March 16, 2022

Wildlife Division

Montana Fish, Wildlife & Parks

PO Box 200701

Helena, MT 59620-0701

[email protected]

Re: Comments on Proposed 2022-23 Mountain Lion Regulations

The Montana Chapter of Backcountry Hunters & Anglers (Montana BHA) represents roughly 3,000 dues-paying sportsmen and women in Montana who value quality recreational opportunities and ethical conduct in the outdoors. Our Chapter values the opportunity to hunt mountain lions in quality habitats and strives to pass our fair-chase traditions to the next generation of responsible hunters. We appreciate the chance to comment.

We oppose the adoption of the Fish and Wildlife Commission's tentative proposal to create a new and overly complex lion hunting season that would split hunters between special permit holders and general license holders.

We stand in opposition as our state is once again looking at an upheaval of our traditional hunting seasons at the expense of our shared and valued lion resource; to the detriment of resident hunters; to the erosion of established and locally attuned hunting practices; and to the sole benefit of none other than the outfitting industry set on allocating our public wildlife to high-paying nonresidents by making Montana the playground for the nation’s wealthy elite.

We are confident the current statewide lion seasons are highly effective and broadly supported in meeting lion and hunting management purposes. We see no reason to deviate from what is working well in the state's various regions under careful science-based management and extensive public input. In fact, resident lion hunters from around the state have been vocal in their support, favoring the current regulations over the proposed seasons. Moreover, local interest groups who have a vested interest have not been consulted in developing any of this. The proposal is simply unnecessary, top-down, and runs counter to sound wildlife management including healthy public involvement.

This proposal – following on the heels of other statewide proposals to manage lions floated by FWP in late January – is a solution in search of a problem as the issue it aims to address is poorly defined, let alone justified. It appears to be aimed at overturning the existing hunting season in northwest Montana’s region which currently requires a limited-draw permit to hunt lions with a set cap of 10% on nonresident hunters. Thinly disguised under the veil of creating the opportunity to kill more lions as currently achieved, it appears that Fish and Wildlife Commission Pat Tabor of Whitefish - himself an outfitter offering guided mountain lion hunts to nonresidents - is single-handedly ramrodding this proposal. Stripped to its core, the proposal would benefit no one other than nonresident hunters who would be able to easily purchase an unlimited lion license and who disproportionately solicit outfitters' services. Commissioner Tabor has a vested interest in creating more opportunity in his backyard, especially for those high-paying clients itching to hunt in the Treasure State. An outfitted lion hunt can easily fetch upwards of $5,000 per hunter; Commissioner Tabor’s outfitting business, Swan Mountain Outfitters, sells these for $6,550 per hunter.

History tends to repeat itself, and the lesson learned in Montana is that a quota system with unlimited licenses can be a recipe for disaster, both for the lion population and the hunting public. In areas with good snow and access conditions, such as in northwestern Montana, a quota system with unlimited licenses can lead to fierce competition among hunters to get to a lion first, with outfitted hunters typically having a stiff upper hand. The harvest quotas are often met on the first day of the season and quota overruns are not uncommon. Moreover, an important factor in mountain lion hunting, this pressured hunt scenario often forces hunters to shoot the first lion they tree, knowing the season may close quickly. In practice, this means more female and younger lions are killed than wildlife managers and resident houndsmen like to see. Favoring quantity over quality to facilitate the financial exploitation of a finite resource is an unwise scheme. This proposal fosters the wrong incentive structure which, in turn, is then used to dictate management decisions.

In summary, we favor the current season structure that evolved over time by creating equitable and fair opportunities for all to a quality lion hunt and by putting the resource first in a principled and justified manner based on sound management of a public trust resource. For some to gain financially at the expense of a devalued opportunity for others is a poor justification to change what is working just fine across the state.

Sincerely,

Thomas Baumeister, Helena, MT

Board Vice Chair & Capital Leader

Montana Chapter of Backcountry Hunters & Anglers

Molly VandeVoort, Columbia Falls,

MT Flathead Board Member

Montana Chapter of Backcountry Hunters & Anglers