I finalized my statewide comments. I've distilled the many pages of notes into nine main points below:
I am now copying and pasting my comments for each Hunting District and submitting those through the portal. I will also copy my statewide comments to each Commissioner and the Director, via email.
I hope we get a huge portion of hunters to submit comments. We've asked for this new EMP for over a decade. Now is our time to be heard.
1. Restrict antlerless harvest primarily to problem areas on private land. For any Hunting District (HD) that is over objective, I would ask that any antlerless tags be restricted to “Private Land Only” (PLO). If there is need for antlerless harvest on public land, those cow elk permits be part of a limited entry draw.
2. Clarify that Private Land Only excludes all public lands, not just Forest Service Lands. In some Hunting Districts antlerless tags are stated as “Not Valid on National Forest.” The HDs that are over objective by the greatest amount have very little National Forest land, sometimes none. These antlerless tags should NOT be valid on BLM or State lands. To allow them to be valid on BLM and State lands results in extremely high hunting pressure on the small amount of public land, thus moving elk to private lands.
3. Do not limit the amount of PLO antlerless tags in units chronically over objective. Give willing landowners the tools needed to solve this problem. Access to tags could be a confining element for willing landowners. Give enough tags that those interested in solving the problem can do so.
4. Align incentives with desired outcomes. This elk management plan should not give further incentives or additional leverage to those who do not want to manage elk. For many non-working ranches, their decision to opt out as a participant in elk management comes at a cost to their working neighbor. The last paragraph on Page 56 speaks to the possibility of making some HDs general elk units if they are chronically over objective. This language provides the wrong incentives to accomplish any of the goals stated in the seven objectives outlined in this plan. That language gives some landowners large incentives to keep numbers over objective, as they are interested in hunting bulls every year, not keeping elk numbers at or below objectives.
5. Manage for more elk where we currently have public access. Many parts of the state have a lot of public access, yet elk numbers are at all-time lows. Do not lower objectives in those units to meet the currently low population numbers. Set higher objectives and work with land management agencies to increase habitat productivity that will grow elk numbers. This complies with Goal #2 in the plan to improve habitat on public land.
6. Consider changing the season dates for the muzzleloader season. This likely requires a change in statute. In Region 3, the current muzzleloader season focuses pressure on public land bulls during their most vulnerable times. It also happens during a period with most motorized travel restrictions are removed on public lands, making these bulls even more vulnerable to hunters using motorized access.
7. Adopt herd objectives on the higher side of the proposed ranges. Much has changed in Montana since the last EMP and the tolerance for elk in many places is higher today. Objective ranges, and where elk numbers lie within that range, are the triggering mechanisms for the prescribed season types. Too low of objective creates unrealistic expectations of what can reasonably be accomplished with the constraints of access to elk, thereby making the plan and management prescriptions of little value. Be reasonable in the objective ranges and give more latitude to managers in addressing the problems that might arise.
8. Be realistic in what problems FWP can solve with an Elk Management Plan and do not waste resources where FWP cannot influence elk population issues. It would be easier to manage if all landowners viewed “too many elk” through the same lens. That is not the case. Many newer landowners who do not make their living from agricultural production view elk far differently than their working ranch neighbors. Those problems will be solved by “good neighbor” principles, not by this Elk Management Plan.
9. Adopt Mandatory Reporting for all elk harvested, antlered and antlerless. Much of the debate around too many or too few elk is aligned between public and private lands, with many private lands not accessible. Use Mandatory Reporting to get better harvest data and include information as to whether the harvest is on public land or private land.
I am now copying and pasting my comments for each Hunting District and submitting those through the portal. I will also copy my statewide comments to each Commissioner and the Director, via email.
I hope we get a huge portion of hunters to submit comments. We've asked for this new EMP for over a decade. Now is our time to be heard.
