Madison River Recreation Plan Proposal.

Montana Fish, Wildlife and Parks is seeking public comment until October 30th, 2020. The results of this will affect your fishing on the Madison River.

Some of you may have heard the buzz about Montana Fish, Wildlife and Parks moving forward with a Madison River Recreation Plan.  This is an important next step in a movement that has been discussed for the past 10 years.  This plan has ultimately come to a head because of perceived overcrowding on the river.  Users wishing to preserve and protect the quality of the experience on the Madison River have been convening to discuss the many points of view and perspectives on how best to manage this.  In many ways, this is a discussion and plan that will set the standard for other rivers in the West for years to come, so it’s worth taking a moment to understand what is at stake here and offering your public comment where you are able.  Montana Fish, Wildlife and Parks (FWP) is accepting public comment until October 30th on this and the commissioners will come to a vote on November 18th, 2020.   

It is our goal to inform those of you that are interested in what Big Sky Anglers’ stance is on these issues, to offer some interpretation and navigability of the current proposals, and include links to the original documents so that those of you that wish to read and decide for yourselves are able to do so easily. The Madison is truly a special river that belongs to all of us (Montana residents and non-residents, commercial users and public users) and we hope that a reasonable plan that achieves the goal of limiting the perceived crowding and, most importantly, protecting the resource can emerge from all of this. As with all public resource management issues, the current discussion needs your opinion, it needs to hear from the public.   

We and others have found the current rules being proposed to the Montana Fish, Wildlife and Parks (FWP) Commissioners are a bit muddy and difficult to navigate, so we are hoping to put the current discussion into simpler terms here.  A link to the actual language for anyone who wishes to read through it more carefully is located here

FWP has clearly stated that this plan will be developed based on the comments received by the public.The Madison River is a public resource with rulemaking driven by public comment, not by commercial users.  Your voice is needed more than you might imagine.

Public Comment can be submitted by the following methods and must be received by October 30, 2020:

Online:  FWP website link

Mail:  Department of Fish, Wildlife and Parks, Madison River Rules, P.O. Box 200701, Helena, MT, 59620-0701

Email: madisonrivercom@mt.gov

PROPOSED RULES 1-16

Rule 1:  Cap outfitting use.

Rule 2:  Rest and Rotation

Rule 3:  Closure of Walk/Wade section to boats

Rule 4: Limit Development on Madison River

Rule 5:  Closure of Walk/Wade section to boats, alternate plan to Rule 3

Rule 6:  Management of Limited Commercial Users

Rule 7:  Transferred Permits

Rule 8:  Flex Trips

Rule 9:  Transfer of Guided Trips

Rule 10:  Mandatory Guided Trip Reductions

Rule 11:  Permit and Application Fees

Rule 12:  Reporting and Use Fees

Rule 13:  Plan Evaluation

Rule 14:  Commercial Use Working Group

Rule 15:  Madison River SRP Trip Distribution Pool

Rule 16:  Madison River Use Stamp

Summary

In short, there are 16 rules being proposed, and these three are standing out as contentious and worthy of comment: Rules 2, 3, and 5.  The rest deal with the management of commercial permits and we accept them as they are.  We believe that limiting our own impact, as commercial users, is critical to any proposed plan. 

Rule 2:  Rest and Rotation**Being proposed here is a Saturday closure of all commercial use from Varney Bridge to Ennis and a Sunday closure from Lyons Bridge to Palisades.  These closures will be active from June 15-September 30**

Our position is that Rest and Rotation as it is currently defined will not work on the Madison River and will in fact make crowding worse. The method needs improvement.

This doesn’t seem too extreme at face value but it should be noted that the language being used for Rest and Rotation is flawed in that the Sunday closure of Lyons-Palisades incidentally results in the closure of AT LEAST 8 float section options to commercial use.  Each of the following sections utilizes a portion of or all of the proposed closure and would be closed for guided trips on Sundays.         

 -Lyons Bridge to Windy Point        

 -Lyons Bridge to Palisades        

 -Lyons Bridge to Ruby Creek       

 -Lyons Bridge to Mcatee Bridge        

-Windy Point to Palisades         

-Windy Point to Ruby Creek         

-Windy Point to Mcatee Bridge         

-Windy Point to Storey Ditch         

-Raynold’s Pass to Windy Point         

-Pine Butte to Windy Point         

-Pine Butte to Palisades 

The incidental closure of all of these sections will force ALL guided float trips on Sundays into Palisades and downstream, into those sections that have much lower fish counts per mile than the upper reaches and cannot handle the inevitable increase of fishing pressure.  The concentration of guide boats caused by the proposed rule will also result in circumstances that we believe will be perceived as overcrowding of the river below Palisades on Sundays – the exact opposite of the intended result of the rule.  

Closing of the entire section doesn’t work on the Madison, perhaps we can explore rest and rotation on the individual fishing access level as a possible alternative.  For example, Lyons Bridge access could be closed on Sundays to commercial use. Another consideration might be to close that particular float on a given day, but still allow for other floats that overlap the same section to occur. Allowing boats to spread out is the key to avoiding crowded situations. 

Rule 3:  Closure of Walk/Wade Section to boats**Being proposed here is a closure to ALL boats (not just commercial) in the sections of river commonly referred to as the walk/wade stretches (Quake Lake outlet – Lyons Bridge and Ennis to Ennis Reservoir) on weekends: Fridays, Saturdays, and Sundays.  These closures will be active from June 15-September 30**

Our position is that we do NOT support the ban of watercraft on the wade section at any time and we do NOT support fishing from boats in the wade section. 

At face value this rule seems noble, but it’s worth noting several things here to consider.   Firstly, the issue we are facing on the Madison is overcrowding, taking boats out of the wade section on weekends lessens anglers’ ability to spread out, forcing everyone into the same wade fishing accesses.   Secondly, several landowners in the upper wade section have become increasingly aggressive about confronting wade fishing anglers, accusing them of trespassing according to their own interpretation of the Montana Stream Access Law.  They are aggressively posting no trespassing signs, arguably illegally, and chasing anglers off of the public water adjacent to their property.   

We believe that actively limiting stream access to public water does not represent Montana values, and establishes a dangerous precedent that flies in the face of our beloved Stream Access Law.  Limiting access in this instance may also result in future litigation, wasting both taxpayer money and State resources. When combined with Proposed Rule #2, this rule has the potential to cause even greater crowding of boat-based anglers and recreational floaters into the sections of river downstream of Palisades. This rule is an access issue and should be looked at with a more critical eye as it benefits very few (a handful of property owners) at the cost of many (the angling public). 

Rule 5:  Closure of Walk/Wade Section to Boats-Alternate to Rule 3**Being proposed here is an alternate rule to Rule 3: this is presented by FOAM (Fishing Outfitter Association of Montana) and proposes a closure to boats on the two walk/wade stretches on Thursday, Friday and Saturday.  Leaving Sunday open to boats to accommodate the Rest and Rotation closure of Lyons to Palisades to commercial use in Rule 2.  It also proposes to allow fishing from the boat in the walk/wade section from Sunday through Wednesday.  These closures will be active from June 15-September 30**

Our position is that we do NOT support the ban of watercraft on the wade section at any time and we do NOT support fishing from boats in the wade section.

As mentioned, this is intended to be an alternate to Rule 3.  Best case scenario in our view is the omission of BOTH of these Rules, retaining the status quo in the walk/wade sections.  We believe that there is significant value to the angling public in retaining the existing rules banning angling from a floating craft upstream of Lyons Bridge.

MT FWP Needs Your Comments

We encourage you to make comments of your own, but if you are inclined to agree with Big Sky Anglers’ positioning on these matters and don’t have time to draft a personal comment, please feel free to utilize any of the following text in your comments to FWP on their website, by mail, or by Email: madisonrivercom@mt.gov.

Please feel free to contact us at info@bigskyanglers.com with any questions or if we can help clarify any of these complicated issues.

Please Feel Free to Copy and Paste this Text if it Suits You

To Whom it May Concern, 

Thank you for allowing the public to comment on this important proposal for the Madison River, I agree with proposed rules 1, 4, and 6-16. I would like to issue the following comments on Rules 2, 3, and 5: 

Rule 2.  The language currently being used to define rest and rotation is flawed and I believe will have the reverse effect from that which is intended.  Specifically, by closing Lyons Bridge to Palisades on Sundays to commercial use, this rule as written will ban commercial float trips on AT LEAST 8 popular float sections of the river:          

1.  Lyons Bridge to Windy Point         

2.  Lyons Bridge to Palisades         

3.  Lyons Bridge to Ruby Creek         

4.  Lyons Bridge to Mcatee Bridge         

5.  Windy Point to Palisades         

6.  Windy Point to Ruby Creek         

7.   Windy Point to Mcatee Bridge         

8.  Windy Point to Storey Ditch         

9.  Raynold’s Pass to Windy Point         

10.  Pine Butte to Windy Point         

11.  Pine Butte to Palisades 

The incidental closure of all of these sections will force ALL guided float trips into Palisades and downstream, into sections that have much lower fish counts per mile than the upper reaches and cannot handle the inevitable increase of fishing pressure.  The concentration of guide boats caused by the proposed rule will also result in circumstances that we believe will be perceived as overcrowding of the river downstream of Palisades on Sundays – the exact opposite of the intended result of the rule.

I encourage the Commissioners to explore other options for Rest and Rotation rather than closing an entire section to all commercial traffic. One alternative would be to close a particular access on a given day, rather than the entire section. Another could be to allow floats to occur that pass through this section but do not start at Lyons Bridge and terminate at Palisades. Allowing boats the ability to spread out on the Madison is the key to helping prevent perceived crowding. 

Rules 3 and 5.  I disagree with removing boats from the walk/wade sections of the Madison.  This will only benefit the few landowners in these areas at the expense of the many public anglers.  It will also increase crowding at wade fishing access points. I believe that there is significant value to the angling public in retaining the existing rules banning angling from a floating craft upstream of Lyons Bridge.  I also believe that actively limiting stream access to public water does not represent Montana values, and establishes a dangerous precedent that flies in the face of Montana’s beloved Stream Access Law.  Limiting access in this instance may also result in future litigation, wasting both taxpayer money and State resources. When combined with Proposed Rule #2, this rule has the potential to cause even greater crowding of boat based anglers and recreational floaters into the sections of river downstream of Palisades.