PCEC's Public Comment for Siskin Island FAS Acquisition Project FWP
To: Mark Filonczuk, Region 3 Recreation Manager, FWP Region 3, 1400 S. 19th Ave., Bozeman, MT 59718
RE: Siskin Island FAS Acquisition Project FWP-CEA-POR-R3-26-004
Dear Mr. Filonczuk,
Park County Environmental Council (PCEC) would like to thank the Montana Fish Wildlife and Parks (FWP) for the opportunity to provide our comments on the Siskin Island FAS Acquisition Project.
PCEC serves as a local grassroots environmental group with more than 500 members and 2,300 supporters. We appreciate your time and consideration on this important matter. PCEC has worked to protect and preserve the vast natural resources of Park County, Montana, since 1989. We are a county-wide environmental group focusing on issues affecting Park County. PCEC works with residents to safeguard and advocate for the county's world-class rivers, diverse wildlife, landscapes, and outstanding natural beauty, while protecting the health and wellbeing of people who live and work here.
Initially formed by a small group of community members to advocate for wild places, wilderness and quality-of-life issues in Park County, PCEC has grown to cover numerous issues related to the Yellowstone River and its tributaries, public land management, land use and threats from development, while encouraging community engagement on these issues.
If we want to ensure that the Greater Yellowstone Ecosystem (GYE) continues to maintain its vital importance for wildlife, intact habitat, and ecological diversity for generations to come, as well as our reverence for wild places, we encourage the FWP to manage Siskin Island in a manner that preserves its inherent natural qualities.
The GYE is home to some of the most vibrant, diverse and intact wildlands in the Lower 48. It is still home to all the major species of mammals that were present on this continent prior to the arrival of Europeans, having long provided refuge for elk, bison, wolverine and grizzly (and room for the return of the wolf). Its wildlife migration corridors are extensive and still mostly intact. All of this is possible because it contains habitat that remains largely unfragmented and preserved into the 21st century.
We applaud the partnership between the Trust for Public Land and FWP to permanently protect this landscape. However, to ensure this project serves the best interests of the river, the wildlife, and our neighbors in Paradise Valley, we offer the following comments on the proposed land acquisition and management of Siskin Island.
Public Process The 15 day comment period was not enough time for the public and community of Park County to assess, analyze and weigh in on the proposal. FWP needs to conduct additional outreach and extend the public comment period another 30 days. We also recommend holding a public meeting in Paradise Valley to present on the draft environmental assessment, and to be on hand to answer any questions or concerns people may have.
Habitat and Resource Protection Siskin Island contains critical cottonwood forests and sits adjacent to some of the most important trout spawning side-channels on the river. We strongly support the permanent protection of these 82 acres from private development. To maintain this integrity, we ask that FWP:
Enforce Strict Fire Restrictions: Given the mature forest, proximity to residential properties, and inaccessibility, a no open fire policy must be strictly enforced to prevent wildfire risk.
Prioritize Weed Management: FWP must commit to an aggressive monitoring and treatment plan to ensure that increased foot traffic does not accelerate the spread of invasive species like spotted knapweed, leafy spurge, and hounds-tongue just to name a few.
Trout Spawning: Clear signage should be placed alerting users to trout spawning redds to prevent their disturbance during spawning seasons. If use and pressure becomes too great, fishing closures should be implemented to protect spawning trout habitat.
Balancing Public Access and Stewardship This acquisition secures rare wade-in and float-in access between Mallard’s Rest and Pine Creek. While FWP recognizes that existing unmanaged and illegal recreational use is already occurring, and that the agency management will be beneficial, it must also be recognized that once Siskin Island becomes public the recreation use pressures will increase significantly.
While we celebrate this public access, it must be properly managed to prevent degradation. Based on what’s presented in the draft environmental assessment we believe greater measures will be needed to manage the island than are typically needed for the average fishing access site, especially given its location one of the most heavily used reaches of the Yellowstone River.
Due to the fact that there is no road access to the property, Siskin Island presents unique management challenges. Our recommendations for public use reflect FWP’s current management of the Smith River.
Limited Overnight Permits To prevent overcrowding and multiple camp site establishment, FWP should implement a mandatory permitting system for all overnight stays on the island.
Cap on Capacity: Limit total occupancy to 3 designated campsites per night.
Advanced Reservations: Permits should be available through an online portal at FWP’s website to allow floaters and anglers to plan their trips in advance.
Walk-in/Last Minute: A small percentage of permits could be held for same-day users to accommodate spontaneous local use, provided the daily cap has not been met.
Fee-Based Stewardship Fund A modest permit fee (e.g., $10–$20 per night) should be established to directly fund the island’s maintenance, similar to existing FAS campsites like Mallards Rest and Loch Leven.
Controlled Capacity and Site Footprint To prevent the industrialization of this wild space, protect understory vegetation, and to preserve as much of the inherent natural character as possible, the human footprint must be limited.
Designated Campsites Only: Camping should be limited to 3 small, clearly marked sites. This concentrates human impact and leaves the remaining acreage as a sanctuary for wildlife.
Stay Limits: Overnight stays should be limited to 3 consecutive nights to prevent long-term occupying of the best river-access spots.
Group Size Limits: Each permit should be limited to a maximum of 10 people, matching the capacity of the designated campsites and preventing the degradation of the surrounding cottonwood forest to maintain the quiet, low-impact character of the upper Yellowstone.
Day-Use Access (No Permit Required) To maintain the tradition of open access on the Yellowstone, day-use (fishing, picnicking, and hiking) should remain permit-free.
Signage: Clear signage at the primary wade-in and float-in points should distinguish between permit-required camping areas and general day-use areas.
Human Waste Management Because Siskin Island is an undeveloped river site with no road access for permanent restrooms, protecting water quality is paramount.
Mandatory Pack-Out System: All overnight users should be required to use a portable, leak-proof toilet system (e.g., a "groover" or WAG bags).
Prohibition of Ground Burial: Due to the island's porous river cobble and proximity to trout spawning side-channels, burying human waste must be prohibited to prevent pathogens from leaching into the Yellowstone River.
Graywater Disposal: All dishwashing and bathing should occur at least 150 feet from the river and side channels, using only biodegradable, phosphate-free soaps.
Wildlife Stewardship (Bear Awareness) Siskin Island sits within a known corridor for both black and grizzly bears.
Food Storage Orders: All food, trash, and scented items must be stored in IGCB-approved bear-resistant containers or hung properly when not in use.
Carcass Management: For hunters using the island, strict rules should be in place regarding the immediate removal of internal organs and carcasses to avoid attracting predators to high-use recreation areas.
Hunting and Safety Buffers Given the island's unique position near a residential neighborhood extra hunting measures need to be taken.
Weapon Restrictions: To ensure the safety of nearby residents and other river users, we recommend restricting hunting on the island to archery for big game and shotguns (with shot only) for waterfowl. Prohibiting the use of centerfire rifles and shotgun slugs will provide a necessary safety buffer for the adjacent Paradise Valley neighborhood.
We believe that with these smart management tools in place, Siskin Island will become a model for how we can provide high-quality recreation while protecting the wild character of the Yellowstone River. Thank you for the opportunity to comment and for your work to ensure this special place remains intact for future generations.
Sincerely,
Max Hjortsberg
Managing Director