January 13, 2020

The Montana Chapter of BHA

PO Box 9257
Missoula, MT 59808

Montana Fish, Wildlife & Parks

Commissioners: Shane Colton, Richard Stuker, Tim Aldrich, Pat Byorth and Logan Brower

Director: Martha Williams

1420 East Sixth Avenue

Helena, MT 59620

Dear FWP Commissioners and Director Williams:

The Montana Chapter of Backcountry Hunters & Anglers is a non-profit organization representing more than 3,200 Montanans who love to hunt and fish. We are concerned about the manner in which elk shoulder seasons (ESS) are being used to manage elk in Montana. Six-month long elk hunting seasons cannot become the new norm for managing elk in Montana. The ESS was meant to be temporary, used only on private land, and used when effective. However, according to Montana FWP, the ESS have proven ineffective in many areas and have been damaging to accessible elk herds in other areas. Yet, ESSs continue to be applied in many districts across the state.

We consider the tentative as amended by the FWP Commission an appropriate and timely response to FWP’s proposal to continue ESS as is. As amended, the tentative calls for ESS to end in those hunting districts that have not met harvest objectives and continue to be over management objectives – in other words, in districts where ESSs clearly aren’t working. In devising workable alternatives, we support the following: 

• Eliminate all ESS prior to the regular archery season and end them no later than Jan. 1.
• Continue ESS in only those hunting districts where harvest criteria are being met and elk herds are trending in the desired direction until objectives are met.
• Explore additional regular season antlerless harvest opportunities in districts with ESSs.
• Evaluate all elk hunting seasons quantitatively and according to harvest criteria and make decisions based on actual performance.
• Exempt “inaccessible elk” (those residing primarily on private land) from the objective number as provided for in Montana FWP’s current elk management plan (#5, p. 55).
• Finalize the revised elk management plan prior to the 2020 fall hunting season including establishing realistic elk management objectives.
• Establish elk working groups statewide (similar to the Devil's Kitchen group and recent efforts by FWP Region 2) to work collaboratively among diverse and representative stakeholders.
• Revitalize the hunt roster/damage hunt program to ensure effective and equitable public participation. 

To recap, the Montana Chapter of Backcountry Hunters & Anglers supports and applauds the FWP Commission in its stance and leadership to uphold the promise to Montana sportsmen and women to manage elk as a public trust resource. Along with our support for the amended tentative, we hope that the aforementioned suggestions are valuable in devising an effective strategy to manage elk in Montana.

Sincerely,

John B. Sullivan III, Board Chairman

The Montana Chapter of Backcountry Hunters & Anglers

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