Subject: Elk Management in Areas with Brucellosis 2014, Work Plan Modifications Paradise Valley
From: Kathryn QannaYahu <>
Date: 2/12/2014 4:18 PM
To: Gary Wolfe <>, 'Dan Vermillion' <>, Larry Wetsit <>, Matthew Tourtlotte <>, Richard Stiker <>

FWP Commissions, I have been attending these Park Co. watershed meetings, which have also been called “working group” meetings. I say this, because they are truly an extension of the Upper Yellowstone Watershed Basin group, which even Quentin Kujula has referred to them as.

This “working group” is not set up as the Statewide Elk Brucellosis Working Group Proposed Recommendations, which y'all approved Jan. 10, 2013, envisioned with the multi stakeholder representation and input. As a result, you can clearly see from the audio recordings of meetings (at the link above), this is not really about reducing any possible risk of brucellosis risk transmission, but about the elk on their land during all times of the year, what they can get FWP sportsmens dollars to subsidize, without any public hunter access in the general season. Though not hidden, when members of this group realized that I was recording the public meetings for other members of the public that could not attend, some of the comments and dialogue changed, becoming calmer and more politically acceptable. Their 3rd recommendation was to do away with the hunt roster and utilize only Park County hunters of the landowners choosing. Thankfully, Dr. Mark Albrecht pointed out how this would be perceived by Montana hunters and they did not submit that one to you.Yet, I still do not have my requested documents for the previous seasons dispersal hunts, involving the hunt roster, which is doubtful it was followed, as other portions of the law were not, from public meeting obstruction, minutes, record of attendees, kill permits, etc.

I have numerous objections to these modifications, besides the base objection to this whole Elk Management in areas with brucellosis program not complying with any MCA or ARM statutes. 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

Please request the necessary Environmental Review, according to MCA 87 -1-301 (J) FWP Commissioners requirements shall comply with, adopt policies that comply with, and ensure the department implements in each region the provisions of state wildlife management plans adopted following an environmental review conducted pursuant to Title 75, chapter 1, parts 1 through 3. (Last Statewide Elk Management Plan 2004). MCA 87-1-323 Management of viable elk populations are based on habitat acreage, not brucellosis management.

Thank you,
Kathryn QannaYahu
Bozeman, MT