Montana BHA delivered the following comments to the Commission on December 20th, 2022:

“Chair Robinson, members of the Commission… my name is Kevin Farron and I’m the coordinator for the Montana Chapter of Backcountry Hunters & Anglers.

First, we want to acknowledge the new and improved process we're dealing with here. The outcry this recent 313 proposal has created really illustrates how problematic the previous process was, with commissioners having the ability to amend proposals on the fly without any public notice at all. At least today we had a little notice.

That said, Vice Chair Tabor's 313 change is not really an amendment to FWP's proposal, and that's why this has created such heartburn; it's an entirely new and largely unrelated proposal to the others that deal with quota and district boundary corrections in completely different areas.

That, coupled with the controversial nature of the amendment leads us to politely ask that the Commission please table the amendment today and either advance Vice Chair Tabor's idea as it's own, new policy proposal, to be voted on in February or - ideally - punt on this entirely until the next round of biennial season-setting which - coupled with a new elk plan - would ensure ample public engagement from all stakeholders on this significant change to Montanan's hunting opportunities, something that Vice Chair Tabor just mentioned he'd like to see happen.

Thank you for the opportunity to comment, but before I close, I have to say, Commissioner, Byorth, your beard looks grayer than when you first joined the Commission. I hope Montana BHA isn't solely responsible for that. And Commissioner Waller, I hear you're moving to Utah. I hope Montana BHA didn't have anything to do with that either. In all seriousness, I'd like to again express our deep gratitude for both of you for your time and service. We wish you well on whatever the future holds.

Thank you for the opportunity to comment."

Vice Chair Tabor ultimately withdrew his motion.

Commissioner Byorth - who represents Region 3 - mentioned that the comments he received were 10-1 against the proposal, but the reason Vice Chair Tabor ultimately decided to withdraw the motion was him conceding that this issue deserved more conversation with the public. This is exactly what Montana BHA had been asking for in our comments, and we thank the Commission and Vice Chair Tabor for recognizing and agreeing to this.

However, Commission Cebull quickly followed this with a new motion to change the limited-entry quota in 313 from 50 to 100. While this increase to permits doesn’t represent as significant of a change, the logic of first admitting that this needs more conversation and then following that up with a proposal to make a permit change decision without more thorough public conversation was a head scratcher for all of us.

After some discussion and a few comments that echoed our concerns, Commissioner Cebull then moved to withdraw his second motion as well.

So no change to 313 limited-entry elk permits, for now.