This is a comment submitted by one of our members. We thought it was exceptional so we wanted to share. June 25th is the last day to comment on the CR102!
I would like to give input on the proposed CR102 to increase the harvest for cougars to 2 tags per hunter only in the affected Blue Mountain area. I believe this change will not have positive affects and will likely “indirectly” Hurt the Elk Calves in the Blue Mountains and I’ll explain why below.
1. My first question is how will the Department measure success? What are the objectives of this change?
2. Will the department be held accountable for the success or failure of this if it does not meet objectives??
3. What does that accountability look like?
4. Lastly How long will the department Take to make corrective changes if cougar Harvest is not measurably Increased?
This rule change will not accomplish very much if anything at all. The fact that WDFW is only proposing this change for certain areas (the At-Risk Area’s) speaks to me. It tells me they know this assessment on the Blue Mountain Elk Herd has bad optics and they are trying to do the very minimum to try and appease critics of the department. This Proposal allows them to say they did “something”, They will be able to claim they gave some “effort”. While they know in the back of their mind these changes will have a minimal effect with no measurable change. It’s a shell game with no measurable change.
As many following the cougar issue in Washington we understand WDFW staff has been and is still setting their guidelines/quotas for a stable population using old estimated Population data. They continue to claim over Harvesting of Cougars using this faulty data. This is misleading in the best case. With the lack of trust around Cougar management in Washington it’s time for the Biologist to be transparent and use current Science to calculate their Harvest Objectives. Continually stating overharvest when they do not have any measure of current population.
WDFW is still not attempting or trying to reduce (or Measure) the populations or density of cougar in the state of Washington. Cougars in our state are in abundance in the state and there are many credible indications that our cougar density is high. Many tribal Biologist working in our state have no issues finding and collaring cougars, Depredations are High, Harvest is Up, and this assessment shows that Predation is extremely high as well. Yet WDFW Cougar Specialist continue to put their head in the sand and make no efforts collaborate with studies in recent years to confirm what many are experiencing with cougar population and densities and to Double Check their math before making Claims about High Percentage Cougar Harvest.
WDFW Staff and Cougar experts commonly mention how expert they are with cougars, yet they always turn to 15-year-old science to calculate harvest to support their “expertise”. I recently watched WDFW’s Rich Beausoleil’s presentation to the 2022 Mountain lion workshop where he almost bragged about how much of an expert they are on Cougar. Is it Odd WDFW Cougar Staff are not engaged and helpful with other studies in NE Washington regarding Cougar behavior and interactions with humans trying to research if there are non-lethal ways to manage cougar/human conflict? It appears that Rich and his team are only interested in collaboration with studies that support a narrative for their agenda and groups like Western Wildlife Outreach, and the Mountain Lion Foundation, who also according to Rich’s own words in the 2022 presentation he works closely with.
For the Record I’m familiar that current commissioner Lorna Smith’s was the executive director of the group (western Wildlife OutReach) and now her Husband is the acting executive director of Western Wildlife outreach, considering they at the table and a vocal political force in this discussion while they hold a Commission Seat I feel that is a conflict of interest and does not look well for the commission. In fact it is obvious to me that the commission is more politically motivated than ever before and is not looking at Science but rather politics of the situation, but I digress.
A good example, reading the literature on the Blue Mountain Elk Herd at risk assessment, released in July of last year, I notice the department continues to mislead the public on Cougar Harvest % claiming statements of cougar harvest. They state these as fact when they are only guessing what the harvest of Cougars assumes that Cougar populations never change and are always static in their calculations. On Page 23 of the at-risk document, it is stated that WDFW regularly exceeds the 12-16% harvest Guidelines for Cougar. However, they do not clarify that they use a static denominator in their calculation of % based on data older than 10-years-old or from another area.
Look at Figure 15 on page24, cougar harvest for 2018 in one of the PMU was Over 55%?? Did WDFW staff stop to wonder why or how hunters killed more than ½ of all the cougars in that PMU? Yet the next year or two cougars still the leading predation on calves?? Shouldn’t an expert give pause to wonder is the >50% cougar mortality number even accurate, Should they put a footnote in that graphic? Are we expected to believe that if Rich Beausoleil, or Brian Kertson for a second thought that more than ½ of the Cougars in the Blue Mountains PMU were wiped out in a single year, We honestly believe they would not be sounding the alarm about Cougars and making emergency efforts to lower their guidelines in that PMU? Yet they didn’t mention any concern about it, in fact they use this statistic in a manner that suggests cougar populations may be in decline without first checking into how it or they could be wrong in their calculation? I suspect they know their math is not accurate, but they continue to publish this faulty data as fact and use it with authority when they should be investigating.
Without knowing the population of Cougars at the year of harvest it is not acceptable to state as fact that harvest exceeds the guidelines. If perhaps the cougar density was higher (2X) it may be very well possible that hunters are harvesting well below the 16-24 % needed to reduce cougar populations. Simple Math would indicate if the Departments Math is off by a factor or 2, a 12% harvest would in reality be a 6% Harvest. And a 32% Harvest that the department claims if Grossly Over harvesting would in fact be the 16% that they are targeting.
Is has been and continues long overdue for WDFW to double and triple check the denominator of Cougar harvest percentage calculations? Are we “under harvesting” cougars, while at the same time the department Experts claim we are “Over Harvesting” I don’t know? I have my suspicions, but It’s time to find out.
In closing, it is for these reasons that I don’t feel this 2nd Cougar tag will have any measurable change in Cougar population or density. In fact, I believe this change has a strong potential to harm Elk calves in the Blue Mountains by allowing the department not to make any measurable or accountable change for several more years, it allows more time for the department to skirt the real issues happening while they do nothing measurable and continue to publish and make decisions with false or inaccurate data.
We need measurable and accountable science, or the Elk will continue to get decimated in Washington. I see nothing with this proposal this that is measurable, and I feel there is again no accountability with WDFW Staff when this measure fails and does not change any cougar harvest, as I suspect it was designed to do.
So, for those reasons I regrettably don’t have any opinion on a 2nd Cougar tag in Washington. It does absolutely nothing for the Elk Calve recruitment, it provides a distraction to the real problem and only allows WDFW to continue to ignore and make effort for sound Cougar management by continuing to use Faulty Science for their calculations and decisions.
It’s time for this commission and the WDFW to act. As stated in the Blue Mountain Elk Herd At Risk Assessment, it’s time for an Emergency Rule Process, The commission should authorize a season to mitigate Cougar Predation on the Blue Mountain Elk Herd like several other states have done. I also believe the Commission has the authority to authorize and direct the department for a statewide emergency study using DNA capture/re capture efforts to measure and check the density and populations in the Blue Mountains, and quickly reduce the cougar density in the Blue Mountains to the respected 2.2 Cougars per square 100km they claim is standard.
I’m a strong advocate and proponent for using dogs to help with Cougar management, Using Dogs is widely accepted as the best method for Cougar, whether it is meeting harvest objectives, or Capturing Cougar for Science and population estimates. I believe Houndsmen in your state would be more than happy to help the department to find solutions which are measurable and meaningful for all wildlife management.
Although I am frustrated, I appreciate your time and Efforts on this topic and I’m open for discussion and finding real and measurable solutions to the political storm surrounding Cougar Management.
https://publicinput.com/2022CougarSeasonCR102?fbclid=IwAR2hIZJcdSj0LtZMck_NNyoeyIPxfEDEGYldHCLHo_--gD-hX0YYOOry1Xg