December 12, 2019
Montana Fish, Wildlife and Parks
Attn: Commissioner Aldrich;Commissioner Byorth; CommissionerStuker; Commissioner Brower; Commissioner Colton; Director Wiliams; Wildlife Division Chief McDonald; Game Bureau Chief Vore
1420 East Sixth Avenue
P.O. Box 200701
Helena, MT 59620-0701
Dear Commissioners, Director Williams, Wildlife Division Chief McDonald, and Game Bureau Chief Vore:
In Montana, elk are a public trust resource. FWP is entrusted with the duty to manage and conserve this resource for the benefit of current and future generations. Using ‘the best science available’ is a cornerstone of the public trust mandate, a pillar of science-based resource management, and a principle that guides the work of FWP (see FWP’s Vision and Guide 2016-2026).
We believe this tenet may not have been fully realized in the recent evaluation of the performance of the 2016-2018 Elk Shoulder Seasons (ESSs).
We believe the approach used by FWP to perform the evaluation to be incomplete. This may lead to erroneous conclusions by both FWP and the public regarding the performance of ESSs and may undermine the credibility of the tentative 2020 ESS, which draws upon this analysis.
We respectfully ask for the following concerns to be addressed:
- FWP Harvest Data: FWP uses ‘harvest data’ to evaluate the performance of ESSs. In doing so, the department surveys hunters using stratified sampling to arrive at point estimates for harvest rates. Since the harvest rates are estimates only, the procedure also includes computing confidence intervals (range of values presented by lower and upper bounds) and including a measure of reliability, e.g., FWP is confident that a sample of this size contains the true harvest rate 80% of the times. This has been the standard protocol developed by FWP years ago and used to this day. Yet, the data tables, see attached, fail to list the corresponding confidence intervals with each harvest estimate. This may lead to the perception that harvest rates are absolutes based on a census of hunters, rather than the survey that it is. Furthermore, it tends to result in a simple computation of the difference between the estimated harvest and a target harvest using point estimates only, as has been done by FWP, which is not an appropriate approach given the nature of the data involved. Technically, the ‘recruitment model’ used to set the initial harvest targets is subject to similar concerns but won’t be addressed here. Relatedly, we encourage FWP to seriously consider mandatory harvest reporting and/or mobile/electronic reporting techniques in the future to strengthen our confidence in harvest data moving forward.
- Evaluation Criteria & Upper Harvest Cap: According to the Final Elk Season Guidelines (adopted 10/08/2015), ESSs “are designed to supplement existing harvest, not replace or reduce harvest during the existing general archery and firearm seasons.” Furthermore, “harvest criteria … have been developed to reflect this intent, to describe the harvest necessary to reduce elk populations, and to help ensure transparent and consistent assessment of how shoulder seasons are performing.” Specifically, the Commission and Department committed to conducting an annual public review of shoulder season performance relative to criteria and fundamental objectives and review shoulder seasons and associated decisions in scheduled season-setting processes. Accordingly, FWP established ‘harvest that is needed’ to be compared against ‘harvest that was realized’. For some hunting districts, the ‘harvest that was realized’ vastly exceeded the ‘harvest that is needed’. Yet, the evaluation performed by FWP considered only two possible outcomes: meets criteria(coded in green) and does not meet criteria(coded in orange). Given the aforementioned goals, we believe a third outcome deserves genuine consideration: exceeds criteria. In our opinion, the additional category is necessary to comprehensively examine the effectiveness and impact of ESS. Our concern is that in some hunting districts elk may be harvested at rates greater than necessary, resulting ultimately in smaller populations especially in more publicly accessible areas. By not specifying an upper cap on desired elk harvest, FWP creates the perception of a ‘the more the merrier’ management approach to elk which is not consistent either with managing a public trust resource nor the statutory requirement to manage populations to objective (MCA 87-1-323).
- ESS Evaluations: The 2020 Elk Shoulder Seasons Master List and Justificationsused by both FWP staff and FWP Commission during the December Commission meeting includes hunting districts for which there have been only one or two years of ESSs. These seasons appear to have been evaluated by FWP but the findings have not been shared with the public yet. We ask that any and all ESS evaluations be compiled and published in a comprehensive report in order for the public to have a full accounting of the performance of ESSs.
We kindly request FWP to address the aforementioned concerns to the evaluation ideally prior to the close of the public comment period on the tentative 2020 ESS to facilitate informed public comment and decision-making. Please let us know when we might expect this to be accomplished.
Capital Chapter Leader, Montana Chapter of Backcountry Hunters & Anglers