The Montana Chapter submitted the following comments to the FWP Mule Deer Citizen Advisory Committee in response to the Guiding Principles that MDCAC has developed to help shape a mule deer statewide management plan: 

The Montana Chapter of Backcountry Hunters & Anglers (MT-BHA) comprises approximately 2,500 dues-paying members and thousands of supporters. Our mission is to ensure North America's outdoor heritage of hunting and fishing in a natural setting through education and advocacy for wild public lands, waters, and wildlife.

MT-BHA recognizes the ecological, cultural, and recreational importance of mule deer in Montana and supports the development of a Mule Deer Management Plan (MD Plan) to ensure healthy and abundant populations statewide. 

The MD Plan should be anchored in the understanding that mule deer are a public trust resource managed by the state on behalf of its citizens. The plan must reflect this understanding, maintain FWP's accountability, and serve as the sideboard for FWP and the FWP Commission to make policy decisions. MT-BHA evaluated whether the guiding principles are consistent with state trust responsibilities. 

We commend the Mule Deer Citizen Advisory Council (MD Council) for their dedication to developing the guiding principles as a critical first step in this process. We agree with the members' overall assessment of the challenges in managing mule deer populations due to fluctuating environmental conditions and emphasize the need for collaboration and a willingness to consider new approaches to ensure the long-term viability of the species.

MT-BHA fully supports the following guiding principles with specific emphasis as noted:

• Engage Stakeholders in Plan Development & Enhance Communication. FWP should prioritize transparency and public input while fulfilling its trust obligations.
• Commit funding for science and research. FWP should invest in and commit to the best available science to inform timely and relevant management decisions.
• Increase MD populations. FWP should implement mandatory reporting to better monitor deer populations and seasonal harvest, revive the adaptive harvest management program for mule deer previously developed by FWP, conservatively manage antlerless harvest, and maintain regional flexibility without creating crowding and experience issues.
• Manage CWD in MT and MD populations. FWP should intensify efforts to monitor and minimize CWD prevalence.
• Minimize negative anthropogenic impacts on MD. FWP should actively manage mule deer by understanding what drives population dynamics, especially concerning habitat, competition, and predation, including hunting, in light of large-scale environmental changes. 
• Provide MD Hunter Opportunity. FWP should prioritize resident hunter opportunities in a general season framework.
• Improve the Quality of MD Hunting Experience. FWP should address crowding, improve public access, increase deer distribution on public lands, increase the proportion of older bucks, and reduce non-resident OTC hunting opportunities.

While acknowledging the importance of the following principles, MT-BHA believes they are not essential for guiding the MD Plan specifically because they are either too general (FWP should do this across the board as part of its mission) or not relevant in the sense that they are not part of the duties of public trust management.

• Maximize partnerships for MD management. While collaboration is important, it should not be specific to mule deer management but rather be part of the overall approach.
• Improve landowner relations. While landowner relations are important and FWP should collaborate with our landowning public across all realms of wildlife management, we caution against creating incentives and rewards that undermine public trust or privatize a public resource, such as exclusive and transferable landowner licenses/permits.
• Increase compliance with rules and regulations. While enforcement is essential and FWP should uphold its duty to enforce laws and regulations as required per statute, it is not specifically warranted in the context of mule deer management.
• Maintain the economic benefits of MD hunting. While economic benefits are welcome and contribute to the viability of Montana communities and professions, they should not become a primary guiding principle for a public trust manager as they are not in FWP’s mission. While money gained from MD hunting is a perk, it’s not guaranteed, nor should MD hunting ever be construed as a for-profit enterprise.

MT-BHA appreciates the opportunity to provide input and looks forward to continued engagement in developing the MD Plan that prioritizes healthy, productive, and abundant mule deer populations for the benefit of all Montanans.

Signed,

Thomas Baumeister, Montana Chapter Vice Chair & Capitol Conservation Policy Leader (volunteer) on behalf of the Montana Chapter of Backcountry Hunters & Anglers

MT BHA Members are encouraged to submit their own comments by August 15th at the following link: 

Mule Deer Citizen Advisory Committee