January 21, 2022

Chair Robinson, Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull & Lane
Montana Fish Wildlife & Parks
1420 East Sixth Avenue
P.O. Box 200701 
Helena, Mt 59620-0701

Re: Comments on the 2022/2023 Region 3 Deer and Elk Proposals

Chair Robinson; Vice Chair Tabor, Commissioners Waller, Byorth, Walsh, Cebull and Lane:

The Montana Chapter of Backcountry Hunters & Anglers, on behalf of our 3,000+ dues-paying members, submits these comments regarding the 2022/2023 Region 3 elk and deer proposals. Montana BHA believes the foundation of Montana’s successful hunting heritage is rooted in our state’s adoption of public trust principles. The Montana Chapter strongly urges the FWP Commission to maintain the status quo with the seasons as they currently stand until the following issues can be addressed by FWP.

Our primary issue is with how the process has unfolded. The introduction of new districts happened as hunters were in the field for 2021 hunting season, focusing on the current year’s hunt. On top of the many changes with districts, additional, wide-sweeping regulation changes were introduced in early December, often with either the sole justification of simplification or the sole justification based on outdated deer and elk management objectives. While the changes may have been simple to conjure up, they were far from simple to track down and comprehend. For example, while listening in to the CAC virtual meetings discussing the proposals, we were told that additional changes had been made that were not reflected in any of the documentation found online. This oversight means Montana hunters simply don’t know if we’re commenting on the correct proposed regulations. This alone should invalidate the entire process or, at minimum, trigger a 60-day extension with clear and congruent proposals.

A secondary issue is focused only on the elk regulations and management. The proposed changes are being justified with management objectives that are severely outdated; it is our understanding that new elk objectives are currently being drafted. Why introduce sweeping changes without a current blueprint for operation? Would it not be in everyone’s best interest to roll out the new management objectives and then use that to make necessary regulation changes? Although this suggestion may give the impression of “kicking the can down the road,” it really is finding proper – and current – justification for the management of Montana’s elk herds.

Finally, we would like to point out some specific issues in Region 3 districts, with the caveat that these are the proposed districts, which have not yet been approved (cart/horse). While there are many other issues, the following are examples of our concerns:

HD 331 – this is the combination of 331 and 332

This a district where the online documentation does not reflect what is currently being proposed. While the regulations discussed during the CAC meeting do have sound reasoning, its troubling that folks don’t really know what they’re commenting on.

HD 322 – Combination of 322, 323, 324, 325, 326, 327 & 330

The main concern we have for this massive district is the management of mule deer. The current districts have three different rules: 322, 325, 326 & 330 are all either-sex mule deer; 323 & 327 are mule deer buck-only; and 324 is a limited buck-only permit. The proposal is to change the entire district to either-sex with a general tag. While Montana BHA supports increased opportunity, we have real concern with the ability to maintain a healthy population when the district is so large and of differing habitat and access. With no biological justification for this change, it would have significant impact on the size of the deer herds and age class of bucks. At the very least, creating two districts here would be a better solution: 322, 325, 326 and 330 could be either-sex, while 323, 324, and 327 could be buck-only. An even better solution, however, would be to make the area three districts, leaving 324 on it’s own, as is, and combing 323 and 327. A secondary concern with the liberal mule deer management proposal here is that increased and unchecked hunting pressure will likely push more deer (and elk) onto inaccessible private land.

HD 343 – combination of 343 & 293

MT BHA opposes the expansion of HD 343 to include the portion of the public lands of HD 293. HD 293 public lands provide a refuge for elk during hunting season. Many of these elk will migrate to the winter range on the east side of the Continental Divide in HD 343 after the rifle season ends. This refuge is responsible for HD 343 maintaining an elk population at the management objective. If we combine these districts and allow cow elk harvest on public lands in the current HD 293, we will likely experience a significant decline in elk numbers in HD 343 and HD 293.

We applaud, however, the dropping of the shoulder season in 391 because it’s just slightly above the (outdated) objective, the shift to mule deer buck-only in 340 due to declining populations, and the combination of 321 and 334, which were separated just a few years ago. We question the rationale of changing regulations for elk in 314, mule deer in 393 and the combination of 350 & 370, when they will still be managed as portions.

In closing, the introduction of these wide-sweeping changes in combination with the district realignments, all before new elk management objectives are landed on, has muddied the waters significantly. In the spirit of simplicity, we implore the commission to reject all current proposals and maintain the status quo or, at a minimum, extend the season-setting process for an additional 60 days so all the changes can be properly and accurately vetted.

Respectfully,

Chris McCarthy, Gallatin Board Member

Montana Chapter of Backcountry Hunters & Anglers

Belgrade, Montana