Madison River Negotiated Rules Committee meeting. Sportsman’s Lodge, Ennis, Montana, 3/6/2019.

from Chris Gentry:

Negotiating Rule Making Committee and FWP:

As time was a constraint in public comment periods, I would like to submit my written comments for the record and for your consideration.

Thank you committee members for the time and effort you are putting into this process. This is a HUGE undertaking with HUGE consequences. Your recommendations will be the most heavily weighted part of this rule making process. Do not take this lightly. Do your due diligence and do not rush into any decision.

My name is Chris Gentry and I own Madison Foods in Ennis, MT. I have called Ennis my home for the past 17 years. These are my own personal views and opinions as an independent business owner in the Madison Valley/Ennis community. I have sat through 2 days of public meetings and I plan to attend the remaining meetings.

Everyone can agree that the Madison River needs to be protected. This river is the “lifeblood” of our community. I do not think that adequate attention is being given to the economic impact that the river, and tourism has on our community. I heard FWP attorney say that you can gather information and take in information as stakeholders of the committee. I have attached a link at the bottom of my email including economic data.

I implored you to do an economic impact study as part of your research. I found out in the 2nd day of meetings that FWP is required by MEPA to conduct that study AFTER you make your recommendations to the commission and prior to them filing notice of adoption through the Montana Secretary of State. How are you able to make a recommendation to the commission without that information? Can you make another recommendation or pull your recommendations after this study is completed? Seems to me that this process is lacking an informed decision making element. Whatever your proposals are…impact on business not only in Ennis but the businesses between here and West Yellowstone, Bozeman, Twin Bridges, Virginia City and Sheridan?

This is a hot-button issue that FWP is trying to keep out of the public eye and under the radar so it is pushed through quickly without a lot of public interaction and attention.

As one of Ennis’ largest employers, I employ over 5% of Ennis’ population alone. My employees are my largest asset. The money that I make in the summer months goes back to my employees during the winter. I do not lay them off when business demands are down. I carry them through the starvation months. In my 17 years of experience I feel that I have my finger on the pulse of the economy in Ennis. My daily detail in my business can tell you when the May Fly hatch happens, when Salmon flies arrive, when the Hebgen Dam failed, and when mother nature decides to send an early spring. The Madison river dictates our economy.

I asked at the meeting and was told that the businesses of Ennis are being represented. I have yet to be contacted by anyone on your committee. Two other large employers, Madison Valley Medical Center who employs 10% of Ennis’ population has also not been contacted. Robin Blazer at Willie’s Distillery employs 2.8% of the population and also has not been contacted. These 3 businesses account for almost 18% of Ennis’ population. These are the only businesses that I have contacted to ask to share their % of employment. I have also heard from other businesses in the community that they have not been contacted either. My intent is not to lessen any local businesses impact. Ennis is made up of entrepreneurs.

Outfitters and guides are a vital piece of Ennis’ infrastructure; $23,523,000.00 to be exact. But they are even farther reaching than that. The “other halves” of our guides and outfitters can be traced to our hospital, real estate, schools, motels, restaurants, banks, bars and volunteer organizations. I would like to refer to Justin Edge who spoke publicly about his 6 year old year old daughter wanting to be a guide. THIS SHOWS HOW DEEP THE MADISON RIVER REALLY RUNS. THIS RIVER DOES NOT JUST RUN OUT THERE IN ITS BANKS, IT RUNS IN OUR VEINS.

You are guided by Mike Mitchell in a facilitated rapid prototype format, this is not working due to the immense scope of this project. In my opinion the Negotiated Rule Making process will set this committee up to fail and will do what they want to anyway. I encourage you to revaluate this process and suggest that a Region 3 CAC specific to the Madison be formed. You cannot possibly get this done CORRECTLY in 6 work sessions.

I feel that the main issue that is missing in your alternatives is the economic impact specific to communities and businesses along the Madison. The alternatives that have been presented are DRASTIC and are not data driven. To make an informed recommendation, you need data and facts.

We are in agreement that these are social issues. The FWP statics are misleading as they are only social studies and there is not strong scientific or economic research/data on these issues. FWP is on record as saying there are no biological issues with the river and its fish. Managing for social science rarely produces positive results. There has been unfounded speculation as to tipping points, thresholds, and red line. If there was an actual measurable threat to the biology to the river, we wouldn’t even be having this conversation.

Some of these DRASTIC alternatives include but are not limited to Caps, Closing parts of the river to commercial and public use, SRP limitations, Outfitting limitations, allocations, a 5/10 rule, Resident day, and rest and rotation days.

The positive alternatives that I have heard include education, opening up the WHOLE river to floating and fishing from a boat which would reduce the perceived crowding, and putting restrictions in place only upon biological triggers.

I would like to ask that more time be given to public comment. There is too much information being covered to properly weigh in with public comment. I understand why you do not allow public comment during your work meetings, as nothing would be accomplished. The public should not be stifled because of the time constraints. Possibly consider a day of public comment.

I am also including a screen shot of a graph out of the Angler Satisfaction, Demographic and Creel Surveys of the Upper Madison River, 2015-2017 conduct by FWP that is taken off of the Madison River Foundation website. Please tell me what the problem is???

Please see below links to 2017 Non Resident Traveler Expenditures & Economic Contribution in Madison County.

Chris Gentry, Ennis, Mt.