The Ecology Center
801 Sherwood, Suite B
Missoula, MT 59802
(406) 728-5733

									April 7, 1999

Montana Fish, Wildlife and Parks 
Trapping Advisory Committee
P.O. Box 200701 
Helena, MT 59601-0701                    
Fwpwld@state.mt.us

Trapping Advisory Committee,

	I am writing regarding the proposed trapping regulation amendments in the state of Montana.  I am writing on behalf of the Ecology Center, a non-profit citizens group based in Missoula.  We are writing in support of the Friends of Buddy group and their work to bring about changes in the outdated trapping regulations.  It has come to our attention that the members of this group are responsible for making recommendations to the Fish Wildlife and Parks.  I have been told that the committee has made recommendations to the FW and P that delete regulations that were adopted last year, shifting the burden of proof away from the trapper and onto the general public.  This seems to be the wrong approach to a problem that can place both domestic and wild animals in danger.  In addition these regulations were adopted with overwhelming public support, and should be upheld.  We stronlgy support that all trapping should be prohibited near public roads, and all body-gripping traps are banned in high-use areas.

	The Ecology Center is concerned with not only the above recommendation, but also find that the following will put wildlife and domestic animals at risk of injury or death.  We do not support the Trapping Advisory Committees (TAC) recommendation to require use of offsets for leghold traps.  There is no scientific data indicating that offsets are more humane than steel-jaw leghold traps, and it has been shown that they may cause even more injuries.

Secondly, TAC is recommending a restriction on public access to public lands, by creating "trapping only" areas or seasons.  The Ecology Center does not support this proposal due to the fact that this would be giving privileges to a small minority (around 2, 000 trappers) and placing a large number of recreationists (320,000 plus) at risk.  This would be an unfair restriction of to our public lands. 

Third, the TAC is recommending that there should be no mandatory trap checks, which we strongly disagree with.  24 hours is the maximum amount of time that should be allowed between trap checks.  This is the only respectful and humane way to curtail the trapped animals suffering.  Montana should follow the lead of other state's fish and wildlife agencies that have a mandatory check time.  For the sake of the animals, the Ecology Center urges you to adopt a 24 maximum check time.    

Our fourth concern is that TAC is requesting a voluntary "trapping in progress" posting policy.  The Ecology Center firmly believes that this should be made mandatory at all access points to public lands.  I can not emphasize enough how important it is to me, and probably most of the public, to know where these traps are located, so I do not put my dog, friends, or children in danger.  The location of these traps should not be a guessing game for the public, and should instead be the responsibility of the trappers to let us know where they are.

In general, the Ecology Center feels that the trapping community should not be given privileges that will place the general public at risk.  In addition, if trapping must be conducted, it should be carried out in the most humane manner possible.  Thank you for giving us the opportunity to comment, and we would appreciate being kept on the mailing list.

Sincerely,


Deborah Kmon
Ecosystem Defense