July 28, 2022

Chair Robinson, Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull & Lane

Montana Fish Wildlife & Parks

1420 East Sixth Avenue

P.O. Box 200701

Helena, Mt 59620-0701

cc: [email protected]

Re: Delaying Implementation of Madison River Commercial Use Cap

Chair Robinson; Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull and Lane:

On behalf of the Montana Chapter of Backcountry Hunters & Anglers, and our nearly 3,000 dues-paying members, we submit the following comments regarding the delay of the commercial use cap on the Madison River.

Back in 2020, after an extensive public comment period and public process, the Fish & Wildlife Commission adopted rules regarding a commercial cap for the Madison River. The goal of this rule was to lower both conflict (perceived or real) and crowding on the river. The cap was to be set based upon the number of Madison River trips a given outfitter or guide had in 2019 or 2020, whichever year was higher. Both 2019 and 2020 were record use years for guiding and outfitting on the Madison (until the years to follow). The new cap was to allow more than 16,000 commercial trips annually.

In 2022, under the instructions of the Fish & Wildlife Commission, the Madison River Work Group (MRWG) was tasked with developing a new river use plan for the Madison River. The MRWG, with a strong contingent of river-related businesses, voted unanimously to keep the commercial cap rule, with a start date of January 1st, 2023. With such a strong recommendation by the MRWG, which was put together by the Commission, the proposal to delay implementation seems unnecessary and at odds with the MRWG suggestion.

This is one of the reasons why Montana BHA requests that the Commission stop ‘kicking the can down the road’ on the Madison crowding issue and vote “No” on unnecessarily and indefinitely delaying implementation. While there are certainly many other use considerations to work out on the Madison, this one piece of the puzzle has broad support, makes a lot of sense, and still allows for our friends in the guiding and outfitting industries to be successful; we ask that this be implemented as planned, and we look forward to working with the MRWG and the Commission to address other concerns on the Madison.

Montana BHA appreciates both the opportunity to comment on this proposed change and the work put in by the MRWG. We strive to find a balance between habitat protections, public access and opportunity for all Montanans and our guests, certainly no easy feat, but it’s much harder if we never take that first step.

Sincerely,

Chris McCarthy, Belgrade, MT

Gallatin Valley Board Member

The Montana Chapter of Backcountry Hunters & Anglers