Changes in trapping WACs now up for comments

[Humptulips]

https://wdfw.wa.gov/about/regulations/development/2024-2026-season-setting

The changes are on the CR-102. Also, you can open the page for comments from this page.
It should be presented to the Commission on March 26th, Public Comment allowed at this time also.

Here is what they are though: Changes are in yellow.
 WAC 220-400-050  Requirements for sealing of pelts and collection
of biological information for river otter, cougar, lynx, and bobcat.
(1) It is unlawful to possess river otter, cougar, lynx, or bobcat
taken in Washington without a department identification seal which has
been attached to the raw pelt, on or off the carcass, prior to the
pelt sealing deadline.
 (2) The raw pelt of a bobcat or river otter must be presented to
an authorized department employee, or authorized individual under per
mit with the department, for sealing
 , and the associated harvest re
port must be submitted to the department by April 20th after the close
of the appropriate hunting or trapping season in which it was killed.
 Any person who takes a bobcat must present a cleaned and air
dried complete lower jaw (both sides), in such a manner that the ca
nine tooth can be extracted for aging, to an authorized department em
ployee at the time of sealing before a pelt seal will be issued.

 WAC 220-417-030  Wild animal trapping.  (1) The trapping season
authorizes the taking of furbearing animals for their hides and pelts
only. Furbearers may not be taken from the wild and held alive for
sale or personal use without a special permit from the director.
 (2) Any wildlife trapped for which the season is not open shall
be released unharmed. Any wildlife that cannot be released unharmed
must be left in the trap, and the department of fish and wildlife must
be notified immediately.
 (3) Lawfully trapped wild animals must be lethally dispatched or
immediately released. A firearm may be used to dispatch trapped ani
mals.
 (4) It is unlawful to trap for wild animals:
 (a) With body-gripping traps without a special permit from the
director.
 (b) Unless kill traps are checked and animals removed within
((
 seventy-two))
72 hours.
 (c) Unless animals captured in restraining traps (any nonkilling
set)
are visually checked (via binoculars, trail camera, spotting
scope, or in person) each calendar day and are removed within ((
 twen
ty-four))
24 hours of capture.
 (d) Using game birds, game fish or game animals for bait, except
nonedible parts of game birds, game fish or game animals may be used
as bait.
 For purposes of this section, the meat of animals classified as
furbearing animals in WAC 220-400-020 is not considered edible.
 (e) Within ((
 thirty))
30 feet of any exposed meat bait or nonedi
ble game parts which are visible to flying raptors.
 (5) Game bird feathers may be used as an attractor.


I would urge trappers to comment about the requirement to turn in bobcat jaws. I have not been able to get them to budge on this but why are trappers required to destroy a bobcat skull and cougar and bear hunters get by with removing a premolar. I have spoken with the lab that handles these teeth for aging and while not as accurate it is possible to use an incisor. Please urge the change to allow the use of a pulled incisor in place of the entire jaw.

I am not happy with the language on trap check times but I think it is the best we are going to get.

[JakeLand]

Our game dept. Sucks ! Air dried clean jaw *censored* I’m not cleaning the jaw , if it goes through they’ll get what they get

[TeacherMan]

I sell on the taxidermy market, that would not work in any way. And a 24 hr check? 🤣😳

[Humptulips]

I sell on the taxidermy market, they would not work in any way. And a 24 hr check? 🤣😳

Well, not in so many words but we now have a 24 hour check essentially so it is hard to argue against that.

[Loup Loup]

The trap check rule is essentially the same, just the wording is now longwinded.
It is better than it could have been.
The Bobcat jaw proposal is unrealistic, and unsustainable. We ( hundreds of successfull Bobcat harvesters yearly) are not going to clean and air dry jaws for them. Period. Then what is WDFW going to do when a jaw does not meet their cleanliness standard? Refuse to tag that Sapp’s cat? Forcing the Sapp to be in possession of an illegal raw Bobcat skin? This rule as proposed is set up for failure.
The skull whether separate, or as Teacherman stated, on the carcass, has monetary, or sentimental value to the harvester. Why waste that and devalue the animal when it is not nessesary.
The premolar has always been used on Cougar, Bear, and Wolf. Bobcat is no different.
If the premolar tooth gives good enough data for Cougar, Bear, and Wolf (in Idaho), bobcats no difference.
I remember when we had to turn in the whole carcass of Otter, and Bobcats when we had the pelts sealed. I remember always into late spring a pile of slimy carcasses out back by the garbage cans at the regional WDFW office rotting away. They never did anything with them.

[HillHound]

Having to turn in the lower jaw on a predator is stupid And in my eyes it’s just another rule change to try to turn people who are now law-abiding citizens into lawbreakers. We will all be criminals when they are done changing enough laws. Yes even you Boy Scouts that won’t do anything wrong because as soon as drinking your morning cup of coffee is wrong guess what you’re a freaking criminal to. Why would you have to turn in half your trophy. That would be like having to cut the left antler off every deer or elk that you harvest to turn it in to WDFW. Makes no freaking sense why they can’t use the same tooth we use on everything else like was already stated. And if you live in an apartment or somewhere you don’t have the means of boiling animal heads yourself you are going to have to pay someone to do it, a cost they should be paying If they want to confiscate your trophy from you, or half of it anyways. Who knows maybe they will start requiring us to cut all the feet off our clams to turn in so they can verify counts and ages too. Maybe half the legs off every crab or a fillet off each king salmon we catch this spring might be going to them too I suppose because it would make just as much sense…NONE

[Skyvalhunter]

Don't be giving them ideas now!!

[boneaddict]

The lower jaw thing bothered the heck out of me.  That’s half the trophy. 

[Elkaholic daWg]

 Made my thoughts known and was pleased to see those only comments from those involved or affected by the change, unlike in the comments for Elk hunting changes.

[JakeLand]

The lower jaw thing bothered the heck out of me.  That’s half the trophy.

the lower jaw on cats is a big blow to trappers financially and for euro mounts

[Loup Loup]

Overly burdensome for all hunters, trappers, taxidermists, and any person or agency that wants a Bobcat skull for their collection.

[Humptulips]

I agree with everyone but just a few points.
When they say the jaw has to be cleaned I think they mean skinned and most of the meat cut off. I don't believe they mean it has to be professionally cleaned. Probably just don't want something that is going to rot and stink. This should be clarified.
Abut the teeth. I think we should ask to substitute an incisor because there already is a study on using bobcat incisors. Nothing that I know of on premolars at least as far as bobcats are concerned. I think a skull missing an incisor would still look pretty good and not detract from the value.

[boneaddict]

Is this going to bother any of you guys if it goes through?

WAC 220-417-040 add: common rat and mouse traps cannot be used to trap
furbearers

[Humptulips]

Is this going to bother any of you guys if it goes through?

WAC 220-417-040 add: common rat and mouse traps cannot be used to trap
furbearers

Where did you get that from? It is not in CR-102 that I can see.

[Loup Loup]

Humptulips: the wording says cleaned. Who are we to say how that is to be interpreted. Taking the jaw is wrong on many levels. Simple as that. I don’t care how much meat is acceptable on it.
The incisor is the front teeth right up front. They take incisors out of ungulates. All predators that I know of they take the premolar. A small tooth, between the canines and the molars. (Reference bear hunting regs). The removal of which does not detract too much from the appearance of the skull. A Bobcats tooth information is no different than a bear, cougar, or wolf. The premolar is an “easy” tooth to remove. In Washington the hunter removes the premolar on bear and sends it in. In Idaho you take the bear to a participating business where an employee pulls the tooth. Heck, many times it’s the barmaid that pulls the tooth. Predators incisors are so tight together I don’t know how you would get one out without destroying most of the row. Irregardless if some other agency uses incisors, that’s a bad decision on their part.

[Humptulips]

Humptulips: the wording says cleaned. Who are we to say how that is to be interpreted. Taking the jaw is wrong on many levels. Simple as that. I don’t care how much meat is acceptable on it.
The incisor is the front teeth right up front. They take incisors out of ungulates. All predators that I know of they take the premolar. A small tooth, between the canines and the molars. (Reference bear hunting regs). The removal of which does not detract too much from the appearance of the skull. A Bobcats tooth information is no different than a bear, cougar, or wolf. The premolar is an “easy” tooth to remove. In Washington the hunter removes the premolar on bear and sends it in. In Idaho you take the bear to a participating business where an employee pulls the tooth. Heck, many times it’s the barmaid that pulls the tooth. Predators incisors are so tight together I don’t know how you would get one out without destroying most of the row. Irregardless if some other agency uses incisors, that’s a bad decision on their part.

I agree with you on the cleaned interpretation. It does need to be clarified and I urge people to comment on this language.
About the incisor. The reason I mentioned the incisor is, there is a study comparing aging incisors and canine teeth of bobcats. We will have some literature to back us up in our arguments. There is none that I know of on premolars. On top of that the literature recommends removal of the incisor for aging animals to be released so if they create a database it would all be the same by using the incisor.
Just to be clear, yes there is literature on aging premolars but from larger animals, not bobcats.
I spoke with Matsons Labs who does all of this work and they want to do canines so we will get pushback on using another tooth. I think there is a higher chance of success if we ask for the incisor then the premolar. I have 13 bobcat skulls lined up for us to practice on so we can come up with a good way to pull an incisor without damaging the rest of the teeth so my plan would be do a you tube video for everyone to learn from but we need to get this jaw destruction quashed first.

[Loup Loup]

This Bobcat tooth submission idea is totally without merit on another level.
When a producer brings in a Bobcat in the round, or a pelt, to have sealed, the WDFW person asks if it’s an adult or “kitten”. Kitten is inaccurate label, it should be :young of the year. YOY. The producer answers the question, or the WDFW can look at the cat or pelt and tell if it’s an adult or YOY. It’s obvious. By the size difference alone. They, ( every state in the union) has CITIES seal data on Lynx, Bobcat, and River otter since, I don’t know, prolly early 70s. And now somebody prolly wants a grant from somewhere and comes up with this confiscating jaws plan.
What is even more telling is the mistaking the sex of felines, (both Cougar and Bobcat by WDFW employees at time of sealing. On both cats in the round, and skins. Enough so that this sex data (all called females) on cougar is what first curbed the cougar take in central wa years ago. This missexing still goes on. I had it happen on Bobcat pelts two seasons ago. But, that’s a subject for another post.

[Loup Loup]

The correct language from me on tissue on jaws is…. Heck no!! We don’t interpret, we don’t negotiate on which teeth. It’s just no.
In Idaho their Bobcat jaw submission program was voluntary. And IDFW reimbursed the producer $5 for the jaw.
I’ll  make a call and get the skinny.
Humptulips, you and me need to talk too.

[Humptulips]

Another thing that makes aging bobcats questionable is trappers turning YOY and females loose. I don't know how they are going to get a good population dynamic when trappers turn up with nothing but big males. I tried to explain this to them but I think they just want to produce a bunch of statistics and don't really care how accurate they are.

The correct language from me on tissue on jaws is…. Heck no!! We don’t interpret, we don’t negotiate on which teeth. It’s just no.
In Idaho their Bobcat jaw submission program was voluntary. And IDFW reimbursed the producer $5 for the jaw.
I’ll  make a call and get the skinny.
Humptulips, you and me need to talk too.

If they pass the WAC as is we'll be stuck with it and you have to have the pelts sealed for them to be saleable. We are not in a position to dictate. Not really a negotiation either. We need to convince them we are right and make changes. Honestly the odds are probably not in our favor so we have to make a supremely good case.

[Humptulips]

Is this going to bother any of you guys if it goes through?

WAC 220-417-040 add: common rat and mouse traps cannot be used to trap
furbearers

Just so people don't freak out this is not up for passage. This was an item suggested from within the Department but never made the cut and was not recommended by the Director. It is not on the CR-102 and it has to be for the Commission to pass it. The public has to have 30 days to comment and without it being published for comment it won't happen.

[Loup Loup]

Thanks for the info Humptulips, and your time.
But again I’d rather go on record as saying “ no, it’s a bad idea” than giving them a different bad idea to pivot to. As then they can go back to the office and say they have the sportsmen’s buy in. Then ten years from now they can rewrite history and say “hey it was the sportsmen’s idea”.

[Frank The Tank]

How does the language of checking a trap every 24 hours, how would this affect the 72 hr rule for things like drowning colony sets for muskrat and the like that would be considered a "kill" trap under current regs?

[Frank The Tank]

Would the language of  72 hr check of "Kill traps" like muskrat colony etc in the current reg/manual be left, or would this be removed under this guise and also be moved to 24 hours?

[Humptulips]

Would the language of  72 hr check of "Kill traps" like muskrat colony etc in the current reg/manual be left, or would this be removed under this guise and also be moved to 24 hours?

72 hour check on killing traps remains unchanged.

[KNOPHISH]

Is the jaw submittal only for trapped bobcat?

[JakeLand]

Is the jaw submittal only for trapped bobcat?

any bobcat taken by hunting  or trapping and cougar

[Humptulips]

Is the jaw submittal only for trapped bobcat?

any bobcat taken by hunting  or trapping and cougar

I don't believe cougar are included in jaw submittal. For some reason a tooth is OK for cougar.

[Humptulips]

I just thought I would emphasize how important it is to comment on this. I know there is some disagreement in what might be acceptable so some of us may be writing slightly different opinions.
I will note however if the Commissions takes our comments to heart, they will not be able to simply rewrite the WAC and pass it. They have to allow 30 days public comment on any new WAC before passing it so they will have two choices pass or no pass. No matter how you think this should read any change results in no new WAC. Sure, they can send it back to be rewritten and bring it back up at a different meeting but in my experience, they won't want to take the time to handle this on its own.
Also, I think it is unlikely Commissioners will read your comments. Someone will and they will keep a running total on for and against. They will likely take note of a lot of against comments if they get a good argument at the Commission meeting.

Comment here and e sure and be specific on the WAC you are commenting on:
https://publicinput.com/3yearseasonsetting

[Frank The Tank]

My comment I posted:  Re: Bobcat jaw submission.  As a fur buyer who works extensively with hunters and trappers, the method to support this data collection is overburdensome, and has negative downstream effects economically.  Many states the require teeth submission use incisors.  There is no need to use canines specifically.  Submission of canines renders the jaw/skull useless in any form, which leads to waste.  Secondly, "Cleaned and air-dried" is an ambiguous statement that would be left to the individual biologist's interpretation and wildly different acceptance.  The proposed change is also ambiguous in general.  Must the lower jaw be separate, or can the skull/lower jaw remain intact?  The reading of this means that the hunter/trapper could be forced to keep in possession a hide that is not sealed, therefor forcing them to be in violation.  Suggestions:  Work with Washington State Trapper Assoc leadership to best meet WDFW data collection.  move from Canine to incisor in order to allow less wastage of this precious resource. Allow licensed Fur Buyers to be trained and submit incisors with required documentation that removes administrative/biological burdens hunters/trappers. A hunter/Trapper could then present this documentation to the biologist/WDFW staff with pelt for sealing. 

[Dysfunctional Vet]

I went over and left comments for the trap check and bobcat jaw. I’m not as versed in all the issues as some folk, but personally I’ve been chasing bobcats for years with a bow and if I’m ever lucky enough to harvest one (trapping or bow) I’d like to keep the skull intact. Looking forward to the rendezvous next weekend, I know I’m new and I took trappers ed online, I don’t know how to set traps “correctly” or how to read sign “correctly” but I can help in anyway I can.

[Humptulips]

For what it is worth I found out today it costs WDFW $7.30/each to age the canines and $12.35 to age an incisor.

[TeacherMan]

For what it is worth I found out today it costs WDFW $7.30/each to age the canines and $12.35 to age an incisor.

I’d say stick it to them but reality the sportsman will eat that cost somehow.

[Humptulips]

I gave testimony today on the bobcat jaw submission. Tom Parker, our NTA Representative also gave testimony and did a great job I might add. I think we have made our case as best we can. Now to see what the Commission does. Still no agenda out on their next meeting so unable to say when it comes up but now we wait I guess.
Thank you to all that commented on the proposal. There were a lot.

[Dysfunctional Vet]

Thank you sir

[redi]

Thank you Bruce

[Frank The Tank]

Recently had a conversation with a WDFW field biologist on this.  Most, if not all of you probably know all this, so I'm really just articulating what I'm personally hearing:

1: Field Bios had no idea this was a thing until it came down from the "Flagpole".  In this Bio's words, "Good, this will prove bobcats are doing just fine and are everywhere."
3. The Bio didn't understand why a canine was necessary as it was common practice, knowledge to pull a small incisor to get the same data.  Granted, this may be harder, improbable on bobcats, but the question, especially since this comes from the flagpole, is why the canine?
4: As a Field Bio, and being reactive to top-down directive instead of a vetting process by those interacting with hunters/trappers when tagging, this person hadn't fully processed/appreciated, much less had an opportunity to have a conversation with other Field Biologists on exactly how much of a ClusterF&%K this was going to be for them.  Some things realized by this Bio in our conversation:
   a. "Clean" and "dry" and even "presented" will have wildly different interpretations by different biologists.   There won't be one standard.  Even if the biologists are trying their best and being helpful, this will invariably create friction.
   b.  Biologists have a thought that every hunter/trapper can perfectly skin his/her own catch.  I explained I had 2 hunters show up with 8 frozen, newly sealed bobcats.  These guys would have no idea how to skin/care for hides in order to retain value. Now they have to find someone to skin and either freeze or dry then turn back over to them, with correct skull to correct hide so they can then turn jaws in and hides sealed.   Many turn their full catch over either as a sale, or to have an experienced skinner handle their fur.    Plus, as mentioned before, these guys would show up with their skulls, a biologist would turn them away saying the skull wasn't prepped correctly, and now these guys are really pissed, being forced to possess what is tantamount to an illegal hide since it's not sealed and now possibly past sealing date because the skull didn't meet some imaginary subjective criteria.
 
5.  The bio saw the reality of this, and saw the implications and second and third order effects that were going to be felt by the hunter/trapper.   Now, Biologists being biologists, will they rock the boat, push back and at least make the flagpole come up with some sort of policy based in some reality to execute this if/when it comes to pass?  Let me check with my Magic 8 Ball.....

On my end, I'm going to do my best to assist those hunters/trappers with their hides/skulls so that if nothing else, when it comes time to present said to the biologist at least that part is smooth.