Montana BHA responds to 2022/23 season-setting regulations

Here's a recap on some of the statewide season-setting proposals that were decided on during last week's Fish & Wildlife Commission meeting.

Overall, we were pleased with some of the discussions at the meeting, the acknowledgement that the process was broken, that the proposals were confusing and ever-changing, and that it was critically important that we get this right.

While many different interests were represented on Friday, nearly all parties in the room agreed on one thing: that the process that had unfolded was an absolute mess. Our own board chair asked the Commission to “throw the proposals in the garbage" since we couldn't even be sure what we were commenting on anymore. This is further confirmed as it’s taken FWP a week to provide any clarity on the proposals adopted last Friday.

To the Commission's credit, they tried to clean up some of the messes the best they could, and we thank them for that, but they still ended up approving many of the misguided proposals simply from a standpoint of 'too much work went into this to abandon the whole thing.'

While we understand the tough place these Commissioners were in, we still think this is a poor way of doing business; we blame the Department leadership for this failure in the process rather than the Commission.

Regardless, now that the fog has lifted a bit, here's what we're left with and how this relates to the Montana Chapter's comments and our stances on these statewide proposals:

1) Unbundling and un-limiting the 900-20 archery districts - Montana BHA opposed this proposal because archery pressure isn't how you control elk populations and this change would open the floodgates to unchecked hunting pressure on public land, further driving public lands elk onto private. You can read our full oppositional comment letter here.

We were pleased that this proposal was amended by the Commission. A compromise of sorts was accepted in which 900-20 archery districts are unbundled, but individual districts will now have permit quotas rather than being general or unlimited as proposed by the Department and advocated for by groups like UPOM and MOGA. These changes now mean that hunting pressure will be kept in check, and that, importantly, non-resident hunters will remain limited to a 10% cap of the available permits. These changes alleviated many of Montana BHA's concerns regarding crowding and pushing more public lands elk onto private. We thank the Commission for hearing us here.

2) Increase bull permits by 50% - Montana BHA opposed this proposal because the number of bull permits available is not the problem that needs to be solved to address elk distribution on private lands; instead, we should be aggressively targeting antlerless elk, ideally on private lands only. Adding 50% more rifle pressure on public lands will only drive more elk onto private. You can read our full oppositional comment letter here.

We were pleased that this proposal was denied, though some permit numbers were still amended, far less drastically. These changes alleviate many of Montana BHA's concerns regarding crowding and pushing more public lands elk onto private, while targeting the wrong elk (bulls). We thank the Commission for hearing us here.

3) Pick your district - Montana BHA was neutral on this proposal. The Commission accepted this change in all permitted elk districts in the state, other than HD 270 in the Bitterroot.

4) Unlimited cow tag shoulder seasons - Montana BHA opposed this proposal which - during the comment period - was clearly to apply to private lands only, and only in units 200% or more above objectives. While we agree that targeted cow harvests on private is certainly the way to address over-objective elk numbers, we still opposed this based on the fact that shoulder seasons have proven to be ineffective, that the elk objective numbers being used to justify these are incredibly outdated, and that hunting elk through mid-February raises ethical concerns from both within the hunting community and outside of it. You can read our full oppositional comment letter here.

Unfortunately, not only was this proposal approved, but a last-minute change directed from the Department after the public comment period had ended changed this proposal drastically from a private-lands-only situation to one that now applies on many public lands as well. The change takes any existing 004 and 005 permits available and makes them unlimited. This no longer limits hunter numbers (including non-residents) and makes these unlimited, often six-month seasons, valid on public lands (BLM and state lands). While non-resident A tags are capped at some 17,000 elk licenses, the B tags are not capped; so unlimited is literally unlimited for both Montanans and folks outside the state.

This also doesn’t just apply to units with 200% or more above objective elk numbers, but all districts with 004 or 005 B permits.

In our opinion, this last-minute change entirely defeats the purpose of the shoulder seasons which is to address elk distribution issues on private lands; by hunting them with unlimited pressure for up to half the year on public lands, all we're doing is pushing more and more elk to private lands. This proposal was approved with zero supportive public comments because these changes came after the public comment period ended. Montana BHA remains very concerned about this and we look forward to finding better solutions to address the stated problem rather than making it worse.

5) Extension of the upland bird season - Montana BHA opposed this idea for a variety of reasons. We we're happy to see that the Commissioners agreed; the proposal was tabled, and the existing upland bird season dates remain the same for mountain grouse, pheasant, huns and sharpies.


All in all, while the outcomes are certainly a mixed bag (from our perspective), it's important to note that many of the proposals we were facing in December were improved and then improved again, and this was all because of you - the public land owner - speaking up for equitable opportunity and science-based wildlife management. We can't thank you enough for making your voices heard, and we want you to know that we'll continue to fight in your corner.

If you're looking to get more involved and support our efforts, we ask you to join Montana BHA (or renew!). We also encourage you to follow us on social media to stay up to speed on the latest threats or opportunities related to your wild public lands, waters and wildlife here in the Big Sky State.






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