| January 12, 2003
Mr. Jeff
Hagener
State Director,
Montana Department of Fish, Wildlife and Parks
1400 6th Ave
Helena, Montana 59620
Subject: Montana Elk Management Plan
Dear
Director Hagener,
The
Gallatin Wildlife Association (GWA) is a non-profit wildlife conservation organization
representing concerned hunters and anglers in Southwest Montana and elsewhere. The GWA is an affiliate of the Montana Wildlife
Federation which is an affiliate of the National Wildlife Federation. We are volunteers working to protect habitat so fish and wildlife populations and
hunting and fishing opportunities can be conserved for future generations. GWA supports sustainable management of fish and
wildlife populations through fair chase regulation of public hunting and fishing
opportunities. Please keep the GWA informed
about all aspects of the Montana Elk Management Plan (Plan) and all opportunities for
public input along the way.
On
behalf of GWA, I’d like to commend Fish, Wildlife, and Parks (FWP) on doing a
generally superb job managing elk in Montana. The
fact that every elk management unit (EMU) in the state is above population objectives
attests to that, but also raises the points that (a) perhaps these objectives should be
raised, and (b) harvests have generally been inadequate in recent years. Part of the reason for the low elk harvests has
been the mild weather conditions, but an increasingly significant factor is that many elk
seek refuge during the hunting seasons on private lands either closed to hunting
altogether, or only allowing hunting on a limited commercial basis. As you are well aware, this is a very complex issue
with no easy answers, but discussions between the members of our group as well as other
individuals has produced some interesting and possibly very effective potential remedies. Please consider the following ideas and scientific
literature when drafting a new elk management plan.
Habitat Quantity and Quality: We believe the key
to sustainable fair chase hunting opportunities for elk and other wildlife is the
preservation of large quantities of quality habitat. Unfortunately,
the quantity and quality of many key seasonal habitats for elk such as aspen stands, big
sagebrush grasslands, riparian areas and security cover are in decline (see attached
literature citations). Water availability,
especially in droughts, may also be an issue as we noticed a lot of what we thought were
dependable year round seeps, springs, wetlands and creeks drying up in recent years. Thus, it is important to know what the potential is
for elk habitat. We encourage the FWP to begin
the Plan with a thorough description of pristine or optimal elk habitat in general, and
then add a brief description of optimal conditions for each individual EMU.
Although
commercial timber harvest is not the threat it used to be, logging on State Lands in the
Blacktail country has significantly altered elk security cover where timber harvest has
taken priority. Such actions are not in the
best interest of Montana hunters and conservationists, especially on isolated forest
patches of elk security cover. Logging at the
expense of elk is not conservation. We
believe, as stated by Aldo Leopold in 1939:
“Conservation
means harmony between men and land.”
Aldo
Leopold
Habitat is
the golden goose which lays the golden eggs of conservation.
Without habitat, there is nothing to conserve.
Therefore, we support FWP coming out strong against any further commercial
timber harvest in the Blacktail, Snowcrest, Greenhorn and Gravelly mountain ranges where
elk security cover is already a significant limiting factor, especially for mature
animals.
Disturbance
activities such as logging, mining, road building, prescribed fire, livestock grazing and
fences can significantly influence elk habitat potential and may already be limiting elk
on some public lands. Additionally, the Forest
Service (USFS), Bureau of Land Management
(BLM) and Department of State Lands (DSL) are continually advancing new or “improved” ground disturbing
activities on public land elk habitat at both the project and landscape level. Many of these activities can significantly effect
elk habitat, other wildlife and the quality of the hunting experience. Therefore, we encourage FWP to initiate an
aggressive, comprehensive and consistent oversight of these federal government actions by
developing standards and guidelines for elk habitat in the Plan.
For example,
federal government travel management planning is ongoing on the Gallatin National Forest,
the Beaverhead-Deerlodge National Forest and on BLM lands in southwest Montana. These travel management plans will significantly
effect the quantity and quality of elk habitat and elk hunting in southwest Montana (FWP
Region 3). Entire USFS and BLM Land Use Plans
are being revised as well. The FWP has an
opportunity to influence large quantities of public land habitat by developing science
based standards and guidelines for elk. GWA
also has concerns about ongoing federal government planning in the Elkhorn mountains
(Helena National Forest). We encourage the
FWP to outline standards and guidelines in the Plan for ground disturbing activities on
public lands including logging, mining, road building, prescribed fire, livestock grazing,
fences and any we may have missed as they relate to quantity and quality of elk habitat.
Elk Populations - Apparently, we currently exceed
all FWP population objectives for elk on every EMU. Is
this an accurate statement? If this is the
case, we suggest our elk population objectives are too low across the board and should be
adjusted upward. We don’t believe there
are too many elk, too many big bulls or too many good elk hunting spots. Also, land owner tolerance for elk has increased in
many areas. It is the distribution of elk and
elk hunters during hunting season that appears to be a major problem here. Three examples
that come to mind are the Yellowstone Club (Big Sky area), Sun Ranch (Madison Valley) and
the Bar TT Ranch (Horse Prairie) where elk “keg up” during the hunting season. Other examples certainly exist. The Department should identify those high conflict
areas and seek conservation easements with hunting access attached or fee title
acquisition. Weather is also an important
factor affecting current elk populations, which might be addressed by adjusting season
lengths or timing (see season length or timing below).
Please discuss the pros and cons of increasing the elk population objectives
for each EMU.
Season Length or Timing: One idea is having a
procedure in place for the FWP Commission to extend the season when conditions call for
it. Some interests are calling for a
quota-based season, instead of strict calendar-based closures. That idea has some potential merit, but in years
like we’re currently experiencing, it appears doubtful that merely extending the
season would have a significant effect on hunter success.
Having more flexibility with season length and timing though, would offer an
opportunity to address potential goals or conflicts if the need arises. Please discuss the pros and cons of harvest/weather
based elk hunting seasons. Why do we hunt when
we do? Are current season lengths and timing
achieving elk management objectives? How can
the existing season length and timing be improved?
Establishing and Managing Safe Havens: Elk rapidly
learn where they are safe and where they are likely to get shot at. An innovative approach to alleviate elk
congregating on private lands that have become de facto game preserves might be to create
“safe havens” on public lands. We
suggest a portion of FWP owned Wildlife Management Areas (WMAs) could be managed as safe
havens, while the majority of our WMAs should be opened to public hunting access. Safe havens could be rotated seasonally, yearly, or
as management objectives or elk movements dictate. Over
a period of several years, this would likely have the effect of drawing elk off the
private lands where they’re inaccessible to hunters, and would quite likely increase
harvests. Increased FWP administration would
be required, but is probably a good idea for our WMAs anyway. Could dollars from the Habitat Montana maintenance
fund be used to pay for these increased maintenance and administration activities? Please review the pros and cons of establishing
flexible safe havens for elk on public lands, especially on our WMAs.
Livestock grazing: Scientific literature indicates
that livestock grazing can adversely affect all aspects of elk habitat (Reppert 1960;
Hansen and Reid 1975; Thomas et al. 1979; Rickard and Cushing 1982; Skovlin et al. 1983;
Gillen et al. 1984; DeByle and Winokur 1985; Fitzgerald et al. 1986; Fleischner 1994;
Clary et al. 1996; Belsky and Blumenthal 1997;
Werner and Urness 1998; Belsky et al. 1999; Kay and Bartos 2000). Cattle grazing, even at very low and highly
controlled levels in Montana, does not appear to improve the amount or nutritional quality
of bluebunch wheatgrass for wintering elk on our WMAs (Wambolt et al. 1997). In addition, livestock grazing is commonly not a
viable economic alternative that will prevent subdivision or maintain open space on
private land in elk country. Increasingly, in
order to maintain open space, large sums of money are required to pay for conservation
easements or development rights to private landowners who run livestock operations in elk
habitat (Habitat Montana Funding Summary available from the FWP online at their web site
http://www.fwp.state.mt.us). Without
these public expenditures, many privately held parcels managed as livestock operations
will continue to become subdivisions. Therefore,
we suggest, as an objective of the elk management plan, Habitat Montana and Block
Management funds be targeted to work with interested private land owners to protect and/or
increase the amount of land available to elk and elk hunters. As well, commercial livestock grazing should be
completely phased out on all FWP owned WMAs where habitat is important for elk, unless the
Department can clearly articulate the benefits of such an arrangement exceed the costs. This would free up WMA maintenance moneys currently
spent on administering and mitigating livestock impacts for other more important wildlife
related issues and uses.
Motorized Vehicle Access and Road Management (Any and all motorized vehicles
including ATVs and motorbikes). In
general, from our perspective there are too many roads and too much motorized access in
what would otherwise be excellent elk habitat. Without
the time to get specific, many roads within public land elk habitat should be converted to
walk-in trails either seasonally (during hunting season) or permanently to enhance the
suitability (quantity) and quality of elk habitat, as well as the hunting experience. We encourage FWP to recommend road conversion to
walk-in trails, at least on some public lands where elk security habitat is limiting or
adversely affecting elk movements during the hunting season (for example, mass migrations
onto private land). Please discuss the pros
and cons of such a conversion in the Plan on an EMU basis.
This may be especially practical and appropriate on WMAs, as well as some
BLM and Beaverhead-Deerldoge NF lands in southwest Montana.
In general, THERE ARE TOO MANY OPEN ROADS DURING HUNTING SEASON.
Federal
road construction on Idaho's Targhee National Forest so reduced elk security that general
elk hunting seasons were slashed from 44 to 5 days between 1969 and 1989. Idaho Fish and Game has yet to restore habitat
security or hunting seasons due to the destructive combination of all-terrain vehicle
abuse and excessive forest roads. Road
management and or complete conversion to walk-in trails would go a long ways to improving
wildlife security habitat, the quality of the elk hunting experience and elk just might
stay on some of our public lands.
Game Retrieval:
There might be a way to administer/allow motorized access on certain
otherwise closed roads strictly for game retrieval, maybe on our WMAs. Motorized access, strictly for game retrieval
during hunting season, on existing otherwise closed roads, is an option FWP should
consider on its WMAs and perhaps recommend on key USFS/BLM lands where increased elk
harvest is an objective. GWA is cautious and
remains apprehensive about authorizing motorized travel for game retrieval, especially on
areas currently protected from motorized travel. In
general, we do not support opening any backcountry roadless habitat to motorized vehicles,
even for game retrieval. However, we might
support the concept where it is applied in conjunction with conversion of existing roads
to walk-in trails. Please discuss road or
motorized vehicle access opportunities and conflicts in the Plan for all WMAs and EMUs.
Horse Management - Suggestion - No horses on WMAs for
hunting access (walk-in only), to promote more secure habitat on state owned public
land. However, perhaps an outfitter(s) or
individuals could be authorized/allowed to ride horses for the purpose of packing out
downed game (packers or anybody with them can’t carry rifles, bows, etc. into the
kill site). Please discuss the pros and cons
of such a proposal where elk movements onto adjacent private lands is a problem.
WMAs - We expect the most from our FWP
administered WMAs, many of which are elk winter ranges.
However, hunting opportunity will need to be regulated somehow. We suggest making hunter access to the WMAs
walk-in only as the best way to provide quality fair chase hunting opportunities with
limited conflicts. However, we would like
the Department to explore the opportunities and implications or allowing limited motorized
use on existing roads for game retrieval (see Game Retrieval section). We also see a need for increased FWP monitoring and
administration during the hunting season. Can
WMA maintenance funds be spent on monitoring and administration?
Some
of the ideas we discussed previously would limit access to some degree (road, motorized
vehicle and horse management), basically walk-in access from designated parking areas. Hopefully, further regulation will not be required. Camping is not an authorized activity on WMAs,
correct? This should be clarified in the Plan. Another idea that came up was closing portions of
the WMAs to hunting, alternating these closures during the hunting season and/or closing
the WMAs on certain days, for example Monday and Tuesday to make the WMAs more attractive
or “secure” to elk. This might help
alleviate elk movements and impacts to adjacent private lands (see Safe Havens section).
The
Elk Management Plan should include detailed maps of each WMA in the state that provides
habitat for elk, including features such as land ownership, soils, vegetation, water,
roads, trails, fences, stock water tanks, pipelines, spring developments, corrals, salting
areas, buildings, weed infestations, etc. Please
include a brief but thorough explanation of the management plan in place for each WMA and
any future proposed management changes the Department is contemplating. The Department should also include an accounting of
all maintenance funds spent on each WMA. For
each WMA, please identify the three most limiting factors for elk and discuss how the
Department will address each issue.
Elk Management Units (EMU) : The Elk Management
Plan should include detailed maps of each EMU, including features such as land ownership,
soils, vegetation, water, roads, trails, fences, stock water tanks, pipelines, spring
developments, corrals, salting areas, buildings, weed infestations, etc. Please include a brief but thorough explanation of
the management plan in place for each EMU and any future proposed management changes the
Department is contemplating. Please identify
the three most limiting factors for elk for each EMU and discuss how the Department will
address each issue. Please also discuss any
major elk management conflicts or limitations, if any, for each EMU and how the Department
intends to address each issue.
Block Management and Habitat Montana: We believe
these two programs offer the best opportunity to address current private land elk and
hunter management conflicts. Please discuss
the opportunities to expand the funding of these two programs.
Elk Tags: Why only one? If we need more elk harvested, and even if we
don’t, why not consider a B-tag for antlerless elk like we do for deer. There is probably a down side to this or up side
depending on your point of view. Please
discuss the pros and cons of issuing B-tags for antlerless elk.
Citizen Advisory Committee(CAC): Should FWP
organize one? If FWP does organize and
administer a CAC, the members should be able to demonstrate a strong commitment to elk and
public elk hunting in Montana.
Thank
you for considering our comments and we look forward to reviewing the Department’s
Draft Elk Management Plan.
Sincerely,
Glenn
Hockett
President,
GWA
Literature Citations Relevant to Elk
Habitat Management
Anderson,
J.E., and K.E. Holte. 1981. Vegetation development over 25 years without grazing on
sagebrush-dominated rangeland in southeastern Idaho. J. Range. Manage. 34:25-29.
Belsky, A.J.
and D.M. Blumenthal. 1997. Effects of livestock grazing on stand dynamics and soils of
upland forests of the Interior West. Cons. Biol. 11:315-327.
Belsky,
A.J., A. Matzke, and S. Uselman. 1999. Survey of livestock influences on stream and
riparian ecosystems in the western United States. J. Soil and Water Cons. 54:419-431.
Bureau of
Land Management. 1980. Mountain foothills grazing management program draft environmental
impact statement. USDI, BLM 308 pp.
Chadde, S.W. and C.E. Kay. 1991. Tall-willow
communities on Yellowstone’s northern range: a test of the “natural
regulation” paradigm. In: The Greater Yellowstone Ecosystem Redefining America’s
Wilderness Heritage. Yale University Press. 430 pp.
Clary, W.
P., N.L. Shaw, J.G. Dudley, V.A. Saab, J.W.
Kinney, and L.C. Smithman. 1996. Response of a
depleted sagebrush steppe riparian system to grazing control and woody plantings. USDA Forest Serv., Intermountain Research Station,
INT-RP-492, 32pp.
DeByle, N.V.
and R.P. Winokur. 1985. Aspen: ecology and management in the western United States. USDA,
USFS, Rocky Mtn. Forest and Range Exp. Sta. GTR RM-119. 283 pp.
Eckert Jr.,
R.E. and J.S. Spencer. 1986. Vegetation response on allotments grazed under rest-rotation
management. J. Range Mange. 39(2):166-174.
Fitzgerald,
R.D., R.J. Hudson, and A.W. Bailey. 1986. Grazing preferences of cattle in regenerating
aspen forest. J. Range Mange. 39(1):13-18.
Fleischner,
T.L. 1994. Ecological costs of livestock
grazing in western North America. Conservation Biology. 8(3):629-644.
Gillen,
R.L., W.C. Krueger and R.F. Miller. 1984. Cattle Distribution on Mountain Rangeland in
Northeastern Oregon. Journal of Range Management. 37(6):549-553.
Gross, J.A.,
and J.E. Knight. 2000. Elk presence inside various-sized cattle exclosures. J. Range.
Manage. 53:287-290.
Hansen, R.M.
and L.D. Reid. 1975. Diet overlap of deer, elk, and cattle in southern Colorado. J. Range
Manage. 28(1):43-47.
Harrington,
R.D. 2002. A historical perspective of Montana’s sagebrush. Intermtn. J. Sci.
8(2):60-66.
Harrison,
B.J. and A.P. Thatcher. 1970. Winter sheep grazing and forage preference in southwestern
Wyoming. J. Range Manage. 23(2):109-111.
Hobbs, R.J.
2001. Synergisms among habitat fragmentation, livestock grazing, and biotic invasions in
southwestern Australia. Conserv. Biol. 15(6): 1522 -1528
Kay, C. E.
and D. L. Bartos. 2000. Ungulate herbivory on Utah aspen: assessment of long-term
exclosures. J. Range Manage. 53:145-153
Kovalchik,
B.L. and W. Elmore. 1992. Effects of cattle grazing systems on willow-dominated plant
associations in central Oregon. In Proceedings - Symposium on ecology and management of
riparian shrub communities. USDA, USFS, Intermtn. Res. Sta., Gen. Tech. Rpt. INT-289. pp.
111-119.
Leopold, A.
1924. Grass, brush, timber and fire in southern Arizona. J. Forestry (from The River of
the Mother of God: p 114-122.).
Lommasson,
T. 1948. Succession in sagebrush. J. Range Manage. 1:19-21
Mueggler,
W.F. 1988. Aspen community types of the
intermountain region. Gen. Tech. Rpt. INT-250. USDA, Forest Service, Intermtn. Res. Sta.
Ogden, UT. 135 p.
Peterson,
J.G. 1995. Sagebrush: ecological implications of sagebrush manipulation. Montana Dept.
Fish, Wildlife & Parks, Wildlife Manage. Div. 49 pp.
Reppert,
J.N. 1960. Forage preference and grazing habits of cattle at the eastern Colorado range
station. J. Range Mange. 13(2):58-65.
Rickard,
W.H. and C.E Cushing. 1982. Recovery of streamside woody vegetation after
exclusion of livestock grazing. J. Range
Manage. 35(3):360-361.
Schulz,
T.T., and W.C. Leininger. 1990. Differences in
riparian vegetation structure between grazed areas and exclosures. J. Range Manage.
43(4):295-299.
Skovlin,
J.M., Edgerton P.J., and B.R. McConnell. 1983. Elk
Use of Winter Range as Affected by Cattle Grazing, Fertilizing, and Burning in
Southeastern Washington. Journal of Range
Management 36(2):184-189.
Thomas,
J.W., C. Maser, and J.E. Rodiek. 1979. Wildlife habitats in managed rangelands - the great
basin of southeastern Oregon: riparian zones. USDA, Forest Service, Gen. Tech. Rpt.
Pacific NW Forest and Range Exp. Sta. GTR-PNW-80. 18 p.
Wambolt,
C.L., M.R. Frisina, K.S. Douglas, and H.W. Sherwood. 1997. Grazing effects on nutritional
quality of bluebunch wheatgrass for elk. J. Range Manage. 50:503-506.
Werner, S.J.
and P.J. Urness. 1998. Elk forage utilization within rested units of rest-rotation grazing
systems. J. Range Manage. 51:14-18.
Zarn,
M. 1981. Wild ungulate forage requirements - a review. USDI, BLM, Denver, CO
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