Montana BHA Responds to '454' Program Changes

We have long encouraged FWP to improve the 454 agreements, including most recently at March’s EQC meeting and in an oped published by one of our board members, Jake Schwaller. Some of our suggestions included a cap on these agreements (which are currently unlimited) and to move up the application process to time these with the existing landowner permit allocations and draws.

Yesterday, FWP sent a press release announcing that our concerns are being heard; they are planning to take two big steps in the right direction by requiring 454 applications to be submitted by May 15th and by capping these at 10% of existing district permit quotas. Both of these changes are on the agenda at next week’s Fish & Wildlife Commission meeting.

The role of FWP is to represent the wide range of interests of the people who hold wildlife in common. This requires involving the public in the decision-making process and being transparent about how wildlife is managed and opportunities are allocated; these are cornerstones of sound wildlife management in Montana, we have a proud history of doing this exceptionally well.

We appreciate that FWP is making a strong effort to uphold these standards. Announcing how the department intends to administer the 454 agreements in 2022 and presenting this clearly on the website for people to see and understand is what good government is all about. Even if we do not agree on everything, seeing the pendulum swing in the direction of letting the public know ahead of time and getting Montanans involved in ways to improve things are what matters most.

To that end, while we are pleased to see FWP taking steps to improve the 454 program and working to gain back the trust of the public, we encourage the department, the legislature and the commission to consider making some additional tweaks that will improve this program even more for 2023 and beyond.

For example, the 10% cap is currently over and above the biologist-recommended quotas; to ensure that this cap is part of the quota rather than in addition to it, the timing of this program needs to be part of the existing landowner and general permit draws with a deadline of April 1. Applicants already need to check a box denoting that they are applying for the 15% of set aside landowner permits; the 454s could easily be another box to check on that application for those landowners wanting to be considered.

We certainly applaud these steps in the right direction, and we look forward to working with FWP on continued improvements to the 454s among other elk management tools.

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