Montana's new Elk Management Plan is out for comment now. It's nearly 500 pages. So what's in it? 

Well, there are some things to like, for example, the raising of objectives - now called goals - in many districts in the eastern half of the state. And using a three-year average rather than just yearly counts to decide if we’re at, above or below objectives or goals seems like a prudent change. Additionally, allowing the plan to be updated, with evaluations scheduled every five years, can help ensure that we don’t find ourselves operating with a dusty, 20-year-old plan once again down the road. We appreciate that adjustment too, and we hope regular updates become more of a requirement than simply a possibility.

However, some language raises our eyebrows. For example, "under circumstances where an HD is chronically and significantly over the stated population size goal and is using limited either-sex permits or limited bull permits, FWP will propose to allow a brow-tined-bull or any bull on a General Elk License regulation type," states the new Elk Management Plan. 

In other words, FWP is proposing to eliminate the limited-entry permitted bull hunts in Montana in areas that are over objective "for 3 or more consecutive years without a demonstrable change in population trajectory." 

But will this really help achieve population goals? Does harvesting bulls or cows have more of an impact on the herd size? Are there already ample tools to harvest cow elk and incentivize public access? Would property owners who outfit their lands be more likely to work to get to objective with this change, or would they be tempted to allow elk herds to grow or stay where they are so bull tags become more readily available? Are we incentivizing the right behavior, and using the right incentives to get there?

If this sounds like déjà vu, it's because it's very similar to HB 417 brought by Rep. Kassmier (R-Fort Benton) during the 2021 session (the same lawmaker who sponsored HB 635 this session, which removes nonresident deer and elk tags from the draw and awards them to non-resident landowners). HB 417 would have prohibited FWP from offering limited permits in any hunting districts over objective for elk, deer or antelope, and would have eliminated many of Montana's most coveted hunting permits including Missouri River Breaks bull tags in the process. Hunters showed up for that one, making phone calls and sending letters (BHA members sent nearly 6,500 emails on that bill alone). HB 417 was withdrawn by the sponsor before it even had a hearing.

Needless to say, we're guessing that this part of the new EMP will be an unpopular idea with Montana's hunters once again.

But we're anxious to hear your thoughts on this change and others, and so is FWP: comments on the Elk Management Plan are due by July 31st.

Here are some other things we have our eyes on:

- Broadly, we appreciate the department’s efforts to update the long outdated EMP, and most of what we see is largely reasonable. 

- We commend the department for looking at more than just population size and we’re intrigued by some of the new metrics the new EMP will use to measure success, including goals around elk distribution, agricultural impact, and recreational hunting. But until we see how these play out in practice, it’s hard for us to support or oppose these changes. For example, we can see how managing for ag impacts can be beneficial, but we can also see how it might put into question elk as an equitable resource held in public trust. As with much of the EMP, the language is vague while the implementation and impacts remain to be seen.

- Similarly, there’s an added emphasis on both public lands elk habitat and increased use of refuge areas by elk; we’re glad FWP is taking a close look at these related issues, and we encourage even more attention and focus on motorized routes, seasonal restrictions and security habitat on public lands. We also recognize that when it comes to land and travel management practices on federal public lands, FWP has limited influence.

- What concerns us most is what’s not in the plan, namely the language found in the 2005 Plan around an unfollowed provision of not counting inaccessible elk. Doing so only balloons the herd counts and leads FWP to implement more liberal tag allocations; this only puts added pressure on the accessible elk, thereby pushing them onto inaccessible properties, and making the problem even worse. The 2005 language around not counting inaccessible elk recognized this problem, but needed better definitions to be implemented (it was never followed, not once), but it was certainly a provision worth keeping and improving rather than tossing out entirely. Doubly concerning, the proposal to replace this by moving these sort of districts to general season bull licenses (mentioned above) will likely amplify the problem even more rather than alleviating it.

- Additionally, the new EMP mentions nothing about the need for mandatory reporting. We’re currently missing a lot of needed inputs in these discussions that could be gathered from mandatory reporting, things like what weapon did you use? What season were you out in the field? When did you harvest? Were you hunting public, private, or publicly accessible private? And more. Good management decisions require good data.

Overall, despite growing anticipation, FWP has sought to make it known that this EMP is really just a guide. While understandable, some of the prescriptive tools that are outlined give us pause, and the remaining lack of clear directives means the true impacts and implications of this new plan are uncertain.

Montana BHA is still working on our final comments, but if you have feedback or think we’re missing something, please let us know.

Comments on the Elk Management Plan are due by July 31st.