HomeMy WebLinkAboutadditionalcorrespondence4LC `. (',()
RECEIVE D
1114-
Peggy Kotee n
253 Via San Blas
MAR 0 261E1
SLO, CA 93401
SLO CITY CLER K805.441 .589 7
March 1, 2010
3/c?-//0 Ce .q-G
Honorable Mayor and City Council Members :
f .p &"E
I hope that the City Council will urge the California Department of Fish and Game (CDFG) to reject th e
proposal to expand bear hunting in California .
I am opposed to the CDFG's proposals to expand black bear hunting that adds San Luis Obispo county t o
the area where hunting of black bears can occur, that permits an unlimited number of bears killed durin g
hunting season, and that allows the use of high-tech global positioning (gps) equipment on houn d
collars .
Lifting all numerical limits to bear hunting could dramatically increase the number of bears killed b y
hunters across California . Previously, the agency has closed bear season after 1,700 bears were reporte d
killed, however by lifting this "closure mechanism," the CDFG is permitting an unlimited number o f
bears to be killed during hunting season .
It is terribly disturbing that CDFG is proposing to increase bear hunting at a time when there are so man y
negative impacts on bear habitat.
Poaching is becoming a larger problem in CA and the proposal does not address the impacts o f
poaching . Recent discoveries of black bear poaching operations in California call into question th e
CDFG's recommendation to allow bear hunting . Poaching of bears has increased nationwide, fueled b y
growing international market in bear parts . With the worsening of the economy, poaching could escalate .
Bears already face a host of increasing threats from poaching, habitat alteration, human encroachmen t
into wildlife areas, aggressive government lethal control programs, and climate change .
Hunters may claim that killing bears will reduce human conflicts with bears, however this is far fro m
accurate. Trophy hunters target the largest bears who may look good on a wall or as a throw rug, not th e
young males who are primarily responsible for conflicts . Furthermore, hunting often takes place deep i n
the woods, far from homes, while so-called "problem bears" usually live in the urban-suburban interface .
Using hunting as an aggressive and expansive lethal control of bears ignores the root cause of bear -
human conflicts . Most encounters with bears are the result of irresponsible human behavior (e .g .
landowners who refuse to depose of garbage properly).
I hope that our city will urge the CDFG to reject the proposal for expansion of bear hunting i n
California.
Thank you for your time ,
Peg
Opinio n
Published : Tuesday, Feb . 09, 201 0
Editorial : No bear hunt without local hearin g
We continue to have serious reservations about a proposal by the state Department o f
Fish and Game to allow bear hunting in San Luis Obispo County — an idea that's bee n
on the table three times in the past three and a half years .
For starters, we're disappointed that the agency has so far ignored repeated requests t o
schedule a local hearing.
The meeting schedule for the next few months includes hearings in Upland/Ontario ,
Monterey and a teleconference in Sacramento — with our county again noticeably absen t
from the list .
That strikes us as odd, since lack of a local hearing was a major point of contention las t
year . There also were concerns about a lack of evidence to justify a hunt . The Fish an d
Game Commission ultimately decided against expanding the hunt to include San Lui s
Obispo County last year, after staff said it needed more time to address questions an d
concerns.
Interestingly, a newly released draft environmental report from Fish and Gam e
acknowledges the public's negative reaction to expanding the hunt to San Luis Obisp o
County : "This option has recently generated public opposition and has been identified b y
the Department as an area of controversy ."
Why, then, would the department want to further alienate local residents by once failin g
to schedule a hearing here? Expanding bear hunting to San Luis Obispo County is goin g
to be a hard sell as it is — and leaving the public out of the loop makes it that muc h
harder .
It's true that Fish and Game has gathered more data on the local bear population, and it's
come up with what it terms a conservative estimate of the number of bears here : 1,067 .
Yet we wonder, why the urgency? Why make the change at this time? As was the cas e
last year, we're not aware of any substantial increase in bear vs . human encounters in ou r
county .
For example, Caltrans — which posted bear crossing signs on the Cuesta Grade —
reports only two bear-versus-vehicle accidents on the grade between 2006 and 2008 .
"Overall, we have had very few incidents along the Cuesta Grade," a Caltrans official e -
mailed us .
Nor are there any glaring red flags in Fish and Game's draft environmental report . It
shows that the number of incidents, bear depredation permits and depredation removal s
have been holding steady at only one or two per year .
It's always been our position that a hunt should be authorized based on scientifi c
evidence that the population is growing at a rate that jeopardizes the health of the animal s
and/or is posing a danger to residents .
We still aren't convinced the evidence is there — but we welcome Fish and Gam e
officials to come here and make their case before San Luis Obispo County residents .
We strongly urge the commission to schedule a local hearing before it votes on whethe r
to allow bear hunting in our county .
November 27, 200 9
Doug Updike, Environmental Program Manage r
Wildlife Branc h
California Department of Fish and Gam e
1812 9th Stree t
Sacramento, CA 9581 1
RE :Scoping Comments on 2010 Changes to Mammal Hunting Regulation s
Dear Mr . Updike :
We are writing today in response to the California Department of Fish &Game's
("the Department") news release dated November 2, 2009 . According to the release, th e
Department is soliciting public comment regarding changes to the mammal huntin g
regulations for 2010, and will incorporate these comments into a draft Environmenta l
Impact Report ("ETR") to be released on February 4, 2010 followed by certification of the
EIR in April 2010.
Los Padres ForestWatch is a local,independent non-profit organization working t o
protect wildlife and wild places in the Los Padres National Forest, the Carrizo Plai n
National Monument, and other public lands along California's central coast . Our work i s
supported by more than 800 outdoor enthusiasts, hikers, mountain bikers, horsebac k
riders, hunters, anglers, ranchers, scientists, educators, business leaders, and other s
throughout the Central Coast region and the state who share our conservation mission .
ForestWatch participated in the Department's proposal earlier this year to expand bea r
hunting into San Luis Obispo County . We remain concerned about the lack of accurate
.population studies for black bears in the Central Coast region,and we respectfully submi t
the following recommendations for the Department's mammal hunting regulations fo r
2010 .
We are pleased that the Department has decided to prepare a full EIR for thi s
proposal .As you know, the preparation of an EIR is governed by the Californi a
Environmental Quality Act ("CEQA"). The EIR process begins with a process known a s
"scoping,"wherein thelead agency determines the proper scope of an EIR by consultin g
with other agencies and the public .See Pub . Res . Code § 21080 .4(a), CEQA Guidelines §
15082,
As part of this "scoping" process, once a lead agency decides to prepare an EIR, i t
must immediately prepare a Notice of Preparation ("NOP")and publish that NOP to th e
Office of Planning and Research .CEQA Guidelines § 15082(a). Please consider this letter to
be our written request to receive the NOP and other CEQA notices and document s
(including thedraft and final EIR), pursuant to Pub . Res . Code §21092 . We would prefer t o
receive such notices via email at <info OLPFW .org>.Please notify us of any additiona l
Post Office Box 831 •Santa Barbara,CA 93102 • 805-617-4610 • www .LPFW .org
procedures that we must follow to receive such notices in the future, as we would like to
continue to provide our comments and recommendations to the Department on thi s
matter.
Once we receive the NOP, we will be able to provide the Department with mor e
specific recommendations and suggested alternatives. In the meantime, we respectfull y
submit the following recommendations for possible changes to the Department's 201 0
mammal hunting regulations :
1.The Department Should Not Allow Bear Hunting in San Luis Obispo Count y
For the reasons outlined in our April 16, 2009 letter to the Commission, we strongl y
believe that black bear hunting should not be allowed in San Luis Obispo County . To ou r
knowledge, adequate survey and baseline data still does not exist for black bea r
populations in San Luis Obispo County . Because of this lack of data, we continue to believ e
that any proposed regulatory changes to allow black bear hunting in San Luis Obisp o
County are premature .
Recommendation : Do not amend the Department's mammal hunting regulations to
allow hunting of black bears in San Luis Obispo County .
2.The Department Should Schedule a Public Hearing on the Matter in San Lui s
Obispo to Solicit Input from Local Residents
When the Department proposed allowing bear hunting in San Luis Obispo County i n
February 2009, many county residents (including three County supervisors and th e
editorial board of the County's largest daily newspaper) urged the Department to conduct a
public hearing on the matter in San Luis Obispo . Despite these requests, the Departmen t
continued to hold meetings at a location more than 200 miles away from San Luis Obispo ,
creating an extreme hardship for most county residents to attend the hearing and provid e
testimony to the Commission .
If the Department decides to move forward with the proposal to allow bear huntin g
in San Luis Obispo County, it seems fair to request that the Department schedule a publi c
hearing on the matter in San Luis Obispo to solicit input from local residents . We believe
that the Department should make an extra effort to include those citizens who are mos t
affected by this issue, particularly since this proposal would affect a discrete geographi c
area . San Luis Obispo County residents have a unique perspective on this issue, and th e
demand to schedule such a meeting in San Luis Obispo is high . We would be happy to assis t
the Department in locating a suitable location for this meeting .
Recommendation : If the Department proposes to allow bear hunting in San Lui s
Obispo County, it should schedule a public hearing on the matter in San Luis Obispo to solici t
input from local residents .
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3 . The Department Should Consider Reducing the Number of Bears Allowed t o
Be Taken Each Year Statewide, and Should Improve the Method of Notifyin g
Hunters that the Season is Close d
The Department's regulations currently provide for the closure of bear seaso n
"when the department determines that 1,700 bears have been taken pursuant to th e
reporting requirement in section 708(e). The department shall notify the commission, th e
public via the news media and bear tag holders via the U .S. mail and the news media whe n
implementing this closure ." Section 708(e) requires hunters who have killed a bear t o
"immediately" return their bear tag to the Department .
Despite these regulations, the number of bears killed each year for the last thre e
years has significantly exceeded this 1,700 threshold . Specifically, 1,822 bears wer e
reported taken in 2006, 1,861 bears were reported taken in 2007, and 2,028 bears wer e
reported taken in 2008 . The Department attributes the difference between the 1,70 0
threshold and the actual number of bears killed to the "lag time" between when th e
Department receives notice of the 1,700 th bear killed, and when hunters receive th e
Department's written notification that the bear season is closed .
Due to this large discrepancy (particularly in 2008), it seems reasonable to reques t
that the Department explore alternative approaches that more effectively and efficientl y
notify hunters of the closure . Such regulatory amendments may include placing the burde n
on hunters to take affirmative steps to inquire about the status of bear season, requirin g
hunters to "pre-validate" their tags at Department offices before entering the field ,
lowering the notification threshold, or limiting the number of bear tags issued per year .
Many other states already have these simple measures in place . For example, i n
Arkansas, hunters must call an 800 number the evening before hunting the next day t o
inquire whether the quota has been reached . Amending the state's mammal huntin g
regulations to include a similar requirement seems reasonable .
We also believe that the requirement to "immediately" return a bear tag to th e
Department could be made more clear, thus reducing the amount of "lag time" betwee n
when the 1,70 0 th bear is killed and when the season is officially closed . For example, th e
regulations should specify that hunters are to return their bear tags "immediately, an d
within 24 hours of, taking a bear ."
Making the notification process more efficient is particularly important given th e
reduced hours of operation of Department offices pursuant to the statewide furlough order .
If Department offices are closed three Fridays of each month, this increases the likelihoo d
that bear hunting season will not be closed when that 1,700 threshold is reached . If, fo r
example, that threshold is reached on a Friday, the public would not be notified until a t
least the following Monday that the season is closed - allowing an additional three days o f
take beyond the legal limit .
Recommendation : Consider regulatory changes to improve the method of notifying th e
public that bear season is closed . Consider reducing the number of bears that trigger th e
season closure notification .
4.The Department Should Track the Total Number of Bears Killed Per Year b y
All Causes, Including Legal Hunting, Poaching, Depredation Permits, Vehicl e
Strikes, Wildlife Management Activities, and Other Activitie s
The number of bears killed in California varies widely from year to year, partl y
because hunting is not the only source of bear mortality . In addition to legal hunting, bear s
are also killed by illegal poaching, depredation, vehicle strikes, wildlife managemen t
activities, and other causes . We believe that the Department should place a cumulative limi t
on the total number of bears that can be killed each year. This limit should be set at a leve l
that sustains the state's bear population .
For example, the New Mexico Department of Game and Fish establishes a "Tota l
Sustainable Harvest Limit" that includes bear mortality caused by hunting, depredation ,
roadkill, and other causes . The hunting season closes once this cumulative Tota l
Sustainable Harvest Limit is reached, allowing wildlife managers to more accurately an d
sustainably control the number of bears taken per year .See
http ://www.wildlife .state .nm.us/recreation/hunting/harvest/documents/bear harvest i n
fo .htm .
In California, on the other hand, the bear season closure mechanism is only based o n
the number of bears harvested by legal hunting. This could result in a cumulative take o f
black bears that exceeds sustainable levels if, for example, there are an unusual number o f
bears killed by vehicle strikes, depredation, or other causes in a given year .
Recommendation : Establish a "Total Sustainable Harvest Limit" that closes th e
hunting season based on the cumulative number of bears taken by hunting, depredation ,
vehicle strikes, wildlife management activities, and other causes .
5.The Department Should Establish Bear Management Units and Limit th e
Amount of Take in Each BM U
Many states that allow bear hunting have established Bear Management Unit s
("BMUs") that divide a particular state up into discrete units based on a variety of factors .
Typically, different hunting season and take limits are established for each BMU .
We believe that the Department should consider establishing several BMUs fo r
California . The Department's Black Bear Management Plan states that "differences i n
vegetation, water availability, and bear density, allow biologists to differentiate thre e
regional 'subpopulations' of black bears in California—North Coast/Cascade, Sierra, an d
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Central Western/Southwestern .See BBMP at 7 . The Department should conside r
establishing three BMUs based on these distinct subpopulations .
Establishing a Central Western/Southwestern BMU is particularly important due t o
the small number of bears in this region . The Department's bear management plan
estimates that "less than 10 percent of the statewide black bear population inhabits th e
Central Western/Southwestern California bioregion ." Due to their limited population i n
this region, black bears are more susceptible to overharvesting . Establishing a BMU for this
bioregion along with specific take limits would allow the Department to manage bea r
populations more sustainably in this region .
Recommendation : Establish three or more Bear Management Units in California, an d
establish specific take limits for each BMU based on differences in bear density, habita t
quality, and other factors.
6.The Department Should Increase the Number of Wardens and Implemen t
Other Measures to Reduce Poachin g
The Department's Black Bear Management Plan ("BBMP") includes severa l
recommendations to address poaching and law enforcement, including :"If curren t
regulations are found to be ineffective in preventing significant impacts to California's
black bear resources, regulation changes should be considered to make these regulation s
more effective ."See BBMP Section 3 .6 .
The Department recently estimated that illegal take of bears by poachers i s
estimated at approximately 25% of legal harvest . For 2008, when 2,028 bears were legall y
killed, that equates to an additional 507 bears killed by poachers . Several sources have
noted that poaching is on the rise in California . At the same time, California has one of th e
lowest per capita rates of wardens in the country .
Our state's wardens do an excellent job .with the resources they have, but the y
simply need more resources . The Department should consider increasing the number o f
wardens in the state and other measures to reduce poaching rates .
Recommendation : Consider increasing the number of wardens and implementing
other measures to reduce poaching rates throughout the state .
7.Consider Closing Bear Hunting in Santa Barbara and Ventura Counties t o
Allow Bear Populations to Rebound From Large Wildfire s
Since 2006, several large wildfires have burned hundreds of thousands of acres o f
black bear habitat in Santa Barbara and Ventura Counties . These fires and their acreag e
burned include :
5
2006 Perkins Fire Santa Barbara County 15,043 ,acre s
2006 Day Fire Ventura County 162,702 acre s
2007 Zaca Fire Santa Barbara & Ventura 240,207 acre s
2008 Gap Fire Santa Barbara County 9,443 acre s
2008 Tea Fire Santa Barbara County 1,940 acre s
2009 Jesusita Fire Santa Barbara County 8,733 acres
Altogether, these wildfires affected more than 438,000 acres of black bear habitat i n
a relatively small geographic area . Because so much black bear habitat was modified b y
these fires, it seems prudent to institute a temporary closure to allow biologists time to
assess the current state of the black bear population in these two counties .
Recommendation : Institute a temporary closure on black bear hunting in Sant a
Barbara and Ventura counties to assess the impacts of massive wildfires on black bea r
distribution and abundance.
Please contact us if you would like to discuss any of these recommendations in mor e
detail . We look forward to receiving copies of the Department's NOP and draft EIR an d
providing more substantive comments at that time . Thank you for your consideration o f
these recommendations .
Sincerely,
/s /
Jeff Kuype r
Executive Directo r
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