April 27, 2021

RE: Montana Chapter of Backcountry Hunters & Anglers Comments on the Montana Elk Management Plan Guiding Principles

Employees of FWP and Members of the Fish & Wildlife Commission:

We appreciate your commitment and leadership to revise the elk management plan.

We represent the interests of the Montana Chapter of Backcountry Hunters & Anglers. Our 3,000 dues-paying members care deeply about elk and how they’re managed.

For years, we’ve been actively involved with issues surrounding elk. Recently, our Chapter championed revising the elk management plan. We see ourselves as part of the solution and strive for fair and equitable - and ideally win-win - outcomes. We understand and hold firm to the notion of elk as a public trust resource. Here, we offer comments specific to the Montana Elk

Management Plan Guiding Principles.

Specifically, we asked ourselves whether the guiding and strategic principles would provide us (assuming we had a seat at the table) with both the guidance and the sideboards to draft a comprehensive, responsive, sound, relevant and inclusive elk management plan. We answered as follows:

1. We believe the citizen group identified relevant issues that need to be addressed.
2. We believe the guiding principles address the issues.
3. We believe the guiding principles are relevant and reasonable.
4. We believe the guiding principles can inform the specific strategies and actions of the plan.

Along with our overall support, we’d like to express some caution regarding the following:

1. Additional issues and principles may surface during the planning process and may need to be addressed.
2. Further definitions are necessary to operationalize the specific wording of some principles such as maximize, minimize and incentivize in order to arrive at a fair and equitable distribution among stakeholders.
3. Care must be taken to avoid assigning preference to some over other principles; the value of these principles lies in their aggregate as they provide a way to sort out competing interests.

Furthermore, we appreciate FWP’s commitment to use a collaborative, inclusive and transparent process to develop the specific strategies and actions of the elk plan. To that end, we appreciate the strategic principles as “things that FWP should do, no matter what.” We’d like to offer suggestions based on a review of FWP’s in-house publications including FWP’s Vision and Guide, Who We Are and Where We’re Going, and The Public Trust to improve on the 6 strategic principles offered (suggestions in caps):

1. Maximize collaborative opportunities for stakeholders to be involved in the decision-making process both in transparently formulating and implementing the Elk Management Plan
2. Maximize the integration of the best available peer-reviewed scientific data into the elk-management decision-making processes
3. Maximize coordination between predator- and elk-management plans
4. Maintain public-trust management of elk BY THE STATE INCLUDING PREVENTING PRIVATIZATION
5. BALANCE AND WEIGH STAKEHOLDER NEEDS AND INTERESTS TO ALLOCATE THE PUBLIC TRUST FAIRLY AND EQUITABLY
6. MAINTAIN PROFESSIONAL AND SCIENTIFIC INTEGRITY
7. Maintain FWP’s primary role in the management of elk
8. Ensure regular review and update of management and population objectives

We would like to thank the Department and the Commission for their commitment to manage elk as a public trust resource on behalf of and for the people.

We stand ready to assist in whatever capacity necessary to help make the new elk management plan become a reality.

Sincerely,

John Sullivan, Board Chair, Missoula (406-360-4086)

Doug Krings, Central Montana Board Member, Lewistown, (406-350-0451)

Paul Kemper, Chapter R3/DEI Leader, Bozeman (814-490-3653)

Thomas Baumeister, Capital Leader, Helena (406-431-4326)

Montana Chapter of Backcountry Hunters & Anglers

[email protected]