July 31, 2019

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 run by diverse volunteers from across the state. We represent more than 3,000 resident sportsmen and women who love to hunt and fish. We are deeply concerned about the current elk “Shoulder Season” structure and distribution.

The original intent of the Shoulder Season was to reduce elk population numbers towards the 2005 Elk Management Plan (EMP) objectives. It was to be implemented only on private land in an effort to redistribute elk herds from private lands back onto public lands. Shoulder Seasons were going to be conducted over a 3-year test period. In many areas the goals have been met and we believe it is time reconsider the continuation of Shoulder Seasons in some areas. 

Montana FWP is proposing to continue the Shoulder Season into the 4^thyear, even in hunting districts where elk populations are are at or below the 2005 EMP objectives. Shoulder Seasons should be removed from all districts where elk populations have met, or are below, the 2005 EMP population objectives.

Shoulder Season hunts are being expanded onto public lands within some hunting districts. In our assessment, Shoulder Season hunts on public lands do not redistribute elk herds from private lands onto public lands. If anything, expanding Shoulder Seasons onto public land drives elk back to private land. Districts with the most accessible areas of hunting tend to take the bulk of the pressure, resulting in fewer elk on the public land during the general season. Shoulder Seasons on public lands should be immediately ended.

Montana’s 2005 Elk Management Plan is nearly 15 years old; it is outdated, and it needs to be revisited in earnest. Access to private land has changed a lot over these last 15 years, as has landowner tolerance for elk. Montana FWP must amend or remove artificially low elk objectives to better reflect the changing situation in Montana, prior to authoring new elk management plans and seasons.

Shoulder Seasons have effectively replaced Montana’s popular Hunt Roster. The Hunt Roster created organized hunting opportunities in an equitable and timely way, whereas an equal opportunity access requirement is not part of the agreement with today’s Shoulder Seasons. This results in a loss of opportunity for every elk hunter. Montana FWP should resurrect the Hunt Roster as a targeted and effective tool for managing problematic elk herds on private lands where Shoulder Seasons have proven to be ineffective.

The continuation and expansion of Shoulder Seasons in areas where it is not needed places great pressure on local elk herds and diminishes opportunities available to public land hunters.

In review, we respectfully ask that Montana FWP immediately take action to implement the following:

• End and/or remove Shoulder Seasons in all hunting districts where elk populations are at or below management objectives detailed in the 2005 EMP.
• End and/or remove all shoulder season hunts from public lands.
• Amend or remove artificially low elk objectives to better reflect the changing situation in Montana, prior to authoring new elk management plans and seasons.
• Put resources towards resurrecting the Hunt Roster as a targeted and effective tool for managing problematic elk herds on private lands where Shoulder Seasons have proven to be ineffective.

The current situation is troubling to us – the district-wide, broad-brush approach to elk management has an adverse effect on our cherished elk herds and the quality of elk hunting. Montana citizens, including members of the Montana Chapter of Backcountry Hunters & Anglers, trust-in and rely-on the experts at Montana FWP, along with the FWP Commission, for sound decision making to maintain and improve Montana’s wildlife, habitat and public-land hunting opportunities.

We look forward to your consideration of our reasonable requests detailed above.

Sincerely,

John B. Sullivan III, Board Chairman
Montana Chapter of Backcountry Hunters & Anglers