Trapping Reg Changes Published in the State Register

[johnrockwood]

This issue is NOT dead. Final decisions by the Department WILL be made based on responses to the Management Plan posted on the DEC website earlier this year AND the comments submitted now, by June 29, to the posting of the new regs in the State Register. If you have not written to comment on the regulation changes yet, as published in the State Register, do so now. This is the last chance to make changes. We can make a difference, but only if an overwhelming number of comments from trappers is received by the Department during this process. Unfortunately, lack of participation in this process, by trappers, is viewed by the Department and our law makers that we are in agreement with all they propose. If YOU do not forward your comments and concerns during this process then YOU are part of the problem and part of the reason why WE will lose important, necessary changes to this regulation proposal.

The JTI Committee has been engaged in discussions with the Department for over two years on these issues. We are at a stalemate with the Department and both sides realize this. I have some ideas that I hope will resolve the stalemate and bring about further negotiations and quite possibly some changes with the fisher management plan and the resulting regulations. The members of the JTI Committee have spent countless dedicated hours on this issue. Without YOUR support, we have wasted our time.

I will, within a few days, post our finalized response here. Hopefully many of you will agree and submit your own comments paralleling those of the JTI Committee. There is less than ten days left to comment, so time is of the essence.

NOTE: I've said this before, but want to repeat it again because some folks just don't seem to get it. There are MANY folks on this site and others reading every word we print. I know of several in the Department that monitor this site regularly. The change in trigger regs to include Duke #330s is because of statements made on this site and others, bragging about how to circumvent the previous regulation. It is the direct fault of trappers themselves that this reg is going to be changed. Talk on here of utilizing "other" traps to replace #330s to further circumvent the regulations could come back to haunt us further. Keep it up and we will lose more. You can count on it!

FURTHER MORE: No matter how much we become disgruntled and upset with the Department's direction and their biologist's decisions, these folks are NOT stupid, they are NOT ignorant, they are NOT all the other derogatory names they've been called on here and other sites. Resorting to the name calling and derogatory statements I've seen, and the Department personnel have seen here as well, do nothing more than weaken our positions and reduce our credibility. COMPROMISE IS GAINED THROUGH MUTUAL RESPECT. I would highly suggest the disrespectful rhetoric be stifled. Honest, open, forthright discussion can be accomplished without this undeserving disrespect to anyone.

Thank you for taking the time to read this. Now, I'll be spending the entire day, and probably part of tomorrow, putting all my facts, thoughts, ideas, comments together for submission. Hopefully, you will start doing the same if you have not done so already. Remember, you can make more than one submission of comments. All must be addressed by the Department after the close of the comment period. These new regs WILL be implemented, either this year or next. Whether or not there are any changes made depends on input from ALL of us.

John

[austinp]

Jun 20, 2015 6:26:30 GMT -5 johnrockwood said:

NOTE: I've said this before, but want to repeat it again because some folks just don't seem to get it. There are MANY folks on this site and others reading every word we print. I know of several in the Department that monitor this site regularly. The change in trigger regs to include Duke #330s is because of statements made on this site and others, bragging about how to circumvent the previous regulation. It is the direct fault of trappers themselves that this reg is going to be changed. Talk on here of utilizing "other" traps to replace #330s to further circumvent the regulations could come back to haunt us further. Keep it up and we will lose more. You can count on it!

John, you and I have been friends for a long time and we agree on just about everything related to trapping. But not this time. As one of the most vocal people on what I feel is a piss-poor judgment call on 10" size bodygrip traps here, I'll reiterate my stance once more.

The regulations for blackpowder rifles in deer season used to prohibit optical sights with magnification. Then later on, magnified scopes were permitted. That same year I put a 3x9x50mm Redfield on my .50 cal Encore and made it a 200+ yard single-shot rifle that was legal to use in a shotgun only half of this state. The term "muzzleloader" was rendered moot because all of us worked with existing regulations to use the most effective tools possible for harvest.

The trigger regulations for 10" sized bodygrip traps designed to spare most otter in turn do not dispatch most small or medium beaver. I don't mean a few left alive all night in the trap... I mean what I said: MOST small and beaver caught are held alive. Now maybe that's acceptable to all the powers that be who read these words here, perhaps they'd like to don chest waders for a day or three, join us on the line and see for themselves where small beaver caught by the hips in 10" traps with tensioned triggers pinned to the side have blown out a big circle in the mud while rubbing their fur worthless if not cut up and bleeding from the dog/trigger abrasion.

I personally set bodygrip traps for beaver so that my targeted catches, beaver, are humanely dispatched as intended. If the regulations permit a 9" trap for effective performance, so be it. If they permit an 8.5" trap, so be it. If they permit a 7" trap, well then that's what we have to work with. Myself and many other NYS licensed beaver trappers are far more concerned with humane dispatch of ALL our targeted catches than we are about the very occasional otter. The four incidental otter I personally know of that were caught last year ALL came from coilspring foothold traps off muskrat feedbeds while they were obviously in the process of hunting & killing muskrats. None that I know of in 9" bodygrip traps with triggers properly set in the middle of trap frame as designed for humane dispatch upon firing.

**

It's a good thing that various powers that be monitor this site. That should provide them firsthand knowledge of what we think and feel as the field force end of fur producers here. If what you suggest is true and our words influence their decisions like the manipulation of bodygrip trap triggers, shouldn't the very next action they take be directed by the tens of thousands of words recently posted here concerning fisher regs? If indeed the powers that be are influenced by us here, I would presume their viewpoint is open, unbiased and compliant to our desires equal to our complaints. We should therefore see and enjoy positive change per the fisher regs in the exact-same manner as negative change to the 10" trap restriction regs. All those licensed trappers who took the time and effort to share all those words of opinion in several fisher-related threads here should have equal influence for reg changes as the one or two threads concerning 10" bodygrip trap triggers.

Equal balance, equal treatment, equal actions taken for all. Would you agree to that assumption?

Lastly, the people who currently lead and direct the decisions process are highly educated and most likely highly intelligent. But the decisions being made lately are head scratching at best to those of us afield if not downright stupid in our collective opinions. Very smart people make very stupid decisions all the time, been doing that since the dawn of modern man. What we have been negotiating here for many years now is a collective compromise of what we feel is the most intelligent, sensible regulatory outcome. I for one am most interested to see exactly how much compromise will result in the final version of this process.

I have the utmost respect for people on all sides who listen with open minds and negotiate fairly. Hopefully that is what we have to work with here on all sides... not just ours from the field. We do buy licenses and gear every year which directly support the entire DEC program, and we do vote for elected positions too.

[johnrockwood]

You and I are NOT really in disagreement Austin. In fact, I agree with pretty much all you have said. The only place we may be a bit in disagreement is on what can/should be put on a public forum and what should not. Sometimes there is a very fine line. Sometimes it is better for ALL involved (on both sides) not to bring some things into the public limelight. I am sure that ALL (on both sides) are aware - without these open forum statements. I will reiterate that the sole reason for this new change to the regulation regarding the body grip trap size and further trigger restrictions is a direct result of previous discussions here on this forum. I'm absolutely sure that there has been no study done to prove that 1/2" makes a serious difference in this case I'll also bet, once implemented, this change makes absolutely no significant difference regarding how many incidental otters are taken nor will it make it any more humane for the purposely targeted beavers. It is a "feel good" regulation change, nothing more, nothing less. Trouble is, it causes more unnecessary compliance issues for trappers.

Some things are better left talked about around the campfire............ Enough said.

And we are still good friends Austin!

[austinp]

Of course we are still good friends... nothing I can think of would ever change that

My definition of the terms "compromise" and "negotiate" center around mutual benefit for both sides. From my viewpoint and perhaps shared by others, what exactly have NYS trappers gained lately? The only addition I can think of is a very limited bobcat season two full months before cat fur even begins to prime in a handful of WMA units. What else?

An example of what I consider good-faith negotiation would go something like this...

NYSTA/JTI: "where are we at on the legalization = implementation of cable restraints use on land?"

Legislation: "we cannot complete that process this time around, but is there something else we can accomplish in turn?"

NYSTA/JTI: "well, how about passing legislation to allow a 48-hour trap check for water sets in the southern zone? That should be simple enough... it already exists in the northern zone"

Legislation: "OK, we can do that. Maybe we can finalize something on cable restraints on land at another time, but for now let's move forward with this improvement for all NYS trappers"

**

Negotiations should result in forward progress for both sides... that's the very definition of "compromise"

[austinp]

Jun 20, 2015 8:11:02 GMT -5 johnrockwood said:

I'll also bet, once implemented, this change makes absolutely no significant difference regarding how many incidental otters are taken nor will it make it any more humane for the purposely targeted beavers. It is a "feel good" regulation change, nothing more, nothing less. Trouble is, it causes more unnecessary compliance issues for trappers.

my final though and post here on this particular topic...

Our elected and/or appointed leadership in the DEC and state legislation must keep in mind they are essentially servants to the people. We in turn must keep in mind we are subject to their final decisions while they hold said service positions.

"Feel good" decisions are designed to appease egos, to make one side of a process happy. My question is, where are all or even any of the "feel good" decisions to benefit NYS trappers? We are adult men too. We have egos and pride too. We come to the proverbial table in good faith with expectation of some benefit in our favor, too. I can't speak for others but I myself see none of that happening thru the past decade or so. Despite whatever lobbyist representation of all NYS trapper parties involved, where are the big or even small concessions made in our benefit?

I agrees that the latest tightening of 10" bodygrip trap regulation is a "feel good" act as you opined. Now how about a reciprocal "feel good" adjustment in favor of trappers? The use of repeating catch traps for muskrats, the legalization of 48-hour set checks in water are simple enough to implement this season, along with finalization of fisher regs.

Personally I'm all for the democratic, mutual-benefit negotiation process. In fact I wouldn't mind being part of it, if indeed we have a clear two-way street to travel.

[johnrockwood]

There is a possibility of compromise within this presently proposed regulation which is at the forefront of all discussions at this time. Going outside of the task at hand, at this point in time, is futile.

We did get a larger positive regulations package passed a couple years before the bobcat season of which you spoke (and of which I disapprove of the season dates on as well). That package included, but was not limited to, the allowed use of certain traps for muskrat, mink, coon, etc. on and/or within 15' of a beaver dam during a closed otter season which I view as a huge plus for trappers everywhere in NY.

There is already full support for cable restraints from the Department's Furbearer Management Team. Those negotiations have long since been concluded with the Department on a positive note. However, a law has to be changed first. Making changes in Legislative Law, with or without Department support, is very difficult. We have gained a lot of support in the legislature for cable restraints, but not enough yet. That continues to be worked on. I wish all trappers could spend a day or two in the LOB with Dave Miller to see how difficult the process of changing Law is.

Ditto for the 48 hour trap check in the SZ. It is fully supported by NYSTA and JTI, agreed upon and supported by the Furbearer Management Team. But again, a Law has to be changed. Why the SZ was ever regulated this way by Law and the NZ by regulation is beyond me. Way beyond, in fact, because I believe it happened long before I was born.


"Negotiations should result in forward progress for both sides... that's the very definition of "compromise"." EXACTLY, and that is why we are going in the direction we presently are hoping to take with these proposed changes to regulations. However, that won't get done if I don't get to work on this

[bobsheedy]

Thank you John and Austin for some thought provoking ideas. I hope this motivates everyone to contact the DEC and voice your opinion in a positive way. We also need to encourage other trappers to speak out also. I believe only about 1/6th of the licensed trappers in NYS are members of NYSTA.

[austinp]

Jun 20, 2015 9:44:54 GMT -5 johnrockwood said:

There is a possibility of compromise within this presently proposed regulation which is at the forefront of all discussions at this time. Going outside of the task at hand, at this point in time, is futile.

yes, one thing at a time. Beaver traps, otter seasons, etc are further negotiations for a later time

that said, if what we post in here has the power to affect regulations concerning beaver traps, it most certainly functions the same way to affect proposals for the all-important fisher trapping regulations. That in itself is the most encouraging news I've gleaned from this positive conversation

[papabear]

Comments will be accepted from May 13, 2015 through June 29, 2015.

Send comments to:
Michael Schiavone
NYSDEC
625 Broadway
Albany, NY 12233

or e-mail comments to: Proposed Rulemaking Part 6, Sections 6.2 and 6.3 - Fisher Trapping Seasons and Bag Limits and General Trapping Regulations for Furbearers

[johnrockwood]

Between visitors and other "things" going on here at home today, I've only so far been able to slightly revise the comments that were emailed to the Department on behalf of the JTI Committee and NYSTA on March 21, 2015. This document will be a part of our response to this comment period regarding the proposed regulation changes as posted in the State Register on May 12, 2015. I am going to copy/paste it here. It's a long read - several pages long. However, I want all to be aware of the position NYSTA took during the previous comment period via the DEC website. We are, as I have said, at a stalemate with the Department on this issue. I am working on a draft response now that will offer the first hand of compromise to break this stalemate. The rest of the JTI Committee will then proofread and offer suggestions regarding any language or position changes they feel appropriate. The final draft, once everyone agrees with the content, will be our official response to this proposed regulations change.

Here is the previous JTI/NYSTA response to the 30 day comment period on the Draft Fisher Management Plan for New York, with a few slight revisions from the original March 21, 2015 submission:

Official Comments Of The New York State Trappers Association Relative To The Draft Fisher Management Plan For New York State

March 21, 2015

To Whom It May Concern:

The New York State Trappers Association (NYSTA), on behalf of our membership representing the trappers of New York, respectfully wish to provide comments on the Draft Fisher Management Plan for New York.

First, we would like to acknowledge the extensive commitment of time, human, and financial resources that the NYSDEC Furbearer Management Team and staff have contributed in the development of this plan. The NYSTA duly recognizes the amount of work involved and would like to extend our appreciation to all involved. We would also like to personally thank Andy MacDuff for making us immediately aware of the comment period for this plan within a very few hours of its publication.

The NYSTA fully supports the principals of conservation of our natural resources and we are dedicated to the responsible consumptive use of our sustainable furbearer populations. We have reviewed and discussed the entire plan and offer the following comments for your consideration and response.

The NYSTA supports expanded harvest opportunities in new WMUs across Central and Southern New York. We agree that fisher populations have increased dramatically across portions of New York where previously there have been no open seasons. We are very pleased that the Department recognizes that a sustainable harvest can now be accomplished in those WMUs. We would hope that the Department continue it's studies in the hope that even more WMUs can be opened to fisher trapping in the not too distant future.

The NYSTA supports the setting of season dates for valuable, low population density furbearers such as marten, fisher, and bobcats that allow for harvesting when their fur is prime. Seasons for some of these species are necessarily and understandably short. Therefore, we believe harvest opportunities for these species should be provided when their fur is of greatest value; thus following the principals of true conservation.

The NYSTA supports continued scientific studies of furbearer species distribution, habitat requirements, and population dynamics that support preparation of defensible furbearer management decisions regarding harvest opportunities.

The NYSTA supports the utilization of up to date, sound scientific data, collected in New York, upon which to base future management decisions relative to the harvest of fisher in NY. Using old, outdated studies is unacceptable. Using data from other states/provinces presents too much room for error as there are many factors unique to NY, such as the multimillion acre limited access wilderness of the Adirondack Park, that present important variables that may not exist other places.

The NYSTA supports the use of season length and timing to manipulate the numbers of fisher harvested. These management methods have been the standard policy of the NYSDEC in regard to all furbearers, except American Pine Marten, in NY for decades. Fisher populations have expanded dynamically in many parts of New York State. We feel there is no need for utilizing bag limits for furbearers in a modern management plan. This is especially true when considering changes to a long standing season such as the standard 46 day fisher season we now all enjoy.

The NYSTA supports the implementation of new scientific studies to determine the true status of the Adirondack fisher population. If it is scientifically proven that the fisher population in that area is truly in decline then further studies should be undertaken to determine the real cause of that decline and how to reverse that decline with the least resulting impact to trappers. It will also be important for the Department biologists to determine what effect an increasing or decreasing fisher population in the Central Adirondacks would have in regard to the presently expanding American Pine Marten populations. Can we have both furbearers in significant numbers on the same landscape?

The NYSTA is in complete support of maintaining the length of the present fisher trapping season, without bag limits, throughout the Northern Zone and Catskills/SE New York. However, we feel that the season dates of October 25 through December 10 is inconsistent with proper conservation (wise use) principals as too many fisher are harvested in the early part of the season as evidenced in your data. To allow for better alignment with such conservation principals we would like to propose a 46 day season starting November 15 and ending December 31. Other states provide for a fisher harvest in the month of December so that they harvest the best quality fisher possible and we would like to see New York do the same. Making this change would provide the same amount of opportunity to trappers and provide for better use of the resource. Quality fisher pelts are considered a luxury fur, command premium prices, and are utilized in the making of fine fashion garments. Early caught “flat” skins are of significantly less value and are not desired by the high fashion trade. Additionally, the later season dates would allow for much more participation by young trappers by providing them opportunity to trap fisher during their Thanksgiving and Christmas breaks from school. The experimental season held in WMUs 6A, 6C, and 6H during the seasons of 2006/2007 and 2007/2008 provided for a fisher harvest in those WMUs from December 11 through January 10 with no adverse or detrimental effects to the population as stated in the documented report of that study, after it's conclusion, by Nathan Roberts.

The NYSTA supports concurrent closing dates, regardless of what the opening dates are, in all WMUs with an open trapping season for fisher. This would simplify things for trappers, law enforcement, and pelt sealers while at the same time allowing for the harvest of better quality skins from these animals.

The NYSTA adamantly opposes bag limits on any species of furbearer, other than American Pine Marten, in the state of New York. Documentation within this plan itself shows that the length and timing of the season are sufficient to manipulate the harvest numbers. Using those methods are far less cumbersome, much less open to abuse, and much easier to enforce than bag limits. Also, and maybe most importantly, using season length and season timing would render much cleaner data upon which to base future management decisions. All fisher trappers, that we have personally indulged in conversation, agreed that a temporarily closed season would be preferred over bag limits if some immediate form of protection were at some point deemed absolutely necessary.

The NYSTA adamantly opposes a shortened fisher and/or marten trapping season that would advocate that the days lost are in the latter part of the present season. Documentation within your plan shows that fisher trappers are most successful in the early part of the season. It would only stand to reason that if the Department wanted to reduce the harvest, while at the same time provide a sensible opportunity for trappers to harvest quality fisher, that a later starting date rather than an earlier closing date would be utilized.

The NYSTA most adamantly opposes the use of dated data from Cornell/DEC surveys that was collected before the publication date of this fisher management plan. We maintain that the answers given by trappers prior to the publication of this plan have no relevance as there was no prior knowledge of this proposed plan, nor its contents, when these questions were asked. Trappers answering those questions, especially SZ trappers, chose their answers based on relevance to the trapping of foxes, coyotes, and raccoons as fisher trapping was not even a consideration at that time.

The NYSTA opposes a shortened season in the Adirondacks, or anywhere else, prior to conducting proper studies and collecting relevant data upon which to base the necessity of any such actions. The admitted supposition by the Department biologists that the Adirondack fisher population is in perpetual decline is based purely on unfounded assumptions. There is no factual evidence nor current study data to support the Department's assumptions which are based solely on pelt sealing data. Other very real factors exist that could be influencing the declining harvest numbers in this region such as the overall aging demographic of trappers, fuel prices, pelt prices, loss of reasonable access, changes of land ownership, and the general overall economics of trapping a low density species.

The NYSTA opposes multiple different closing dates for fisher trapping seasons in various WMUs or WMU aggregates. The closing date for all WMUs where fisher trapping is allowed must remain concurrent for the sake of proper law enforcement, ease and cost of pelt sealing requirements, and accuracy of data collected. This plan proposes three different fisher seasons. All would open at the same time but close on three very separate dates. This would direct a 30 day commitment of availability by all Department personnel involved with pelt sealing. There will be a huge financial burden incurred by the Department associated with supplying necessary personnel to seal fisher pelts for 30 days instead of the normal 10 days. DEC law enforcement personnel, already limited in number and crippled by limited resources, will be deterred from dealing with issues arising along the borders of various WMUs affected by the differing season dates. The potential for extremely tainted data is highly elevated if bag limits and multiple closing dates are implemented. Discussions with “boots on the ground” ECOs from four different Regions of NY revealed that every one of them would prefer that fisher seasons in all WMUs close on the same date. Have those who developed this plan even bothered to consult those who will have to try to enforce its directives? In the very recent past we were told that any regulation changes we might wish to pursue as trappers had to be simple; both for trappers and ECOs to understand and for ECOs to enforce. This plan is certainly not of that nature.

Additionally, the NYSTA would like to add the following points to our comments:

The value of the opportunity to harvest a fisher cannot be quantified by the timing of the dates of the open season, but the opportunity to harvest a quality fisher IS determined by those dates.

The data from prior Cornell University trapper surveys is dated and the use of it in this plan is inappropriate. Trappers answering this survey were completely unaware of of any potential fisher trapping season in “expansion WMUs” when answering those survey questions. We also note that utilizing a survey with multiple choice answers can be designed to generate a particular response.

Using TPUE as data to estimate population densities is only accurate if weather, trapper age and experience, and economic factors relative to trappers and trapping remain constant for all seasons evaluated and compared.

Using terms such as “trophy” to describe any furbearer and “recreational” to describe the time honored traditional heritage of fur trapping is misleading to the less informed public and offensive to trappers. Terms such as these would leave the non trapping, uniformed public with the impression that fur trappers kill wildlife as trophies for fun. That is simply not true and NYSTA takes offense to the use of such terms in a furbearer management plan.

Use of study data that is dated or from sources outside of New York could easily be irrelevant, misleading, unreliable, and/or detrimental to the proper management of any of New York's valuable furbearer populations. Again we will mention the 6 million acre Adirondack Park with it's limited infrastructure and lack of reasonable access for most trappers.

Based on the information found in this plan, there is no data to prove a decline in the Adirondack fisher population. Therefore, a 52% reduction in the length of the season there is completely unjustified as there is absolutely no credible scientific evidence to support the Department's statement of a declining population.

Changing management directives for fisher, or any other furbearer in NY, based on seasonal market values of their pelts should be totally unacceptable by any wildlife professional.

The use of bag limits for fisher in NY will inevitably lead to skewed, unreliable data which will be useless for future decision making.

NYSTA maintains that loss of reasonable access, limited infrastructure, an aging demographic of trappers, and the economics of trapping a low density species are the true reasons for the inferred decline in fisher harvest numbers in the Adirondacks.

During the trapping seasons of 2006-2007 and 2007-2008 the NYSDEC conducted an experimental fisher trapping season in WMUs 6A, 6C, and 6H. This experimental season extended the allowable harvest dates well beyond the regular season dates. Trappers were allowed to continue harvesting fisher from December 11 through January 10 of each of those seasons in just those three designated WMUs. Furbearer Research Biologist Nathan Roberts, working in conjunction with the NYSDEC Furbearer Management Team, was involved in that experimental season study. We would like to cite some of the findings in Nathan Robert's report as a reminder of some of the results of that particular New York study. We cite from Nathan's conclusive report:

“We found that capture vulnerability of fisher did not change between the traditional portion of the season (25 October – 10 December) and the experimental season extension (11 December – 10 January). Trapping effort was significantly less during the extended portion of the season, both in terms of active trappers and mean individual effort. Thus, changes in the cumulative harvest appear to be driven by changes in harvest effort, rather than capture vulnerability. Increasing harvest opportunity in this system does not appear to proportionally increase cumulative harvest.”

“We found that capture vulnerability did not change within each season. The mean catch per unit effort was not significantly different during the extended portion of these seasons (11 December to 10 January).”

“Our results suggest that the extension of harvest opportunities until January 10th will not result in increased fisher capture vulnerability.”

“The number of active trappers, and the mean individual harvest effort expended by these trappers, was significantly less during the extended portion of both seasons.”

“Ultimately we found that trappers did take advantage of the increased harvest opportunity. This opportunity was met with decreased relative effort, both in terms of participating trappers and actual trapping effort per trapper, than during the traditional harvest season.”

“We learned that fisher do not appear to be more vulnerable to capture during the extended portions of the seasons than during the traditional portions. We also learned that harvest effort, both in terms of active trappers and mean individual effort, was significantly less during the extended portions of the New York seasons than during the traditional portions. Although we found no change in catch per unit effort between years, an indication that the relative abundance of fisher did not decline, these findings provide indications as to what management and regulatory actions may be most effective controlling harvests if this should be desired in the future. Within the time period examined (October 25 – January 10) capture vulnerability can be considered relatively constant.”

“Our findings suggest that fisher harvest opportunities in northern New York could be extended beyond the traditional closing date of 10 December, possibly as late as January 10.”

All of these statements of findings above, by Nathan Roberts, support the NYSTA position of a later fisher trapping season opening and closing date. The NYSTA does not understand why the NYSDEC is so reluctant to make such necessary changes to the fisher harvest season nor do we understand why the very important and pertinent data from this study/experimental season, conducted here in New York, were not deemed relevant for consideration in the development of this management plan.

Also, we would like to cite the following statement from the same Nathan Robert's report: “The loss of individuals through emigration out of the study area could lead to a negative bias in the index, suggesting a population-level decline that is nonexistent.” A study conducted in Ontario, Canada in 2005 states “The recent appearance of fishers in south-eastern Ontario has created some public interest because the agricultural environment is atypical for fishers and some residents perceive fishers to be a potential nuisance. Our results suggest that this population of fishers has recently expanded into Ontario from New York State. Three of the Ontario landscapes assigned highly to the same cluster as samples from the Adirondack State Park (Denis Carr, Trent University, 2005 published).” This suggests that some of the Adirondack fisher population could be on the move ----- out of the Adirondack Park in search of better habitat with more abundant food sources.

One other thing that NYSTA would suggest that the Department please take into consideration is the detrimental effect that portions of this plan would have upon families in the already depressed rural areas of this state. Families who depend, in varying degrees, on their trapping income.

The New York State Trappers Association would respectfully request that the NYSDEC withdraw this plan or make major changes before suggesting changes to any current regulations. The Joint Trapping Initiative Committee stands willing to work closely with the NYSDEC in developing a more acceptable plan.

Thank you for this opportunity to comment.

Respectfully submitted,

John Rockwood, President
New York State Trappers Association
JTI Committee Chairman, NYSTA
114 County Route 30A
Williamstown, NY 13493

Phone: [phone]
Email: [e-mail]


Content edited and revised on June 20, 2015

John Rockwood, Chairman
NYSTA JTI Committee

[johnrockwood]

Now............back to work on the new material for this comment period....................

[austinp]

John, I certainly speak for both myself and all other NYS trappers when we say a collective "thank you" to yourself, the JTI committee and all others who have dedicated so much time and effort for this cause. Great efforts by real good men like you all are the only reason why we still enjoy the trapping rights which we do have here in New York State.

If we don't all say "thank you" often enough, it's certainly not because we take y'all for granted

[papabear]

Dear Mr. Rockwood, BRAVO!!!!! MOST EXCELLENT!!!!!!STANDING "O"!!!!!!!! my friend. Regards

[johnrockwood]

Thank you - from all of us in the JTI Committee. I am humbled and honored to serve with my peers on this team. The amount of time and research that goes into some of these papers is incredible and it truly is a team effort to accomplish the things that we do. Collectively, the JTI Committee is one heck of a "think tank"!

I just now finished the first draft of our official comments on the proposed rule making in the State Register. Once it is proof read, changes implemented, and the final language agreed upon by the Committee, I will post it, in it's entirety, here....................... right after I hit the "send" button to the DEC. If approved, the above document will be part of this official response.

Please feel free to utilize any part of our documents to help develop or support your own comments - plagiarize them if you wish. Above all, SEND IN YOUR COMMENTS or we will be saddled with this regulation as presently written in the State Register. The NYSTA does not carry enough weight on its own, we need everyone's help on this. Please remember, if you don't submit your comments, you are viewed as agreeing with the Department's proposed rulings.

[mikeb]

yes john a huge thanks for all your time and efforts!!!!

[bmtrapper]

Thank you Mr Rockwood and the rest of the JTI committee for all the long days and hours you put in for us. Hats off.

[papabear]

Dear Friends, The deadline for sending in comments is quickly approaching. If you haven't already done so, I respectfully urge you to do so a.s.a.p.!

I would also like to offer some friendly advise. When crafting your response PLEASE stay in line with what NYSTA's position is on these issues. Offering ideas and suggestions outside the scope of what is contained in NYSTA's position (Mr. Rockwood's letter) may not be in the best interest of all trappers and could diminish the message of unity we need to send. It could also compromise any opportunities for JTI to negotiate, should an opportunity arise! Thank you and Regards

[whartonrattrapper]

Thank you Mr. Rockwood and all within NYSTA who have spent time on these comments. Hopefully all your efforts will inspire some thought from the powers to be.

[johnrockwood]

Please note folks: The comments posted above were those submitted in March on the DEC's Fisher Management Plan. We are still working on the comments to be submitted to the ensuing regulations changes as posted in the State Register with a deadline of June 29, 2015. We may be offering some compromise in the sincere hope of re-opening negotiations and obtaining some of the changes we feel are so important. It isn't easy to offer compromises on items we feel so strongly against. However, it is a consensus of opinion amongst the JTI Committee members that we will get NOTHING if we do not try this alternative approach.

[bobsheedy]

Thanks John.

[paintedpaw]

As a JTI Committee member I am in complete agreement with John Rockwood. Thank God for a leader like him. At this point in time I too would support a reasonable compromise with DEC. Although we have commented before, it is very important that we comment once again. Because a fisher plan is so important to Adirondack trappers and myself I have been very frustrated and out spoken. It is my sincere desire that we can reach some sort of agreement with DEC and that we can put the past behind us and that we can work mutually together on this as well as future plans.

One week left for comments.

[redboneemily]

Today is June 29 and I don't see your final letter. I didn't want to send my personal letter in until I'd seen yours, but the deadline is upon us...

[redboneemily]

The DEC's link doesn't work for me. Does anyone care to share Mr. Schiavone
s email address and/or the dedicated email for fisher management rulemaking?

[redboneemily]

For anyone else still trying to get a comment in, send it to
[e-mail]