Please Read and Complete Survey!
The “Upper-Upper Madison” or Firehole River in YNP
We don’t fish the Madison River a ton, but we do love the Madison River. There is a delicate balance between growing our sport and ensuring quality of our RESOURCES here in Montana. FOAM (Fishing Outfitters Association of Montana) sent out the email below that we are sharing. Please read this email and FILL OUT the survey. WE believe a guided fishing trip includes much more than simply catching fish. When our clients spend a day with one of our guides, you spend a day with a fishing expert, a CONSERVATIONIST, an educator, and someone who will practice and pass along a strong land ethic to our clients. Please take a few minutes. Montana is truly a special place:
“Reminder to complete FWP's Madison Scoping Document
Montana Fish, Wildlife & Parks (FWP) began a public process to assess your ideas on various alternatives for managing recreation on the Madison River. The form of this process is a public scoping survey found here.
As most all FOAM members are aware, we have been very involved in this process from the beginning and it appears we are closer than ever to obtaining a solution. FOAM’s commercial use plan, supported by the majority of SRP holders on the Madison and the large majority of our membership, has risen to the top of preferred alternatives from not only the Commission, but several other organizations as well. Our continued efforts, and willingness to work with the multitude of groups, has been noticed and appreciated.
Currently, FWP received over 3,000 responses to the survey. We strongly urge all of you to participate in this survey, whether the Madison is in your operational plan or not, as similar regulations are likely coming to other rivers in Montana soon. We would also ask that you share this email with 10 of your clients and ask them to complete the survey as well. If all FOAM members and their 10 clients respond to the survey, we would have over 9,000 respondents. There is no doubt other organized efforts are underway to solicit responses from those that oppose outfitting on the Madison and we will need the help and support of everyone to be successful in this endeavor.
Following is a summary of FOAM’s position on each of the survey questions with information as to why we think that way.
Question 1: “On a scale from 1 (very unimportant) to 5 (very important), how important do you think it is to maintain a healthy and sustainable fishery on the Madison River?”
We absolutely support maintaining a healthy and sustainable fishery on the Madison River. 5 (very important)
Question 2: On a scale from 1 (very unimportant) to 5 (very important), how important do you think it is to maintain the economic benefits that derive from recreation and fishing on the Madison River?
The economic benefits that derive from recreation and fishing on the Madison River bring in over $24 million to Madison County each year, and maintaining this is vital. 5 (very important)
Question 3: “On a scale from 1 (very unimportant) to 5 (very important), how important do you think it is to provide for a diversity of angling opportunities on the Madison River?”
Angling diversity currently exists throughout the Madison River, further, attempting to exclude one user group at the expense or exclusivity of a reach of the river for the exclusive use of any user group is not acceptable for us. 1 (very unimportant)
Alternative 1A. Currently there are no limits or caps on the numbers of outfitters on the river or the number of trips they take, provided they apply for a Special Resource Permit (SRP) and pay 3% of gross revenue to FWP after each calendar year. Under this alternative, it is expected that total client days will continue to rise, especially if growth in the Gallatin Valley and visitors to Yellowstone Park continues to grow.
We are not in favor of no limits. We developed a plan that addresses commercial management on the Madison. FWP commercial user data has shown that increasing SRP holders on the Madison has had no effect on growth from 2011 to 2017. The increase in commercial use resulted largely from established outfitters increasing their number of trips per year each year. As well, any type of permit moratorium does not allow for any new outfitters or commercial business to enter the system. 1 (very unacceptable)
Alternative 1B: Cap the total number of outfitters at 2018 levels. This could be done in a variety of ways, but would need to address issues such as how to identify which outfitters are to be allowed in under the cap and how to allow entry of new outfitters under a cap when outfitters retire or cease operating on the Madison. This alternative might do little to stem the growth of outfitter activity as there would be no restriction on the number of trips each outfitter could take.
FWP commercial user data has shown that increasing SRP holders on the Madison had no effect on growth from 2011 to 2017. Trip frequency distribution among outfitters has shown that this increase resulted from established outfitters increasing their number of trips per year each year and NOT from adding 25 new SRP holders from 2011 to 2017. 1 (very unacceptable)
Alternative 1C: Cap the total number of outfitter trips at 2018 levels. This could be done in a variety of ways, but would need to address issues such as how to allocate trips among current outfitters and how to allow entry of new outfitters under a cap when outfitters retire or cease operating on the Madison. This alternative would not restrict numbers of outfitters but would be effective at stopping overall growth of outfitter activity.
Our plan favors allocation of trips across outfitters based on recent historic use with allowance of “flex days” based on 2019 year. We think the latest user data should be used within any recreation management plan. 3 (somewhat acceptable)
Alternative 1D: Manage for a reduction of outfitter trips relative to 2018 levels. This could be done in a variety of ways, but could be accomplished by attrition when outfitters retire or their business declines with the effect of reducing the pool of outfitter numbers or allocated trips. This would be done in an adaptive management fashion to help achieve a reduction in social conflict.
How and at which percentage do you decide to limit the commercial users? 1 (very unacceptable)
Our most preferred choice of all these would be 1C based on 2019 commercial use data.
Alternative 2A: No restrictions. Known areas of congestion would probably get more congested if use trends continue. It may be self-correcting in that some users would avoid these areas or move to other areas out of frustration.
Again, we feel that any attempt to exclude one user group at the expense of another for exclusivity on a reach makes little sense to us. However, we feel that some recreation management plan needs to be enacted. 1 (very unacceptable)
Alternative 2B: Access site social conflict management. This would direct FWP to address crowding at boat ramps, e.g. possibly hiring staff to help direct traffic at boat launches and have its engineers redesign sites to help with limited parking and poor designs that impair traffic flow. Any redesign that results in getting boats on the water quicker would have the effect of transferring some of the congestion to the water, especially during busy times of day.
This alternative encompasses the FAS Ambassador Program, which we are in full support. 5 (very acceptable)
Alternative 2C: Rest-rotation. This would create sections of the river where commercial activity is prohibited anywhere from one to seven days a week on a rotating basis. An example of a two-day rest-rotation model would be to prohibit commercial activity on Saturdays from McAtee Bridge to Varney Bridge and on Sundays from Varney Bridge to Ennis FAS. Although this approach means fewer people are eligible to fish the rested sections, it is unclear how much the effect might be reversed if the closure served to attract more non-commercial anglers.
Rest and rotation in any form is not acceptable for us. Simply, the Madison is at capacity from not only commercial users but orders of magnitude greater in non-commercial users. To put that same amount of capacity in smaller reaches does not effectively alleviate crowding either on the commercial reaches or in the non-commercial reach. 1 (very unacceptable)
Alternative 2D: Walk/wade sections. This would create sections that prohibit use of a boat to gain access to fishing. The two current walk/wade sections (Quake Lake to Lyons Bridge FAS and Ennis FAS to Ennis Lake) only disallow fishing from a boat. The rationale for this approach is that an angler walking into river sections are at a disadvantage since the float angler has an advantage in more rapidly accessing remote areas. Areas where the channel is narrow also can create conflict when float and wade anglers are in close proximity.
We think any closure to access by boats is unacceptable. Any rule prohibiting boat access for fishing will severely limit angler’s ability to access this roughly 13-mile section. 1 (very unacceptable)
Alternative 2E: Daily boat launch restrictions. In sections designated as walk/wade that allow access by boat, boat launches would be restricted to a certain period of the day to reduce conflict with wading anglers. This approach would reduce the interaction between boat and wade anglers, but not to the extent of Alternative 2D.
Restrictions on daily boat launches for us is unacceptable. They are enforced largely only on commercial users and rarely enforced on private parties. 1 (very unacceptable)
Alternative 2B would be most preferred by us.
Alternative 3A: Status quo. No restrictions will be placed on commercial outfitting, recreational floating, or non-commercial angling. Access sites will be managed to accommodate all types of users, and this may require new site development, or enhancement of existing infrastructure (i.e. campsites, latrines, shelters) if use continues to increase.
Status quo on the lower river at this time is very unacceptable to us. The amount of recreational use on the lower river has grown to unacceptable numbers and needs to be managed. 1 (very unacceptable)
Alternative 3B: Evaluate the level of access-site crowding and on-river conflicts between recreational boaters and anglers in order to determine if there is a need to manage use or improve access in the Warm Springs Recreation Access to Blacks Ford FAS section.
We think an evaluation of use on the lower river would be a valuable and necessary undertaking. 5 (very acceptable)
Alternative 3C: Prohibit commercial fishing outfitter use from Greycliff FAS to the Missouri River. This section gets less than 1% of all commercial use on the river, but it is relevant here because floaters in this stretch of river value a primitive floating experience with unique scenery and plentiful wildlife. The prohibition would guard against the growth and establishment of a commercial use presence that recreationists may view as inconsistent with a primitive experience.
This alternative was categorically rejected by the NRC. Additionally, this alternative was addressed comprehensively by the NRC and copious public comment against such an alternative was heard by the NRC. Further, this section of the river receives the least amount of commercial use currently, 0.61% of all outfitted trips or a total of 71 trips occurred in this section during 2017. FWP needs to demonstrate how prohibiting less than 100 outfitted trips per year affects any current natural resource or primitive resource value. We are aware of no literature or evidence that shows commercial users detract or degrade natural resource values. 1 (very unacceptable)
Alternative 3D: Preserve primitive nature of the river below Greycliff FAS. There is only one access site in the 18.9 mile-reach between Greycliff FAS and Milwaukee FAS, a major reason for the primitive conditions. To preserve the experience, FWP would institute a policy that any future land acquisitions maintain the primitive nature of this reach by limiting vessel or float tube access to carry-in only.
We think this alternative is not acceptable as improving or adding another boat ramp in this reach would greatly alleviate crowding. 1 (very unacceptable)
3B is most acceptable for us.
Alternative 4A: No limits. Overall use on the river is expected to rise, even if commercial use is capped or limited in some way. Social conflicts at access sites and on the river will continue to rise, although management tools such as walk/wade, rest-rotation, and access site improvements will help maintain quality experiences for a short period of time but will eventually lose effectiveness if overall use continues to increase.
We do feel that the overall crowding by non-commercial anglers needs to be addressed, though we are not sure how to best address that. 1 (very unacceptable)
Alternative 4B: Establish a cap on non-commercial users equivalent to 2018 levels. This could be implemented through issuance of a no-cost Madison River Stamp when a fishing license is purchased. These would be issued on a first-come basis and would apply to all non-commercial users. This alternative would be most equitably applied if used in conjunction with a similar commercial use cap as described in alternative 1C.
This alternative is acceptable to us as long as restrictions on non-commercial users does not affect or restrict our users. 4 (acceptable)
Alternative 4C: Establish a Madison River Stamp as in Alternative 4B, except that non-residents would be limited to 50% of stamps. This would be done for the purpose of recruiting resident anglers back to the river that have been displaced to other rivers because of unacceptable levels of crowding.
We would rather not see restriction applied to non-residents. We think the economic impact to local communities of Ennis and West Yellowstone could be catastrophic. Outfitting ranked first, $23.5 million, in non-resident expenditures in Madison County during 2017. 1 (very unacceptable)
Alternative 4D: Establish a Citizen’s Day (once a week) on one or more sections of the upper river during the highest-use period, June 15-September 30. This would apply to both commercial and non-commercial users. By excluding non-residents, it would potentially create a relatively uncrowded section for resident anglers, but it is unclear how much this effect would be reversed if it served to increase resident use.
Not acceptable. The establishment of any kind of restriction based on residency is not acceptable to us. 1 (very unacceptable)
4B would be the most preferred alternative for us.
Thank you for taking the time to complete your FWP public scoping survey for recreation management on the Madison River and thank you for encouraging your clients to do the same. We will continue our efforts and work towards an effective and comprehensive recreation management plan for the Madison River.”
