Putting the "Public" Back In "Public Trust"

Park Co. UYWB rancher special interest driving local brucellosis work group proof

Public Comments Deadline March 21st, needed for the Elk Management in Areas with Brucellosis 2014, Work Plan Modifications Paradise Valley - fwpcomm@mt.gov
Please take a few minutes to email the FWP Commissioners before the March 21st deadline, to protect our elk, sportsmen's dollars and Montana elk management laws from special interests.

Members of the public and sportsmen interested in this process have repeatedly been obstructed from the public meeting and multi-stakeholder process involving the local application of the Elk Management In Areas With Brucellosis, specifically what has been occurring in Park County with the rancher special interest groups.

A few days ago, I received a fowarded email, originating from Jessica Anderson, District Administrator/Watershed Coordinator, Park Conservation District, stating that the "UYWB voted to appoint Druska Kinkie (rancher) as the chair of the Elk Brucellosis Local Working Group."

I have expressed my concerns, numerous times, to FWP administrators of this elk brucellosis program, as well as Director Jeff Hagener and the FWP Commissioners concerning the obstruction of this process and the Park County hijacking of the local working group, that this was actually an Upper Yellowstone Watershed Basin group, not the Statewide Elk Brucellosis Working Group proposed and FWP Commission approved multi-stakeholder local process.

I went to all the Park County meetings, recording them, making the information available to the public, and there was not a single meeting that all those attending, had any vote on a chair for the local working group. We came together and it was a done deal from the start. When I requested a copy of the sign in sheet of the first meeting from FWP Quentin Kujula, he replied, "I do not have the sign-up sheet - assumed then and now that a watershed representative picked it up." In the audio of the meetings, as well as the FWP Commission meeting on Feb. 13th, FWP's Quentin Kujula refers to the working group as the "watershed group."

This watershed group seeks to pillage FWP sportsmen dollars for miles of their 6-8 tall, wildlife obstructing fencing, extending kill dates of elk to May 15th, all of this outside of Montana laws concerning elk management.
"Based on a review of the foregoing information, it appears that there is no specific reference in the Montana Code Annotated regarding the Departments's authority to manage elk for purposes of reducing or preventing the transmission of brucellosis between elk and livestock." Dec. 6, 2013 Montana Legislative Services Division Inquiry into the MT Elk Management In Areas With Brucellosis finding

In fact, not only does this Elk Brucellosis program need a MEPA process, but the APHIS directed Montana DOL Designated Surveillance Area needs one. "The DOL is not a state agency that is exempted from MEPA. The DOL Order is an action that is defined under MEPA and the DOL's administrative rules and the DOL Order likely is not exempted or excluded from MEPA review...Based on this unfortunately lengthy but necessary legal analysis, the DOL's Order probably should have been subjected to the MEPA review process" Feb. 25, 2010 Montana Legislative Services Division Opinion on the Application of MEPA to the Department of Livestock's Designated Surveillance Area for Brucellosis Official Order

All of this for a livestock originating disease, which according to MT DOL's State Veterinarian poses as small risk to MT's cattle, a risk of 0.00024% chance. This wildlife naturalized disease is not the harbinger of doom that DOL and APHIS have promoted it as. In fact, not all the cases of brucellosis that have broken out here in Montana's cattle (also WY and ID) have been the result of elk; some have been from cattle and vaccine blooms. We need scientific management of our wildlife, not APHIS and DOL control, with their livestock management over our FWP wildlife. This small risk could have been mitigated by the reasonable proposals that were first promoted by the Statewide Elk Brucellosis Working Group. Since this process has been hijacked by the APHIS/DOL brucellosis eradication in wildlife agenda being directed out of Helena, we need the Montana Environmental Policy Act process that should have been conducted in the first place, to be conducted.

Email the FWP Commissioners before the March 21st deadline, to protect our elk, sportsmen's dollars and Montana elk management laws from special interests. Thank you.

Elk Brucellosis Park Co. "Working Group" Page

Montana Fish, Wildlife & Parks Elk Management In Areas With Brucellosis Page with Timeline showing public meeting obstruction and local working groups

Thank you,
Kathryn QannaYahu



Wildlife &


Bozeman, MT

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