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.
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.
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
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.
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.
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