• "To date, local working groups (which are supposed to have representation by Sportspersons, Wildlife enthusiasts, Landowners that do not raise livestock and Livestock Producers) have not been identified in all areas."  As I supplied the commissioners with documentation, the first local working group meeting ended up being a number of ranchers in Park County, meeting in one of their kitchens and possibly Hayes Goosey of the Park County Rod and Gun Club (PCRGC) in Livingston. Gallatin Wildlife Association (GWA conservation hunters) had notified Quentin Kujala on Jan 12th, that we would like to participate in a local working group. Two members, one of which was Glenn Hockett (president), were on their way to the meeting when they received a call from Karen Loveless, the wildlife biologist involved, per instructions by Quentin Kujala, to inform the GWA members that they could not attend the meeting. Having received an invitation from Lou Goosey (PCRGC) to attend an FWP elk brucellosis mtg being hosted at their club, several GWA members accepted the invitation, only to be told once again, that we could not attend. Hayes Goosey stated it was a private mtg. When Glenn Hockett pressed Quentin Kujala about the open meeting aspect of the FWP presentation, contrary to Montana Annotated Code 2-3-101 - 107. , Kujala stated, "Glen—My understanding is this is Livingston Rod and Gun Club meeting.  That definition is theirs to make. Quentin".

  When I wrote a complaint letter to Dan Vermillion, Ken McDonald, including Quentin Kujajala and Pat Flowers in the communication, complaining about what Glenn and I had to go through that day to try and get into this meeting ( I attended with a copy of the Code, even though I had no confirmation I would be allowed in at that point) Quentin Kujala replied to Ken McDonald, "To be frank again, my first inclination (probably not the best?) is to make no response. " Which is what occurred - no response was made to a complaint about open meeting obstruction. After waiting two weeks for some response and receiving none, I filled a FOIA with Dir. Jeff Hagener on May 3rd, to receive information on this elk management process. Hagener approved my FOIA, sending it to McDonald telling him to comply. McDonald sent it to Kujala and it has been obstructed as well, with only a partial fulfillment. I have sent a follow up on June 14th, with no reply whatsoever.
  
  Also of note, in this "local working group" process, Hayes Goosey, in an email to Glenn Hockett on April 22nd, the day of the meeting at the Park County Rod and Gun Club, stated, "The Park Co. Rod and Gun Club is part of the Brucellosis working group and this is a presentation with the intent of communicating with our board of directors and membership." Another point, the Madison Elk Working Group was an already established group to deal with elk. I was there the day that Kujala made a brucellosis presentation. No educational presentation was done, just an explanation of the original Working Group and a copy of the voted on Proposed Recommendations. There were 5 of us that were sportsmen, all the rest were ranchers, no other stakeholders represented per the Proposed Recommendations – if this is to be counted as one of the “local working groups”. I sat across the room from ranchers that openly stated they wanted all the elk killed, that they were eating all “our grass”. This statement was repeated a number of times during the meeting.

  It was not until I began speaking up about the FWP obstruction of the public meeting and varied stakeholder process that certain members of FWP began saying that there were no local working groups. I have documentation to show that there has clearly been an obstruction of the FWP Commission approved process and this should be accountability and transparency in this process. Please address this situation. I would be glad to provide you with any and all documentation you require to research this matter.

•  Again, the "Unknown number of..." aspects to this plan is not really a plan, but an opened ended recipe for continuing the practices that have been occurring with little accountability or transparency.
  

• Why has FWP used sportspersons dollars to supply stackyard fencing, hazing, kill permits, etc. to ranchers that do not allow public access hunting during the established hunting season as the Game Damage Program requires (Landowners may be eligible for game damage assistance if they allow public hunting during established hunting seasons. Assistance may include hazing, repellants, temporary or permanent stackyard fencing, damage hunts, kill permits, or supplemental game damage licenses.)? When this question was brought up by one of the Elk Brucellosis Working Group members at the July 11^th meeting in Bozeman, Quentin Kujala quickly replied to them that they, the Working Group, did not include it in their Proposed Recommendations that the FWP Commissioners approved. I have a number of questions with this. 1. Why did not Quentin Kujala, FWP's representative and manager of this program point this out to a “civilian” working group when they were compiling their proposed recommendations? 2. Why did no other FWP representative reviewing this document before presentation point this out? And if they did, why was it not presented to the Working Group? 3, Why did the FWP Commissioners not add this as an amendment to the Proposed Recommendations to protect Montana Sportsmen, their access and their dollars coming into FWP? 4. Why is this still not required in this work plan?

• "Hunters will be selected using mechanisms "comparable" (this kind of ambiguity is what has been causing concerns.) to those used for game damage hunts." This should read, "Hunters will be selected from the Hunt Roster ("There is only one Hunt Roster and hunters from this roster may be identified for 3 types of hunts: Game Damage, Management Season, and Dispersal." - FWP website)."
• "Dispersal hunts will be accomplished as early as possible in the risk season..." This whole section should lead with a statement that IF there is a concentration of elk in a commingling situation, then..., not the open ended objective of accomplishing dispersal hunts as early as possible. In effect, what this sounds like is a Montana elk hunt season from Sept. 7th through May 15th. also, Julie Cunningham, FWP's Region 3 wildlife biologist warned in an email, "Furthermore, I think of the Madison-Gallatin herd as an example here. Elk move out of the Gallatin into the Madison during winter. The more we hunt during winter, the more we are reducing a herd which spends summer on public lands and is publicly accessible through early hunting season, AND which is BELOW objective. We could be really hurting our Gallatin herd by allowing post-February hunting. I do have radio-collar data showing mid-winter migrations out of the Gallatin to back this up."
  
• Gut pile management is crucial, IF this whole process is really about minimizing the risk of brucellosis transmission with cattle and other elk. This seasons gut piles were not managed. Why did Quentin Kujala and other FWP personnel familiar with the biology of brucellosis not insist on gut pile management? The only way a bull can transmit brucellosis to cattle is if he is infected (not just seropositive, showing antibodies to exposure), you kill him and then expose his lymph nodes and sexual organs to cattle or other elk. Likewise, with cow elk, with the addition of the birthing materials. There was one pregnant cow that was killed in this years "dispersal" hunts. This would have been a sure fire way, if she was infected/infectious to expose cattle and other elk to brucellosis.
• Why is there nothing in this document about kill permits and dispersal hunts in areas under objective? The Northern Elk herd has been in an average decline of 6-8 % each year for the last decade. Kill permits were issued in HD 313, which is 25% below objective, with yearling bull counts of .56% (less than 1 percent). The dispersal hunt occurred in HD 317 which is 16% below objective, with yearling bull counts of .9% (less than 1 percent). There were no cow/calf counts in HD's 314, 315, 317, and 393. There should be some restrictions against kill permits and dispersal hunts in areas with such a decline, focusing on other means to achieve the dispersal.
  
• Kill permit requirements should follow those of the fencing mentioned above - required public hunting during established hunting seasons and consideration of population numbers.
• Local Working Groups - should be established based on the multi stakeholder representation. I called all the conservation and wildlife advocate groups from Gardiner over to Bozeman and not one even knew about this group and had not been asked to participate. GWA had asked repeatedly to participate and was denied. I am still wanting to participate in the Park County local Working group and still have not heard anything.
• The educational presentation needs some serious work to not look like and be presented as a livestock advocacy presentation, instead of a FWP wildlife presentation. Why is Quentin Kujala stating the inflammatory transmission risk time, from an abortion or birthing materials of brucellosis is 81 days? This is based on a worst case scenario test conducted by Keith Aune, Tom Roffe and others, which restricted any predation, sunlight and temps from normally affecting the bacteria. This has never been replicated in a natural brucellosis scenario. In fact at the Elk Working Group meeting on July 11th, Neil Anderson stated it was a race against the birds to get to an abortion event (notified by a VIT) and generally he lost. This inflammatory 81 day statement is not being qualified and is being used by ranchers as a war cry to eliminate elk and brucellosis from wildlife, even being incorporated on film, which is being passed around to the livestock community. Dr. Marty Zaluski, in public meetings such as the IBMP, has stated 21 days for the transmission period from an abortion. If birthing materials later in the season, the transmission period is even shorter due to temperature and sunlight.
•  "Explore potential habitat management adjustments on WMA's and other lands and hunting season recommendations designed to foster adjusted elk distribution." This section sounds like it is more concerned with elk population numbers, wanting to apply increased elk tag numbers, which has no bearing on brucellosis transmission risks from commingling, especially in areas, such as Park County, that are in a decline. As far as the hunting to affect elk distribution, a recent paper, Effects of Hunter Access and Habitat Security on Elk Habitat Selection in Landscapes With a Public and Private Land Matrix, published 2013, written by FWP's Kelly Proffitt, et al should be considered. They found that elk cow security was affected by threats such as public land hunting and motorized vehicles, causing them to congregate on private lands, which is reducing the public land herds available to the public hunters. "Focusing harvest pressure on private lands currently restricting hunter access while limiting harvests on public lands may be an effective strategy for redistributing elk onto public lands in areas where elk distribution is focused on private lands with limited public hunting access." (pg. 10) This goes back to my earlier point of hunter resources being used for private ranchers that do not allow this public hunter access - its a lose/lose for he Montana sportsmen. Increasing nearby hunting on WMA's will only increase the elk population densities on the very ranches that they are wanting less elk populations on, to reduce the possible spread of brucellosis, which is not a threat during the regular hunting season anyway. So why is this really here, unless the objective is population control or to really drive the elk to the private lands during hunting season?
  
• As to "effective communication, education and outreach" with this Commission, the general public and landowners. I feel the Montana sportspersons should be included in this. I wholeheartedly agree. Y'all should be given the numerous documents from FWP wildlife biologists that you have been excluded from. Educating yourselves on these issues is necessary to your making wise wildlife management policy.
  

With that I will conclude my comments, again asking you to please not pass this 2014 Work Plan, please do an audit of what has been taking place and please manage our elk as wildlife, for the benefit of Montana, her public and her hunting community, not certain private ranches and the livestock industry special interests. The reduction of brucellosis transmission can be attained without throwing our elk, the public process and accountability/transparency under the bus. Thank you for all your hard work.

Thank you, Kathryn QannaYahu