The Wyoming Game and Fish Department is proposing a new regulation which authorizes that a grizzly bear, as a big game trophy animal, can be killed with special Kill Permits and Depredation Hunts, essentially as a “Predator”.
The comment period for this New Regulation, Chapter 28, is now. All comments must be submitted to the WGFD by August 20. This is related to the Chapter 68 Grizzly Bear Hunting Seasons, which the Governor signed into law in recent months. In Chapter 68, the Grizzly Bear Hunting Regulations, there is a section authorizing the baiting of the Grizzly Bear for Management Objectives or due to conflict. The section does not define conflict bear or management objectives. Do our two hunters with a camera allow an increase in their grizzly bear harvest? Now with this new regulation a bear can be baited and killed for getting into bee hives, as just one example of how the harvest of the Grizzly Bear is being expanded at this pivotal time. This requires attention and comment.
Please submit your comment online HERE.
SAMPLE COMMENT: I write to oppose Chapter 28 regulation for the reasons set forth below:
1) There are not been adequate public notice nor ability to comment on this regulation.
2) Permitting the baiting of grizzly bears is inconsistent with the North American Model of Wildlife Management which requires "fair chase". Baiting is unethical and immoral and should not be allowed. It is also dangerous as it can create fights around bait sites between animals and could endanger humans who unknowingly happen upon a bait site.
3) With regard to item (z), there should be requirements for the maintenance and storage of "stored crops" as well as beehives to prevent bears from becoming habituated to human food.
4) With regard to item (ff), I object because it makes the grizzly a "predator" subject to depredation. Dan Thompson previously represented that the grizzly would never be considered a "predator" in 2016 when discussing the "Grizzly Bear Management Plan." Labeling the grizzly as a predator would all kill permits to be issued separate and in addition to the hunting quota.
5) There should be a requirement for landowners to show efforts to deter conflicts with grizzly bears prior to the issuance of a kill permit. It is essential to promote non-lethal deterrence efforts and co-existence.
For the reasons listed above, I object to Chapter 28 regulation and ask that the issues raised above be addressed and that an appropriate period for public comment be issued.
SAMPLE COMMENT: TALKING POINTS FOR DRAFT 6-27-18 - CHAPTER 28
REGULATION GOVERNING BIG GAME OR TROPHY GAME ANIMAL OR GAME BIRD OR GRAY WOLF DAMAGE CLAIMS
I Opposed and do not approve the CHAPTER 28 REGULATION IN TOTAL FOR THE FOLLOWING REASONS (Talking Points):
1. The regulation extends the Chapter 68 Grizzly Bear Hunting Seasons without adequate or appropriate public notice to participate and comment. I oppose that it is promulgated just weeks before the Grizzly Bear Trophy Hunt Commences on September 1 and it extends and expands the scope of the hunt, which was signed into law by the Governor just weeks ago.
2. I object to this extension of the hunting season to hunt aka slaughter the Grizzly Bear as “Predator” and for many reasons which include and are not limited to:
a. Dan Thompson, WGFD Large Carnivore Director promised the public at a full house in the Virginian Hotel in 2016 when discussing the “Grizzly Bear Management Plan” that the grizzly bear would never be hunted as “Predator”.
b. This new regulation expanding the hunt aka slaughter of the Grizzly Bear is too much too late. The lawsuits opposing de-listing the Grizzly Bear from ESA protections were on a briefing deadline which did not allow for a thorough examination of this newly proposed regulation published on July 9, 2018, the briefs due August 8, 2018. This was difficult if not impossible for the lawyers to address.
3. I object to this new regulation because item (k)- Damage is not clearly defined and vague on any legal meaning. And in particular as it related to Bee Hives. How, are the Bee Hives ordered to be maintained, to prevent depredation by a Grizzly Bear? I see no required electric fencing. This allows Bee Hives to serve as bait for a depredation hunt or special kill permit. I object to this proposed regulation in total an in particular Item (s)- “Want to kill a grizzly bear get a bee hive”. No.
4. I object to (q) and the definitions of improvements. The definition of structure is vague and it allows for a “kill permit” or “depredation hunt” of a Grizzly Bear and now with BAIT, with no real loss of any value to property! “Erect a shack, store grain carelessly and kill a grizzly bear”. No.
5. I further object to item (s)- I object to any kill permits for the Grizzly Bear. Chapter 68 has been passed and signed by the Governor into regulation to hunt the Grizzly Bear. This extension of the hunt is now illegal and in violation of your own Grizzly Bear Management Plan, the Wyoming Public Records Act, and your promises to the Public.
6. I object that this Kill Permit an include baiting a grizzly bear to be shot does not comport with the North American Model of Wildlife Management which Dan Thompson told us all at the Virginian guides is management. The North American Model requires “Fair Chase” as do most “hunters”. Montana does not allow bear baiting because it defies the requirement of “fair chase” in hunting practice. The Kill Permit is slaughter of the Grizzly Bear and for little cause. I object to this regulation.
7. I object to item (z) for the reason stated above in terms of bees and beehives and “stored crops”. What are the regulations for maintenance and storage so no bear is chummed to human contact and food rewards?
8. I object to item (dd) – “Accepted Agricultural Practices” is a meaningless term in Wyoming. Agricultural and ranchers can do whatever they choose and with the blessing of the WGFD. You admitted at the late spring public meeting on the increased wolf quota regulation than ranchers can bait wolves to be shot with dead cattle, even when adjacent to neighborhoods and with little regard what food reward that attracts the grizzly bear to eat. I object to item (dd).
9. I object to item (ff) because it makes the Grizzly Bear a predator subject to depredation and “kill permits” separate and in addition to the kill quotas in the hunting seasons.
10.
Section 4 (a):
I object to this section. This is a very vague and nebulous change from landowner to claimant. Define “Claimant”. If claimant and not landowner is only required for a depredation hunt an private land what business is that of the WGFD to make deals behind a land owners back or without the knowing consent of the land-owner. I object to this tactic as illegal and it expands the hunt of the Grizzly Bear by an unknown! Who is the “Claimant”?
Section 4 (b):
Same objection, I know of at least two ranches at issue in this regard for different reasons. The landowner approval for hunting on his/her land is legally responsible as they are liable for the actions and potential injuries on their land. You WGFD cannot be complicit with back dooring the landowner for your own gain or purpose.
Section 5:
Item (11)- Again Beehives are an issue as raised above and I object to this regulation
Section 7:
I object that a landowner must consent to a depredation hunt on his/her land in order to be compensated for legitimate loss due to depredation. This extends hunts illegally and manipulates the landowner unfairly. The public trust in management of our Natural Resources requires a fund which we the public shall fund and finance to reimburse landowners and not the forced agreement to hunting on their land.
There is no requirement in this regulation for deterrence first before a “kill permit” or Depredation hunt this is unconscionable for an agency first endowed with the privileged of managing the iconic grizzly bear and effective deterrence first is required in the Public Trust.
For all of this reasons I object to regulation 28 and I require the management of our natural resources in the Public Trust.
