We apologize for the delay in getting this important request for public comment out to you for wolf, otter, and other trapping proposals. We have been researching and consulting with experts on how best to try and proceed with the Montana wolf proposals, in particular. No, we do not like them, but our recommendations are to try to reduce the unjust war on wolves and the horrific impact on all creatures it will have.

The deadline for submitting comment is Monday July 26 5pm MST. Even if you have already done so, please review our recommendations below and email the Montana Fish and Wildlife Commission, accordingly:

Email: FWcomm@mt.gov

The bills that passed and were signed into law by Governor Gianforte, were Rep. Paul Fielder’s, HB225, designed to lengthen the wolf trapping season, his HB224, allow snaring of wolves, Senator Bob Brown’s wolf killer, SB267 reimbursement bill, and the killing of more wolves through unethical means with his, SB314, such that the Commission shall set wolf hunting and trapping with the intent to reduce wolves down to the bare minimum but to avoid re-listing. With these, far more than wolves will be cruelly and unnecessarily destroyed.

Montana Fish Wildlife and Parks has made proposals for the 2021 wolf season based on what they say must be allowed and what are at the Commission’s discretion. With the passage of HB224, wolf trapping seasons must allow for the use of snares.

Therefore, to help try and reduce the mass and indiscriminate carnage that will unfold, based on our findings and outreach, we urge you to submit public comment regarding Montana Wolf Proposals to:

• Require 24 hour trap checks.
• Prohibit the use of snares on public lands.
• Obtain written permission from landowner for the use of snares.
• Require wolf trapping certification inclusive of snaring for anyone trapping for wolves.
• Require snares have diverters, relaxing lock, 275 lb. rated breakaway, a stop for a minimum loop size of 10″, and the bottom of the loop a minimum of 18″ above the surface.
• Limit the number of wolves who can be snared to one per certified trapper.
• Limit the number of snares and leghold traps a trapper can set.
• Require trappers keep maps of their snare locations. 
• Prohibit power snares and the use of drags on traps and snares.
• Require disclosures and warning signs for traps and snares on block management areas.
• Revise wolf trapping season dates to January 2 – Feb 28 to try to avoid incidental trapping of grizzlies and upland game bird dogs.
• Prohibit the use of snares on high use areas of wintering elk and deer.
• Apply setback of minimum 150’ to all public roads for traps and snares.
• Require trapping warning signage at trailheads and high use recreational areas.
• Establish 1 wolf quota or closure of wolf season in units over elk management objectives, where elk shoulder seasons occur, where chronic wasting disease has been detected.
• Maintain a maximum quota of 1 wolf in units adjacent to national parks. Overage comes off the following year/s or adjacent applicable wolf management units.
• Allow1 wolf per license.
• Present the hide and skull of all trapped or shot wolves in an unfrozen condition to designated FWP. 
• Prohibit the use of bait and night hunting of wolves.
• Require the reporting of all non-target catches.
• Require annual reimbursement reports (SB267) for wolf trapping and hunting.

FOR RIVER OTTER TRAPPING PROPOSALS

Montana Fish Wildlife and Parks claims as a result of meeting with the Montana Trappers Association, Montana Fur Harvesters, and other trappers, FWP proposes increasing the trapping quotas on river otters:

Region 1, Northwestern Montana, by 43% from 28 to 40 river otters.

Region 2, Western Montana, by 60% from 25 to 40 river otters.

Increase river otter quota from 3 to 4 per trapper.

The proposal states, “Why is this proposed change necessary?”  Per FWP, “A change in the harvest regulation for otters is not necessary; however, anecdotal information suggests that we could harvest without negatively impacting the otter population.” In other words, as usual, because the trappers want it and to kill more.

Submit opposition to the increased otter quotas on the basis:

• Otter pelts averaging $15 failed to even sell in the largest fur auction in 2020. 
• Montana otter populations are based on harvest reports and anecdotal information.
• Otter harvest reports provided by FWP are inconsistent in numbers.
• Passage of the increased otter quota equals the approximate trapping total currently for the entire state.
• Montana has been declared in a state of emergency for drought. Temperatures are up and water is down statewide. Wildlife are struggling. Otters will be dying and should not be subjected to increased mortality through increased trapping.
• The otter trapping season, Nov 1 – April 15, runs concurrent to periods of gestation and dependent young. The collateral damage from trapping is ignored.
• River otter are an indicator species of water pollution. Their presence or absence is noteworthy and should be respected not exploited.
• River otter are commonly caught in traps set for beaver. Trapping season on beaver runs 5 1/2 – 9 months out of the year. The incidental catches are not factored in and do not come off the next year’s quota.
• The majority of incidental trapped otter that were reported were from Region 1 and Region 2. 
• Annually, less than 60 trappers kill otters in Region 1 and Region 2. Several dozen trappers should not be held in charge of the fate of otters who under the public trust belong to all U.S. citizens.
• FWP has failed to delineate whether the otter proposals apply to region or districts 1 and 2. There is a difference.

ADDITIONAL COMMENTS for Submission REGARDING TRAPPING:

• Swift fox are increasingly threatened especially now with drought and climate change. The trapping season on this 5-7 pound imperiled species, which are trapped and killed for notoriety purposes, must cease before it is too late or they will wind up on the ESA. They were wiped out before in Montana.
• Beaver need to be respected and protected more than ever. They are critical for water resources, wildlife habitat, agriculture, and fire mitigation.
• It is morally and scientifically reprehensible for the continuation of the   unlimited and unreported trapping of beaver for 5 1/2 – 9 months out of the year in Montana, with most of the state being the latter.
• The checkoff for non-game proposals is devoid of species who FWP reports have not been seen, i.e. spotted skunk, porcupine, and listed species of concern, swift fox. Wildlife management needs to be all inclusive of species. All are interconnected. What happens to one impacts the other.
• The public’s safety continues to be ignored and the wishes and whims of licensed trappers’,  < 1% of the population, take precedence. This is a setup for disaster and for lawsuits.
• Per the Montana 2021 legislature and FWP Director Worsech’s assurance, trapping of dogs would be properly assessed through Montana FWP Citizen’s Advisory Councils. There is no evidence this is coming to fruition.

In your public comments, it is best to include the proposal issue, i.e. wolf, otter, swift fox, etc. in the subject line of the email. Please try to personalize your comment.
Again send your public comment to the Montana Fish and Wildlife Commission:
Email: FWcomm@mt.gov
We appreciate you sending us a copy. Use Bcc and email: info@tfmpl.org

Public comment period closes Monday July 26th at 5:00 pm MST.

The Commission will hold a public meeting, in person, on August 20th to make final decisions on the proposals. We hope to see many of you in Helena! Stay tuned.
As we continue to do what we can, we urge you to be a voice for the voiceless and help us anyway you can! Your public comments do matter!