January 19, 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 Statewide 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 statewide 2022/2023 elk proposals.

Montana BHA believes that the foundation of Montana’s successful hunting heritage is rooted in our state’s adoption of public trust principles, and we hold few species in higher regard than our elk. Montana’s elk hunting legacy is at stake with these proposals. Montana BHA strongly urges the Fish & Wildlife Commission to maintain the status quo with the seasons as they currently stand until the following issues can be addressed by FWP.

First, we ask that the suite of changes re: elk hunting in Montana be denied for failure to follow sound public process. Both this Commission and the public have a right to fully understand what motivated FWP to suggest these changes without any updated elk management plan or clear data. Since the inception of these proposals, there have been issues with incomplete, missing or confusing information provided by FWP. During many regional meetings, FWP’s biologists pointed out that the proposed changes on the website did not match the changes as they understood them, creating a situation where the public truly doesn’t even know what we’re commenting on. This makes it impossible for the public to fully understand the effects of these proposals, rendering the process, at minimum, ineffective, and potentially in full violation of the public’s rights.

Second, the objective population standards being used to justify these statewide changes are based upon numbers that are long outdated. FWP has an obligation to provide updated management objectives prior to any comprehensive alterations to elk hunting in Montana. To make these novel changes without operating on any corresponding new data is not simply unprofessional, it is reckless. It puts the cart well before the horse and provides no means to measure and quantify success, nor to justify the wholesale changes being proposed.

Third, if we were to accept the process and the reasoning behind many of these proposals (which we don’t), we’re still forced to point out that these proposals do not address the stated problem of too many elk, especially on private lands:

1. If access to elk is provided, sound principles of biology have repeatedly shown that reduction in cows will reduce populations. Increased bull hunting will make little to no difference, however. Therefore, adding 50% either-sex (bull) permits in some areas will only increase hunter pressure on public lands, which in turn will drive more elk onto private lands. This is counter to addressing the stated problem of too many elk on private lands. For these reasons we oppose the statewide either-sex elk permit proposal.
   
   
2. Similarly, removing and unbundling the 900-20 permits will have the same effect; unlimited archery pressure on public lands will simply drive more public lands elk onto private lands. Changing these limited-entry archery permits to general or unlimited permits will also open the floodgates to non-resident hunters. While this may make some private land outfitters happy, it will not address the stated problem. Conversely, this will return us right back to the situation we were in prior to 2008, when after 2,000 public comments the Commission changed these units to limited-permit archery opportunities, with a 10% non-resident cap. Undoing this change will result in even more public land hunters and more pressure today. It’s also worth noting that as a population management tool, archery opportunities are largely ineffective. For these reasons, we oppose the statewide archery-only permit proposal.
   
   
3. The Antlerless B proposal would continue the failed experiment of shoulder seasons by extending cow tags through February 15. Shoulder seasons were implemented in 2015 as a three-year experiment; seven years later, they have proven to be as divisive as they are useless at reducing over-objective elk populations. The answer cannot be doubling down on something that simply has not worked and expecting different results. For this reason, we oppose the statewide antlerless B proposal.
   
   
4. And finally, forcing hunters to ‘pick your district’ may have the added benefit of spreading out pressure, but it will come at the cost of many Montana hunters’ traditions and hunting heritage. In terms of a justified management tool, we cannot support or oppose this proposal as it’s unclear what the changes to harvest rates and elk concentrations on public/private will be. For these reasons, we remain neutral on the statewide elk permit proposal.

The Commission’s decision now regarding the future of our elk will echo for many years to come. We implore the Commission to make its determinations based upon updated elk management objectives, sound science and comprehensive and transparent public participation and input. Therefore, we ask that the Commission please reject these proposals and maintain the status quo until new elk management objectives are in place. To do otherwise would be a gross breach of the public’s trust.

Jake Schwaller

Board Member

Montana Chapter of Backcountry Hunters & Anglers