C.A.S.H. Comments On: The Black Bear Management Plan for New York State 2014-2024

These are formal comments submitted to counter proposals by the game agencies.

From a site that promotes bear hunting as “fun.”

The Committee to Abolish Sport Hunting (CASH), a wildlife protection organization with offices in New York and New Mexico, hereby submits comments, on behalf of our members, to the New York State Bureau of Wildlife’s (BoW), Black Bear Management Plan (BBMP) for New York State 2014-2024.

CASH understands that the BoW is an entity that is biased in favor of hunters, and gives their interests preference over those of wildlife. This bias is confirmed by the BoW in its BBMP as one of its stated goals is to “Ensure that we provide sustainable uses of New York’s wildlife for an informed public.” (BBMP p2) The BoW has a long history of catering to hunting industry interests, despite another of its stated goals:  to “Ensure that we meet the public desire for: information about wildlife and its conservation, use, and enjoyment; understanding the relationships among wildlife, humans, and the environment; and clearly listening to what the public tells us,” (Emphasis added) (p2) and despite the acknowledged fact that the “(Department of Environmental Conservation) must address public concern for the health and welfare of bears…” (p8)

Because BoW actions have traditionally favored hunting and building support for hunting among the state’s overwhelmingly non-hunting public (p23), its statements have implied an exaggerated risk to human safety associated with the state’s bear population (“managing bear populations is critically important and managers are challenged to balance diverse public interests in bears with concern for public safety”) despite the state’s bears never having been shown to be a significant public safety risk. (p5)  The BoW considers its priorities to be to “1) maintain bear populations at levels acceptable to the public; 2) promote and enhance bear hunting as an important management tool; 3) minimize the frequency and severity of human-bear conflicts; 4) foster understanding and communication about bear ecology, management, and conflict avoidance; 5) and ensure that the necessary resources are available to support effective management of black bears in New York.” (p5)
Despite the majority of human-bear “conflicts” that are simple nuisance behaviors, such as bears feeding from bird feeders or garbage cans (p19), the BoW continues to mislead the public into thinking that bears pose a safety risk great enough to warrant killing them in all portions of upstate New York. (p16)  It is interesting to note that the BBMP states that human-bear conflicts in southern New York have become more widespread as bear hunting has increased and that this has prompted authorities to reevaluate bear management practices and policies (p7), though it is likely that the newly drafted practices and policies will lead to increased human-bear conflicts and possibly a safety issue where none currently exists.

Because the BoW acknowledges “the relationship between population size and frequency of conflicts is influenced by availability of natural foods, accessibility of human-related foods (e.g., garbage, birdseed), and by public reporting rates,” (p11) one would believe that the reasonable and most effective response to the frequency and kind of conflicts experienced by New York State residents would be one of public education, legislation, and law enforcement regarding the public’s intentional and unintentional feeding of bears in areas where they are known to frequent.  However, even a cursory reading of the BBMP tells the reader that the plan is weighted heavily toward hunting as the primary method of addressing human-bear conflicts, despite the BoW’s own data suggesting that increased hunting may be responsible for increased human-bear conflicts (p7).

Though wildlife is held in trust for the public, it is managed by the state for the <4% of the population that hunts wildlife for sport. Nowhere is this made clearer than in the BBMP that seeks to expand bear hunting to all parts of upstate New York despite bear hunters being less than 0.1% of the state’s population. (p16)

Throughout the BBMP, mention is made of the necessity or desire to increase the number of bear hunters, increase access to bear hunting opportunities, and increase the number of bears killed by hunters (pp 16, 17, 33) and it intends to do this by disseminating its pro-hunting propaganda to conservation organizations, schools and community groups (p23) and to allow hunters to kill bears of any age, including immature cubs, in all areas of the state where bears will be legally hunted (33). The BoW makes no mention of any surveys having been done on New York residents in regard to their acceptance of hunting juvenile bears who have emerged from their dens for the first time, despite its oft-stated desire for public input and opinion.

Because the DEC’s intent is to foster a bear hunting culture among New Yorkers (p33) and to convince the public that killing immature bear cubs is an ethical activity, it seeks to regulate “alternative harvest techniques” such as use of bait, pursuit with hounds, trapping or spring hunts despite such techniques being illegal in New York. (p17).  Whether it intends to do this through regulation change or just through not enforcing current conservation law is not known.

CASH is dissatisfied with – and vehemently opposed to – the current BBMP and the proposed BBMP for 2014-2024.  We believe the plan will not only damage the state’s bear population, but the proposed expansion of bear hunting will endanger the public to an even greater degree.  With hunting being responsible for more injuries and deaths every year than can be attributed to bears, any expansion of hunting can only create a greater risk to public safety and well being.

Because the DEC has seen human-bear conflicts increase with increased bear hunting (p7) a different approach must be taken if the BoW expects the public to believe they have the best interests of wildlife at heart.  DEC regulation 6 NYCRR Part 187.1 must be amended to prohibit all incidental or indirect feeding of bears in New York State, not just deliberate feeding.  It is the incidental or indirect feeding that generates most complaints about bear behavior in the state.

As the DEC has seen, successful implementation of regulation 6 NYCRR Part 190.13 which requires the use of bear resistant food canisters by backcountry campers in the Eastern High Peaks Wilderness has resulted in fewer human-bear conflicts in the backcountry. (p20)

Expanding this program to cover all areas of the state known to be “bear country” will have a similar effect and will show that hunting is not an appropriate response to a situation that can be resolved through peaceful means.  As is stated in the BBMP, “Several communities are transitioning toward greater use of bear resistant dumpsters and garbage cans for commercial and residential trash management.” (p20)  This will have a direct effect on the number of complaints due to bear activity and the use of bear resistant dumpsters and garbage cans should be mandatory and enforced.

Another critical part of the BBMP should be support for wildlife rehabilitators who care for animals injured and orphaned as a result of the BoW’s aggressive and excessive bear hunting program. The public is greatly concerned about the welfare of injured or orphaned wildlife, and the DEC has the obligation to provide for the animals who are made to suffer because of its programs. Aside from licensing, training and evaluating wildlife rehabilitation facilities, the DEC should provide funding for licensed facilities so they can continue to carry out their lifesaving work.  It is almost incomprehensible that wildlife rehabbers are licensed by the DEC and are tasked with cleaning up the mess created by the DEC, yet receive no monetary support from the agency despite an operating budget of over $400 million.

The DEC’s failure to financially support the critical work done by wildlife rehabilitators clearly shows how the agency values violence and killing over life saving work that protects and restores the beauty of the state’s fauna.  The state is responsible for much of the expenses incurred by wildlife rehabilitators and it needs to compensate rehabilitators for their financial burden.

Lastly, given that wildlife watching in New York generates more than 3.5 times the amount of revenue generated by hunters in New York (U.S. Fish & Wildlife Service 2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation report for New York, p13), the DEC needs to immediately end its reliance upon the hunting and weapons industries as a significant source of its funding. As participation rates for hunting wane with each passing year, the DEC will need to stop relying upon and catering to hunters and instead turn to the non-hunting, wildlife watching public to support programs that peacefully and non-violently enhance not only wildlife watching opportunities, but also protect wildlife and habitat for decades to come.

Visit the website of Bear Education and Resource – BEAR and use their material in your efforts to save bears.


Contact Us

Committee to Abolish Sport Hunting / C.A.S.H.
P.O. Box 562
New Paltz, NY 12561