21-23 season setting rulemaking results Furbearers, small game, upland game

Move Toggle Comments Filter by Segment Options
WAC 220-400-020 Classification of wild animals
  • 110068%Agree
  • 37423%Neutral
  • 1328%Disagree
1,606 Respondents
Move Filter by Segment Options
WAC 220-400-020 Classification of wild animals
March 4, 2021


Washington Department of Fish & Wildlife c/o Larry Carpenter, Chair P.O. Box 43200 Olympia, WA 98504-3200


RE: 21-23 Hunting Season Setting and Rulemaking


Dear Chairman Carpenter and Members of the Commission,


The Mountain Lion Foundation submits these comments regarding Washington Department of Fish & Wildlife (WDFW)’s 21-23 Hunting Season Setting and Rulemaking on behalf of our Washington
members.


Specifically, we are concerned with the proposed amendment to
WAC 220-413-060, which would allow hunters to use one blood-trailing dog (hound) to track wounded big game. We are concerned because, the Washington Fish & Wildlife Commission (Commission) recently voted to adopt WAC 220-413-130 – WDFW Managed Nonlethal
Pursuit Training Program, which allows up to 50 houndsmen to “train” their dogs by chasing cougars year-round with very little oversight or enforcement. We have already submitted our opposition of WAC 220-412-130 as written, citing concerns about allowing
up to four family members to join on these training sessions, as well as allowing the hound trainers to carry firearms, and that the number of hound trainers permitted by the program is out of proportion to the State’s needs. Approving the proposed amendment
to WAC 220-413-060 would put even more hounds into Washington’s wilderness, which is not the will of the people of Washington, who outlawed the use of hounds by recreational hunters by initiative in 1996.


To cater to the hunting community, alone, is out of line with WDFW’s own strategic plan, which states an objective to provide increased recreational opportunities for wildlife
viewers, outdoor recreationists, and families with young children. There seems to be a common theme in WDFW’s recommendations to “increase hunter opportunity” on vulnerable populations, including cougar, big horn sheep, mountain goat and moose. Again, this
does not align with the mission of WDFW, as outlined in WDFW’s 25-Year Strategic Plan. The stated mission is “to preserve, protect, and perpetuate fish, wildlife, and ecosystems while providing sustainable fish and wildlife recreational and commercial opportunities.”1


1
Washington Department of Fish & Wildlife. 2020.
25-Year Strategic Plan: A Path to an Improved Era for Fish, Wildlife and People.
Web. Accessed 03 March 2021. https://wdfw.wa.gov/sites/default/files/publications/02149/wdfw02149.pdf


We ask the Commission to consider how WDFW’s common recommendation to increase the length of hunting seasons and increase hunting quotas aligns with their own strategic plan.
Using “increased opportunity” for hunters is not a justifiable reason to increase hunt quotas and make changes to state environmental and hunting regulations that benefit hunters, alone. Increasing the number of days that hunters (only a small portion of


Washington’s population) are on the landscape, reduces opportunity for the rest of Washington’s citizens to enjoy viewing wildlife and recreating
in Washington’s wilderness safely.


Between the recent increase in cougar hunting quotas and the new hound pursuit training program (WAC 220-413-030), Washington’s cougars are now under greater
threat and stress from humans than ever before. There is high potential for increased human-cougar interactions as a result and increased public safety incidences may be an unintended consequence of this increased stress on Washington’s cougars.
Not only does heavy hunting pressure shift the age-structure of cougar populations and the spatial organization of male cougars,2
studies have also shown an increase in human-cougar conflicts for heavily hunted populations.3, 4
Approving this proposed amendment would bring even more hounds into Washington’s wilderness, would put even more stress on Washington’s cougars, and may likely lead to an increase in human-cougar
conflicts and livestock depredation; the very thing the Department should be trying to mitigate.


2
Maletzke, B.T., R. Wielgus, G.M. Koehler, M. Swanson, H. Cooley and J.R. Alldredge. 2014.
Effects of hunting on cougar spatial organization. Ecology and Evolution 4(11): 2178-2185.


3
Peebles, K.A., R.B. Wielgus, B.T. Maletzke and M.E. Swanson. 2013.
Effects of remedial sport hunting on cougar complaints and livestock depredations.


4
Teichman, K.J., B. Crestescu and C.T. Darimont. 2016.
Hunting as a management tool? Cougar-human conflict is positively related to trophy hunting.
BMC Ecology 16:44.


5
Laundré, J.W. and C. Papouchis. 2020.
The Elephant in the room: What can we learn from California regarding the use of sport hunting of pumas (puma concolor) as a management tool?
PL0S ONE 15(2): e0224368.


Our staff has witnessed firsthand that controlling a dog once it has treed a cougar takes much longer than is expected or made to believe by houndsmen. With the new hound pursuit
training, who will be there to enforce the rules as outlined in the rulemaking? Who would be with hunters who bring their hounds into the woods to search for injured big game to ensure dogs are kept on leash and not allowed to opportunistically chase after
an adult cougar, or even kittens, citing an “accident” if anyone were to find out? We are concerned that this proposed language will only increase the risk to cougars, other non-target wildlife, and may lead to increased human-cougar conflict.


Justifying sport hunting as a tool for managing cougars is outdated and the science is clear: sport hunting does not help to reduce human-cougar conflicts, does not help to reduce
livestock depredations, and state agencies should re-assess the efficacy of using sport hunting as a management tool for cougars.5
Listen to the science: reduce quotas, reduce stressors on cougars (such as frequent hounding), and shift to non-lethal measures to deter conflict in the first place.


We are also concerned that WDFW does not follow Washington State Environmental Policy Act (SEPA) guidelines for non-exempt proposed changes to existing hunting rules, such as
adding an exception to Washington’s hound hunting restrictions for the use of hounds to track wounded big game, in their decision-making recommendations. Such a recommendation is not exempt under WAC 197-11-305. As such, this recommendation should have undergone
an initial analysis under SEPA before being brought forth to the Commission. WDFW is required under
RCW 32.21C.030 to:


(1)(c) Include in
every recommendationor report on proposals for legislation and other major actions significantly affecting the quality of the environment, a detailed statement by the responsible official on:


(i) the environmental impact of the proposed action;


(ii) any adverse environmental effects which cannot be avoided should the proposal be implemented;


(iii) alternatives to the proposed action;


(iv) the relationship between local short-term uses of the environment and the maintenance and enhancement of long-term productivity; and


(v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented.6


6
Washington State Legislature.
RCW 43.21C.030: Guidelines for state agencies, local governments – Statements – Reports – Advice – Information.
Web. Accessed 03 March 2021. https://app.leg.wa.gov/RCW/default.aspx?cite=43.21C.030


7
Washington State Department of Ecology.
Overview of Washington State Environmental Policy Act (SEPA). Web. Accessed 03 March 2021.
https://ecology.wa.gov/Regulations-Permits/SEPA/Environmental-review/SEPA-guidance/Basic-overview


The intent of SEPA is to “ensure that environmental values are considered during decision-making by state and local agencies.”7


Thank you for the opportunity to comment on this matter. Please make this letter a part of the official record regarding this decision.
ReplyAgree3 years ago
I do not understand the survey that is posted for comments on the


3 year rule-making for hunting regs for a long list of species,


Everything from mountain goats to grouse and turkeys.


 


If this is the time for the 3 year review of hunting regs, is this also


The time to consider real changes?  Or is that done at another time,


and if so, when is the other time????


 


In the survey, it looks like staff is just proposing minor changes and


The public is asked to respond for, against or neutral on these


proposals. In trying to complete the survey, most of my responses


did not fall into those three categories. I am interested in having


other choices than just those proposed by staff.


 


How does the public respond when we want something different


Than what staff is proposing?  Is the correct response “oppose”??


 


Sometimes there is something in a proposal in the survey that I


support and other things I do not support, and the public is asked


To make a single response. How can this be done?     


 


These problems occur in many of staff’s proposals for rule-making,


not just this one. How do we get better surveys, ones more appropriate


for the general public?  I do not want to hunt anything, but I care a lot


about wildlife and I think I should have a say in how and when and why


wildlife is killed by hunters. Wildlife belongs to the public, not just to


the fewer than 5% who choose to hunt.
ReplyAgree3 years ago
NO NO NO. Allowing the use of dogs to track a wounded animal from a hunter will ENABLE UNETHICAL TARGETING!!!!
ReplyAgree4 years ago
We do not need to expand "recreational harvest" If anything we need to reduce these "recreational" hunts.
ReplyAgree4 years ago
None
ReplyAgree4 years ago
Move Toggle Comments Filter by Segment Options
WAC 220-413-090 Field identification of wildlife – Evidence of sex – Definitions.
  • 98563%Agree
  • 40426%Neutral
  • 17311%Disagree
1,562 Respondents
Move Filter by Segment Options
WAC 220-413-090 Field identification of wildlife – Evidence of sex – Definitions.
None
ReplyAgree4 years ago
this is still convoluted.
ReplyAgree4 years ago
with all the new technology that is date and timed stamped, why cant multiple pictures and video be recorded at the harvest site take place of leaving evidence of sex attached?
ReplyAgree4 years ago
If you can’t tell the sex on your own you probably shouldn’t be hunting thunder chickens
ReplyAgree4 years ago
What are the changes for evidence of sex. Poor description- not enough info
ReplyAgree4 years ago
Move Toggle Comments Filter by Segment Options
WAC 220-416-010 Small game and other wildlife seasons and regulations.
  • 97663%Agree
  • 41627%Neutral
  • 16110%Disagree
1,553 Respondents
Move Filter by Segment Options
WAC 220-416-010 Small game and other wildlife seasons and regulations.
March 1,2021
Dear Wildlife Program Director,
I am writing to request that you change the current Eastern Washington pheasant hunting season for the
next three-year cycle back to dates similar to those in the "old" system in which the pheasant opening in
Eastern Washington began around the 2nd Saturday in October and ended at the end of the calendar year.
My understanding is that the dates for the current pheasant seasons, which run from 4th Saturday in
October through the middle of January, were adopted in the early 2000's without input from the upland
bird hunters. From my perspective, there has been virtually no added benefit from the "new" season
timeframe. Rather, the "new" season has had detrimental impacts:
* Hunter participation has been adversely impacted by the change in seasons, based on my
observations. The weather in January is typically far worse than in early October, thus I see very few
pheasant hunters in the field after the new-year.
* I have come to realize that having a hunt in January is discriminatory to older hunters who have
limited balance and flexibility. (Let me explain.) The ground in January is typically far more slippery
than in October. It is frozen, iced over or snow covered and far more difficult to maintain a safe
balance and footing. I have had some scary falls as have most of my hunting friends on the late
season hunts. As a result, most of my long-term hunting friends, who are getting older, will no
longer venture out after year-end.
* The late hunting pressure puts added stress on wild birds during colder winter days when they
struggle most for survival. While this may not be an issue in states like SD where there are lots of
pheasants, there are clearly not enough wild/holdover pheasants in Eastern Washington. Thus,
January pheasant hunting in Eastern Washington should be eliminated to help increase the odds that
pheasants will survive the winter. The elimination should also help, all else being equal, increase
successive bird numbers in following years.
* I cannot recall or hearing of any fire-arms accidents involving big-game hunters and upland bird
hunters when the respective seasons had the same opening time-frames. If there are still safety
issues that I'm not aware of, why not begin pheasant hunting at 10 a.m. daily so as to keep upland
bird hunters out of way of early morning big game hunters?
Thank you for your consideration. I look forward to your action.
ReplyAgree3 years ago
I recently completed the "WDFW 21-23 Hunting Season Setting Rulemaking" survey and wanted to provide some feedback. I found it frustrating and a disservice to have rules
lumped into questions. For every proposal there numerous rules that would be changed by said proposal. In a limited few cases it made since that they were lumped together but in numerous instances it made no sense and often detracted from gaining the right
information. Some examples would be WAC 220-416-010 where as there were numerous changes to the regulations for turkey hunting including the addition of an extended youth turkey season along with the additional harvest male turkeys in unit 124 in the spring
and a fall hunting season for turkey in the northern central region. I would support or stand neutral on the youth addition but oppose the later. Another example would be WAC 220-414-020 where there was the inclusion of air rifles for hunting grouse which
I could agree with but then also inclusion of using a rimfire for hunting fall turkey which I would not agree with. WAC 220-414-040 again, there are 4 different GMU/Elk area descriptions bulleted out as amendment 1, 2, 3, and 4. I know I dont agree with 2,
I like the idea of number 1 but could be neutral on amendments 3 and 4. 


 


I understand trying to keep it simple but these are complex matters. The above examples along with countless others in the survey should have been broken down further. I
understand there is a comment section with I had to over use and am unsure if it would play out in the numbers. If I agree with 3/4 amendments do I agree or am I neutral? I know my comments may get read but it won't change the polling. I would suggest in future
rulemaking survey/comments it be considered to have a push button for each amendment and not each WAC.
ReplyAgree3 years ago
I love the youth turkey opportunity but extremely dislike moving grouse opener to the 15th. I’ve had a family Labor Day grouse hunt since before I was born.
ReplyAgree4 years ago
I would like to see center fired as well as rim fired handguns to be allowed as to make it easier for those with handicap to be able to carry handguns attached to other devices other than a waist belt. This can make it easier for those of us with disabilities.
ReplyAgree4 years ago
I don't support moving the grouse season statewide to account for over harvest in one area. Make a special rule for the area of concern.
ReplyAgree4 years ago
Move Toggle Comments Filter by Segment Options
WAC 220-417-010 Trapping seasons and regulations.
  • 68546%Neutral
  • 67645%Agree
  • 1409%Disagree
1,501 Respondents
Move Filter by Segment Options
WAC 220-417-010 Trapping seasons and regulations.
March 2021


Commissioners:


Below (and attached) please review an email package that we sent to the Washington Dept. of Fish and Wildlife (WDFW) in September 2020 as public input into the 2021-23 Hunting Season setting process. This submittal
was a small game/furbearer proposal to change the seasons and regulations to generally protect beaver on many public lands,
with the intent of maintaining or enhancing the ecosystem services beavers can provide.


Populations of many bird species, salmonids, other fish and wildlife, and biodiversity in general are declining, and climate change effects are already apparent. But, we believe that a relatively simple action
could be taken now that would help alleviate those impacts by improving water retention, raising water tables, creating fire breaks, increasing habitat complexity, providing habitat for many fish and wildlife species, and increasing biodiversity on WDFW and
other public lands. That proposed action is changing the regulations so that beaver, and their dams, ponds, and associated side channels would be protected on most public lands.


Beaver have been harvested, or otherwise lethally removed, in large numbers for over 200 years across Washington. Past intensive removals of beaver have left adverse environmental effects that continue to persist.
It is evident from WDFW data that the number of beaver harvested, or otherwise lethally removed to reduce property damage, has declined to much lower levels in recent years (likely partly because of depressed pelt prices). However, even the removal of as few
as 1-4 beavers from a localized area can create adverse ecological impacts in that area that can last for many years. Much of the ecosystem benefits, as well as biodiversity from beaver and their dams and ponds, are likely to decline or disappear for many
years after a few beaver are removed. Yet, much time, effort, and money is currently being spent by many organizations across Washington State relocating beaver to public lands, adding wood to streams, or installing beaver dam analogs to try and replicate
the ecosystem benefits that can be naturally provided by beaver. Currently, even after beaver are relocated onto public lands, they are generally not protected from removal.


Also, there is ample evidence that beaver dams, ponds, and side channels are important to native salmonids, such as for coho salmon ecology.
1 Beaver-enhanced habitats have been shown to benefit steelhead, water quality and quantity, as well as stream function. For example, in Bridge Creek (eastern Oregon), juvenile steelhead
densities were shown to be 27 fish/100 m2
greater in impounded than un-impounded reaches, and steelhead survival increased by 52% after the addition of beaver dam analogs, and the subsequent recruitment of beavers.
2 Four years after initiation of the addition of dam structures and ponds, which attracted more beaver, juvenile steelhead production in Bridge Creek increased 175 % compared to the
nearby control stream. 3 Much money has been, and is currently being spent to improve freshwater habitat for ESA listed salmonids, but the currently approved removal/trapping seasons
for beaver on public lands is highly inconsistent with these ecosystem restoration efforts.


The recently completed WDFW 25 Year Strategic Plan emphasized that WDFW intends to demonstrate bold leadership in conservation, recovery, science, and management, as well as to identify
nature-based climate resilience solutions. We believe that protection of beaver and their dams, ponds, and associated side channels on public lands is very consistent with these strategies, and that the proposed change of regulation would help WDFW achieve
those stated priorities. It seems that it would be prudent to protect beaver that have built, or will build, dams and ponds on public lands instead of relying on relocating beaver to some of those lands.


Since we submitted our 2021-23 hunting season small game/furbearer proposal to WDFW in September to protect beaver on WDFW Wildlife Areas and similar public lands (e.g. US Forest
Service and Bureau of Land Management), we have had several other conservation organizations join our effort by either sending a letter of support (see attached 2 letters), or by becoming co-signers for this proposal (logos shown below). The dozen identified
conservation organizations now supporting this proposal represent thousands of Washingtonians who are interested in seeing change of management that will particularly enhance stream and riparian ecosystems and benefit many species of birds, salmonids, and
other fish and wildlife species, as well as biodiversity in general.


We sincerely hope that you will show bold leadership that emphasizes the agency mandate to preserve, protect and perpetuate fish, wildlife,
and ecosystems, while providing sustainable fishing, hunting and other recreation opportunities by approving this proposal to close beaver seasons on many public lands. Management of beaver should not minimize their value to healthy ecosystems, as it
currently does. We believe that this proposed regulation change will definitely benefit the environment and many fish and wildlife species, and that it will affirm WDFW’s commitment to improved ecosystem management on their lands, as well as on other public
lands.
ReplyAgree3 years ago
Dear Sir/Mame:


Please see my enclosed comments on proposed changes found in the 2020-2021 Hunting season-setting and rulemaking proposal breakdown that was published on the WDFW website. There are multiple issues addressed in this single document.


 


Small Game & Furbearer Rules: Support Proposal



Issue 1: Support increase
Issue 2: Support increase
Issue 3: Support increase
Issue 4: Support Increase
Issue 11: Support restricting rifle for forest grouse to rimfire only.
Issue 13: Support delay of forest grouse season to improve brood hen survival.
Issue 14: Support extending Chukar season in WA state.

Chukar hunting is very difficult and has very low productivity, there is very little chance an extended season will have any negative effect.

Issue 16: Support closing Marten trapping.

 


Small Game & Furbearer Rules: OPPOSE Proposal



Issue 6: Oppose the use of dogs to hunt turkey in WA state.

Use of hounds for hunting has been an inroad for anti-hunting groups in the state of Washington to end effective hunting practices. I do NOT support giving these groups a publicly sympathetic
angle of attacking hunting.

Issue 7: Oppose allowing handgun shot shells to harvest turkey.

Traditional handgun shot shells have no killing power due to the low powder capacity and small shot needed to fit in the shell.
The handgun proposal will tempt people to illegally shoot turkey from their vehicle while on the road as turkeys do not see vehicles as a threat.
There is no reason to alter the current turkey firearm regulations

Issue 8: Oppose allowing rimfire for turkey hunting in any season.

Increase the season length for fall turkey.
Scoped rimfire rifles will require use of hunter orange because the shot distance and carry distance of the projectile can go beyond sight distance, unlike a shotgun shell.

Issue 10: Oppose allowing the use of Air Rifles for forest grouse and lagomorphs.

The common availability of suppressed air rifles will lead to illegal harvest in urban areas and from roadways.
A .22 rifle rifle cost the same or less than an air rifle capable of producing similar velocity.

Issue 12: Oppose a spring forest grouse permit.

There is no data that indicates the Sooty Grouse population can support a spring season that targets vocalizing males.
ReplyAgree3 years ago
trapping should be eliminated.
ReplyAgree4 years ago
None
ReplyAgree4 years ago
The Eastside Audubon Society supports beaver protections and encourages the Washington
Department of Fish and Wildlife to update state policies regarding beaver management on public
lands in Washington state.

Eastside Audubon Society has a service area that includes all of eastern King County from Lake
Washington up to the Cascade Crest. We have around 1,100 members in 11 cities, towns, and
unincorporated areas. We recognize beavers as a keystone species as it pertains to in-stream and
riparian habitat areas.

Beaver are nature’s true ‘ecosystem engineers,’ whose dams enhance waterways and provide
complex and healthy riparian habitat that directly benefit salmon, bird, and other vulnerable
wildlife populations. Additionally, their dams alter waterflow that has been shown to have
positive ecological impacts in a world facing climate change. Not only does slowing water
increase water retention and supply, but it also forces water under the stream bed helps to cool
water, which salmonids need to survive. However, the current WDFW management practices do
not adequately acknowledge the ecological benefits of beaver, often treating them as a nuisance
and game animal. We believe this species deserves far more consideration when taking into
account their essential ecosystem function.

We stand alongside fellow Audubon chapters statewide and other fish and wildlife nongovernmental
organizations in supporting the protection of beaver and their dams and ponds on
all public lands in Washington, especially on WDFW Wildlife Areas. We believe this change in
management would both re-shape community opinion of beavers and demonstrate to the public
that supporting ecosystem function and biodiversity is a top priority for WDFW. We also
believe that this important issue should have a discuss to be discussed in public as it impacts all
residents of Washington State. Twelve conversation organizations representing thousands of
citizens have shown support to protecting beavers due to their importance in an environmentally healthy
Washington.

Sincerely,

Eliza Kronenberger
At-Large Board Member
Eastside Audubon Society

Jeremy Lucas
Conservation Chair/Board Member
Eastside Audubon Society
ReplyAgree4 years ago
Move Toggle Comments Filter by Segment Options
WAC 220-417-030 Wild animal trapping.
  • 81654%Agree
  • 59540%Neutral
  • 876%Disagree
1,498 Respondents
Move Filter by Segment Options
WAC 220-417-030 Wild animal trapping.
eliminate trapping, it is amazing to me that a wildlife program would support a killing method that is slow and cruel.
ReplyAgree4 years ago
None
ReplyAgree4 years ago
There should be a bag limit on bobcats.
ReplyAgree4 years ago
Thanks for the request for comment. I have no further comments.
ReplyAgree4 years ago
Let these animals thrive.
ReplyAgree4 years ago