MSSA position on the draft FWP wolf EIS

April 17, 2003



Mr. Jeff Hagener, Director
Montana Department of Fish, Wildlife and Parks
1420 E. 6th Avenue
Helena, Montana 59620

Dear Director Hagener:

This is the official comment of the Montana Shooting Sports Association (MSSA) concerning the 
"alternatives to wolf conservation and management" as examined in the wildlife agency's recently 
released "draft environmental impact statement".

For the record, MSSA is the primary organization advocating the specific interests of hunters in 
Montana, with members in communities across Montana.  Unlike some other special interest 
organizations, MSSA does not pretend to advocate for "wildlife", other than in the context of 
ensuring traditional and historical levels of hunting opportunity for MSSA members and the citizens 
of the state.  That is, MSSA is clearly not a wildlife advocacy entity, masquerading as also 
representing the interests of hunters.  MSSA is first and foremost an entity advocating for Montana 
hunters, and for continuation of traditional hunting opportunities in Montana.

It must be recognized that hunting, especially hunting of big game animals, has always been a 
cultural imperative in Montana, and also a very significant component of the Montana economy.  The 
economic and cultural effects of big game hunting in Montana are profound.  The reintroduction and 
protection of the gray wolf must not be allowed to erode this cultural and economic base by 
significantly reducing Montana hunting opportunities.

Correct but almost passing mention of this issue is made in the Executive Summary of the Draft EIS 
when it says:

"Because of their long-term financial investments and willingness to restrict themselves when 
necessary, Montanans enjoy relatively liberal hunting seasons for more ungulate species than other 
western states. The financial investments and sacrifices made by the hunting public to restore 
ungulate populations are significant. Safeguarding those investments for present and future 
generations is an important priority for many of Montana's citizens and MFWP. MFWP seeks to 
maintain the public's opportunity to hunt a wide variety of species under a variety of 
circumstances, and to do so in a sustainable, responsible manner."

FWP must prepare a wolf management alternative that places this issue front and center, and which 
goes well beyond the near-footnote mention contained in the current draft EIS.

When crafting a wolf management plan for Montana, FWP must recognize that it is required to honor 
the political will of the people of Montana.  The greatest confluence of interest concerning wolves 
in Montana is that common ground shared by hunters and stockgrowers.  MSSA recognizes that the 
threats to tradition, culture and economy shared by hunters and stockgrowers have a significant 
overlap - our interests are very similar - that wolves must not be allowed to disrupt our 
traditions, culture and opportunities.

We submit that the common ground shared by hunters and stockgrowers is the single greatest area of 
political interest concerning wolf reintroduction in Montana.  Further, we submit that this 
collective interest is the dominant influence, and most nearly expresses the collective will of the 
people of Montana than any other.

Also, MSSA wishes to remind FWP that it is hunters who pay the bills for wildlife management in 
Montana, and therefore, the collective voice of hunters must be given a commanding role in FWP 
management decisions that may have a profound effect on our traditions, culture and opportunities.  
Said differently, although wildlife advocates may be "interested" in the wolf issue, they are not 
true stakeholders in the way hunters are.

No matter how wolf reintroduction is spun or explained, there is no escaping the reality that 
advocates of wolf reintroduction and subsequent wolf management have always envisioned feeding 
their pet project on the savings account of hunting opportunity that hunters have fostered with a 
century of effort and financing.  That savings account is the current populations of huntable game.  
We insist that this raid on the savings account hunters have so long and carefully fostered be kept 
to the absolute minimum.

The historic mechanism by which the will of the people of Montana is properly expressed is through 
the acts of the Legislature.  It is beyond choice and discussion that in crafting a wolf management 
plan for Montana, FWP must give full credence to the will of the people of Montana as expressed by 
the acts of the Legislature, regardless of anything else.

In consideration of the foregoing, MSSA rejects all proposed alternatives for wolf management 
contained in the draft EIS, and recommends adoption of a new alternative that would most closely 
resemble "Alternative 4. Minimum Wolf" in the EIS.  In addition to the management directives 
contained in Alternative 4, the new alternative would spell out the extent to which this 
alternative is required by controlling acts of the Legislature, as follows:

HB 262 has been passed by the Legislature and signed by the Governor, and carries an immediate 
effective date.  It is now controlling law in Montana.  HB 262 requires that FWP manage large 
predators (wolves, lions and bears) to maintain hunting opportunities, protect livestock and pets, 
and for the safety of people.  The mandate of HB 262 must be discussed in the new alternative as 
circumscribing, narrowing and limiting the focus of FWP in managing wolves.  It must drive the wolf 
management plan.

HJ 32 contains legislatively-approved terms of delisting and wolf management, especially including 
the definition of "breeding pair" of wolves for management purposes (one adult breeding male of any 
pack, one adult breeding female of any pack, and their pups less than six months old).  This 
definition, the expressed will of the people of Montana via the Legislature, must be given special 
cognizance in the new alternative.  More specifically, this definition must be stated as one of the 
limits of the new alternative.

HB 306 will allow the people of Montana to vote on putting the right to harvest wild game and fish 
into the Montana Constitution.  Although this right (encompassing the right to hunt) is not yet in 
the Constitution, it is highly likely that it will become part of the Constitution early in the 
implementation of any FWP wolf management plan.  The new alternative should recognize this likely 
event on the horizon, and incorporate into the new alternative the intent to be in full compliance 
with this constitutional provision when it becomes effective.

SB 209.  Since one clear goal of the new alternative will be to protect and preserve traditional 
hunting opportunities, FWP will have an unarguable need for the best possible information about 
wildlife population numbers and trends.  The performance audit of FWP game counting methodologies 
requested by MSSA and performed by the Legislative Auditor disclosed that FWP needs significant 
attention to improving its game inventory practices.  SB 209 requires, essentially, that FWP 
disclose progress in compliance with audit recommendations.  It is essential that the new 
alternative recognize the critical importance of accurate inventories of both huntable game and 
large predators consuming huntable game, so FWP may correctly regulate wolf populations in order to 
comply with the mandate to preserve hunting opportunities.

In order for any Montana wolf management plan to be authoritative, it must be in compliance with 
superior law.  That means that the alternative eventually adopted by FWP must be consistent with 
these acts of the Legislature.  The new alternative prepared by FWP will necessarily be 
circumscribed by these acts, and not driven by public opinion polls, and not even by any perceived 
consensus of public comment concerning the draft EIS.

MSSA will be very interested to see the new alternative that is drafted in compliance with the 
principles and legislative mandates iterated above.

Sincerely yours,



Gary Marbut, president
Montana Shooting Sports Association

Other organizations concurring with the MSSA comment:

Western Montana Fish and Game Association (1,000 members)
Friends of the Northern Yellowstone Elk Herd (3,500 members)
Prickly Pear Sportsmens' Association (1,000 members)
Manhattan Wildlife Association (1,000 members)
Carbon County Commission
Fergus County Commission
Lake County Commission

Legislators concurring with the MSSA position on the FWP wolf EIS

Senators - 18

Senator Bob Keenan
Senator Fred Thomas
Senator Ed Butcher
Senator Aubyn Curtiss
Senator Jerry O'Neil
Senator Dan McGee
Senator Duane Grimes
Senator Robert Story
Senator Jerry Black
Senator Gary Perry
Senator Rick Liable
Senator Kim Hansen
Senator Sherm Anderson
Senator Bill Tash
Senator John Cobb
Senator Glenn Roush
Senator Tom Zook
Senator Royal Johnson
 

Representatives - 33

Representative Doug Mood
Representative Jeff Laszloffy
Representative Joe Balyeat
Representative Dan Fuchs
Representative Pat Wagman
Representative Carol Lambert
Representative Ron Devlin
Representative Don Roberts
Representative Scott Mendenhall
Representative John Bruggeman
Representative Michael Lang
Representative Dee Brown
Representative John Witt
Representative Dave Lewis
Representative Jeff Pattison
Representative George Everett
Representative Paul Clark
Representative Sylvia Bookout-Reinicke
Representative Allen Rome
Representative Ron Stoker
Representative Karl Waitschies
Representative Rick Maedje
Representative Penny Morgan
Representative Scott Sales
Representative Bernie Olson
Representative Bill Thomas
Representative Verdell Jackson
Representative Diane Rice
Representative Dave Kasten
Representative Steve Gallus
Representative Brad Newman
Representative Gary Forrester
Representative Dick Haines