Dear FWP and the Elk Management Citizen Advisory Group -

Thank you for the opportunity to comment on your 'Promote Focused Damage Hunts' proposal.

We agree that game damage hunts can be an effective tool, and we'd love to see this program ‘reinvigorated.’ When done properly, this is exactly the kind of tool landowners and hunters should support - a targeted and equitable opportunity to both address problem elk and fill Montanan’s freezers.

Now, let’s make it better.

It’s no secret that participation in the hunt roster has been dwindling. Hunters are partially to blame for this as folks aren’t showing up, aren’t being effective killers and/or aren’t respecting private property (leaving gut piles, driving where they shouldn’t be, etc). However, the alternative programs FWP has recently offered are also to blame for this drop in participation: thanks to liberal B tags, 454s, shoulder seasons, etc, landowners can now simply ask friends/family/neighbors to come shoot cows from August through February often only needing readily available OTC B tags for $20. In other words, landowners don’t have to go through the hassle of including FWP and allowing random members of the public on their land. In some ways, we don’t blame them.

However, we can help make this work once again giving landowners the tools they need (reliable hunters) and keeping these opportunities to harvest a public resource equitable and available to the public.

1) We fully agree with the proposal to split the hunt roster and the application for the hunt roster in two. Hunt 1 should be from August 15th-December 1st and registration for that June 15-July 15; Hunt 2 should be from Dec 15th - Feb 15th and registration for that can be Dec 1 - 10. This will allow hunters to re-evaluate their freezers and ask themselves after the regular season if they really want to drive X miles to shoot a cow off a hay bale in the cold when they already have plenty of meat. In turn, landowners and FWP should be left with a better list of willing and able hunters when called upon.

2) We fully agree with the proposal to charge a small fee to apply for the hunt roster(s). $10 seems fine, but if successful applicants are given free B tag, we encourage FWP to consider charging the full price for this B tag at the time of the application, and refund all but $10 of that if the applicant is not selected in the hunt roster hunt. We feel that charging a small fee up front will force hunters to think twice about this and ask themselves if they’re serious enough to pay a few bucks for this opportunity. We don't want this to be cost prohibitive, but just enough to weed some folks out. As mentioned, this fee could be returned if folks aren’t called or - preferably - this fee could be put towards block management, habitat Montana, or other game damage efforts like fence repairs, payments for crop damages, etc - this could be an optional refund like some license fees are now. But the main goal isn’t to raise a bunch of money it’s to flash a sign saying ’serious hunters only please.’

3) For the most part, we agree that this should be for residents only, though we do think some concerns around the borders are warranted (ie some folks in SD are closer to some of these ranches than someone in Bozeman). But we must draw the line somewhere and with ample non-resident opportunities already, that seems like the easiest line to draw. If possible, however, we suggest the line being residents and/or non-residents within 150 miles only. An additional exception should be made for non-resident landowners who own land in MT and would want to apply, as could full-time non-resident students in Montana.

4) We support the idea to expand the hunt roster eligibility to all landowners who enroll in any of FWP's private land/public access programs. However, if 87‐ 1‐225 needs to be revisited by the legislature, we hope FWP and hunting groups like BHA are included in that process so the language leads to more participation but does not lead to abuse and/or further blocking public hunting opportunity during the regular seasons.

5) We agree that this needs to remain a public hunting opportunity and that "FWP should reevaluate the random draw by giving the landowner and biologist the ability to select the hunters who signed up for roster to participate. Biologist and landowners can select a portion of people who sign up and a portion will remain randomized." We recommend that portion remain 25% selected by the landowner with the remaining 75% being randomly selected by FWP.

6) We fully support the other recommendations to allow landowners and biologists the ability to give participants a strike and they are removed from participation in the damage hunt roster in the future for bad behavior," along with removing participants from applying during the following year if they're a no-show.

That said, we think that excluding participants who must decline the opportunity for some reason is too rigid of a requirement. With the steps taken above, we'll be left with a better list of willing participants leading to fewer 'declines,' but it will never be perfect. Life can still get in the way of participation, and we'd be wise to offer some flexibility to account for that.

7) The requirement that 'all game taken is mandatory to report to biologists within 24 hours' seems reasonable as well.

8) And finally, while it's not a driving force behind our support of this proposal, it's also worth noting that FWP's fiscal analysis suggest a net increase in revenue of $54,910 from this change. This revenue could (and should) be used to further improve the hunt roster program by improving the management/implementation of this program (dedicated FTE?) and/or providing additional fencing assistance or other incentives to participating landowners.

Thank you again for the opportunity to comment on your 'Promote Focused Damage Hunts' proposal. We appreciate your careful consideration.

-The Montana Chapter of Backcountry Hunters & Anglers