Montana FWP makes seismic shift in elk permits

Even nicer would be folks to use some of their work in their own comments.

We need to flood the commission with comments not only about what we oppose, but what we want them to do.
Totally agree. But I think this being in plain view for everyone in MT to see makes it a little less harder to ignore than the comments we send in, although they do have lots of potential value if acknowledged by the commission.
 
All cervids get CWD. That's the issue with it in WY hitting the feedgrounds - lots of dead elk.

Cows get a different type of encephalopathy. Both Mad Cow & CWD can be transferred to humans, creating a significant health risk.
Come on Ben, when has CWD transferred to a human?

Secondly the feedground and CWD will not equal lots of dead elk. Don't make me post pictures in the hottest zone in Wyoming for CWD in elk, that has hovered around 3-5% infection rate for decades. They yard up in the multiple 100's-1k's, year round. The herd Jeff and I shot ours out of earlier this winter had 400+.

A unit that we can't shoot enough elk in, has over 50 bulls per 100 cows, cow-calf ratios 30+/100 many older aged class bulls, ancient cows, and rocking 8-10K total elk.

Why would CWD infection rates in elk be higher in the feed grounds?

Lets keep the discussion fair and honest.

Finally, to keep the discussion on track per BigFins request...Montana needs to look at elk management in Wyoming...the states are separated by an imaginary line, the difference in hunting quality is staggering.
 
I did attend the Hamilton FWP meeting last week - and I'll post a few of my overall comments/thoughts regarding the public input and FWP involvement.

1) FWP staff is listening - but emphasized MANY times during the meeting that we NEED TO COMMENT ONLINE. I know that can be tough for some (and they probably are not following this thread either) - but comments are actively being looked at. Focused, relevant comments have a shot at helping us.

2) I think that our local Bio and FWP representation has listened to comments coming from our region. The more radical idea's thrown out in Sept were scaled back, at least for HD's South of Missoula. Kudo's to the working relationships that have been established down here over time.

3) I'm still frustrated with some of the folks at the meeting - mainly pertaining to access / elk distribution. It seemed to be that the thought of "getting my elk every year" over-rides long term management. They can see the issues in certain units, but rather than address those long-term - instead want to make sure that they can shoot an elk.

4) Very little landowner attendance from what I could surmise - if they were present then they were not vocal. Maybe this is because they feel like their issues are being addressed outside of the Public Meetings?

The meeting was just focused on Region 2 - and my comments to FWP will be similar to HHA's comments from the pdf above.

Just thought I'd try to get this thread back on track somewhat - and give my impression of the meeting last week.
 
Finally, to keep the discussion on track per BigFins request...Montana needs to look at elk management in Wyoming...the states are separated by an imaginary line, the difference in hunting quality is staggering.

And that's why I'm ignoring your fly, Mr. fisherman. ;)

I seeing a lot of traction in folks wanting to explore the WY model for elk hunting. We've certainly been encouraging that among folks both inside and outside the Helena bubble.
 
Finally, to keep the discussion on track per BigFins request...Montana needs to look at elk management in Wyoming...the states are separated by an imaginary line, the difference in hunting quality is staggering.
Couldn't agree more and I would add that the same could be said for mule deer and antelope. Wish MT would just cut and paste WY big game management structure...everything except for the NR wilderness rule ;)
 
Good stuff Justin. I only laughed at 2:03:00.

I didn't laugh. I saw a ton of ammo given by the guy on how to effectively fight back.

If you give up now, you're giving up forever.

We fight. That's what we do. Not for ourselves, but for the wildlife that can't speak, and for the future generations to have it better than we do now.
 
Helena Hunters & Anglers has submitted their comments. Attached.

As I try and craft my own comments, which could be a short novel, one of the things I am struggling with is the balance between what I really think and what I think can be realistically influenced.

HHA is totally right that the dissolving of districts simply shouldn't happen due to the degradation or outright loss of continuity in data from past years, but how realistic an opposition is it? FWP is gonna combine districts at this point. In some instances - HD350 for example- I am not opposing the new superdistrict of 370 (350 +370),though I do deep down, but am voicing support in managing them as portions (The biologist went out on a limb in direct opposition to the directive to do this).

It's tough, and I hope folks will share their comments on Hunt Talk as they provide them. I need help understanding all the changes. The amount we are dealing with and are supposed to consider is a crime in and of itself. The whole "tell us what you support" is largely a tactic to weight and water down responses that I largely won't play along with.

I am sending my specific proposal based comments to FWP via their website.

But I did send the commissioners a more general comment, and I received one response that made me hopeful. I think this could be a good tactic. Be specific with your comments to FWP, but also send a comment to the commissioners as well. They don't have to be the same, and nothing says you can't. The comment I sent to the commissioners is below:

My name is.... I grew up in Clancy, MT and now live in Jefferson City, MT. I , love to hunt and fish, love the community in which I grew up, and have a family - a daughter who just graduated from hunters education and two boys who cannot wait to be old enough to do the same.

I know you are inundated with comments, emails, and calls. I go nuts getting half a dozen a day during election season, and so I can’t imagine what you are dealing with. I appreciate and thank you for your service. That said, I write hoping you will read my comment.

During the commission work group meeting prior to the December 14th meeting, Commissioner Waller spoke of the importance of public’s trust. That was an important moment in my opinion, and was refreshing to hear. It’s also something you and the public should be concerned about, because one doesn’t have to engage in any sort of special pleading to be a cynic about the process, and that is shame.

Last week we saw the agency charged with managing the public trust of wildlife, propose something incredibly unpopular and obviously contra to what they claim to be the reasons for their proposal. When public outcry arose, they walked it back, claimed it was purposeful to “get folks talking”, and then concocted something on the spot to replace it. Montanans don’t like to be played. I am not alone in preferring people just be honest with me. Whether that statement was a fib to not look so foolish, or in fact that terrible proposal was an act of trolling to rile the public up, neither are acceptable behaviors from a bureaucrat. I was really bothered when one Commissioner gave Director Worsech a kudos for “initiating a firestorm”. Would it be unreasonable for me to wonder if this was the plan all along? I despise that it doesn’t seem so unreasonable. I struggle to trust.

I hope for well-thought out proposals that include all stakeholders, not these seemingly half-thought-out concoctions created on the spot, that I know biologists were not privy to prior to their creation. Director Worsech spoke of a working group he is creating. That sounds like a great idea. We have a new EMP on the way as well that also brings promise of updating our elk management for a new and rapidly changing Montana. Why the rush?

Instead this new proposal, to unbundle the 900 permit with many districts going to general, as well as increase either-sex permits in numerous districts, seems just another bad idea having nothing to do with reducing populations to alleviate the strain elk numbers cause on landowners who work the land. Instead, it is an obvious path to incentivizing harboring, removing the 10% cap on non residents, and further degrading the average Montanan’s experience who doesn’t pay someone to take them hunting.

Public Trust in the Commission is paramount. Here, you have an opportunity to pump the breaks and think things through. I think of what would happen if you said, “Hold up, let’s take our time and see what these groups and the new EMP come up with before undoing many years of elk management.” The public trust would be significantly repaired, and the stage would be set for some real progress in elk management in Montana. In my opinion, it would be an example of conservative and admirable leadership and careful consideration. I respectfully ask that you choose this path.

Thank you for the opportunity to comment and for your service to the citizens of Montana.
 
As I try and craft my own comments, which could be a short novel, one of the things I am struggling with is the balance between what I really think and what I think can be realistically influenced.

HHA is totally right that the dissolving of districts simply shouldn't happen due to the degradation or outright loss of continuity in data from past years, but how realistic an opposition is it? FWP is gonna combine districts at this point. In some instances - HD350 for example- I am not opposing the new superdistrict of 370 (350 +370),though I do deep down, but am voicing support in managing them as portions (The biologist went out on a limb in direct opposition to the directive to do this).

It's tough, and I hope folks will share their comments on Hunt Talk as they provide them. I need help understanding all the changes. The amount we are dealing with and are supposed to consider is a crime in and of itself. The whole "tell us what you support" is largely a tactic to weight and water down responses that I largely won't play along with.

I am sending my specific proposal based comments to FWP via their website.

But I did send the commissioners a more general comment, and I received one response that made me hopeful. I think this could be a good tactic. Be specific with your comments to FWP, but also send a comment to the commissioners as well. They don't have to be the same, and nothing says you can't. The comment I sent to the commissioners is below:

My name is.... I grew up in Clancy, MT and now live in Jefferson City, MT. I , love to hunt and fish, love the community in which I grew up, and have a family - a daughter who just graduated from hunters education and two boys who cannot wait to be old enough to do the same.

I know you are inundated with comments, emails, and calls. I go nuts getting half a dozen a day during election season, and so I can’t imagine what you are dealing with. I appreciate and thank you for your service. That said, I write hoping you will read my comment.

During the commission work group meeting prior to the December 14th meeting, Commissioner Waller spoke of the importance of public’s trust. That was an important moment in my opinion, and was refreshing to hear. It’s also something you and the public should be concerned about, because one doesn’t have to engage in any sort of special pleading to be a cynic about the process, and that is shame.

Last week we saw the agency charged with managing the public trust of wildlife, propose something incredibly unpopular and obviously contra to what they claim to be the reasons for their proposal. When public outcry arose, they walked it back, claimed it was purposeful to “get folks talking”, and then concocted something on the spot to replace it. Montanans don’t like to be played. I am not alone in preferring people just be honest with me. Whether that statement was a fib to not look so foolish, or in fact that terrible proposal was an act of trolling to rile the public up, neither are acceptable behaviors from a bureaucrat. I was really bothered when one Commissioner gave Director Worsech a kudos for “initiating a firestorm”. Would it be unreasonable for me to wonder if this was the plan all along? I despise that it doesn’t seem so unreasonable. I struggle to trust.

I hope for well-thought out proposals that include all stakeholders, not these seemingly half-thought-out concoctions created on the spot, that I know biologists were not privy to prior to their creation. Director Worsech spoke of a working group he is creating. That sounds like a great idea. We have a new EMP on the way as well that also brings promise of updating our elk management for a new and rapidly changing Montana. Why the rush?

Instead this new proposal, to unbundle the 900 permit with many districts going to general, as well as increase either-sex permits in numerous districts, seems just another bad idea having nothing to do with reducing populations to alleviate the strain elk numbers cause on landowners who work the land. Instead, it is an obvious path to incentivizing harboring, removing the 10% cap on non residents, and further degrading the average Montanan’s experience who doesn’t pay someone to take them hunting.

Public Trust in the Commission is paramount. Here, you have an opportunity to pump the breaks and think things through. I think of what would happen if you said, “Hold up, let’s take our time and see what these groups and the new EMP come up with before undoing many years of elk management.” The public trust would be significantly repaired, and the stage would be set for some real progress in elk management in Montana. In my opinion, it would be an example of conservative and admirable leadership and careful consideration. I respectfully ask that you choose this path.

Thank you for the opportunity to comment and for your service to the citizens of Montana.
Great comment.
Can you share the response you got or at least paraphrase it?
 
Great comment.
Can you share the response you got or at least paraphrase it?
Basically

Thank you Nameless for your email. I sincerely appreciate your comments and hope you also commented on the FWP website. Elk management is a complicated issue and I agree with you that trust is paramount between FWP and the public. Thank you again.

Maybe a nothing burger, but the response makes me think they actually read my comment.
 
I am just wrapping up my comments. I have whittled it down to 7 pages. It was originally over 12. I have consolidated many of the comments for the sake of not losing the reader, if they are inclined to read my comments.

I will be on the Zoom session this evening to give my Region 3 comments, with my statewide comments going to all the Commissioners and the Director via email. I could have done 7 pages just on Region 3, but I understand the law of diminishing returns when dealing with disinterested parties.

Specific comments to Region 3 proposals


Combining Hunting Districts 301, 311, 360:

There appears to be no need to change or consolidate these districts. Districts 301, 31 and 360 have significantly different landownership patterns and distinctly different elk herds that behave in different manners. Combining these units will likely expand the areas that meet the criteria for shoulder seasons where such criteria is currently not met. I oppose combination of these hunting districts when they are very different in terms of objectives, elk population numbers, migratory versus non-migratory patterns of the elk, and the differences in land ownership that is expressed in differences in elk tolerance.


Combining Hunting Districts 310, 360, 362:

There appears to be no need to change or consolidate these districts. Historically, Districts 310 and 360 have been under or at objective, while 362 has historically been above objective. Combining these units will likely expand the areas that meet the criteria for shoulder seasons where such criteria is currently not met. I oppose combination of these hunting districts when they are very different in terms of objectives, elk population numbers, migratory versus non-migratory patterns of the elk, and the differences in land ownership that is expressed in differences in elk tolerance.


Combining Hunting Districts 321 and 334:

I oppose combining HDs 321 and 334 into NEW HD 321. I oppose changing mule deer opportunity on general license from antlered buck only to either-sex.


Combining Hunting Districts 322, 323, 324, 325, 326, 327 and 330:

I oppose combining these Hunting Districts into NEW Hunting District 322. I oppose changing mule deer opportunity on general license from antlered buck only to either-sex in these hunting districts. I oppose elimination of the limited entry mule deer hunt in Hunting District 324.

These Hunting Districts have vastly different land ownership patterns that result in different hunting access and different landowner tolerance for elk. Combining these units will make it harder to respond to the diverse needs of hunters and landowners. Each of these units should stay as they are and have regulations that reflect the management goals specific to the unique attributes of each Hunting District.


Antlerless mule deer harvest in Region 3, all Hunting Districts:

Any antlerless mule deer harvest should be restricted to private land only. There has not been a demonstrated need for public land antlerless mule deer harvest in any hunting district in Region 3. I oppose any antlerless mule deer harvest on public land in any Hunting District in Region 3, either by either-sex general deer tag or with antlerless B licenses, in either archery or rifle seasons.


Antlerless harvest on public lands in Region 3, all Hunting Districts, mule deer and elk:

The term “Not valid on National Forest” does not do enough to protect public land mule deer and elk. Focusing on only National Forest lands still allows the harvest of antlerless deer and elk occur on Bureau of Land Management (BLM) lands or State Trust lands. These B licenses and any general season harvest of antlerless mule deer or elk should be restricted to “Private Land Only” (PLO). Replace the language of “Not valid on National Forest” to “Valid only on Private Lands.”


Eliminate Antlerless Mule Deer B Licenses in the following Hunting Districts:

I support the proposal to eliminate antlerless mule deer B licenses in the following Hunting Districts; 318, 319, 321, 334, 335, 341.


Travel Management Restrictions on extended muzzleloader seasons to be the same as archery and rifle seasons:

Many of the elk seasons in Region 3 that have been extended for muzzleloader season are in areas that have travel management restrictions through December 1. Those restrictions were often coordinated with the Department for purposes of elk security during the general rifle season. With the extended muzzleloader seasons, hunting with motorized travel is allowed in many of these Hunting Districts where motorized travel was not allowed in archery and rifle seasons. These long-standing restrictions were supported by hunters as a way to reduce elk vulnerability. Now, we have one group of hunters, muzzleloader hunters, who are no longer subject to most of these travel management restrictions and will increase bull elk vulnerability during a time when elk have traditionally been allowed to recover from 11 weeks of general season. I oppose allowing muzzleloader elk hunting in the areas that are subject to motorized travel restrictions during archery and rifle seasons.
 
Basically

Thank you Nameless for your email. I sincerely appreciate your comments and hope you also commented on the FWP website. Elk management is a complicated issue and I agree with you that trust is paramount between FWP and the public. Thank you again.

Maybe a nothing burger, but the response makes me think they actually read my comment.

It's important to remember a few things:

1.) We are being asked not just by the Helena staff, but by our neighbors who are wardens, managers, biologists, etc, to submit detailed arguments for and against specific proposals. That's a pain in the butt, yes, but it does show a deep understanding of what you are talking about, and it makes it easier for FWP staff to make changes based on those comments because they can show precisely where the concern comes from on why the changes need to be made. We all have justifiable skepticism about what happens when comments hit Helena, but honestly, by providing those kind of detailed comments, we can point to those later and rebuff the tired sobriquet that hunters only complain and don't offer solutions.

2.) Tentatives are temporary. This is only a two year regulation and we'll have to force them to justify their decisions in 2023/2024, when they will be less inclined to disregard our voice due to statewide elections & a massive outpouring of opposition to what the administration is trying to accomplish, if they continue to push this too far in one direction. We don't die on the hill of tentatives, but we do sharpen our axes here.

3.) The approach we take today matters. It sets the tone for how the issue will play out over the next few years. if we continue to lambast, berate and accost officials, elected or appointed, we come across as unreasonable and unthoughtful. We are all deeply passionate about this issue, and that's a tough thing to do - tamp that passion down, but by controlling that anger, we control the narrative and we don't fall into the angry trap laid for us by those who profit from conflict.
 
I am just wrapping up my comments. I have whittled it down to 7 pages. It was originally over 12. I have consolidated many of the comments for the sake of not losing the reader, if they are inclined to read my comments.

I will be on the Zoom session this evening to give my Region 3 comments, with my statewide comments going to all the Commissioners and the Director via email. I could have done 7 pages just on Region 3, but I understand the law of diminishing returns when dealing with disinterested parties.
Randy, would you be willing to share your full written comments when you are finished?
 
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