Montana Fish, Wildlife & Parks
Elk Mangement In Areas With Brucellosis

Below are the quotes from the APHIS-VS Concept Paper which drives the MT FWP Elk Managment In Area With Brucellosis Program. This is how APHIS/DOL are strong arming our wildlife agency to throw our elk and bison under the APHIS brucellosis eradication bus.

A Concept Paper For A New Direction For the Bovine Brucellosis Program - APHIS VS 2009, "The goal of the program is to eradicate brucellosis from the United States." "Despite cooperative Federal-State-industry efforts to eradicate this disease and the significant progress we have made, final eradication will not become possible unless the country adopts new strategies to address current challenges. Eradication depends on finding the last remaining brucellosis-reactor animal, the last remaining brucellosis-affected herd, and eliminating the disease from wildlife reservoirs. All potential risks for exposure and transmission of brucellosis from infected wildlife populations must be mitigated and eliminated as well. Currently, the last known reservoir of disease is the wildlife populations in the GYA. A new direction is needed that will allow VS and States to apply limited resources effectively and efficiently to this unique disease risk."(pg. 2)

"While the term 'disease management area' has been used in this document to describe a national concept, the term 'designated surveillance area' is being used for the GYA. This term can be found in the core principles that were presented at a meeting held in Idaho Falls, Idaho, on June 18, 2009. This meeting included representatives from the Idaho, Montana, and Wyoming State livestock, agriculture, and fish and wildlife departments; representatives of the offices of the governors of Idaho and Wyoming, congressional staff for each State; staff from APHIS VS and Legislative and Public Affairs; and representatives of the National Park Service. This meeting focused specifically on the issues associated with the endemic brucellosis situation in elk and bison in the GYA and the risk posed to livestock in the area." pg. 11

"Eradicating brucellosis in the GYA remains the long-term goal, with the short-term goals of disease management and prevention. Resources and cooperation from all partners are needed to achieve these goals." pg. 12

"Elimination of brucellosis in wildlife should not be the burden of livestock stakeholders; it should be the responsibility of wildlife agencies.
Implementing a disease managment area is only part of a successful approach to eliminating brucellosis in an area of increased disease risk such as the GYA. It also requires a concurrent planning effort with the many wildlife and land-management agencies and entities that have jurisdiction and authority over the impacted area. VS fully recognizes the role that wildlife plays in spreading brucellosis and the critical role that the U.S. Department of Interior and State Departments of Natural Resources and Land Management play in managing wildlife and combating this disease. VS has engaged these entitites to ensure that the wildlife issue is addressed appropriately. VS is eager to partner with these entities to develop and implement appropriate strategies for the disease management area concept." pgs. 13, 14

I like how APHIS VS writes of their strong arm tactics, forcing the GYA States to "cooperate", "partner", or they dont get their Brucellosis Class Free Status for the state.

I believe, that is called extortion.


The following are FWP Documents, Timeline of Events and Local "Working Group" Meetings that reveal the APHIS, Department of Livestock control over Fish, Wildlife & Parks concerning our wildlife (primarily elk and bison) exposed to the livestock disease of brucellosis - with the objective of eradication of brucellosis in wildlife.



Timeline of Events

  • 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.
  • 11/9/2012 - 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 by Quentin Kujula.
  • 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 because test and slaughter was added back in by Quentin Kujula, when the Working Group had rejected it. Dr. Albrechts letter was first sent to Quentin Kujala to see if it should be passed on to the Commission members, by the commission secretary. I am including the version from my Public Information Request, so you can see that it was intercepted first. Dr. Albrecht was concerned, " it appears that the FWP Department had a fundamental objective to ultimately eliminate brucellosis. - this cant be done!"
  • 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 (of which I was a member then) 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", 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 called FWP Karen Lovelss, told they cannot attend that it is private, directed by FWP Quentin Kujala, approved by FWP Commission Chair Dan Vermillion as a "smart move". Oct. 2013 email reply on working group attendee's, when I was finally able to get at least some information on who attended this working group meeting. This was part of my original information request from May 3, 2013.
  • 3/10/2013-4/7/2013 Dispersal Hunts on T-Bar, Elbow Creek, Strawberry Ridge and Melin ranches.
  • 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 FWP Quentin Kujala. I, 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. I take the Montana statues and go 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 - As a concerned member of the public, conservation hunter and wildlife advocate, I emailed an official complaint letter concerning local working group meeting's obstruction with FWP 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 my Information Request.
  • 5/2/2013 - Email referring to Rep. Alan Redfield (Paradise Valley Rancher, Park Co., who sponsored the HB 312 Elk Brucellosis Test & Slaughter Bill) being complimentary of the elk brucellosis actions, late season dispersal hunts. He also had an LC2040, which would have gutted the required PUBLIC hunter access requirement of Game Damage laws. But this Elk Management In Areas With Brucellosis did far more than that. All these actions in the Proposed Recommendations never required Public Hunter Access and when I pointed this out to the FWP Commissioners, it was never amended to require it, making all actions paid for by sportsmens dollars, but no public hunter access in return.
  • 5/3/2013 -I,as an individual, since GWA president did not wish to file, filed 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 - I received 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, I was 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.


Montana Legislative Services Division - Legal Services Office, Legislative Inquiry into the MT Elk Management In Areas With Brucellosis finding - "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

UPDATE: FWP Elk Brucellosis Management Acceptability Surveys

Sportsmen's Lawsuit Against FWP & FWP Commissioners
Over Elk Brucellosis Management Program

MCA & ARM Violations of the Elk Managment in Areas With Brucellosis Program


Park Co. Elk "Working Group"
Not local working groups as defined by Statewide Elk Brucellosis Working Group Proposed Recommendations, passed on Jan. 10, 2013 - Local Working Groups- "At a minimum, they should reasonably represent the various constituencies that would typically include sporting and other wildlife interests, livestock producers, landowners that do not primarily raise livestock and any associated resource or land management agencies...All would be open meetings." Obstructing a number of sportspersons from attending the original meetings, primarily of local ranchers, I repeatedly brought before the FWP Commission the obstruction of this process and the lack of various stakeholders. FWP decided to say they never had any "local working groups, couldnt get any public interest." See Timeline to the left for proof otherwise. What is taking place in Park County now, is the Watershed group, made up of ranchers, chaired by rancher Druska Kinkie.

MT Statewide Elk Brucellosis Working Group
Charlie Noland is also Ag, according to the EWG ag subsidies database, and Dr. Raths is involved with Raths Livestock, so there are actually 8 of the 12 members involved with ag/livestock, though the list tries to make it look about half.

Nov. 2012 Draft Proposed Recommendations
Which included Test and Slaughter, originally rejected by the Statewide Elk Brucellosis Working Group, added back in by FWP Quentin Kujala

Jan. 10, 2013 Final Proposed Recommendations
While these Recommendations were passed, they were not implemented as they were written. Along with the local working group obstruction, concerns over the obvious lethal objectives in this management, rather than the risk mitigation, forage habitat improvement, etc., began raising red flags, which prompted the investigation into this program. Further research has resulted in the uncovering of the APHIS/DOL Brucellosis Management Plan required by Montana, which compromises elk and bison management by FWP - managing for USDA and local livestock. See Brucellosis

2013 Elk Brucellosis "Work Plan"
This was not a plan, it was an open ended, unlimited number of, outline at best.

Feb. 2013 FWP Commissioner Minutes
Approving 2013 Elk Brucellosis "Work Plan"

2013 Elk Management Actions Region 3

2013 Elk Management Actions Region 5

July 11, 2013 Elk Brucellosis Working Group Review Meeting
The day before this meeting, I went to Helena, to the FWP Commissioners meeting, to speak for three minutes in the public comment period, concerning this Elk brucellosis debacle. I ttok folders for each commissioner of documentation concerning the public meeting obstruction, the wildlife biologists statements on this program, the stats on the elk in this region being under objective, no public hunter access requirement, asking them to call for an independent audit of this program.

I attended this Working Group meeting from beginning to end. A number of concerning subjects were brought up, primarily by Dr. Mark Albrecht, such as: obstruction of public meetings, why are there no local working groups, gut piles from the dispersal hunts not managed (if an elk had been infected with brucellosis, the gut piles would have been transmission vectors for cattle or other elk to become infected).

Joe Cohenour asked why there was no required public hunter access for this program. FWP's Quentin Kujula, quickly replied that they, the Statewide Working Group members, had not included it. This is bullshit to put that off on the working group members, who are not FWP employees, knowing the laws involving Game Damage and public hunter access. As the administrator of this program and an employee of the FWP agency working for wildlife and hunters, it was Quentin Kujulas responsibility to make sure these "civilians" were advised of this point. Neither did the FWP commissioners amend the Proposed Recommendations on Jan10, 2013, nor did Ken MacDonald, Quentins supervisor, bring it up to the commissioners. And when I have, they ignored it and there is still no public hunter access required for this program, which does not follow any Montana Code Annotated to operate. So basically, hunters are subsidizing the ranchers to kill elk in an area that is under objective, as well as pay for stack fencing.

2014 Elk Brucellosis Work Plan Original
This plan was 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 spring of 2013, with some "Cover My Ass" thrown in. I very vocally, email and internet networking complained about this "work plan".

2014 Elk Brucellosis Work Plan
Altered Work Plan submitted to FW Commissioners Aug. 8, 2013

2014 Elk Brucellosis Work Plan Final














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