Post by papabear on May 24, 2015 10:32:51 GMT -5
Dear DEC employee,
I am strongly opposed to the proposed regulation changes regarding fisher trapping and the amendment changes for body-gripping traps. After thoroughly reading the "proposed fisher plan" it is my belief that the biologist's involved, used outdated data, reference materials and information irrelevant to the Adirondack region. It is my contention, that at best, the "proposed fisher plan" is incomplete, lacks sound and updated scientific data, and bears no recommendations or input from the NYS Trappers Association's JTI committee.
The following statement should be struck from any mention in the syllabus "No person shall use traps of the body-gripping type that have teeth in the jaws", as such an implied device is not manufactured, marketed, or sold to trappers and therefore bears no factual relevance.
Season and regulation changes for the following listed WMU's 5C, 5F, 5G, 5H, 5J, 6F, and 6J should not be imposed without first obtaining updated, sound scientific research that is relevant to the region. Data applied from other regions and states would not be relevant because of the uniqueness of the Adirondacks, as no other state where reference data was used for comparison has a 6 million acre forest preserve within its borders.
I believe an ideal fisher season would run from Thanksgiving thru the end of December, when the fishers fur is prime and of most value, therefore ensuring optimal use and value of the resource. In the fur trade, prime fisher pelts are used in the manufacturing of luxury fur garments. Fisher harvested before the fur is fully prime has little value and is therefore excluded from use on luxury garments. The "fisher management plan" states that most fisher are harvested during the first two weeks of the season. If limiting the harvest and best use of the resourse are truely the main objectives, why then would DEC biologists recommend implementation of a shortened season during the first two weeks of the season when the potential for harvesting fisher is at its highest and value of the resource at its lowest? A harvest study conducted by NYSDEC biologist Nathan Roberts, conducted during an expanded fisher season, concluded a later season would not have any detrimental effects on the fisher population. I also believe fisher trapping data collected by DEC during a later season would prove to be more realistic and valuable than data that has been collected during a less than ideal season and when the fisher season runs concurrent with a deer gun season.
I believe that all factors have not been taken into consideration by the DEC biologist's before reaching their conclusions. I am not convinced the Adirondack fisher population has declined to the point the biologist's suggest, but has merely shifted to areas of more sustainable habitat. The vast expansivenss of the Adirondack state forest lands with its limited access and inaccessable remote areas would seem ideal for insuring that fisher populations thrive and remain healthy and also serve as a natural deterrent against overuse or detriment to the overall population. I have searched and have not been able to find any data that indicates that a thorough, initial population density study has been conducted for the Adirondack fisher population. Without a base line to start from and not knowing or having some idea what an actual 100% population is how would DEC biologist's be able to accurately determine a decline in the fisher population or even how many animals would constitute the intended <20% harvest goal? At best, strictly using harvest data as a determining factor would be unreliable and inaccurate as trapper effort varies from season to season due to various reasons such as fur prices, gas prices, family and work obligations and other factors. Aquisiton and restrictive classification, and reclassification of state forest lands have also caused limited access to trappers of areas inhabited by fisher. Trappers, especially experiened, older fisher trappers who have spent years establishing productive fisher lines and whos catches used to heavily contribute to the states overall harvest numbers are slowing down due to age, health or death, indicating a reduction in the annual harvest data. The forementioned factors would certainly contribute to the fisher study biologist's claims of a ten year fisher harvest decline, however bears no wieght towards proving a population decline. Also of concern is confusing and conflicting data that indicates fom previous target studies, based off a <20% harvest of population, concluded that a 60-70% ratio of female to male fisher harvest rate was normal to sustain and not be detrimental to the population, while the new fisher proposal suggests a 1 to 1 female to male harvest ratio is cause for concern. At the very least a dedicated and thorough, scientific and region relevant study, including all factors should be conducted to factually confirm an actual base fisher population density before implementing sanctions and warranting restrictive regulation and unnecessary season limitations.
At this time I respectfully request that DEC reconsider implementation of regulation and season changes until a more complete, region relevant, scientifically based "fisher" study is completed.
Regards
Robert D Shaut
37 Center Street
St. Johnsville, NY 13452
Please feel free to contact me at rdshaut@gmail.com or call 1-315-200-9328
My heros have always been Trappers
I am strongly opposed to the proposed regulation changes regarding fisher trapping and the amendment changes for body-gripping traps. After thoroughly reading the "proposed fisher plan" it is my belief that the biologist's involved, used outdated data, reference materials and information irrelevant to the Adirondack region. It is my contention, that at best, the "proposed fisher plan" is incomplete, lacks sound and updated scientific data, and bears no recommendations or input from the NYS Trappers Association's JTI committee.
The following statement should be struck from any mention in the syllabus "No person shall use traps of the body-gripping type that have teeth in the jaws", as such an implied device is not manufactured, marketed, or sold to trappers and therefore bears no factual relevance.
Season and regulation changes for the following listed WMU's 5C, 5F, 5G, 5H, 5J, 6F, and 6J should not be imposed without first obtaining updated, sound scientific research that is relevant to the region. Data applied from other regions and states would not be relevant because of the uniqueness of the Adirondacks, as no other state where reference data was used for comparison has a 6 million acre forest preserve within its borders.
I believe an ideal fisher season would run from Thanksgiving thru the end of December, when the fishers fur is prime and of most value, therefore ensuring optimal use and value of the resource. In the fur trade, prime fisher pelts are used in the manufacturing of luxury fur garments. Fisher harvested before the fur is fully prime has little value and is therefore excluded from use on luxury garments. The "fisher management plan" states that most fisher are harvested during the first two weeks of the season. If limiting the harvest and best use of the resourse are truely the main objectives, why then would DEC biologists recommend implementation of a shortened season during the first two weeks of the season when the potential for harvesting fisher is at its highest and value of the resource at its lowest? A harvest study conducted by NYSDEC biologist Nathan Roberts, conducted during an expanded fisher season, concluded a later season would not have any detrimental effects on the fisher population. I also believe fisher trapping data collected by DEC during a later season would prove to be more realistic and valuable than data that has been collected during a less than ideal season and when the fisher season runs concurrent with a deer gun season.
I believe that all factors have not been taken into consideration by the DEC biologist's before reaching their conclusions. I am not convinced the Adirondack fisher population has declined to the point the biologist's suggest, but has merely shifted to areas of more sustainable habitat. The vast expansivenss of the Adirondack state forest lands with its limited access and inaccessable remote areas would seem ideal for insuring that fisher populations thrive and remain healthy and also serve as a natural deterrent against overuse or detriment to the overall population. I have searched and have not been able to find any data that indicates that a thorough, initial population density study has been conducted for the Adirondack fisher population. Without a base line to start from and not knowing or having some idea what an actual 100% population is how would DEC biologist's be able to accurately determine a decline in the fisher population or even how many animals would constitute the intended <20% harvest goal? At best, strictly using harvest data as a determining factor would be unreliable and inaccurate as trapper effort varies from season to season due to various reasons such as fur prices, gas prices, family and work obligations and other factors. Aquisiton and restrictive classification, and reclassification of state forest lands have also caused limited access to trappers of areas inhabited by fisher. Trappers, especially experiened, older fisher trappers who have spent years establishing productive fisher lines and whos catches used to heavily contribute to the states overall harvest numbers are slowing down due to age, health or death, indicating a reduction in the annual harvest data. The forementioned factors would certainly contribute to the fisher study biologist's claims of a ten year fisher harvest decline, however bears no wieght towards proving a population decline. Also of concern is confusing and conflicting data that indicates fom previous target studies, based off a <20% harvest of population, concluded that a 60-70% ratio of female to male fisher harvest rate was normal to sustain and not be detrimental to the population, while the new fisher proposal suggests a 1 to 1 female to male harvest ratio is cause for concern. At the very least a dedicated and thorough, scientific and region relevant study, including all factors should be conducted to factually confirm an actual base fisher population density before implementing sanctions and warranting restrictive regulation and unnecessary season limitations.
At this time I respectfully request that DEC reconsider implementation of regulation and season changes until a more complete, region relevant, scientifically based "fisher" study is completed.
Regards
Robert D Shaut
37 Center Street
St. Johnsville, NY 13452
Please feel free to contact me at rdshaut@gmail.com or call 1-315-200-9328
My heros have always been Trappers