This is the departments take on the petition…
This petition asks the Fish and Wildlife Commission to initiate rulemaking to implement an area-specific deer tag that requires deer hunters to choose either an east or west hunt area, like the system currently used for elk. The petitioner asserts that the proposed system will increase deer abundance by reducing harvest, with a specific focus on northeast Washington white-tailed deer populations.
The Department has used area-specific elk tags to manage elk hunter densities since 1979. Though the east-west elk tag system has implications for elk harvest, the system was primarily implemented to resolve hunter crowding issues. Initially this system included multiple tag areas corresponding to individual or aggregated elk populations that ultimately transitioned to the east-west system in use today. Hunter crowding has higher potential during elk than deer seasons for a few reasons, namely that the number of hunters per elk is consistently higher than those per deer (currently about ~1:1 vs. 1:3, respectively) resulting in greater competition for elk than deer. Elk populations are also relatively more discrete than deer, which concentrates hunters and compounds the potential for hunter crowding. Historically this resulted in unacceptably high elk hunter densities in areas where hunters perceived a high potential for success, such as in the comparatively large and easily accessible populations of central and southeastern Washington. Elk general season timing was also more discrete (i.e., no overlap) than deer seasons between east and western Washington, as is the case today for modern firearm seasons. This provided some advantage to westside resident hunters that could hunt the earlier eastern season and, if unsuccessful, hunt again in a local western season, which created concerns about equitable opportunity.
An area-specific elk tag resolved crowding and equity issues in general seasons by distributing elk hunters and effort more uniformly. This system is also important for managing opportunity in the current special permit draw system. All elk special permit applications specify a tag type (i.e., east or west) and special permit applicants cannot change the tag type regardless of the draw outcome. Without this system we would expect more applicants from western Washington for the highly valued special permits in eastern Washington because, if unsuccessful in the draw, the applicant would likely hunt nearby in a general season (i.e., there is no tradeoff in their application choices). This would ultimately lead to reduced special permit draw odds and raise hunter concerns about equity and fairness.
Deer population abundance is partly a function of how many animals survive and therefore Department staff acknowledge that hunting has the potential to influence both mule and white-tailed deer population dynamics (i.e., how a population changes through time). However, deer population trajectory is predominantly due to variation in adult female survival. For that reason, the Department restricts most deer hunting to antlered male (i.e., “buck”) only opportunities to maximize female deer survival and ultimately promote population stability or growth. The Department restricts antlerless harvest opportunities, where available, as a function of population monitoring results. For example, if a population is trending downward contrary to management objectives the Department responds by proposing limitations on general season or special permit antlerless opportunities. Specific to the northeast part of the state (i.e., District 1, GMUs 101-121), the Department has restricted white- tailed deer harvest to antlered male only since 2019 and further restrictions to buck harvest opportunities are unlikely to change the population’s trajectory.
Further, a recent study (2017-2020) of white-tailed deer in northeast Washington did not identify harvest as a limiting factor to growth, though this study did identify a stable to slightly declining population suggesting that there are limitations to growth. Many independent and interactive non-hunting factors, such as outbreaks of hemorrhagic disease (in 2015 and 2021), changing land use practices, human encroachment, non-human predation, or changing climatic conditions (e.g., more frequent drought), are likely acting on Washington white- tailed deer and influencing their population dynamics.
For the above reasons, an east-west tag structure is unlikely to influence population trajectory, though it has the potential to reduce the harvest of east-side deer taken by western Washington hunters. From 2018-2022, about 49% of deer hunters with western Washington addresses consistently hunt only in western Washington, 27% consistently hunt only in eastern Washington, and 24% hunt some mixture of east and west. Western Washington residents account for approximately 32% of all eastern Washington deer harvest and approximately 25% of all white-tailed deer harvest. The Department expects that an east-west tag structure would result in some proportion of the “mixed-side” hunters choosing to hunt western Washington, but the reduction in harvest of eastern Washington deer may be nominal (i.e., single digit percentage decrease) and the reduced harvest by westside hunters may be nullified by increased success (i.e., harvest) of those hunters choosing an east-side tag.
The implementation of an east-west deer tag is a significant restrictive change to hunting opportunity and may be contrary to the preferred structure of most deer hunters. As such, the Department must conduct formal public scoping to understand and evaluate the implications of an area-specific deer tag on hunter participation and its potential consequences to deer harvest, which is not feasible prior to the current three-year package rulemaking process.
Staff recommendation:
Department staff recommend denying this petition because a) the requested rule change is unlikely to result in increased white-tailed deer populations, and b) the requested rule change has statewide implications and therefore requires extensive public scoping to evaluate its acceptability to all deer hunters
https://wdfw.wa.gov/sites/default/files/2024-03/9-summary-sheet-petition-deer-tags.pdf