I sent my comments in yesterday afternoon, WITH the documentation to back up the reasons why. I never use the form, no paper trail or guarantee it got there. After seeing examples of comment intercepts and missing comments from people that had blind carbon copied me or forwarded their comments, I dont trust the system, so I email the fwpcomm@ mt.gov address for the public record part, but I email each commissioner my comments to make sure they get them.
My comment made it to each commissioner, but bounced back from FWP, saying it was too large. I separated the map, sent that separately and the mail pdf comment still came back. So I split it in two and one of the sections came back again. I called Helena and asked for an email that could handle some data. Since they have to receive academic papers, maps, charts, photos, etc. from agencies and other biologists, surely they have to have emails that will handle more megabytes than they are allowing the commissioner comments to receive? THe woman who answered the phone asked Kujula, who told her I could burn it to a CD and mail it, they would accept it even though it would arrive after the comment deadline. Not willing to risk the snail mail and such, I broke it down again, so I had to send my comment in 4 parts to get the maps, charts, science, etc to the commissioners on this complex subject - including the documents for the process that HD 270 had to go through to utilize pg. 55 of the EMP to not count harbored elk.
This begs the question, if FWP is not providing this type of data to the commissioners, and the public is having to step in the gap to make sure this kind of information is on the public record and in the commissioners hands, they are further limiting/capping the public's ability to advocate by limiting the electronic process. Good thing I did not wait to the very last minute and after business hours.
Someone brought up a very good question last night. They were asking me about the elk brucellosis lawsuit, which is still on file. They asked if that lawsuit basis was applicable to "shoulder seasons" because of the elk brucellosis program not being in the elk management plan, which MCA states Title 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).
PG. 56 of the EMP states:
1) FWP will complete strategic and six-year plans for fish, wildlife and parks programs to clarify public expectations, allocate resources and define a common direction for FWP and our partners.
I called Helena to find out when the last time the Game Damage and Block Management programs last had that done. They are looking that up for me.
Also, on pg. 61 it states,
"Although FWP intends to manage elk within the framework of a 5-week general season, where game damage criteria apply, all EMUs have the option of special early seasons, an extended general season, or special late seasons. However, seasons outside the 5-week general season framework are not intended to be solutions where outfitting, other paid hunting, or land totally closed to hunters or with severely restricted access compromises general public access during the general 5-week season."
This paragraph is exactly what this elk shoulder season is all about.
