what I originally wrote...
-Please do not include the proposed 'Hunting at Night Regulations & Penalties' in the permanent WDFW 2012-2014 Hunting Rules as written. They seriously threaten lawful and beneficial night time hunting opportunities for game (Raccoons, Coyotes and Bobcats) and unclassified (Bullfrogs and potentially Feral Pigs) wildlife. In addition, how effective these shortcuts will be in enforcement remains dubious.
According to the 2006 USFWS "National Survey of Fishing, Hunting and Wildlife - Associated Recreation" 1.1 million hunters spent 15 million days and 0.2 billion dollars hunting 'other' animals. Based on the popularity of national groups like the United Kennel Club Coonhound programs, hundreds of thousands of these 'other' hunters are raccoon hound hunters.
Washington, likewise, has an active hound hunting community. The Washington State Hound Council is comprised of four regional clubs and has several hundred members statewide. Activities include off-season field trials and open-season buddy hunts. The regional Olympic Treehound Association's entry in the 2012 Shelton, WA holiday parade took first place.
I highly encourage the WDFW Commission, Enforcement, and Game staff to contact representatives from the Washington State Hound Council (President, Chet O'Brien) and other hunting groups to educate themselves on why these rules are highly egregious to already overlooked hunting families.
These rules were never discussed during public meetings nor are they within the scope of rules that were to be considered according to WDFW’s own issue scoping guidelines:
http://wdfw.wa.gov/hunting/regulations/ ... elines.pdf. Likewise their presence contradicts the press release dated February 07, 2012, which states “Only rules necessary for resource conservation, required by state or federal law, or requested by those affected were considered by WDFW.” (
http://wdfw.wa.gov/news/feb0712a/). None of these conditions are true of the proposed Hunting at Night regulations.
As an agency, which - at its best, should be seeking to increase hunter opportunity, retention and recruitment while applying science based management fish and wildlife, the inclusion of these rules that are simultaneously redundant and restrictive, demonstrating the worst kind of narrow and shortsighted rules making.
I’m submitting the following critique of these rules as a Houndsman; one of millions in the US today. However, as an active member of the big and small game hunting and fishing community, I find these rules, intended to allegedly simplify WDFW enforcement’s job, an erosion of hunting rights and an application of the murkiest form of logic.
To my knowledge, currently, WDFW does not collect any data on raccoon, other mesopredator, and unclassified species hunting activities. I am sure that Raccoons, account for some of the largest volume of nuisance animal complaints, since they are not considered ‘dangerous’ animals little effort is made in the tracking of this information either. Without the collection of metrics WDFW cannot claim any sort of scientific management and by extension the impact of these rules on raccoons as a game species is completely unknown, although not by any means insignificant.
Obviously other night hunting activities will also be impacted by these rules. Like raccoon hunting these other night hunting activities may have long term benefits for healthy fish and wildlife populations.
WAC 232-12-063 Hunting at night--Regulations--Penalties.
(1)It is unlawful to hunt small game animals or unclassified wildlife at night, unless all of the following requirements are met:
(a) Artificial lights used in the hunting activity are not attached to or projected from any motor vehicle.
REDUNDANT: The published rules already state it is unlawful to use artificial light (spotlighting)when hunting Big Game, as is hunting ANY game at any time other than legal hunting hours with the exception of Raccoons, Bobcats, Coyotes and unclassified animals. Any person suspected of hunting ANY game animal illegally should be investigated by an enforcement officer. (b) Shooting occurs at least fifty feet from a motor vehicle.
UNINFORMED: Most raccoon hound hunters spend a great deal of time training ‘rig dogs’ that detect or ‘strike’ upon the scent of their quarry from a moving vehicle. Once the rig dog has struck the dog(s) are unloaded to pursue the raccoon(s). Raccoon generally will tree at the first opportunity when pursued. This can easily be (or end up being) within 50 feet of a motor vehicle. (c) Firearms are restricted to .22 caliber rifles and handguns, and shotguns are restricted to no. 6 shot or smaller. Hunting with bow and arrow is allowed.
UNINFORMED: While the .22 long rifle and .22 magnum round is by far the most popular caliber used in raccoon hunting, like with any dog training a young hound-in-training will eventually encounter their quarry on the ground and in these instance ensuring the raccoon is stone dead is advisable if the young hound isn’t to be attacked and ultimately ruined by a wounded raccoon. I find an O/U .22/.410 slug rifle very effective while training hounds. Although I don’t think it particularly humane to use #6 shot or smaller on 30-40 pound animals, this rule is especially poorly thought out considering nontoxic shot (steel-shot) rules. Hunters I known have used 7 or 9mm handguns, .227 or.228 rifles and some have gone ultra-traditional using .35 caliber muzzleloaders for raccoons.
Again, any person suspected of hunting ANY game animal illegally should be investigated by an enforcement officer.
(d) During the months of September, October, or November hunting does not occur in areas closed to hunting for deer or elk with centerfire rifles.
REDUNDANT: The published rules already state it is unlawful to hunt bobcat and raccoon at night in during the months of September, October or November in any area open to centerfire deer or elk season. Any person suspected of hunting ANY game animal illegally should be investigated by an enforcement officer.(e) Hunting activity is further than five hundred yards from any structure or temporary habitation located on public land.
UNINFORMED: Safety buffers of 150 feet around buildings are common. 500 yards is nearly one third of a mile and would create a buffer around any structure or ‘temporary habitation’ over 162 acres in size. I doubt most public agencies, including WDFW, can even provide the public with detailed locations of all the structures on the land they manage. As a reality check: there are at least three structures on the 926 acres Scatter Creek Wildlife Area Unit, overlaps not withstanding that would be a total are of nearly 487 acres, over half of the Unit, that would be unavailable for hunting. (f) The hunting activity occurs within published open seasons.
REDUNDANT: For obvious reasons.
Respectfully,
Kung Fu Master
