November 3, 2014
Wildlife and Heritage Service Department of Natural Resources P.O. Box 68
Wye Mills, MD 21679 firstname.lastname@example.org
RE: Comments on Proposed Action [14-280-P], 41:19 Md. R (September 19, 2014)
Dear Mr. Jayne:
The Maryland Horse Council (MHC) is a membership-based, umbrella trade association of the entire horse industry in Maryland. Our membership includes horse farms; horse related businesses; individual enthusiasts; and breed, interest and discipline associations. As such, we represent over 30,000 Marylanders who make their living with horses, or just own and love them.
MHC is pleased to submit the following comments regarding the above referenced regulation that is being proposed by the Maryland Department of Natural Resources (DNR).
The Maryland Horse Council objects to Proposed Action [14-280-P], which proposes to amend Regulation .01 under COMAR 08.03.03: Open Seasons, Bag Limits for Game Birds and Game Animals. This proposed regulation is unnecessary and counterproductive to DNR’s own analysis and stated goals, as well as contrary to public policy.
DNR has stated repeatedly in legislative hearings and elsewhere that it needs Sunday hunting as one of its most important and effective tools to help reduce burgeoning deer herd populations by increasing the harvest of deer by hunters. DNR’s own white-tailed deer harvest data however, demonstrate that deer harvest numbers have declined, instead of increased, since the introduction of Sunday hunting.
DNR acknowledges this in its “Wildlife and Heritage Service Stakeholders Bi- Annual Review of Regulations,” stating that the “Harvest in Region A has been stable, or declining since 2004.”
It is no surprise, therefore, that according to DNR’s “Final Selection of HUNTING AND TRAPPING REGULATION PROPOSALS for 2014-2015 and 2015-2016,” “Many hunters remain dissatisfied with the current deer population levels in Region A and think they should be higher.”
Thus, According to DNR’s own documents and its stated interest in stabilizing and even growing the deer population in the western counties, expanding deer hunting on Sundays in western Maryland makes no sense.
The proposal states that there is no economic impact or small business impact as a result of the increased days of hunting. The law requires that an agency must make an accurate and realistic analysis of the impact of a proposed regulation. DNR’s statement of “no impact” clearly violates this requirement, since it ignores the effect of the proposed regulation on such things as crop damage, contribution to the local economy by visiting hunters vs by other users of hunting lands, etc.
Furthermore, DNR’s own research demonstrates that the majority of Maryland residents oppose deer hunting on Sundays. According to DNR’s “Maryland White-tailed Deer Plan 2009-2018:” “Opposition exceeds support for deer hunting on Sundays in Maryland among Maryland residents. . . . Large landowners are like residents in that opposition exceeds support for hunting deer on Sundays.”
DNR’s continued promotion of expanded Sunday hunting on private lands when its own study found that landowners do not want it: (“large landowners are less likely to allow Sunday deer hunting on their property than allow it”) (supra), could be considered a failure of its regulatory mission and a violation of the public trust. Given that DNR manages recreational and wildlife lands for the enjoyment of and use by all Maryland citizens: hunters as well as hikers, bikers, bird watchers, mushroom hunters, etc., DNR should support, and not undermine, fair shared use of those resources one day a week during gunning season.
In conclusion, expanded Sunday hunting in the Western counties should be abandoned, since it demonstrably does not advance DNR’s stated goal of increasing (or at least not further reducing) the deer herd size in those counties. Moreover, DNR should not continue to promote expanded Sunday hunting throughout the state, since it clearly disadvantages the majority of other stakeholders whose interests DNR is statutorily tasked to serve and since it goes against the wishes of the majority of Marylanders.
The State should continue to work with various stakeholder groups, including but not limited to the Maryland Farm Bureau, to find the most effective and efficient means to reduce deer populations in areas where they have a quantifiably negative financial impact on agriculture (as well as similarly quantifiably negative impact in certain suburban areas). In working with various stakeholder groups, DNR should continue to pursue initiatives for deer herd reduction not considered in the 2009-2018 White- tailed Deer Plan, such as market hunting.
MHC appreciates the opportunity to comment on these proposed regulations, and urges DNR to adopt the recommendations set forth here.
Jane Seigler President