November 9, 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 proposed 2024/25 statewide season-setting regulations.
First, we appreciate the ongoing efforts of the Department to provide opportunities for public engagement with these efforts. Citizens must have a say in these matters, and while we generally have confidence in FWP's field staff and think their opinions matter, they shouldn't be the be-all and end-all when it comes to decisions on wildlife held in the public trust. The current season-setting process could be further improved by creating better opportunities to solicit and include ideas from citizens.
While many of our members will submit comments on their own focusing on regional proposals, we have a few suggestions related mostly to the statewide season proposals.
The Montana Chapter supports mandatory submissions in CWD management areas, and we flagged this during scoping. CWD is one of the biggest threats to the health of our wildlife and hunting opportunities, and any and all efforts to curb the spread are greatly appreciated. Surveillance is key, which is why we support the proposed mandatory testing requirement in Region 1 CWD management areas and request that this requirement be expanded to the Region 6 CWD Management Zones as well.
Additionally, we encourage the department to take the necessary steps to require mandatory harvest reporting statewide across all reported species. It’s way overdue. 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. We flagged this in our scoping comments, and are disappointed that mandatory reporting is not included in the final proposals.
Many proposals related to deer-hunter crowding discussed during scoping did not make it to the final proposals. We remain neutral on the deer-hunter crowding proposals discussed during scoping, and we recognize the real and growing concern that is hunter crowding. We encourage the Department to not only require mandatory reporting but to launch a statewide mule-deer management plan to help outline specific management objectives and address hunter distribution and crowding issues.
We support and appreciate the clear definition of 'first and only choice.' However, the definition states that "licenses and/or permits issued through a drawing identified as a "first and only choice" opportunity will not be offered as a surplus license/permit opportunity if the department receives fewer applications than the number of licenses/permits available". We request that in this scenario the 90/10 resident/nonresident allocation split still be followed.
The proposal to 'eliminate quota ranges for all elk permit license-permit types' is concerning (for deer too) and could lead to drastic increases (or reductions) in limited-entry permit districts. We ask that the quota ranges for both deer and elk permit license-permit types be kept in place to provide sideboards for Commission actions.
In all areas/HDs with unlimited OTC elk B and deer B/antelope B permits, we ask that these be permitted/capped instead. Issuing unlimited B tags is leading to both hunter-crowding and game-distribution issues. Additionally, by capping/permitting all B tags/permits will help track use/pressure and automatically implement the 90/10 split with residents/non-residents, which is an important step to get a handle on non-resident hunting pressure.
We ask that all late/early season elk B tags (formerly known as shoulder season tags) are valid on private lands only; many existing and proposed late/early season opportunities include BLM and state lands, but exclude USFS lands only. We recommend making these private-land only to better manage elk distribution and to honor the original intent of shoulder seasons. Additionally, we ask that late/early season elk B tags are only considered in HDs found to be above management objectives according to the new EMP.
HD 309 is the Gallatin Valley Weapons Restriction Area. The proposal to make a weapons-restriction exclusion zone for private landowners owning 160 acres or more is something we can support. However we ask that the general weapon season dates be followed for archery-only and that the exclusion zone only applies to antlerless deer/elk. In other words, we support a change that will allow rifle harvests on larger properties that align with the general rifle season (including antlered harvests during the general rifle season) and/or with shoulder seasons (antlerless only), but only approved archery-only equipment should be allowed for antlered animals during the archery-only season dates.
Finally, we appreciate the unique and quality opportunity offered with the 313-45 permit and support keeping this a limited-entry area (50 permits) valid during the last two weeks of the general rifle season.
Thank you for the opportunity to comment. We appreciate your careful consideration.
The Montana Chapter of Backcountry Hunters & Anglers’ Board of Directors