July 14, 2023

Dear Montana Fish, Wildlife, & Parks:

On behalf of the Montana Chapter of Backcountry Hunters & Anglers (MT BHA), please see the comments below regarding the statewide proposals discussed and distributed at the statewide biennial hunting season-setting scoping meetings.

First, we appreciate the efforts of the Department to be transparent and provide ample opportunity for public engagement with these efforts. The public scoping meetings provided needed information to public hunters, and we applaud the Department for providing us with the opportunity to ask questions and to be heard.

Many of our supporters and board members will be submitting comments focusing on regional proposals, but regarding the statewide season proposals, we have a few suggestions related to the proposals that we believe most directly affect our membership and mission. Specifically, we would like to speak to the proposal to require mandatory submissions in CWD areas and efforts to reduce hunter crowding.

The Montana Chapter wholly supports mandatory submissions in CWD management areas. CWD is one of the biggest threats to the health of our wildlife and our future hunting opportunities, and any and all efforts to curb the spread are greatly appreciated. Enhanced and more accurate data collection will only help the Department with this effort, and we fully support mandatory testing in specific deer/elk hunting license or special permit areas, or by specific portion(s) of a hunting district (on a specific range of dates), or both.

Additionally, we encourage the department to take the necessary steps to require mandatory reporting statewide, across all reported species. This would provide far more accurate data for not only pressing issues like CWD, but also broader concerns like wildlife (and hunter) distribution, harvest rates, age class, and success rates by weapon/season, among other things

Regarding the proposals to address hunter crowding by limiting "hunters to hunting mule deer on their general license in only ONE of FWP’s seven administrative regions," we ask the Department to first consider applying this sort of change to nonresidents only. Doing so, along with the proposed "cap placed on the number of mule deer hunters that could hunt in each administrative region of Montana," and applying that to nonresidents only would distribute hunting pressure from the group of hunters responsible for growing hunter numbers, according to data from the Department, without forcing resident hunters to make sacrifices to their hunting traditions. At least not yet.

This, coupled with the impacts from SB 281 passed this session (which limits the number of deer B tags nonresidents can purchase to one or two) could lead to better hunter (and wildlife) distribution, fewer hunters days from nonresidents in overcrowded regions, an increase in hunter harvest rates for all, and improved mule deer population numbers, all desirable outcomes for Montana’s hunters.

Applying these changes to nonresidents and implementing mandatory reporting together would provide the needed data after a five year period to better understand if this sort of change is helping, hurting, or worth reconsidering.

Furthermore, we believe the idea of restricting "hunters that apply for special mule deer permits from hunting antlered mule deer bucks on their general license in other hunting districts (e.g., if you apply for a special permit, you would NOT be able to hunt antlered mule deer in other hunting districts even if you did NOT draw the permit you applied for)" is intriguing, but likely too drastic of a change and sacrifice in opportunity to gain the needed favor amongst resident hunters, according to the research done by the Department. We remain neutral on this.

The proposal to limit mule deer hunting to antlered deer only in areas where mule deer populations are lower than desired seems reasonable. However, this begs the question of how to define 'lower than desired.' We encourage the Department to launch a statewide mule deer management plan to help answer that question and outline specific management objectives. In the meantime, we remain neutral on this.

Finally, regarding a proposal to expand waterfowl hunting, we support expanding waterfowl opportunities within the framework of the existing federally controlled seasons in whatever areas of Montana that the shared public resource can sustain. The area between the confluence of the Bighorn and Yellowstone Rivers to the Rosebud-Custer County seems like it now fits that description. Let's open it.

Thank you for the opportunity to comment, and we look forward to engaging further this fall during the draft regulation proposals comment period

We appreciate your careful consideration,



Jake Schwaller, Billings, MT

Volunteer Board Member, Eastern Montana Conservation Leader
Montana Chapter of Backcountry Hunters & Anglers