23 Mar 2009, 3:37pm
Homo sapiens Wildlife Agencies
by admin

Three Basic Problems, One 3-Part Solution

By George Dovel, editor and publisher, THE OUTDOORSMAN, Feb-Mar 2009

Problem #1 – Beneficiaries of Expanding Non-Hunting Programs Will Not Support Them Financially

For more than 100 years, North American hunters and fishermen have been footing the bill for wildlife conservation. But for the past 29 years the lobbying group for North American wildlife agencies has been trying to get taxpayers to fund separate management of species that are not normally harvested and used as food by hunters and fishermen.

The term “management” is hardly appropriate as the limited nongame funding that has been made available has been spent to catalog the species and help provide facilities for people to view them, while claiming they are managed. With game and non-game species increasing during the 1980s, wildlife agencies sought funding to hire nongame biologists “to help all citizens enjoy the species that were not sought by hunters and fishermen.”

Back then, everyone recognized that enhancing habitat for deer, ducks, pheasants and rainbow trout provided similar benefits to non-game species. Although Congress passed the “Nongame Act” in 1980, authorizing $5 million in total annual funding, it failed to appropriate any money to fund it.

Bird Watching Usurped Hunting, Fishing

In 1990 the (International) Association of Fish and Wildlife Agencies hired bird watcher Naomi Edelson as its “Biodiversity Director” to sell bird watching and other non-game activities to the American people and their elected officials. In the USFS 2005 technical publication, “Finding Our Wings: The Payoff of a Decade of Determination,” (originally presented to a group of bird watchers in 2002) she details how bird watchers have gotten their “agenda to become someone else’s agenda.”

Edelson explained that in 1990, “The States, through IAFWA, made nongame their biggest priority, as it has remained through the decade.” Since 1990 “Partners in Flight” (PIF), with help from high profile bird watchers (including former TNC Chairman - Goldman Sachs Chair - Treasury Secretary Henry Paulson), has substituted its agenda for the “sustained yield of wild game” agenda at every level of government.

Edelson continued, “Now Audubon is back in the bird business in a big way through their Important Bird Areas program (IBA), in part because of all of this bird conservation activity (by [I]AFWA and PIF). If there is one thing we should have learned from our duck friends in all of these years: be part of the movement that gets the money, then you can be part of spending of the money.”

By 1998 IAFWA’s “Teaming With Wildlife” (TWW) biodiversity funding group claimed 3,000 member organizations. Yet its proposal to have Congress fund nongame with a federal excise tax on recreation equipment failed to generate even lukewarm support from either manufacturers or the bird watchers it would have benefited.

TWW then joined forces with parks, historical preservation groups and coastal states’ interests in an intense lobbying campaign for Congress to pass the Conservation and Reinvestment Act (CARA). Finally the 2000 version, which passed the House but failed in the Senate, would have provided ~$3.1 billion in annual funding – with $350 million of that going to FWS for state nongame wildlife conservation, and up to $900 million appropriated to condemn and acquire private lands.

This massive “pork” bill, which would have used oil and natural gas royalties and monies from offshore oil exploration for funding, had numerous flaws. According to opponents, these included violation of 5th Amendment Property Rights and using money needed to maintain existing federal lands to instead condemn and acquire new lands from private citizens.

The highly watered-down version (substitute) that finally passed as “State Wildlife Grants” allowed the non-governmental wildlife lobby, including bird watchers and an anti-hunting advisor (i.e. Defenders of Wildlife), to determine the criteria for each state to receive a share of the money. Virtually the only federal government criteria is that sportsman dollars, as in P-R and D-J excise taxes, may not lawfully be used as any part of the mandatory 100% state match for the federal SWG funds for nongame and “at risk” species.

Non-Consumptive Wildlife Programs/Activities

Nongame programs and “non-consumptive wildlife related recreation” activities supervised by mid-level Idaho IDFG employees include:

1. Partners in Flight (PIF) and its assorted regional and international bird activities;

2. Watchable Wildlife (WW) refers to any activity in which people are enjoying –- but not consuming –- wildlife, but also includes photographing plants and landscapes, wildflower walks, plant or mushroom identification and watching fish (newsletter is “Windows to Wildlife”);

3. Important Bird Areas (IBA) including site identification, site selection and site monitoring of both state and global (international) IBA sites and also including the Idaho Bird Inventory Survey (IBIS) which hires a few temporary employees, providing housing and vehicles, for the annual bird survey (newsletter is Idaho IBA News);

4. Project WILD (PW) produced by the Council For Environmental Education with multiple workshops for teachers and children from pre-Kindergarten through 12th grade, including Wet, Wild, Learning Tree (LT) and Early Learners projects and classes, plus dozens of “Wild” workshops at Nature Centers and other locations (newsletter is Wildlife Express);

5. Idaho Master Naturalist Program;

6. Idaho Conservation Data Center (ICDC) (Idaho Natural Heritage Program) established by The Nature Conservancy, now part of its NatureServe network with more than 75 comparable Heritage programs in the United States, Canada, Latin America, and the Caribbean. Its Mission: “The ICDC collects, analyzes, maintains, and disseminates scientific information (to individuals, groups and government entities) necessary for the management and conservation of Idaho’s biological diversity.” With 28 field research projects in 2008 ranging from Bat Surveys in abandoned Idaho mines to the Giant Palouse Earthworm survey, ICDC provides information in 723 publications totaling a few thousand pages;

7. Nongame Program, although considered part of the Wildlife Bureau, with both Headquarters staff and nongame employees in the seven Regions and McCall Sub Region, the nongame employees are involved in multiple programs and multiple elaborate publications. These include a few birding and wildlife viewing guides that are sold, plus a larger number of free booklets with up to 45 pages of color photographs.

Obvious NonGame Funding by Sportsmen

In its Jan. 28, 2009 IDFG Commission and Idaho Legislative briefings of its Nongame Trust Account Program, IDFG itemized $220,000 of nongame expenses that were charged to sportsman license income because nongame expenditures exceeded nongame income by that amount. But, as mentioned in the Jan. 2009 Outdoorsman [here], published expenditures are only the tip of the iceberg.

In its IDFG FY 2008 Actual Expenditures Report sent to me on January 14, 2009 by the Department’s legal counsel, several hundred thousand additional dollars of nongame activities were paid for with sportsman excise tax dollars. This included Pittman-Robertson tax dollars that IDFG had said were used to make up 12% of nongame employees’ wages – along with a media explanation that these nongame employees spent time manning check stations or performing other duties involving game species “to offset the subsidy.”

My Jan. 30, 2009 request for the total amount of nongame employee wages and benefits resulted in IDFG immediately removing $427,534 in P-R/D-J funding of Nongame from the FY 2008 Report and adding exactly $427,534 in unidentified “federal grants.” Using P-R/D-J sportsman taxes to fund nongame programs deprives game species of the dollars that are intended to be used solely for game and sport fish restoration.

Another example of Idaho hunters and fishermen subsidizing nongame in FY 2008 is the use of $7.8 million in sportsman license fees and taxes to pay Administration Bureau expenses – yet the use of only one dollar from the Nongame Set-aside Account! If the $11.6 million total Administration expenditures had been properly prorated based on the amount of expenditures in each Bureau, state Nongame revenue sources would have paid $578,435 (see Jan. 2009 Outdoorsman [here]).

Wolf Management Depletes Game Species Funding

In 2008 Montana Fish Wildlife and Parks Wolf Management Specialist Kent Laudon explained that there was insufficient federal funding to pay for the expanded wolf radio-collaring and monitoring necessary to record new packs and expanding pack sizes. Although Idaho gets more federal money for wolf management than Montana, it is divided among IDFG, the Nez Perce Tribe and the Governor’s Office of Species Conservation.

The federal allocation is not sufficient to pay the massive cost of GPS-collaring and closely monitoring enough prey species to determine the statewide impact of wolves on elk or deer. Although IDFG reported spending about $1.1 million of sportsmen license fees for aerial flights in FY 2008 (see Feb. 5, 2009 report to the Legislative Joint Finance and Appropriations Committee [JFAC] page 4), most of it was apparently spent to monitor only a small sample of radio-collared elk and deer to see how many were killed by wolves (pages 19 and 29).

Using any sportsman fees for this purpose violates the Idaho Wolf Conservation and Management Plan approved by the Legislature (see Plan pages 23-24). In addition to the extreme financial loss from wolves killing elk (IDFG now estimates that loss is up to $24 million annually), using sportsmen funds for wolf management deprives game species of costly management tools needed to sustain wild game harvests.

Public Wildlife Management Areas and Boating, Camping or Other Outdoor Recreation Facilities

On page 19 of the aforementioned report to JFAC, IDFG reports it manages 32 Wildlife Management Areas (WMAs) and 325 boating and fishing access sites. It provided visitor use days for the Boise River WMA, where three out of four users do not purchase any kind of sport license!

Several years ago a visitor-use survey at Horsethief Reservoir, a popular trout fishing reservoir owned and operated by IDFG, revealed that only one out of five users purchased any type of IDFG license. Yet IDFG employees built and maintained roads, campsites, and potable water and restroom facilities to serve campers, canoeists and assorted other non-fishing visitors.

In FY 2008, in addition to paying their share of the $1,089,112 in D-J taxes that helped fund fishing access, Idaho fishing license purchasers were charged an additional $594,358 in matching funds while other boaters got a free ride. On WMAs, hunting license purchasers paid both the license fees and the entire D-J excise taxes while other users paid nothing.

To put that cost in perspective, until the IDFG Stockholder’s Report was discontinued, reported WMA maintenance averaged about $4.5 million each year. That information is no longer provided to the public but IDFG is still fighting an expensive losing battle with noxious weeds –- and hunters are still paying all of the costs for public use.

What Has Happened to IDFG Costs?

The following chart compares Actual IDFG Expenditures in FY 1980 with what the expenditures would have been in FY 2008 based on the U.S. Dollar Inflation Calculator, and with the Actual Expenditures in FY 2008:

IDFG Actual Budget Expenditures

FY 1980 …………… FY 2008 …………… FY 2008
Actual Total ….. Inflation Index ……… Actual Total

$10,335,300 …… $27,005,100 ……….. $75,773,368

Amount of
increase (%) … $16,669,800 (161%) … $65,438,068 (633%)

In other words, IDFG has increased its total spending by almost four times the rate of inflation during the past 28 years, while populations and harvest of almost every game species is presently declining. Yet in FY1980, the population and harvest of every game species in Idaho had been increasing for the preceding five years, with reduced season lengths and no antlerless elk or mule deer harvest allowed.

What Caused the Dramatic Increase in Expenditures?

The short answer to what caused the dramatic increase in expenditures is that none of the programs discussed above existed in FY 1980 when Director Greenley retired and Director Conley took over. In his dual role as IDFG Director and IAFWA President, Conley implemented every non-consumptive wildlife program dreamed up by the bird watchers and anti-hunters.

When Greenley retired, IDFG had added only 77 full time employees during the preceding 24 years from 1956-1980. But when Conley resigned 16 years later in FY 1996 he had added 240 more. In FY 2008, 12 years later, by using so-called “eight-month permanent benefited employees,” the full time equivalent number of benefited employees with job titles had increased to 800 in mid-winter – an additional increase of nearly 300*.

(*This does not include non-benefited part-time employees classified as “Temps” or “Temporary.”)

Sportsman Fees Subsidize Nongame Agendas

Like its counterparts in some other states, IDFG basically ignores its lawful mandate to provide continued supplies of wild animals, wild birds and fish for hunters, fishermen and trappers to harvest. Following the changing agendas dictated by FWS and AFWA, it now professes expertise of all of Idaho’s flora and fauna; environmental stewardship; forest, range, and aquatic sciences; energy development; global warming; and environmental education of our youngsters and their teachers. IDFG is also a self-proclaimed provider of assorted “wildlife-related” outdoor recreation and enjoyment for everyone.

Yet every one of these agendas is subsidized to some extent with fees and/or excise taxes paid by licensed hunters and fishermen because the beneficiaries won’t pay.

During the 1990s, the AFWA Teaming With Wildlife (TWW) Coalition, including nongame employees in state wildlife management agencies, lobbied Congress for CARA’s nongame funding from offshore oil fees. When SWG funding passed as a substitute in 2000, they continued to lobby for increased SWG funding.

Lieberman-Warner Climate Security Act

But by 2007 the state nongame action plans had been approved and many states could no longer come up with the new 100% required match to receive the Grants. With no source other than sportsman fees to make up the difference, they hitched their wagon to the Lieberman-Warner Climate Security Act (S. 2191).

That proposed Act included a promise to use receipts from a carbon offset scheme to “mitigate the negative impacts of any unavoidable global warming on low- and middle-income Americans and wildlife.” AFWA and its TWW Coalition included the following claims in their testimony urging Sen. Barbara Boxer’s Committee to provide mitigation funds to state wildlife agencies.

In response to a charge from Congress, the state fish and wildlife agencies and their many conservation partners have worked together to complete wildlife action plans for every state and territory…we’ve seen the tangible benefits of these plans in the communities where we live and work. Unfortunately, the landscape-level effects of climate change, including alteration of habitat, disruption to migratory patterns, changes in predator-prey interactions and the spread of invasive species are already placing greater stresses on fish and wildlife, eroding some of these recent gains.

The alleged fear of catastrophic carbon-caused global warming (which scientists tell us has changed to global cooling for the past nine years) is the justification used for the massive network of wildlife corridors created by nongame biologists in the state agencies. And the use of projected funds from carbon penalties and/or carbon trading by 2012 is their current “plan” for future funding.

Meanwhile, some states with inadequate nongame funding, including Idaho, continue to create excuses to charge sportsmen for non-game activities such as publication of Idaho’s Project Wild newsletter “Wildlife Express.”

Problem #2 – Nongame Education Causes Youngsters and Teachers to Question Ethics of Hunting

During a Feb. 3, 2009 meeting with five IDFG officials, I pointed out to Communications Bureau Chief Mike Keckler that the February 2009 issue of Wildlife Express sent the wrong message to potential young hunters and their teachers. That issue highlights bighorn sheep and says that Native Americans depended on them for food and killed very few but when pioneers, settlers and miners came to Idaho they killed them all in southern Idaho and almost wiped them out in central Idaho.

The article continues, “So why are there bighorn sheep in these places now? Fish and Game put them there.” Some of those statements are true and some are false. Yet the theme that comes through to the youngsters and their teachers is the Hollywood myth that the noble Red Man conserved his wild game while white hunters destroyed it.

I applaud Mr. Keckler for correcting this false image in the March issue of Wildlife Express. An article entitled, “Wildlife and Hunting,” explained that hunters were the conservationists who got market hunting banned and rebuilt our wildlife populations during the 20th century.

But that does not alter the disturbing image of non-Native American hunters that Project WILD has taught to the Nation’s teachers and youngsters. Project WILD (PW) is a joint project of the Council for Environmental Education (CEE) and the Western Association of Fish and Wildlife Agencies – WAFWA (see PW website).

Since 1980 when WAFWA first contracted with CEE to provide environmental education to school children in the 12 Western states (with the first workshops taking place in 1983) PW was accepted by an increasing number of wildlife agencies. In 1991 it finally included all 50 state agencies plus 11 national or international agencies.

Project WILD Teaches Hunting is Controversial

Its basic message to young fishermen is that if they promote clean air and water they will have abundant fish. But in its 537-page “Project Wild K-12 Curriculum and Activity Guide,” the chapter titled “The Hunter” presents hunting as a controversial subject and uses material from primarily non-hunting and anti-hunting sources to leave youngsters with mixed emotions about killing any animal.

It begins with students reading “The Twins,” a fictional account of a Depression-era youngster who passed up a shot at a doe with twin fawns on his first deer hunt and was later happy he had done so because they survived a severe winter when half of the deer herd died. The story ends abruptly the next year while he has one of the yearlings in his sights and is asking himself, “He made it through the winter, who am I to kill him now?”

As he takes the safety off he tells himself not to look at the deer’s head and says, “I just have to think of him as meat for the family,” and the story stops.

After reading the story, or having it read to them, the students are asked to write an ending to it. Then they are asked a series of questions about whether or not hunting should be allowed and, if so, under what conditions.

This is comparable to having the students watch “Bambi” at the movies and then asking the students those questions. But “The Hunter” lesson plan generates even more doubts about whether present-day hunting is ethical by publishing opinions from seven selected organizations – none of whose members are all hunters.

PW Provides Forum for Anti-Hunting Radicals

Two of the groups, the National Rifle Association and Ducks Unlimited, supported “the concept of sport hunting as a management tool” and as either “a healthy experience” or “a wise use of a renewable resource.” The other five groups have been involved in litigation to prevent predator control and/or wolf delisting and their opinions ranged from “we do not promote hunting” to “we strongly oppose the hunting of any living creature for fun, trophy or for sport because of the trauma, suffering and death to the animal that results.”

Several of the groups were adamantly opposed to wildlife managers providing a sustained yield of wild game as is required by some state laws and/or Constitutions. For example: “Defenders (of Wildlife) opposes the utilitarian notion that wildlife is most important for human consumption; opposes claims that wildlife, plants and animals are ‘renewable resources’ to be managed or harvested like crops; and opposes single species management plans where the primary goal is the production of more ‘game’ for hunters.”

With Project Wild providing access for the anti-hunting radicals to propagandize our children through their teachers, and to our state and federal wildlife managers as well, they have managed to instill the idea that controlling predators to restore healthy populations of both prey and predator is pandering to greedy hunters.

As growing numbers of teachers and youngsters are encouraged to touch and pet wild animals and birds by IDFG personnel in what amounts to classroom petting zoos, and then required to list reasons why hunting and other killing of wildlife should not be allowed, a new generation of anti-hunting activists has emerged. The new Project Wild program for high school students, teaching them how to become environmental activists with their state legislatures rather than wildlife conservationists, says it all.

The number of teachers, even in rural areas, who are telling our children that “killing our beautiful wild creatures is cruel and inhumane” is alarming. For the past three days an Oregon college student –- a product of ~16 years of Project Wild indoctrination –- has been exchanging emails with me in an effort to find a way to ban citizen input into the legislative process concerning wildlife management.

Problem #3 – Nongame Theory/Agenda Conflicts With Scientific Wildlife Management

For several decades extensive research by the top wildlife scientists in North America has demonstrated that the so-called “balance of nature” is a myth. Historically the wildlife manager’s job is, and always has been, to maintain a healthy balance by regulating populations of prey species when necessary so they do not exceed the normal forage carrying capacity, and regulating populations of predators when necessary to maintain healthy viable populations of both prey and predator.

The nongame biologists’ claim that restoring large predators and native vegetation to vast areas will conserve wildlife and enhance biodiversity is not supported by either recorded history or scientific research. The term “Conservation Science” was originated by a former “Earth First!” radical to lend legitimacy to a preservationist agenda that ignores both conservation and science.

The 25-Year Pygmy Rabbit Fiasco

In 1979 Washington Department of Fish and Wildlife (WDFW) biologists began trying to halt the decline in pygmy rabbit populations in the five counties in central Washington where they were known to exist. For the next 25 years WDWF, The Nature Conservancy and the federal government spent millions of dollars buying and restoring sagebrush habitat, destroying fences and other potential perches for avian predators, using assorted buried fencing and other devices in unsuccessful attempts to deter mammalian predators, and transplanting pygmy rabbits from Idaho in an effort to restore genetic diversity.

The rabbits were listed by ODFW as “Threatened” in 1990, “Endangered” in 1993, and placed on the federal list as an “Endangered Distinct Population Segment” in 2001. In 2004 no more rabbits could be found and the Washington rabbits were declared “extirpated” (destroyed).

This complete report, published on pages 11-12 of the Oct-Dec 2007 Outdoorsman, is one of several examples we have published of the total failure of the nongame management agenda to restore populations of declining species in the various states. Yet this same destructive philosophy now drives big game and upland bird management in Idaho and many other states.

The vague promise that trying to manipulate ecosystems by restoring native plants and protecting large carnivores will eventually achieve the desired result once ecosystem “equilibrium” is achieved implies that a natural balance will exist in time. When we ask why that did not happen after 15 years with Yellowstone elk or 25 years with pygmy rabbits in central Washington, we are told that it may take much longer to reach “equilibrium.”

A few biologists admit that “equilibrium” will not mean the high populations of game species we have enjoyed in the past. They point to the “Low Density Dynamic Equilibrium” that exists in Denali Park and a growing number of other locations in Alaska where wolves kill each other once they have depleted their available prey.

During a private February 3, 2009 meeting requested by IDFG Director Groen and Deputy Director Unsworth, Groen told me that 40 of the Idaho wolves found dead in 2008 were killed by other wolves. Then he loudly added, “It’s habitat,” and the meeting ended.

The 3-Part Solution

Part 1 – Redefine “Wildlife”

In 1976 when IDFG convinced the Idaho Legislature to change the definition of “Wildlife” (I.C. Sec. 36-202[g]) to “Any form of animal life living in a state of nature,” it created a requirement that every animal life form must be preserved, protected, perpetuated and managed.

Thousands of assorted invertebrates, parasites, microorganisms, etc. cannot be managed or even identified, and should be deleted by changing that definition to read:

(g) “Wildlife” means all wild mammals, wild birds and fish living in a state of nature.

Or, the definition could more properly be changed back to what it meant prior to 1976 as follows:

g) “Wildlife” means all wild mammals, wild birds and fish legally taken by licensed hunters, fishermen and trappers in Idaho and certain species classified as protected.

Part 2 – Restore IDFG and Fish and Game Commission Allegiance to Idaho, and Restore Adherence to the Idaho Code and Idaho Wildlife Policy

Neither the agency name, “Idaho Department of Fish and Game,” nor Idaho’s “Wildlife Policy” defined in Idaho Code Section 36-103 have been changed since adoption of that Policy in 1938 and there is nothing in Fish and Game Code Title 36 that requires or suggests the Idaho Fish and Game Commission may take its direction from any entity other than the Idaho Legislature.

Yet the 1990 change from “manage wildlife to provide continued supplies of wild game for hunters, fishermen and trappers to harvest” –- to its new number one priority of “nongame, biodiversity and non-consumptive wildlife recreation” –- was ordered, facilitated and accomplished by the (international) Association of Fish and Wildlife Agencies staff operating in Washington, D.C. Working with environmental activists in other organizations and in the U.S. Fish and Wildlife Service, this group infiltrated and hijacked western state fish and game agencies without Legislators and sportsmen even knowing anything had happened.

In virtually all of the fee increase promotion IDFG has published during the past five months, it emphasizes that its Mission is to carry out Idaho Wildlife Policy –- “Preserve, Protect, Perpetuate and Manage to Provide Continued Supplies for Hunting Fishing and Trapping”.

It fails to include the rest of 36-103 (”It shall be the authority, power and duty of the fish and game commission to administer and carry out the policy of the state in accordance with the provisions of the Idaho fish and game code. The commission is not authorized to change such policy but only to administer it.” (emphasis added)

Yet on Page 3 of the “Conservation Sciences” issue of Idaho Fish and Game News, Commissioner Randy Budge announced creation of the new Conservation Sciences division in the agency with a very different mission that is not found in the Fish and Game Code. He repeated its published mission statement:

To preserve, protect, perpetuate, and manage Idaho’s biological diversity for all generations.

I.C. Sec. 36-104 “General Powers and Duties of the Commission, subparagraph (d) Organization of Work” states:

The commission shall organize the department… into administrative units as may be necessary to efficiently administer said department.

But nowhere in the Code is the Commission authorized to change its mission from “providing wildlife” to “preserving biodiversity.”

The Idaho Conservation Data Center has maintained its autonomy and its “Biodiversity” Mission Statement as part of the International NatureServe Network for several years (see Page 4). Now the IDFG Commission has brazenly adopted its agenda and Mission Statement, both of which violate Idaho law.

To the average citizen this means the Idaho Legislature, which is solely responsible for the management of the natural resources owned by Idaho, must tell the IDFG Commission to stop violating the IDFG Code and Idaho Wildlife Policy. Yet Legislators claim the only “hammer” they have to force bureaucrats to stop breaking the law is to withhold funding.

The State’s chief law enforcement officer, the Attorney General, is required to represent (defend) the agencies –- even when that conflicts with citizen interests. And the major news media in most urban areas print only the self-serving news releases provided by well-funded agency communicators.

A few carefully cultivated legislators promote the bureaucratic requests for funding –- especially when that funding is not being paid for by the average taxpayer in their district. But despite these formidable obstacles, legislators with the integrity to represent the citizens must find the courage to draw the line and demand restoration of allegiance to the citizens and the law. If drastic budget cuts are the only hammer that works that tool must be used.

Part 3 – Either Eliminate, or Transfer to the Appropriate Agencies, All Functions That Do Not Restore Populations of Wild Mammals, Wild Birds, and Wild Fish For Hunting, Fishing and Trapping

Natural resource conservation is “the protection, planned management and wise use of natural resources.” All so-called wildlife conservation programs that teach or advocate environmental activism as a substitute for wildlife conservation must be eliminated.

Habitat is only one leg of the three-legged milk stool that is wildlife management. Regulation of predator-to-prey ratios and adjustment of seasons to regulate vulnerability to hunters –- especially when needed to mitigate extreme weather –- are both equally vital.

IDFG is not an air, land or water quality manager, a manager of habitat including grass, timber and riparian areas, a bureau of parks and outdoor recreation or an office of species conservation. Its sole mandate is found in its name and spelled out in Idaho Wildlife Policy.

From 1989-2008 recorded Idaho deer, elk, and small game harvests declined from record highs to 20-year record lows. The fate of this once valuable renewable public resource rests with the Legislature.

*****

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