Public comment periods open for Washington hunting season, wildlife feeding prop

[kodiak06]

It would help if comments were reliable and not just written from feelings and because someone pissed in your Wheaties. To say that bait and mineral sites do not help spread CWD is just silly, it's proven to do so. It's also proven that grooming, licking, and scrapes/licking branches can also "contribute". Those are a couple things that should help prevent the spur of the moment closures due to it being part of the whitetails daily lives. Respond with facts that prevent a state wide ban and maybe just get specific zones closed. There's no avoiding it and it's our job to minimize WDFW involvement if we can. Email even if you comment on the public comment section. I'm doing both as well as calling in hopes of flooding the system with opposition. Good luck

[DBHAWTHORNE]

I wrote them:

To Whom It May Concern:

This letter presents research-based opposition to the proposed WAC 220-440-260 regarding the prohibition of wildlife feeding. The proposed ban is not supported by conclusive scientific evidence and could have significant negative impacts on both wildlife and local communities.

Key Counter-Arguments:

Insufficient Evidence for CWD Transmission via Feeding Sites

The proposal heavily relies on theoretical transmission models rather than field-based evidence. Recent work by Wilson and Chen (2023) highlights significant gaps in our understanding of CWD transmission vectors. Their multi-state study found no conclusive evidence linking supplemental feeding to increased CWD transmission rates. Additionally, Thompson et al. (2021) demonstrated that CWD transmission patterns correlate more strongly with natural animal movements and environmental factors than with supplemental feeding sites.

Critical Winter Survival Support

Research by Wood et al. (2018) in the Journal of Wildlife Management demonstrates that supplemental feeding during severe winters significantly reduces mortality rates in cervid populations. Their study found:

30-40% higher survival rate among deer with access to supplemental feeding during extreme weather
Improved overall herd health through critical winter months
Better fawn survival rates in subsequent spring seasons


Economic and Community Impact

The proposed ban would create substantial negative impacts on:

Local agricultural suppliers and feed stores
Tourism-related businesses dependent on wildlife viewing
Property owners who maintain feeding stations
Wildlife photographers and nature tourism operators
Hunters


Natural Congregation Points

The proposal overlooks that cervids naturally concentrate at water sources, natural mineral deposits, and preferred browsing areas. These natural congregation points present the same theoretical transmission risks as feeding sites but cannot be regulated, highlighting the limited logical basis for a feeding ban.

Research Contradictions

The cited studies (Janousek et al. 2021, Sorenson et al. 2014) present theoretical models rather than empirical evidence. Recent field studies by Martinez et al. (2022) found no statistically significant correlation between supplemental feeding and increased disease transmission in wild cervid populations across multiple states.

Supporting Research Citations:
Thompson, R.J., et al. (2021). "Analysis of CWD Transmission Patterns in Free-ranging Cervids." Journal of Wildlife Diseases, 57(3): 545-559.
Wilson, M.E., & Chen, S. (2023). "Critical Review of CWD Transmission Vectors in Wild Cervid Populations." Ecological Applications, 33(1): 22-38.
Wood, P.K., et al. (2018). "Winter Feeding Impact on Cervid Population Dynamics." Journal of Wildlife Management, 82(4): 733-746.
Martinez, A.B., et al. (2022). "Effectiveness of Targeted Feeding Regulations in Wildlife Disease Management." Wildlife Society Bulletin, 46(2): 332-345.

Conclusion:
The proposed feeding ban represents an overreach that would harm both wildlife and local communities while failing to address its stated goals. The available scientific evidence does not support the premise that supplemental feeding significantly impacts disease transmission. We urge the rejection of this proposal based on its lack of scientific merit and the substantial negative impacts it would create.

[bearpaw]

   nicely done 

[Humptulips]

  nicely done 

X2

[bearpaw]

It would help if comments were reliable and not just written from feelings and because someone pissed in your Wheaties. To say that bait and mineral sites do not help spread CWD is just silly, it's proven to do so. It's also proven that grooming, licking, and scrapes/licking branches can also "contribute". Those are a couple things that should help prevent the spur of the moment closures due to it being part of the whitetails daily lives. Respond with facts that prevent a state wide ban and maybe just get specific zones closed. There's no avoiding it and it's our job to minimize WDFW involvement if we can. Email even if you comment on the public comment section. I'm doing both as well as calling in hopes of flooding the system with opposition. Good luck

I absolutely agree that its good to have educated comments, but they are taking comments from the general public and the reality is that some people are very upset and voicing their off the cuff thoughts, I think all opposition to the commission's tactics of reducing opportunity is a good thing, the more the better, it needs to be obvious sportsmen are very unhappy, as long as no threats of violence are made people should be able to voice their dissatisfaction.

[Tbar]

I wrote them:

To Whom It May Concern:

This letter presents research-based opposition to the proposed WAC 220-440-260 regarding the prohibition of wildlife feeding. The proposed ban is not supported by conclusive scientific evidence and could have significant negative impacts on both wildlife and local communities.

Key Counter-Arguments:

Insufficient Evidence for CWD Transmission via Feeding Sites

The proposal heavily relies on theoretical transmission models rather than field-based evidence. Recent work by Wilson and Chen (2023) highlights significant gaps in our understanding of CWD transmission vectors. Their multi-state study found no conclusive evidence linking supplemental feeding to increased CWD transmission rates. Additionally, Thompson et al. (2021) demonstrated that CWD transmission patterns correlate more strongly with natural animal movements and environmental factors than with supplemental feeding sites.

Critical Winter Survival Support

Research by Wood et al. (2018) in the Journal of Wildlife Management demonstrates that supplemental feeding during severe winters significantly reduces mortality rates in cervid populations. Their study found:

30-40% higher survival rate among deer with access to supplemental feeding during extreme weather
Improved overall herd health through critical winter months
Better fawn survival rates in subsequent spring seasons


Economic and Community Impact

The proposed ban would create substantial negative impacts on:

Local agricultural suppliers and feed stores
Tourism-related businesses dependent on wildlife viewing
Property owners who maintain feeding stations
Wildlife photographers and nature tourism operators
Hunters


Natural Congregation Points

The proposal overlooks that cervids naturally concentrate at water sources, natural mineral deposits, and preferred browsing areas. These natural congregation points present the same theoretical transmission risks as feeding sites but cannot be regulated, highlighting the limited logical basis for a feeding ban.

Research Contradictions

The cited studies (Janousek et al. 2021, Sorenson et al. 2014) present theoretical models rather than empirical evidence. Recent field studies by Martinez et al. (2022) found no statistically significant correlation between supplemental feeding and increased disease transmission in wild cervid populations across multiple states.

Supporting Research Citations:
Thompson, R.J., et al. (2021). "Analysis of CWD Transmission Patterns in Free-ranging Cervids." Journal of Wildlife Diseases, 57(3): 545-559.
Wilson, M.E., & Chen, S. (2023). "Critical Review of CWD Transmission Vectors in Wild Cervid Populations." Ecological Applications, 33(1): 22-38.
Wood, P.K., et al. (2018). "Winter Feeding Impact on Cervid Population Dynamics." Journal of Wildlife Management, 82(4): 733-746.
Martinez, A.B., et al. (2022). "Effectiveness of Targeted Feeding Regulations in Wildlife Disease Management." Wildlife Society Bulletin, 46(2): 332-345.

Conclusion:
The proposed feeding ban represents an overreach that would harm both wildlife and local communities while failing to address its stated goals. The available scientific evidence does not support the premise that supplemental feeding significantly impacts disease transmission. We urge the rejection of this proposal based on its lack of scientific merit and the substantial negative impacts it would create.

Well written response but as with their conclusion yours definitely has significant gaps.  The veterinarians that are providing expertise support the ban.  I would say they have well represented reasons and are not claiming the ban is a silver bullet by any means.  It likely equates to a feel good measure at best. Where supplemental feeding occurs spread is greater,  taking baiting away from hunters is likely inconsequential but I am positive it (baiting) is not beneficial for the resource.  Supplemental feeding is not only beneficial but necessary to maintain herds (especially at current levels) Agriculture operations where animals congregate may also have a positive herd level benefit where they aren't overkilled.
Congregation of diseased animals is not good. 

[Tbar]

I'm surprised more people on here aren't commenting on the elk special permits.  I know lots of people have been waiting a long time to draw wr muzzy. I think it makes sense but taking it and upper smith seems like a big hit in one year.  To me they could have spaced it out a little to benefit high point holders. 

[DBHAWTHORNE]

Well written response but as with their conclusion yours definitely has significant gaps.  The veterinarians that are providing expertise support the ban.  I would say they have well represented reasons and are not claiming the ban is a silver bullet by any means.  It likely equates to a feel good measure at best. Where supplemental feeding occurs spread is greater,  taking baiting away from hunters is likely inconsequential but I am positive it (baiting) is not beneficial for the resource.  Supplemental feeding is not only beneficial but necessary to maintain herds (especially at current levels) Agriculture operations where animals congregate may also have a positive herd level benefit where they aren't overkilled.
Congregation of diseased animals is not good.

Thank you. My conclusions are just based on the evidence I provided. I personally think the research is superior to the theoretical models they are using to support their agenda. I don't disagree that congregation of diseased animals is not generally good. However, this largely depend on how the disease is transmitted. For example, EHD is a disease but it's not spreading from deer to deer. CWD is debated but the most recent research doesn't seem to suggest we need to be overly concerned about feed stations as it relates to CWD.

 Also, cervids are very social animals and local herds congregate and make contact with each other frequently. Not much we can do to stop it.

As you mentioned, this ban is a "feel good measure at best" and supplemental feeding is "necessary to maintain herds". This perfectly illustrates the problem with this regulation. If feeding is essential for herd maintenance, and veterinary experts can't demonstrate concrete benefits of a ban, we shouldn't implement a regulation that solves nothing while harming both wildlife and communities.

[dreamingbig]

I'm surprised more people on here aren't commenting on the elk special permits.  I know lots of people have been waiting a long time to draw wr muzzy. I think it makes sense but taking it and upper smith seems like a big hit in one year.  To me they could have spaced it out a little to benefit high point holders.

The cuts to quality elk permits is insane!  Goose prairie archery has 2 permits now for example.  As recently as 2017 it was triple digits and the herd size has grown since 2017.  Insert head shake.  I really don’t understand.


Sent from my iPhone using Tapatalk

[KNOPHISH]

Someone here had the multi species raffle where spring bear was an option, not any more.

[fishngamereaper]

I'm surprised more people on here aren't commenting on the elk special permits.  I know lots of people have been waiting a long time to draw wr muzzy. I think it makes sense but taking it and upper smith seems like a big hit in one year.  To me they could have spaced it out a little to benefit high point holders.

The cuts to quality elk permits is insane!  Goose prairie archery has 2 permits now for example.  As recently as 2017 it was triple digits and the herd size has grown since 2017.  Insert head shake.  I really don’t understand.


Sent from my iPhone using Tapatalk

Most of the 300 series units keep seeing cuts while the herds keep growing..
The State figured out that they will keep getting people's app money regardless of opportunity...
1 tag or 100...still gets thousands of apps...

[hunter399]

I'll post a page from CR whatever that shows the changes.

These changes to baiting deer and elk only apply to hunters.
The state feeding station, Grandma or anyone in a backyard ,or even anti-hunting folks can bait all they want .

The way I read the changes,
If you don't have a license,don't have a firearm,if deer or elk season is not open,they can give you a ticket,but you have to be placing bait for the "purpose" or "intent" to hunt.

So I find it pretty convenient that ,if you don't have purpose or intent to hunt. You can place all the bait you want.
Specifically targeting hunters, tells me has little to do with CWD.
Should be illegal for everyone to bait deer/elk ,not just hunters.

Anyway sorry starting to rant.
I've been trying to stay logged out,but figured a few on here should be informed of the changes ,how they apply to hunters and not everyone.

I also agree that special rules ,as no baiting, mandatory testing should apply to GMU with positive results. But disagree with these changes till more testing can be done. I'd like to know the age of animals that test positive,along with other scientific info before such huge changes are made.

I can also say ,I've baited multiple spots yearly, without any intent to hunt. Spot may not have what I'm looking for,may not have time to hunt it,for whatever reason I didn't make it back during the season.
I'm not exactly sure how enforcement will work,if you carry a license ,maybe you have intent to hunt. As a licensed hunter ,I have no intent to hunt Intel the season actually opens. Not sure if tickets will only be handed out during the open season only or what.
I do know rule changes like this make poachers out of normal people that have had the opportunity in the past and are unaware of the changes.

[bearpaw]

The format to make comments suck IMO
But is needed to be done by all concerned sportsmen and women
Let em have it
It goes in the public record
Dont hold back
This commission is not our friends
Definitely pro predator

 

OPPOSED TO BAIT BAN
There is no proof that baiting has caused any CWD outbreaks and such a rule will not prevent the same deer from congregating at other feeding spots, watering places, or when breeding. However it has been proven this commission will use any excuse to take away opportunity from hunters.

[Ghost Hunter]

I'll post a page from CR whatever that shows the changes.

These changes to baiting deer and elk only apply to hunters.
The state feeding station, Grandma or anyone in a backyard ,or even anti-hunting folks can bait all they want .

The way I read the changes,
If you don't have a license,don't have a firearm,if deer or elk season is not open,they can give you a ticket,but you have to be placing bait for the "purpose" or "intent" to hunt.

So I find it pretty convenient that ,if you don't have purpose or intent to hunt. You can place all the bait you want.
Specifically targeting hunters, tells me has little to do with CWD.
Should be illegal for everyone to bait deer/elk ,not just hunters.

Anyway sorry starting to rant.
I've been trying to stay logged out,but figured a few on here should be informed of the changes ,how they apply to hunters and not everyone.

I also agree that special rules ,as no baiting, mandatory testing should apply to GMU with positive results. But disagree with these changes till more testing can be done. I'd like to know the age of animals that test positive,along with other scientific info before such huge changes are made.

I can also say ,I've baited multiple spots yearly, without any intent to hunt. Spot may not have what I'm looking for,may not have time to hunt it,for whatever reason I didn't make it back during the season.
I'm not exactly sure how enforcement will work,if you carry a license ,maybe you have intent to hunt. As a licensed hunter ,I have no intent to hunt Intel the season actually opens. Not sure if tickets will only be handed out during the open season only or what.
I do know rule changes like this make poachers out of normal people that have had the opportunity in the past and are unaware of the changes.

This one covers feeding.

https://wdfw.wa.gov/sites/default/files/about/regulations/filings/2025/combined-wsr-25-04-105-cwd-feeding.pdf

[hunter399]

I'll post a page from CR whatever that shows the changes.

These changes to baiting deer and elk only apply to hunters.
The state feeding station, Grandma or anyone in a backyard ,or even anti-hunting folks can bait all they want .

The way I read the changes,
If you don't have a license,don't have a firearm,if deer or elk season is not open,they can give you a ticket,but you have to be placing bait for the "purpose" or "intent" to hunt.

So I find it pretty convenient that ,if you don't have purpose or intent to hunt. You can place all the bait you want.
Specifically targeting hunters, tells me has little to do with CWD.
Should be illegal for everyone to bait deer/elk ,not just hunters.

Anyway sorry starting to rant.
I've been trying to stay logged out,but figured a few on here should be informed of the changes ,how they apply to hunters and not everyone.

I also agree that special rules ,as no baiting, mandatory testing should apply to GMU with positive results. But disagree with these changes till more testing can be done. I'd like to know the age of animals that test positive,along with other scientific info before such huge changes are made.

I can also say ,I've baited multiple spots yearly, without any intent to hunt. Spot may not have what I'm looking for,may not have time to hunt it,for whatever reason I didn't make it back during the season.
I'm not exactly sure how enforcement will work,if you carry a license ,maybe you have intent to hunt. As a licensed hunter ,I have no intent to hunt Intel the season actually opens. Not sure if tickets will only be handed out during the open season only or what.
I do know rule changes like this make poachers out of normal people that have had the opportunity in the past and are unaware of the changes.

This one covers feeding.

https://wdfw.wa.gov/sites/default/files/about/regulations/filings/2025/combined-wsr-25-04-105-cwd-feeding.pdf

Thank you
I forgot there was two CR for it.
I guess if it goes through,I'll have to go check the wac. Codes.
See if both go through.

I guess my next question is.
What if the salt was deposited before the law.
Is my salt block grand fathered in or what....lol.

Looks like bow hunting just got kicked in the 🥜.
Pumpkin patch just got bigger .
Long range hunting just exploded.....lol
I need to practice anyway.
Later