How to Comment to Game & Fish
The Arizona Game and Fish Department will be hearing public comment on February 9 about the proposed hunting regulations for coming year. They will be accepting written comments until March 1. We urge everyone to attend the Feb. 9 meeting AND submit a written comment. Even if you do not wish to make a comment in person, your presence at the meeting would be a big help.
Contact information for where to send written comments is at the end of this post. Also included is the information about the February 9 public hearing.
Below are some talking points about several of the hunts that we oppose. At the public meeting you may wish to touch on points about all the hunts or focus on only one. There is no set time limit (it’s at Game & Fish’s discretion), so the choice for how to organize your comments is up to you. In a written comment, we definitely encourage people to write about all the hunts that they oppose. Remember that with either a verbal or written comment, it is important to incorporate your own reasons and personality so that it doesn’t come across like a form comment.
For your convenience, we have included both No Compromise Recommendations and “Reasonable” Recommendations. For those who do not feel comfortable with the full, Earth First!, no-compromise demands, the “reasonable” recommendations are our idea of the bare minimum that Game & Fish should be doing.
For those who wish to find out more about Earth First!’s efforts to end ecologically senseless sport and trophy hunting, please join us on Wednesday, February 8 at 7pm at the UA College of Law in Tucson, 1201 E. Speedway (NW corner of Mountain and Speedway), Room 140 for a special event — Defending Mountain Lions: Earth First! and Rod Coronado. Rod will give an update on his recent conviction for interfering with the Sabino Canyon mountain lion hunt. EF! will talk about Game & Fish’s hunts for mountain lions, sandhill cranes, prairie dogs and bighorn sheep and how you can help stop the slaughter.
Also, the event will feature the premiere of our short film about the sandhill crane hunt and our efforts to protect them - you don’t want to miss it! The event is free, but all donations go toward legal appeals.
MOUNTAIN LIONS
No Compromise Recommendations:
1. Mountain lion hunting should be banned in Arizona, as it is in California. There are no reliable population figures for mountain lions anywhere in North America. Because of this, it is impossible for Game & Fish to scientifically manage the species — they are shooting in the dark and gambling with the future of our wildlife. Large predators like mountain lions fill keystone roles in any ecological system, and their removal places serious stresses on all levels of the ecology. With development increasingly destroying wildlife habitat, sport hunting is a pressure this species cannot afford - especially since large predators require vast amounts of habitat just to feed themselves.
2. If mountain lion hunting is allowed, the use of hounds should be banned. This would allow only the most skilled trackers to kill mountain lions, and would probably ensure a sustainable “harvest.”
3. Reducing predation on game species is not a valid reason to kill mountain lions. If a pronghorn or bighorn population is in danger, Game & Fish should ban hunting of that population and work to secure it more habitat and other protection. Scapegoating predators is not only unfair, it is foolish: you can’t protect an ecosystem by wiping out its predators!
Lions should not be killed out before the reintroduction of bighorn sheep. Instead, where reintroduction occurs on public lands, Game & Fish should work with the appropriate land management agencies to remove commercial livestock. Livestock, not lions, fragment habitats, forage on some of the same areas needed by bighorn sheep, and most importantly, spread diseases to bighorn sheep populations. Domestic sheep, not predation, are the problem.
“Reasonable” Recommendations:
1. Mountain lion hunting should not be year-round — a season must be imposed. The proposed season (for only those units with multiple bag limits) is insufficient.
The best time for a three month closure would be at the height of the summer (June-August), when most mountain lions are giving birth. Since the bulk of lion hunting occurs from November-March, another reasonable closure would be March-November. Having a year-round season allows hunters to merely buy a tag so that they can kill any mountain lion they might happen to come across in the course of the year. This casual approach to wildlife killing should not be allowed or encouraged by Game & Fish.
2. Mountain lions should not have multiple bag limits in any unit ( a “multiple bag limit” means that Game & Fish allows the killing of more than one mountain lion in a given region per year). There is no population or scientific justification for this practice. Multiple bag limits make it easy to overstress lion populations by killing too many animals. In addition, there is no way for lion hunters to be in contact with each other, to determine when limits have been reached.
Related Comment:
1. Lions must never be killed merely because they are found within close proximity to human populations. If lions appear near trails or other recreation areas frequently, those areas should be temporarily closed, or notices put up that individuals recreate at their own risk. Lions should not be destroyed just because developers are encroaching upon their habitats and forcing them to get used to human presence. Game & Fish’s response to the Stonegate and Queen Creek lion sightings in the Phoenix area was the right and professional one. That response should become the standard upon which all future Game & Fish/mountain lion interactions are based.
BIGHORN SHEEP
No Compromise Recommendation: The bighorn sheep hunt should be discontinued.
1. Bighorn populations over the long term do not appear to be stable. Bighorn habitats are fragmented and overgrazed, and domestic livestock are constantly spreading disease to native wild sheep with severe consequences (for example, the infection of the herds in the Peaks area for domestic sheep in the Herb/Reno Sheep Driveway in the mid-1990s) .
2. The Department has a tendency to blame local predators for unnaturally high bighorn mortality caused by disease. Game & Fish must take a stance against livestock grazing in areas where bighorns are found or introduced - currently, it is wasting too much time and money inoculating or killing diseased sheep without addressing the root problem.
3. Game & Fish uses declining or threatened bighorn populations as a pretext for mountain lion hunts, but then allows hunting of bighorns in the same units! If Game & Fish admits that the species is threatened, how can it justify ANY hunt?
4. Trophy hunts are evolutionarily dangerous, because they tend to cull the largest animals from a species. It has been repeatedly documented that when humans selectively kill the largest and most impressive members of the species, gene frequencies change within a few generations and the species as a whole becomes smaller and weaker. For a species as threatened as bighorn sheep, this practice is unjustifiable - especially since trophy hunters have been culling powerful bighorn males for centuries already.
“Reasonable” Recommendation: With a species so obviously threatened with extinction that even Game & Fish confesses to alarm over declining numbers, we feel that the only reasonable recommendation is the no compromise position taken above.
GUNNISON’S PRAIRIE DOG
No Compromise Recommendation: Hunting of Gunnison’s prairie dogs should be banned.
1. Gunnison’s prairie dogs (GPD) are on the verge of extinction. Efforts are under way to list the GPD as an endangered species under the federal Endangered Species Act. These animals have declined from 90% of their historic range in North America and 98% of their range in Arizona.
GPD are a keystone species in grassland ecosystems. They dig burrows that other animals depend on for shelter, including burrowing owls, foxes and prairie snakes. They are an important prey item for many types of predators. Their burrows facilitate the absorption of rainfall into the water table, aerate the soil and encourage the growth of certain rare plants.
All these functions are jeopardized by habitat loss, disease and hunting. A 9-month hunt with no bag limits is an unjustifiable stress on this species. We want Game & Fish to show some initiative and engage in proactive management for the GPD; we do not want to see the species go the way of the Mexican gray wolf, the jaguar, ocelot, and grizzly bear here in Arizona.
2. Gunnison’s prairie dogs are THE major prey item for the black-footed ferret in Arizona. The black-footed ferret is the most endangered mammal in North America and has been reintroduced in northern Arizona. It depends upon the prairie dog (in Arizona, this means the GPD) for 90% of its diet. Yet Game & Fish allows prairie dog hunting IN THE REINTRODUCTION AREA! The US Fish and Wildlife Service’s Black-Footed Ferret Recovery Program’s national goal is to establish at least 10 self-sustaining ferret colonies by 2010. A federal wildlife biologist who worked with ferrets for 13 years believes that 100 breeding female ferrets are required for each population, and 10,000 acres of plague-free prairie dog colonies.
3. Of all the species that Game & Fish authorizes hunting for, the hunt for the Gunnison’s prairie dog is the most outrageous and reckless. GPD cannot be made into trophies. They cannot be eaten. They are killed and their bodies are left to rot, while their burrows are polluted with leftover lead shot. GPD hunting is a blood sport that involves hunters setting up lawn chairs and blasting away at stationary animals - there is no wilderness or tracking skill involved at all. This hunt betrays a sickness of mind and is all about killing defenseless animals for pleasure.
4. Game & Fish has no good population estimates, no bag limit, and requires no permit for GPD hunting. This means that they allow hunting for an animal when they have no idea how many exist, how many are being shot, or how many people are shooting them.
5. Gunnison’s Prairie Dogs have one of the most complex communication systems of any animal yet studied. They have a confirmed language complete with syntax, external communication, dialect, and the ability to create new vocalizations for alien introductions into their environment (for example, when a GPD witnesses an object that has never before been seen within its area, it will come up with a series of vocalizations to describe it to the other prairie dogs within the colony).
“Reasonable” Recommendation: Game & Fish should declare a complete moratorium on Gunnison’s prairie dog hunting until the federal government can rule on the Endangered Species Act petition and the black footed ferret recovery goals for Arizona have been met.
SANDHILL CRANES
No Compromise Recommendation: Game & Fish should ban the hunting of sandhill cranes in Arizona.
1. Sandhill cranes were almost wiped out by hunting and habitat loss in the first half of the 20th century, and they are still recovering from this brush with extinction. Hunting places an unnecessary pressure on a species that has had its genetic diversity so seriously compromised (although crane numbers have rebounded, they have done so from a small number of breeders, so the population remains vulnerable).
2. The greater sandhill crane subspecies is severely threatened and federally protected, yet it is impossible for hunters to distinguish between crane subspecies from the ground. All the stresses that hunting places on sandhill cranes are even more potent for the less common greater sandhills.
3. Game & Fish claims to closely regulate the number of cranes killed, but does not count birds that are crippled or killed by hunters but not recovered. In all, 24% of the country’s sandhill crane population is killed or crippled by sport hunters every year. Game and Fish should not contribute to this problem, but should instead take positive steps toward crane recovery by making Arizona a sanctuary state for these migratory birds.
4. Sandhill cranes are a highly intelligent and social species that mates for life (birds may find new mates if the old one dies, but there is no good data analyzing the effects of this death and mate change on the individual birds or the population). Yet Game & Fish allows a purely “recreational” hunt for them, despite the inevitable cruelty that must result. In 2005, Earth First! teams in the hunt area witnessed birds being wounded, smashed against farm equipment and strangled by hunters with poor aim. They also witnessed a crippled crane being surrounded and defended by its family members — and this was only in one weekend! The hunt is cruel and senseless and should be stopped — fun is not a valid reason for killing these birds.
“Reasonable” Recommendation: Game & Fish should place a moratorium on crane hunting until it can investigate the widespread hunting violations witnessed by Earth First! teams in the past 2 years. If Game & Fish wishes to continue this hunt, it must expand the no-hunt area around Whitewater Draw and Willcoz Playa, and must make sure that hunting regulations are actually enforced. Until Game & Fish has the will and capability to enforce its own rules, the hunt should not continue.
1. Earth First! observation teams, for two years in a row, have witnessed numerous hunting violations during the sandhill crane hunt. Steven Ward, a prominent hunting guide, was observed participating in a hunt from a vehicle, but Game & Fish took no action when a complaint was filed. Numerous hunters boasted to Earth First!ers of having hunted in no-hunt zones or from roads, and of flushing birds from the no-hunt areas. This behavior is widespread and has been repeatedly witnessed by Earth First! observers, yet Game & Fish patrols have been nowhere to be seen.
2. Hunters lie in wait at the edge of the no-hunt areas, especially Whitewater Draw, and shoot cranes as they are flying low in or out of their roosting areas. This unsportsmanlike behavior should be prohibited, and to ensure that cranes can not be killed while gaining altitude or coming in to roost, the no-hunt areas should be expanded.
3. Sandhill cranes bring vast economic benefit to southern Arizona through birdwatchers who enjoy the animals without killing them. The hunt is a black mark on Arizona’s reputation for these birders, who are almost always upset when they learn that Game & Fish hypocritically allows the pleasure killing of a species that it supposedly works to conserve.
OTHER SPECIES
Pronghorn antelope: Situation and arguments are the same as for bighorn sheep. The only difference is that disease is not a major threat to pronghorns as it is to bighorns.
Coyotes and black bears: Situation and arguments are the same as for mountain lions (consult the Game & Fish website if you’re interested in the specifics of bag limits, etc.)
HOW TO COMMENT
To read the proposed hunt guideline changes for this year, visit www.azgfd.com/h_f/hunt_guidelines.shtml
For more information on Game & Fish’s predator policy see the Animal Defense League site, www.adlaz.org, under campaigns. For more information on prairie dogs see the Forest Guardians website, www.fguardians.org. For more information about Earth First! campaigns to protect wildlife from Arizona Game & Fish, email Chuk’shon Earth First! (sabthebastards (at) hotmail (dot) com) or check out www.azef.org
The Game & Fish meeting on February 9 will take place from 7-9pm at the Game & Fish regional office in Tucson, 555 N. Greasewood (west of I10, between Speedway and St. Mary’s). For carpool information, email sabthebastards (at) hotmail (dot) com
MAIL written comments to Game Branch, Arizona Game and Fish Department, 2221 W. Greenway Road, Phoenix, Arizona, 85023; FAX them to 602-789-3929; or EMAIL them to azgamebranch@azgfd.gov.