I just finished up my comments to FWP concerning the deer and elk changes. For your consideration before I send it to the commissioners and post it on the public comments page. Feel free to offer suggestions for revision or change.
Dear Commissioners,
As the public comment period for the proposed changes to the 2022/23 hunting regulations comes to a close, I am asking each one of you to take a deep breath and stop to consider the probable effects of the changes you are about to approve or reject.
The proposed changes on this season setting agenda are some of the most extensive that I have ever seen and the effects of those changes will carry on for years to come. You as commissioners individually and collectively as a committee bear responsibility to the residents of Montana and the public wildlife that will be affected by your decisions to make wise choices regarding the management of wildlife resources.
Throughout this process FWP Director Worsech has explicitly expressed the intention of proposed changes is to simplify confusing regulation.
FWP’s web page inviting public comment directly states and I quote, “Earlier this fall, Fish, Wildlife & Parks biologists offered science-based regulations proposals that combine some hunting districts, reduce some license and permit types, and eliminate hunting district portions. FWP staff held informational meetings around the state, and the public was invited to submit comments on those initial proposals. FWP adjusted the proposals based on public comment and presented them to the commission.”
I am in strong disagreement that the sum total of proposals before the committee this session is science based and in harmony with the biological recommendations of FWP regional biologists. In fact, I would assert that many of the most controversial proposals are completely political in nature and have been advanced by Director Worsech and FWP leadership either without the input of FWP regional personnel or have disregarded professional recommendations and public comment.
Director Worsech has also repeatedly expressed the need to address population numbers of elk herds in certain units deemed over objective. Throughout the past year, several proposals that evoked the most intense public opposition have been presented by the Director. As recently as Dec. 13, you as a commission expressed your sensitivity to opposition to the Director’s proposal and told him not to present it for your consideration.
The following day at the Dec. 14 commission meeting significant portions of the rejected proposal was repackaged and presented to the commission in different form by way of unbundling the 900 series units and making them either general or unlimited permits. This change does nothing to address the stated objective of reducing over objective elk. Additional proposals thrown in for consideration and approval were hastily concocted and not vetted with various user groups who have conflicting interests.
Director Worsech has stated both publicly and in conversation with me that “the same old thing isn’t working” and “trying the same old thing and expecting different results, is insanity,” and that he’s putting these proposals “out there to get the conversation started”.
If I may speak bluntly, my perception and the perception of many other Montana resident hunters is that Director Worsech is throwing manure against the wall to see what sticks. Many of these proposals illustrate and reinforce the perception that FWP leadership is out of touch with the biological needs of deer and elk herds and out of touch with what Montana residents expect from the department they have entrusted to wisely manage Montana’s wildlife resources.
Montana Fish, Wildlife, and Parks is mandated to manage for the health of Montana’s wildlife, not to serve as a political candy machine dolling out favors for those who have connections and paid lobbyists to ensure that certain interests are first in line to benefit from the commercialization of wildlife.
There has been an incredible amount of work put forth by various groups to try and find consensus and working solutions to many of the problems that have historically caused contention among various interests. FWP has coordinated many of those meetings and compiled recommendations based on input from hunters, landowners and outfitters. That extensive input is not included in the proposals presented for your approval this session. Why would you want to pass proposals presented to you without the input of these diverse user groups?
The proposals that you are being requested to approve will have far reaching consequences in the future health of Montana deer and elk herds and the hunting experiences of Montana residents who place great value on healthy deer and elk herds. It is my opinion that almost all of the late amendments and proposals will have a negative effect and will generate a lot of complaints from affected MT hunters.
The only proposal that is a good idea in this whole mess is to limit elk permit holders to the area their permit is valid for. I can support that proposal.
In summary, I am asking you to please reject the adoption of the proposals for changes to deer and elk management in 2022/23. They do not achieve the stated goals of “simplification of the regulations” or address “overpopulation of elk in over objective units.”
The idea that you can’t “do nothing” is fallacious. Implementing wrong management strategies that will have far reaching negative effects is far worse than maintaining status quo for two more years and bringing diverse user groups together to find solutions that all parties can accept.
Please make the right decision for Montana’s wildlife and the residents who are entrusting you to enact FWP’s declaration of “science-based management.”
Sincerely,
Gerald Martin