become even lower with a pre-shipment test? With no documented case of bulls spreading Brucellosis, why are they bundled into the concern?"

I would like to ask this same question of the DoL who shot the lone bull bison on the Dome Mountain WMA after hazing it off the Dome Mountain Ranch (private property rights ignored) and shooting the 2 bull bison on the west side. DoL knows that bulls dont spread brucellosis, nor the bison to cattle, which is why he only addresses elk in his presentation. And based on the science and stats presented by Zaluski, as well as the statements from the associations and ranchers, brucellosis from elk is extremely low, extraordinarily low and easily manageable, mitigated. So why in Montana do they inflame the dialogue on this issue and we dont hear this kind of testimony and science?

I think it is time that we put wildlife management back into the hands of the FWP as far as bison are concerned and keep it there as far as the elk are concerned. Remove "eradication/elimination of brucellosis from wildlife reservoirs" from our Fish, Wildlife and Parks documents/statements, such as that which FWP is signed onto in the IBMP; support natural regulation of these wildlife in the Gallatin National Forest and the Yellowstone National Park, as it should be (their signatures should not be on the IBMP eradication/elimination of brucellosis either). Brucellosis is a minimal disease threat to the cattle industry (more cattle are killed by weather or vehicular accidents each year than years of extremely low brucellosis transmission from elk), which can be managed through the DoL herd plans that Zaluski describes, as well as efforts from FWP in minimizing possible transmission of brucellosis through approved Elk Working Group measures such as encouraging security and forage on public lands and hazing from private. 



Kathryn QannaYahu

Public Comments Needed for Elk Foundation Public Access Land Purchase

The Rocky Mountain Elk Foundation - "RMEF secured an option on a 40 acre parcel that has access to Lewis and Clark National Forest. This part of the forest does not have an access point for miles in any direction. This will provide hunters with access to some of the best elk ground in all of Montana. RMEF paid $190,000. The seller was a very cooperative person who wanted to see public access improved in the area. Landowners such as that party are at the core of a land ethic that makes some places so special.
FWP wants to own the property and has offered RMEF $50,000 to take over ownership and management. FWP has committed to manage the area as a public trailhead. This will require approval of the FWP Commission and the Montana Land Board. " 

Here is a link to the FWP News Release 

Draft Environmental Assessment Proposed Red Hill Road - East Access Land Acquisition

Here is the Rocky Mountain Elk Foundation Release

This looks like an awesome opportunity for public access in Montana, especially for public hunter access, which has become more restricted due to special interests locking out public access. Please take the time to send in public comments at the following:

Montana Fish, Wildlife & Parks Red Hill Road – East Fork Access Acquisition EA 
PO Box 938 
Lewistown, MT 59457 
(406) 538-4658 ext. 228 

sonjasmith@mt.gov  

Also, please send a note of thanks to the Rocky Mountain Elk Foundation, who was instrumental in this process and for their generosity.
publicrelations@rmef.org



Kathryn QannaYahu

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   fwpwld@mt.gov   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:
http://womwe.blogspot.com/2013/07/montanas-elk-management-in-areas-with.html
http://womwe.blogspot.com/2013/08/reject-elk-management-in-areas-with.html

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


Kathryn QannaYahu

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