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

[kodiak06]

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.

Scrapes and licking branches also congregate whitetails, no different than baiting. CWD, if present will spread either way. Deer are social and ALL OF THEM visit community scrapes/LB and leave saliva, piss, and feces. There's absolutely no reason to close the entire state without targeted species testing positive in the respective hunt unit. If there are closures it should be as it was last year unit specific but to take it a step farther, only areas affected by cwd with a surrounding radius closed. They should also give any hunter checking in a CWD positive deer a replacement tag.

[kodiak06]

Not only is the bait ban proposed, the elimination of using scents and attractants is also part of the WAC 220-440-260 Prohibition of Feeding Deer, Elk and Moose CR 102 proposal.
There's absolutely no scientific studies showing synthetic scents should not be used. There's nothing in those scents to cause CWD nor do they congregate animals any differently than their normal day to day habits already do.

[GWP]

Washington State has already proven they do not care what the public thinks or says. They will eventually do their agenda regardless.

[Skyvalhunter]

Comments to the proposals sent. I want to encourage others to do so also. Our voice needs to be heard.

[hunter399]

Commented
I'll probably go check it out.
Few days ago ,looked like a lot of opposed comments.

[kodiak06]

Some folks commenting on the public portion are just opposing with silly comments. I read one that stated a "loophole left due to not also banning turkey baiting" lol,  and a few mentioning "ethics" when we all know hunting ethics are just opinionated views.