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This is totally unnecessary. It’s not busy enough to dictate the need for permitting. I will gladly comment on this proposal to end this decision
I'd advocate you hit the point I bolded above. Their proposed reservation permit system is a knee-jerk reaction to solve a problem that doesn't exist.
I'm all for them gathering data...but they need to do that first. They're solving a perceived problem, but have no data to back it up.
 

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Madison River Work group:
KC Walsh - Chair - MFWP Commissioner and Executive Chairman (owner) Simms Fishing Products

Commercial outfitters
Mike Bias, Fishing Outfitters Association of Montana
Brian McGeehan, owner Montana Outfitter Fly Fishing
John Sampson, Ruby Springs Lodge

Non-commercial river users
Zach Brown - Gallatin county commissioner
Richard Gockel - Madison River Foundation
Allison Treloar (but she's the wife of a fishing guide Mike Treloar)

Business owners
Daniel Larson, owner of Madison Valley Ranch (Orvis-endorsed Lodge) (this doesn't sound like a "Madison Valley business interest not connected to commercial outfitting")
Christopher Dimichele - owner of Deemo's Meats

Natural resources specialist.
Mac Minard, the executive director of the Montana Outfitters and Guides Association. So a lobbyist for guides

At-Large

Jim Hart - Madison County Commiss

BLM Rep
Chris McGrath

Montana administrative rule establishing work group.

So 6 of them have interests in commercial fishing when there's supposed to be 3? Fawesome.
 

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Madison River Work group:
KC Walsh - Chair - MFWP Commissioner

Commercial outfitters
Mike Bias, Fishing Outfitters Association of Montana
Brian McGeehan, owner Montana Outfitter Fly Fishing
John Sampson, Ruby Springs Lodge

Non-commercial river users
Zach Brown
Richard Gockel
Allison Treloar (but she's the wife of a fishing guide Mike Treloar)

Business owners
Daniel Larson, owner of Madison Valley Ranch (Orvis-endorsed Lodge) (this doesn't sound like a "Madison Valley business interest not connected to commercial outfitting")
Christopher Dimichele - owner of Deemo's Meats

Natural resources specialist.
Mac Minard, the executive director of the Montana Outfitters and Guides Association. Oh, and he's also a fishing guide

At-Large

Jim Hart

BLM Rep

Montana administrative rule establishing work group.

So 6 of them have interests in commercial fishing when there's supposed to be 3? Fawesome.
No surprises here! Looks like business as usual. Seems like the old guard of decent fly fishing guides and outfitters who worked to make fisheries better are long gone. I can name quality outfitters, I’m aware of, on one hand.
 

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"Bear Trap is a prized section of white water as it is one of the few Class IV whitewater runs in our State. (We have numerous Class II-III runs and a lot of technical Class IV creeks but very little Class IV.)

In my experience, this section of the Madison regulates itself. The rapids are big enough to keep most fisherman and novices away and its seclusion paired with the long shuttle times deem it to be a full day excursion. I regularly see 2-3 boats per day while I'm on this section.

1. The Recommendation states that the limited launch
area can also result in congestion and social conflict when multiple float parties arrive simultaneously. I find this to be untrue. Unlike float boaters or fishermen, whitewater boaters tend not to be more social and less prone to conflict. We are a social group and tend to look out for the safety and well-being of others not even in our own party. Launch sites may be limited, but they are on most other whitewater rivers and we tend to cooperate and help get other parties onto the river so we can then have our turn. 1/2hr between groups is a good idea, but is not necessary by regulation. As noted before, this river tends to self-regulate.
2. If permitting is desired for further study, I'd advocate for a self-service Kiosk at the Powerhouse launch site and ask that boaters sign in with the number of people/boats in their party which will allow FWP and BLM to track user data.
3. Since neither FWP or BLM has established any benchmark data (the work group recommendations state that the Permit is recommended to gather use so it is assumed no data exists), a restrictive paid permit is not the best first step. The same information gathering permit as recommended for Non-Commercial Final Recommendations should also be implemented first. If benchmark data from this round then dictates that Social Conflict and Congestion exist at all, then a restrictive reservation float permit system may be implemented.
4. While the Beartrap Canyon whitewater flows through BLM wilderness, the put-in (Powerhouse) is not on on land managed by the BLM. Other than scouting the Kitchen Sink rapid and occasionally the White Horses rapid, VERY FEW whitewater floaters even step foot on BLM land until they reach the Warm Springs take-out. If a given number of people launch in a day, why is there no concern with whitewater boaters at the take-out? It's because there isn't social conflict from the whitewater boaters."

Sent today.
I have very little experience in speaking out in scenarios like this. Is it good practice to copy/paste your message and share with friends, having them sign also, or is it more effective to write up my own full response in order for it to gain attention? Which works best?
 

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Make some edits to mine/paraphrase. :)
(Seriously)

Edit: decision-makers tend to lump copy/pasted verbatim chain emails together and don’t give them as much weight as original letters.

a simply worded hand-written letter carries way more weight than a copy/pasted email.

and written comments that critique their draft points directly carry more weight than an opinioncomment that only tangentially relates to the decision being considered
 

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Bumping this up because the meetings are happening right now (last meeting is zoom the 14th) and we have just over a month to comment. A few of us are collaborating on dissecting this and I'm hopeful we have something to share with interested people soon. If anyone has any federal land use regulations/ law, environmental permitting/law or related expertise, I would love to collaborate with you as we navigate outside of our wheelhouse (at least for me). We cannot let this happen and I think we have a strong case. Laura
 

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"Bear Trap is a prized section of white water as it is one of the few Class IV whitewater runs in our State. (We have numerous Class II-III runs and a lot of technical Class IV creeks but very little Class IV.)

In my experience, this section of the Madison regulates itself. The rapids are big enough to keep most fisherman and novices away and its seclusion paired with the long shuttle times deem it to be a full day excursion. I regularly see 2-3 boats per day while I'm on this section.

1. The Recommendation states that the limited launch
area can also result in congestion and social conflict when multiple float parties arrive simultaneously. I find this to be untrue. Unlike float boaters or fishermen, whitewater boaters tend not to be more social and less prone to conflict. We are a social group and tend to look out for the safety and well-being of others not even in our own party. Launch sites may be limited, but they are on most other whitewater rivers and we tend to cooperate and help get other parties onto the river so we can then have our turn. 1/2hr between groups is a good idea, but is not necessary by regulation. As noted before, this river tends to self-regulate.
2. If permitting is desired for further study, I'd advocate for a self-service Kiosk at the Powerhouse launch site and ask that boaters sign in with the number of people/boats in their party which will allow FWP and BLM to track user data.
3. Since neither FWP or BLM has established any benchmark data (the work group recommendations state that the Permit is recommended to gather use so it is assumed no data exists), a restrictive paid permit is not the best first step. The same information gathering permit as recommended for Non-Commercial Final Recommendations should also be implemented first. If benchmark data from this round then dictates that Social Conflict and Congestion exist at all, then a restrictive reservation float permit system may be implemented.
4. While the Beartrap Canyon whitewater flows through BLM wilderness, the put-in (Powerhouse) is not on on land managed by the BLM. Other than scouting the Kitchen Sink rapid and occasionally the White Horses rapid, VERY FEW whitewater floaters even step foot on BLM land until they reach the Warm Springs take-out. If a given number of people launch in a day, why is there no concern with whitewater boaters at the take-out? It's because there isn't social conflict from the whitewater boaters."

Sent today.
Good on ya MT4!
 

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Laura’s draft is even better!

btw, message her or me, we could turn in a group comment with multiple names
Team effort! You did most the ground work that got me jump started. I think everyone has got to take the info and put their own words to it. Common comments are less weighty to the agency, and the BLM guy said in one of those last meetings how the agency takes comments from other agencies more seriously than individuals. We need a BIG showing of comments.from the public to have an effect when it comes to BLM.
 

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OK folks, here is the summary document Shawn and I and a few others have put together to inform you exactly what a sham this process is. Of the super busy Madison River, the ONLY section they propose new permit limitations on is Beartrap. WTF?!?! Talk about an illegitimate system.

Let me know if you have any more information I can include or anything.

Please send in your comments by Oct 14!!!!

 

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Comments sent.. Your efforts are appreciated MT4Runner and lhowe. I try to assume the best of my fellow outdoor enthusiasts, but this does seem a little, uh, fishy. Does the impetus for the proposal come from the fly guiding industry and if so, what is the specific conflict on the relatively unpressured Bear Trap? Or is this a landowner thing?
 

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Fishing guides in my opinion. There’s 3 stretches that get used. The upper stretch is considered blue ribbon and is like a long gentle rifle , lots of gravel bars and under cuts. Big browns and rainbows. It’s so crowded that it’s no fun. Then beartrap and no one’s there. It’s 14 miles so you can only hike so much. Then the lower which is college kids and family tubers meet fishing guides. In the summer it’s awful and people do really dumb shit. I found a guy passed out adrift on a tube before. So that’s the rub in my opinion. The guides need to make money and they have a very strong voice in Montana (all this is my opinion) but I’ve never once heard of a whitewater advocacy for the Madison. All three stretches are dam realease as well so it is a constant for guides where as the freestone rivers are more seasonal (you know what I mean) . There’s a class v stretch too and no one’s talking about permitting that lol!!
 

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Comments sent.. Your efforts are appreciated MT4Runner and lhowe. I try to assume the best of my fellow outdoor enthusiasts, but this does seem a little, uh, fishy. Does the impetus for the proposal come from the fly guiding industry and if so, what is the specific conflict on the relatively unpressured Bear Trap? Or is this a landowner thing?
I tried to give the outfitters the benefit of the doubt, heck I don't know how I would have ever boated the locha without a kind guide to let me follow them, so I'm not anti guide but very outfitter wary.

That said, watching the planning videos, it seems to be that the impetus is solely the two outfitters that are permitted to run that section of river. Their Yellowstone club Gazillionaire clients don't want to wait or mingle with us plebs at the put in, and its a good excuse to DOUBLE THEIR USE while the entire rest of the river is seeking LESS use. It is absolutely underhanded, having outfitters and not a single private boater, write the private boater regs to carve out a two fold increase in their use. Oh yea, private boaters will be limited to 16 per party, but not outfitters. Whatever limits outfitters have in their special use permits should be incorporated here. Damn, I need to add that to the document. Thanks for more brainstorming!

Don't forget the FOUR daily commercial launches will be BLOCKED out. What does that mean? Which ones? Fuck if I know, other than 10AM - noon will probably never be available for private boaters. Bullshit, utter bullshit.

The work group also tried to implement a MT resident season pass only for MT residents or people that work here. ONLY those people would be able to launch unrestricted after 4PM. It's a FEDERAL WILDERNESS!!!! WTF. Thank goodness that got killed in the work group, it was such a stupid stupid proposal I can't even believe they had the gall to propose it. Ugh!
 

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The
I tried to give the outfitters the benefit of the doubt, heck I don't know how I would have ever boated the locha without a kind guide to let me follow them, so I'm not anti guide but very outfitter wary.

That said, watching the planning videos, it seems to be that the impetus is solely the two outfitters that are permitted to run that section of river. Their Yellowstone club Gazillionaire clients don't want to wait or mingle with us plebs at the put in, and its a good excuse to DOUBLE THEIR USE while the entire rest of the river is seeking LESS use. It is absolutely underhanded, having outfitters and not a single private boater, write the private boater regs to carve out a two fold increase in their use. Oh yea, private boaters will be limited to 16 per party, but not outfitters. Whatever limits outfitters have in their special use permits should be incorporated here. Damn, I need to add that to the document. Thanks for more brainstorming!

Don't forget the FOUR daily commercial launches will be BLOCKED out. What does that mean? Which ones? Fuck if I know, other than 10AM - noon will probably never be available for private boaters. Bullshit, utter bullshit.

The work group also tried to implement a MT resident season pass only for MT residents or people that work here. ONLY those people would be able to launch unrestricted after 4PM. It's a FEDERAL WILDERNESS!!!! WTF. Thank goodness that got killed in the work group, it was such a stupid stupid proposal I can't even believe they had the gall to propose it. Ugh!
Thanks for the local insight. Proposing a state residency restriction on federal land is the nuttiest thing I’ve ever heard come up in a process like this. A real head scratcher that shines some light on the mindset of this work group.

This poverty boater appreciates what you and others have done here. I’d like to see them try this shit in my neck of the woods (not really).
 

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his does seem a little, uh, fishy. Does the impetus for the proposal come from the fly guiding industry and if so, what is the specific conflict on the relatively unpressured Bear Trap? Or is this a landowner thing?

It’s fishy as hell. There was a previous rule put in place in 2020, including full public comments, but the fishing guides were mad that it took away too many of their opportunities, so they got all riled up and quashed the whole thing and got themselves on the new work group
 

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It’s fishy as hell. There was a previous rule put in place in 2020, including full public comments, but the fishing guides were mad that it took away too many of their opportunities, so they got all riled up and quashed the whole thing and got themselves on the new work group
I've completely missed getting any of this information! Messaging you!
 

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Go float the Missouri by Craig in the spring sometime when the freestones are brown. It’s bad and guides are like da hui in the parking lots and man it’s a circus! The ONLY people who would wish for this are getting paid to guide. If it was a whitewater thing it would be those outfitters. Montana is just behind the times cause it’s small but not so small anymore!! I’ve run beartrap a lot and I’ve never seen more than 4 or 5 boats in there ever. Just like all things beautiful…wave goodbye.The local whitewater Facebook group thinks the blm will balk but we’ll see.
 

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The local whitewater Facebook group thinks the blm will balk but we’ll see.
In my experience, local management offices often get an idea from some acute interest in their community; and then yeah, they'll balk under two specific conditions: 1) there is substantial local opposition to whatever proposal, and 2) that local opposition is communicated to higher levels of management as well as locally.

The blood may pale in Dillion Field Office when someone from Western Montana District comes down and says "what's all this ruckus the boaters say about closing down rivers?"
 

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In my experience, local management offices often get an idea from some acute interest in their community; and then yeah, they'll balk under two specific conditions: 1) there is substantial local opposition to whatever proposal, and 2) that local opposition is communicated to higher levels of management as well as locally.

The blood may pale in Dillion Field Office when someone from Western Montana District comes down and says "what's all this ruckus the boaters say about closing down rivers?"
and 3) that the managing agency fears a very real threat of a lawsuit--and not being able to finalize/implement the project because it's tied up in court.

And for this reason, it is imperative that our written comments not only communicate what you think--but they very directly rebut the points and decisions made by the group/agency which gives the writer standing later in the process.
 
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