Dear FWP and the Elk Management Citizen Advisory Group -
Thank you for the opportunity to comment on your 'Choose Your Weapon/Season' proposal.
We appreciate the intent of this proposal, but we do not think now is the time to force this change upon Montana hunters. Here's why:
1) FWP just made sweeping changes to elk hunting and tag allocations in Montana, and we haven't been able to measure these effects yet on either crowding or elk harvests/management. Specifically, the new 'pick your district' for elk hunters serves the same purpose as a 'pick your season/weapon' would, to help spread out pressure on public lands. Let's see where this gets us first.
2) While public lands pressure is certainly part of the equation, the fact remains that FWP is being sued for having too many elk. If there’s an elk surplus in Montana, and there's no shortage of hunters, we ask FWP to focus on connecting those dots rather than further limiting hunting opportunities by forcing hunters to pick a weapon/season.
3) When elk sense pressure, they run to cover (often this means unpressured private lands). Elk don't know if hunters are after upland birds, mountain grouse, looking for a fall bear, a buck or a doe, or hold a widely available cow B tag, which are now unlimited in many districts - even for non-residents - some valid on public lands, and some six months per year. When we talk about pressure on public lands, we need to look more broadly than just bull elk hunters. For starters, we suggest limiting non-residents to the 90/10 split for all hunting opportunities, not just buck and bulls. But even there, last year, far more than 10% of deer and elk licenses were sold to non-residents: 66,624 deer and elk licenses went to non-residents, according to FWP's reporting for 2021. Before hunters are forced to pick a weapon/season, we encourage FWP and the legislature to look closely at non-resident allocations. One solution could be only allowing B tags to non-residents who hold a valid A tag in that area - this, in theory, would not increase the hunting pressure but could still increase harvests, and it could do so without limiting non-resident license sales and revenue.
4) Similarly, in limited-entry permit areas where increased harvests are needed, we suggest bull permits be delivered as a combo with an additional cow B tag applied automatically; this too could lead to greater harvests where needed without adding pressure. FWP has done this (and continues to do this in some areas) with antelope hunters, so why not elk?
5) It’s debatable on whether this change will even have the desired impact of reducing public hunting pressure. For one, if hunters are forced to pick a weapon/season, they'll just hunt during that season even more. In other words, if someone has two weeks vacation to hunt elk, instead of hunting for a week in archery and a week in rifle, they'll just hunt two weeks in one of them; that's not a reduction in hunting pressure, and there are plenty of Western states with shorter pick-your-weapon seasons to point to that illustrate this point. And if numerous rifle B tags remain available regardless, then this will do little to alleviate the number of hunters on public lands; unsuccessful archery hunters will just get a rifle B tag.
In the Breaks units, where it's essentially pick your season/weapon already, we can see that this has done little to solve public land hunting pressure there, so we remain unconvinced that this change will have the intended outcome. FWP admits in their response to this change that, "overcrowding is a perception held by individual hunters and landowners; no data exists to support concerns expressed regarding overcrowding." We suggest that FWP implement a surveying tool/mechanism to help track how many hunters are currently hunting with both archery and rifle, just rifle or just bow; at this point, no such data exists. It's critical that we investigate this further and think carefully about this drastic change before we force hunters to pick a weapon/season.
6) And finally, the biggest elephant in the room is this: FWP's elk management plan states: “to avoid over-harvest of accessible elk on public lands or private lands open to hunting, the inaccessible elk may not be included in objective numbers." Yet these inaccessible elk continue to be included in these counts leading to inflated numbers of tags being given out and six months of hunting pressure. If FWP managed for the actual number of accessible elk, that would improve the issue dramatically. We encourage FWP to take this feedback to heart and focus on the real issue here (access to inaccessible elk) before forcing hunters to pick a weapon/season; if the real issue isn't addressed, a pick-your-season/weapon change is unlikely to have the intended outcome.
Additionally, part of this recommendation is to create a "a two- or three-week break in which only private land cow hunting would be allowed in October." While this sounds good in theory, it's clear that this is unlikely to work as intended because landowners who outfit or reserve rifle hunting opportunities for themselves and friends/family early in the season will be unwilling to let public hunters push elk off their property right before they want to hunt them. While the current 'dead week' season is not part of the current shoulder seasons, it's clear that the majority of shoulder season access is already allowed in the late season and not before rifle. We don't expect this change to result in much use/cooperation from landowners. That said, instead of mandating a longer dead week period, we recommend changing current shoulder season regulations to allow cow harvests on private lands only to continue during the current dead week. And we'd like to reiterate our requests that all shoulder seasons and all unlimited B tags should be valid on private lands only, regardless of when/how long they're allowed.
Thank you again for the opportunity to comment on your 'Choose Your Weapon/Season' proposal, and we appreciate your careful consideration on such a drastic change.
-The Montana Chapter of Backcountry Hunters & Anglers