October 30^th, 2020

Montana Fish and Wildlife Commission
1420 East Sixth Avenue
P.O. Box 200701

Helena, MT 59620

RE: Madison River Recreational Management Proposed Rules and EA

Dear Montana FWP Commission:

On behalf of the Montana Chapter of Backcountry Hunters & Anglers’ roughly 3,000 dues-paying members we submit the following suggestions in response to the Madison River Recreational Management Proposed Rules and EA.

We applaud the Commission’s efforts in taking steps towards achieving the management goals laid out in the EA: 1) ensuring long-term health and sustainability of the fishery, 2) diversifying angling opportunity while reducing conflict, and 3) sustaining the ecological and economic benefits of the river to Montanans and our guests. We believe the following suggestions will help in achieving those goals.

First, we propose establishing a Fee-Based/No‐Limit Madison River User Stamp. The fee should not exceed $5.00 so as to remain non-prohibitive. Ultimately the fee-schedule should be determined by MT FWP just as other license fees are determined by MT FWP. The Fee-Based stamp must be obtained by all river users. Funds generated by the fee-based stamp would go directly back into the fishery in terms of habitat and facility improvements, education, river rangers, surveys, etc. Stamp holders would also be required to report their activity on an annual basis. The information derived from these reports would be used to evaluate and improve management decisions.

The details of our plan include the new rules below and should be implemented on a two-year test and evaluation cycle, which could be funded by the fee-based stamp. 

1.Outfitter Allocation Cap:

• Current Regulation: None
• Montana BHA Recommendation:
  • 2019/2020 Cap + Flex Days.

We support this portion of the FOAM Petition. Commercial trips on the Madison have more the doubled in the last 10 years and we believe managing commercial use is a first step to managing the crowding issues on the river. There are many small Montana businesses who rely on outfitting and guiding on the Madison and establishing a cap based on 2019/2020 numbers allows outfitters to operate at high historic numbers. The Flex Trips will provide a path to success for those outfitters whose historic trip use has fluctuated year to year. 

1. Walk/Wade:

• Current Regulation: 
  • Year-Round Walk/Wade Ennis to Ennis Reservoir, No Fishing from Watercraft
  • Year-Round Walk/Wade Quake Lake to Lyons Bridge, No Fishing from Watercraft
• Montana BHA Recommendation:
  • Year-round: Walk/Wade Ennis to Ennis Reservoir. No Fishing from Watercraft.
  • Seasonal: June 15 - Sep 30: Friday - Sunday: Walk/Wade Quake Lake to Three Dollar. No Fishing from Watercraft.

Preserving the current year-round Walk/Wade section from Ennis to Ennis Reservoir provided confidence and is important to those anglers who regularly return to the Madison in search of a less-crowded walk/wade experience. We propose the creation of Seasonal a Walk/Wade section from Quake Lake to Three Dollar. This Seasonal rule would provide a walk/wade experience during the busiest days of summer on stretches popular to non-commercial users and opens to float-fishing during the work week. We propose to open float-fishing, year-round, from Three Dollar to Lyons Bridge. This section is long enough for a full day float and opens brand new water to float-fishing for commercial and non-commercial. This combination will spread out different users.

1. Rotation:

• Current Regulation: None
• Montana BHA Recommendation:
  • Seasonal: June 15 - Sep 30 Saturday No Commercial Activity Varney Bridge to Ennis
  • Seasonal: June 15 - Sep 30 Sunday No Commercial Activity Lyons Bridge to Palisades

We support this portion of the GGTU petition only when combined with the opening of Three Dollar to Lyons section outlined in our Walk/Wade comments above. This combination provides balance and plenty of opportunities for different user groups to spread out on the busiest days of the year.

1. FAS Ranger:

• Current Regulation: None
• Montana BHA Recommendation: We support this from the GGTU Petition.

1. Access Site Education:

• Current Regulation: None
• Montana BHA Recommendation: We support this from the GGTU Petition.

1. Facility Improvements:

• Current Regulation: None
• Montana BHA Recommendation: We support this from the GGTU Petition.

1. Primitive Designation Below Greycliff:

• Current Regulation: None
• Montana BHA Recommendation: We support this from the GGTU Petition.

The Montana chapter of Backcountry Hunters & Anglers appreciates the opportunity to comment on this proposed rulemaking. We strive to find a balance between Habitat, Access, and Opportunity for all Montanans and our guests. We feel our proposal is the right direction towards achieving that balance the management goals defined in the EA. 

Sincerely,

John B. Sullivan III

Chapter Chairman

The Montana Chapter of Backcountry Hunters & Anglers