Fish and Wildlife Commission
1420 East 6th Ave
Helena, Montana 59620
Dan Vermillion, Chairman, and Commissioners:
We are commenting on the proposal to establish shoulder seasons for big game hunting prior to and after the general hunting season, in an attempt to reduce elk populations to elk number objectives established in the 2005 Elk Management Plan. Our organization is concerned how changes in the current season structure affect Montana hunters on our public lands. Most of our members do not have privileged hunting on private lands, outside of those lands enrolled in Block Management.
A shoulder season proposal has many issues, as follows:
Elk Management Objective numbers were established a decade ago. These numbers were not based primarily on habitat capability to sustain specified numbers of elk, but rather based largely on landowner’s tolerance for elk on their property. In addition, these numbers were established before it became profitable and widespread to harbor elk on private properties . The trend is more elk protected on private lands with limited hunting. Free public access to hunt elk on private land has substantially diminished. Restricted private land elk hunting either through trespass fees or though outfitted hunting skews elk distribution toward private lands. It is appropriate that the current elk management plan be revised segregate that portion of elk living largely on private land from elk living largely on public lands.
Establishment of any shoulder seasons that includes public lands puts additional pressure and harvest on those often diminished elk populations remaining on public land. Through such skewed public land harvest, we are reinforcing elk behavior to select for the relative security of private lands. Therefore we object to harvest of elk during shoulder seasons that will adversely affect future elk populations on public lands unless the habitat capability on public land in that EMU is exceeded. From page 55 of the 2005 Elk Management Plan: “Elk populations in portions of some EMUs may be almost entirely inaccessible to hunters during the general hunting season or accessible to only a few hunters. To avoid over-harvest of accessible elk on public lands or private lands open to hunting, the inaccessible elk may not be included in objective numbers. Trend count number objectives may include only elk normally accessible to general hunting (if they are a distinct segment), though hunter access negotiations will continue. Elk occupying these “refuges” may be counted separately where practical (if they are a distinct segment) and sub-objectives established that could be operative if access negotiations are successful. If significant harvest of these “refuge” elk is possible with special management at some times and locations, they should be included in objective levels.”
We believe shoulder seasons could conflict with existing seasons, particularly archery elk season on public lands. For this reason, we object to elk shoulder seasons allowing rifle hunting during the 5 week archery season on public lands.
We object to any shoulder seasons that might occur in August, as elk calves are very strongly attached to their mothers. One of our members attest that a calf will stay at its mother’s gut pile for several days when killed in August. Hunters certainly should not be part of a scenario where elk calves remain at a gutpile or dead elk.
Any shoulder season designed to reduce elk populations must be limited to antlerless harvest only. Antlerless harvest is, of course, the most direct way to reduce elk populations. In addition, many EMUs already are near or below desired bull-cow ratios. Any additional bull harvest not only adversely affects this ratio, but also creates a situation where landowners or outfitters have further reason to manipulate the fairness or democratic process in the general public having a fair and equal opportunity to hunt.
Any shoulder season must be confined to private lands that have been generally accessible to all hunters during the general season. There needs to be an improved definition of “reasonable access" to assure the selection of hunters in a shoulder season is democratic, and not favoring a select few. Some of our members have found that too many landowners are claiming they allow the public to hunt, but it is rather just limited to their friends or family.
We believe the proposal to create shoulder seasons has many issues as discussed above. Any shoulder season should incorporate the above sideboards. In almost all EMUs where numbers are above objectives, the real issue is insufficient hunting access to private lands. The shoulder season concept should be blended with achieving long term public access to elk residing on private lands, while assuring public land elk and public land elk hunting opportunities are not compromised.
Sincerely,
Greg L Munther
Co-chairman, Montana Backcountry Hunters and Anglers
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