Work group proposes a solution in search of a problem
Important Update: Montana Fish, Wildlife & Parks is seeking comments on a long-awaited and much needed recreational use plan for the Madison River. You can access proposed recommendations from the Madison River Work Group by clicking here.
This action alert concerns one piece of that puzzle: the bizarre recommendation to implement a non-commercial (AKA, public) float permit system for the Bear Trap Canyon portion of the Madison River, a recommendation that would restrict daily launches and limit public floating access to YOUR river.
Upper Missouri Waterkeeper does not send action alerts lightly, so let’s be specific about the proposed change and why it’s of concern.
What’s Proposed: The Madison Work Group recommendation proposes a mandatory Float Permit system for Bear Trap Canyon with half hour launch windows and a daily cap. Four of the daily “public” launch times would be reserved for commercial users, despite the fact that there are only two outfitters with commercial SRP permits for the Bear Trap and data from 2020 shows only two commercial float trips were taken down that stretch of the river.
The Rationale: The Work Group recommendation states that the daily number of parties floating Bear Trap regularly exceeds the parties-per-day guidelines from BLM for this Wilderness Area Float. The recommendation then asserts that “congestion” and “social conflict” occur when multiple parties arrive for launching.
The Goals of Limiting Public Use: Implementing a new, mandatory Float Permit for Bear Trap Canyon would, according to FWP, allow (1) data gathering (presumably to support the decision); (2) force the public to spread out launch times; (3) protect sensitive resources from degradation.
Let’s Examine These Points:
First, while social conflict and overcrowding on the Upper Madison is undisputed, the Bear Trap Canyon segment of the Madison is far from “regularly congested” and there’s no evidence of “social conflict” to support the proposed, radical, change in public access management. At least one 10-year monitoring study from the 1990s found that public use in Bear Trap is, essentially, concentrated on the weekends and self-regulating, and ‘Limits of Acceptable Change’ indicators are not good metrics for making river management decisions in a vacuum.
Is it pleasant to launch, and float, without seeing anyone else? Perhaps, but so too inherently subjective. Boating culture is one of solidarity and community, particularly in whitewater (and Bear Trap is no exception). As recognized by the 10-year study, a multitude of factors aside from floater density have impacts on whether a public land is meeting its multiple use mandate. Bear Trap Canyon’s float experience necessarily entails some overlap with potential other parties by virtue of navigating complicated whitewater stretches, yet those potential overlaps don’t necessarily mean “social conflict” nor do they indicate the surrounding Wilderness Area is experiencing degradation.
Second, the Work Group recommendation contradicts itself by arguing on one-hand (without evidence) that congestion and social conflict is apparent, but on the other hand states that a mandatory float permit would allow better data gathering on actual use. Conclusory and contradictory statements lacking specific, factual support cannot – and should not – be the basis for radical changes to public float access on one of the crown jewel river adventures in western Montana. Ironically, the cited 1990s study found that public and commercial float use of Bear Trap Canyon was self-regulating: people naturally chose different launch times to space themselves out. We agree: the public and commercial users self-regulate on this stretch.
Third, there’s a better, less severe, way to collect data to inform revised management strategies for Bear Trap Canyon. Instead of a mandatory Float Permit rule that substantially limits public access, our agencies could first perform an updated study to build upon the last study from the 1990s.
Put simply, there’s no need to take an axe to the issue when a scalpel will suffice. In managing the public’s right to access and use Montana’s rivers our decisionmakers should always err on the side of conservative, less impactful management decisions that preserve the well-established legal right, and public policy objective, of public access and use of our rivers.
The facts don’t support the proposal to severely
limit public float access on Bear Trap Canyon.
We’ve received a slew of concerned citizens’ comments from boaters both local and regional, all flabbergasted that Montana FWP is proposing to limit public floating access in Bear Trap Canyon when the undisputed social conflict is on the Upper and Lower Madison, and particularly given the lack of evidence of a problem. Neither concerned citizens, Waterkeeper staff who float Bear Trap Canyon annually, or any contacts in the local business community have experienced the “social conflict” being alleged as necessary to significantly limit the public’s access to one of our waterways. As the 1990s study of Bear Trap float usage concluded, float pressure on this river stretch very much so self-regulates.
The proposal to limit public float access to the unique, adventurous Bear Trap Canyon segment of the Madison is a solution in search of a problem. Instead of going nuclear by categorically limiting the public’s floating access to Bear Trap Canyon through a new mandatory Float Permit with daily caps, our management agencies should first collect meaningful data and host a transparent public forum to discuss this enormous management shift.
If you care about protecting the public’s right to float on the Bear Trap segment of the Madison, consider sending a quick comment in opposition during the open comment period. Your voice matters!
FWP is accepting public comments until October 14. Tell the agency you oppose restricting public access to float Bear Trap Canyon now.
Here is a suggested comment for the Bear Trap Canyon Float Permit Final Recommendation, May 2022 – please personalize your letters to share your experiences on the river:
I oppose the Madison River Work Group’s non-commercial Bear Trap Canyon Float Permit recommendation.
Implementing a non-commercial floater permit system will limit public access to this stretch of river and prioritize commercial interests over Montanans. In 2020, FWP’s data indicates only two commercial float trips were taken down the Bear Trap Canyon, yet the proposed permit system allocates four launches per day to commercial users. The recommendation doesn’t provide any evidence to support its conclusions.
There are less severe, and more effective, ways to gather meaningful data to support a significant river use management decision, such as conducting a new survey to update the last Bear Trap use survey from the 1990s.
I have floated Bear Trap (X number of times). (Share your boating experience here). (Share specifically whether you think there is “social conflict” on Bear Trap Canyon river segment).
Imposing a limited float permit system on the Madison’s Bear Trap Canyon segment is unnecessary, and would represent an unjust burden on public access to one of the most unique river stretches in the state. I strongly encourage FWP and the Work Group to instead advocate for a new study to qualify and quantify any harm before jumping to rash conclusions and limiting public float access to Bear Trap Canyon.
Please remove the Bear Trap Canyon float permit recommendation from the final Madison River proposals.
Keep public boating access in Bear Trap Canyon and submit a public comment now!