My cover letter with 9 pages of comments. I also went to the online portal to address the statewide proposals.
____________________________________________________________________________
January 20, 2022
RE: Comments on Proposed 2022-2023 Hunting Regulations
Dear Commissioners of the Montana Fish, Wildlife & Parks Commission:
Included herein are comments related to the proposed hunting season structures that have been published by Fish Wildlife and Parks for the 2022-2023 season setting period.
It is worth mentioning ARM 12.2.301 as context to my summary comments here.
(1) Participation of the public is to be provided for, encouraged, and assisted to the fullest extent practicable, consistent with other requirements of state law and the rights and requirements of personal privacy. The major objectives of such participation include greater responsiveness of governmental actions to public concerns and priorities, and improved public understanding of official programs and actions. Although the primary responsibility for wildlife management, outdoor recreation, and other functions of the Department of Fish, Wildlife, and Parks is vested in the department, active public involvement in and scrutiny of the decision making process is desirable to accomplish these objectives. The intent of these regulations is to foster a spirit of openness and a sense of mutual trust and understanding between the public and the department in efforts to maintain and enhance Montana wildlife resources and outdoor recreation opportunities.
The Department and the Commission are required to provide, encourage, and assist public participation to the fullest extent practicable. That has not happened here. This hastily forced process with ever-changing proposals has hindered the public’s ability to provide comment and has not fostered a “spirit of openness and a sense of mutual trust.”
The process of the last two months has forced hunters to comment on proposals that nobody asked for. The proposals that were withdrawn on December 13th were not asked for by hunters. That evening in your Commission working session, the proposals we spent a month discussing were pulled. By the next morning, a mere 10 hours, a completely new set of proposals, without input from the public, were presented to the Commission, a derivative of which we are now being asked to comment.
Many of the proposals that have been provided for public consideration have no supporting rationale for how these new proposals are intended to address sustainable game populations per MCA 87-1-321---325. Again, these new and hastily adopted proposals were not asked for by hunters and had no transparency as to how the new proposals were arrived at.
I sat through the entire Region 3 Zoom call meeting. There were multiple situations where the presented season proposal on the Zoom call were different from the “Draft Regulations” and different from the Region 3 “Master List” posted on the FWP website. Due to those last-minute changes, it is not completely clear what proposals I should comment on or what FWP is actually proposing. Are we commenting on that found in the posted “Draft Regulations,” that on the “Master Lists,” or that presented on the Zoom calls?
I’ve been involved in season setting processes for 30 years and this is the most confusing and poorly conducted season setting process I have been involved in. The fact that we are on the precipice of making the greatest changes to Montana hunting in three decades, based on completely new and unvetted proposals crafted in the wee hours of December 13th, does nothing to give hunters confidence that the Department is listening to our comments and concerns.
A result of this poorly administered season setting process has been erosion of trust in the Department of Fish Wildlife & Parks, and collaterally, trust in the FWP Commission. Transparency and responsiveness to comments from hunters is the only way to restore what trust is left in the Department, the Commission, and the processes by which we manage wildlife in Montana.
Sincerely,
Randy Newberg