December 11, 2021

Chair Robinson; Vice Chair Tabor; Commissioners Waller, Byorth, Walsh, Cebull and Lane
Montana Fish Wildlife & Parks
1420 East Sixth Avenue
P.O. Box 200701 
Helena, Mt 59620-0701

Dear Chair Robinson, Vice Chair Tabor and Commissioners:

On behalf of our 3,000 dues-paying Montana members, the Montana Chapter of Backcountry Hunters & Anglers vehemently opposes FWP’s new “limited elk season structure” proposal.

First, the proposal is predicated on outdated population objectives, and should be tabled until the new elk management plan is complete; but regardless, it still fails to address the stated problem of reducing elk populations: killing bull elk on private land is not the answer.

Rather, FWP's proposal appears to be creating opportunities to further monetize a public resource: to sell the opportunity to kill bull elk.

Moreover, FWP's proposal unfairly favors private land hunters at the expense of public land hunters, while giving private landowners in these above-objective units an incentive to stay above objective rather than an incentive to go to objective. This is backwards.

We offer the following alternative solutions:

1) Allow hunters a maximum number of over-the-counter cow elk tags allowed in statute, to be valid on private land only to create additional harvest opportunities

2) Prohibit cow elk hunting on public land to redistribute elk onto public lands and off of private lands

3) Retain the current number of the limited-entry draw permits but make them valid only for brow-tined bull elk on public land only until objectives are met (this would incentivize private landowners increase access and opportunity to cow elk to reduce herd numbers, rewarding them with the ability to hunt bulls again once objectives are met)

4) Similarly, a more extreme approach could be no bull elk hunting period until objectives are met - public or private (same reasoning as 3)

As currently proposed, the public land hunter would be penalized by 1) a devalued bonus point system; 2) stiffer competition in the drawing process; 3) fewer available permits; 4) reduced quality of available bulls and experience, and 5) the creation of a class system of a private land hunter (haves) versus a public land hunter (have nots).

In closing, we again ask that the commission pause these conversations until a new, updated elk management plan is complete. If that does not happen, we hold to the core principle of fair and equitable opportunity, and we favor a targeted and aggressive cow elk-only season framework to reduce elk herds on private lands.

Respectfully,

The Montana Chapter of Backcountry Hunters & Anglers