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An amendment and associated motion have been submitted by Vice Chairman Tabor for the December 20th FWP Commission meeting to change elk hunting in Hunting District 313, in Region 3, specifically hunt 313-45. The justification for this motion has been stated as helping outfitters impacted by the summer floods of 2022. Regarding the proposed amendment by Vice Chairman Tabor on behalf of the outfitting community in Region 3, we respectfully submit the following formal comments in opposition for consideration:

This amendment goes against sound biological principles. 

• The intent of the former “late Gardiner hunt” was to protect the bull age class and the bull numbers that were vulnerable to overharvest in late December. If this amendment is adopted and HD 313 is converted to a general hunt as proposed, it would extend pressure on bull elk during their most vulnerable parts of December via the new “Heritage Muzzleloader Season.”

• Using the survey data provided by FWP biologist, HD 313 was below objective in 2014 and was at objective in 2015, 2016, and 2017. HD 313 was slightly above objective in 2018. And while the Department did not survey HD 313 in 2019 and 2020, it was then at objective in 2021 and only slightly above objective in 2022. This means that HD 313 has only been above slightly objective in two of the last nine years and does not demonstrate the need to increase the hunting pressure in this area; instead, it indicates that the collaborative compromise that was struck in 2017 is working. 

• We recommend that if there is a biological need to adjust herd numbers, the Department focus on cow hunting as they are the vehicle to increase or decrease numbers. There is no biological need to harvest more bulls during the dead of winter, which would negatively impact the number and age class of bulls in HD 313. While the Department’s comment on the proposal only states that this amendment would influence the age class, it is clear that more opportunities for bulls mean fewer bulls in a given hunting district.

This amendment breaks trust with the public and relitigates an already addressed issue. 

• This proposal was brought in at the eleventh out, buried on the Commission website, and was pushed by a small minority of the outfitting community. Dropping amendments such as this and in this manner communicate to the public that the Commission and the Department aren’t following through in good faith collaboration with all Montanans. MWF, our affiliates, and the public have made every effort to communicate openly, honestly, and early. We feel blindsided by this change, unfortunately. 

• The current structure resulted from a season some years ago when heavy snow pushed a disproportionate number of elk out of Yellowstone National Park and into HD 313. Word got out, and the convergence of hunters killed an extraordinary number of bulls. The Commission was called upon to end the hunt on an emergency basis to stop the slaughter. To not repeat the mistakes of the past, the current structure was reached after much debate and compromise. This issue was settled at that time, and as we have seen from the hunting seasons’ results, this structure has generally worked well for most Montanans and the wildlife we care about. Therefore, there is no need, other than to line the pockets of a few, to change the current management strategy. 

This amendment deviates from the intent of the “Heritage Muzzleloader Season.”  

• Given the growing popularity of the “Heritage Muzzleloader Season” and the coming push from the legislature to unilaterally insert more effective modern inline muzzleloaders, this proposal deviants once again from what was promised to the public. If this amendment were to pass, the thousands of hunters that used to apply for the late Gardiner rifle hunt that was discontinued would now be able to line up with their highly effective, modern muzzleloader as these bulls try to make it to the wintering grounds around Daily Lake and Dome Mountain. In a year such as the one we are experiencing in 2022, the impact on the bulls of that herd would be devastating with rifles and compounded during the “Heritage Muzzleloader Season.” The current season structure is the only thing that protects the age class and number of bulls in this herd for the winter of 2022-23.

We understand the complexity of issues that influence the Commission and Department’s decisions and efforts to carry out its mandate to manage wildlife and public hunting opportunities. MWF appreciates the Commission’s work on this and other issues; it is challenging. The hunting public, commission, and others put years of work into this most recent round of season setting, the appropriate venue for such a drastic change. MWF has heard from many Montanans who said such moves continue to erode their trust and faith in FWP and the FWP Commission. MWF believes that a good faith effort is to withdraw this amendment and address this issue in the upcoming elk plan or in future season setting where the public can provide comprehensive, fulling informed comments and feedback.

We need people to participate in the commission meeting and voice their opposition to this misguided amendment. Sign up to participate by Zoom HERE. As always, the Commission will take public comments on agenda items both in person and via Zoom. If you wish to make a comment via Zoom, you must register by noon on December 19. If you have any questions, please contact MWF Director of State Policy and Government Relations, Marcus Strange, at mstrange@mtwf.org. As always, we appreciate all you do for Montana’s wildlife.

By Montana Wildlife Federation Director of State Policy and Government Relations Marcus Strange

Everyone at Montana Wildlife Federation is taking time to reflect and recognize that this Thanksgiving holiday has many meanings, and that we must take action to not only give thanks, but remember and continue to learn. We hope you get to spend meaningful time with family and friends, travel safely, perhaps engage in acts of service, take a pause to rest and get out into the wilds of Montana.

MWF staff wanted to share what we are grateful for at this time of year, as well as recognize that the Thanksgiving holiday is known by some of our valued partners in advocating for wildlife, habitat and access as a National Day of Mourning. Out of respect for Indigenous people in Montana and across North America, we believe the day can serve as a reminder of our nation’s difficult history of injustices. We commit to finding ways to right wrongs and do meaningful, informed and positive work by building bridges, trust and relations – to move forward in good ways, and move forward together.

This November we’re reflecting on, recognizing and celebrating Native American Heritage Month and we’re feeling gratitude for the Indigenous peoples who have stewarded and cared for the lands now called Montana, the same lands that we all work, play, hunt and fish on, and advocate for.

From filling our freezers with wild game to accessing public lands to hunt and the memories made and shared in the in-between moments, our gratitude runs deep. Practicing gratitude isn’t just an action to take this week, the week of Thanksgiving, or only in the weeks following, but an action we highly recommend taking the whole year through.

Every time we pull a package of wild game from the freezer, we remember that animal, that hunt, the people we shared the experience with and perhaps even sweat, bled and cried with, and we give thanks, over and over again. That is the beauty of hunting – the experience stays on and sustains us, and our hearts and minds.

We’re hoping you and yours have a wonderful week and however you’re celebrating and remembering, that you enjoy the time. We’re grateful for you and thank you for being a part of the work and advocacy of the Montana Wildlife Federation.

A few reflections on gratitude from our staff:

Sonya Smith, our Communications Director, shared that she’s “thankful for hunting with my family and raising our girls to know they are capable of anything.”

Morgan Marks, our North-Central Field Representative, shared that she’s “thankful to have gone out on her first solo hunts this season, remembering the hunters in her life who can no longer get out – those walks with her rifle greeting the sunrise were for them.”

Ilona Wilde, our South-Central Field Representative, shared that she’s “so thankful for the opportunity to spend time outdoors and enjoy the change of the seasons with the ones I love.”

Garrett Titus, our Data Manager, shared that he’s “thankful to have the opportunity to come full circle to take my grandpa and dad hunting with my dog.”

As the father of an active duty service member, Executive Director, Frank Szollosi, is grateful for the dedication earlier this month of the National Native American Veterans Memorial in Washington, D.C. “I look forward to visiting and reflecting upon the sacrifices made by Indigenous men and women in military service, defending freedom.”

The Bureau of Land Management’s new policy to conserve and restore wildlife movement and migration pathways by working collaboratively with state fish and wildlife agencies, Tribal nations, and private landowners will benefit fish and wildlife and is a positive step forward in tackling the nation’s biodiversity crisis. The new Instructional Memorandum provides valuable guidance that directs the agency’s state offices to consider fish and wildlife movements and connectivity pathways in land use planning.

“Wildlife must migrate and move in order to survive, so this new guidance to conserve and restore wildlife pathways will benefit elk, mule deer, pronghorn, and many species of fish,” said David Willms, senior director for Western wildlife and conservation at the National Wildlife Federation. “It is especially heartening to see the emphasis on collaboration with state and Tribal leaders and private landowners to connect and restore wildlife habitat and remove invasive species, which will have tremendous benefits for wildlife and humans alike.” 

Restoration of wildlife movement to maintain healthy animal populations and promote human safety include wildlife-friendly fencing and wildlife crossings, which have both yielded successful results for minimizing wildlife-vehicle collisions as well as restoring wildlife migration pathways connecting across landscapes, especially for pronghorn. 

“More data is needed to identify such movements and wildlife migration routes,” said Naomi Alhadeff, Montana Education Manager at the National Wildlife Federation. “We’ve been working to gather Montanans together to use the app WildlifeXing, as a way to leverage community and citizen science to support gathering data. The data is used to identify hot spots and pinch points along Highway 2 and throughout Montana, where wildlife are seen on roadways, dead or alive.” 

Wildlife crossings benefit more than just big game species; turtles, rabbits, coyotes, skunks, and myriad other smaller species of wildlife also utilize these crossings. The movement and migration of wildlife in the United States are vital to maintaining healthy animal populations. The continuing fragmentation and disconnection of habitat is resulting in increasingly isolated animal populations; the inability to reach important winter, summer, or breeding habitat; and higher rates of negative wildlife-human interactions. 

“It will take intentional collaboration between federal, state, and Tribal land managers – as well as private landowners – to fully safeguard wildlife movement. We welcome today’s new guidance from the Bureau of Land Management. Now we need help from the public. We’re asking every person to download and input data regarding what they see along Montana roadways,” said Morgan Marks, North-Central Field Representative at the Montana Wildlife Federation. This data will be modeled at the end of 2023 so it’s crucial that as many people as possible serve as citizen scientists before that deadline.”

The National Wildlife Federation and Montana Wildlife Federation applaud the Bureau of Land Management’s new policy and commitment to work with state fish and wildlife agencies and Tribal nations to ensure that connectivity is an integral part of their wildlife management.

By MWF North-Central/Eastern Montana Field Coordinator Morgan Marks. 

Feature photo by Director of Wildlife Programs at National Wildlife Federation Kit Fischer.