October 20, 2014
Below is the letter that CWF sent to the Colorado Parks and Wildlife Commission on October 20.
October 20, 2014
Colorado Parks & Wildlife Commission
c/o Public Involvement Unit
Colorado Parks and Wildlife
Denver, CO 80216
We have had the opportunity to review the Citizen-proposed Issue Paper regarding “Hunting Exclusion Zone at Brainard Lake” and would like to provide input on this issue.
The Colorado Wildlife Federation (CWF) is the oldest continuously active wildlife conservation organization in Colorado, a 501(c) (3) nonprofit whose members consist of hunters, anglers, and other wildlife enthusiasts. CWF’s mission is to promote the conservation, sound management, and sustainable use and enjoyment of Colorado’s wildlife and habitat through education and advocacy.
While we certainly do not agree with all the characterizations and proposals in the Issue paper, there are some points that we can embrace. For example, we welcome the opportunity to work together to create a plan beneficial for all the mentioned interests, especially the health of the moose resource itself. We certainly agree with the stated objective: “Maintenance of a healthy population of moose close to a major metropolitan area, something extremely rare in the lower 48 states.”
In fact, our concern for a healthy moose population goes beyond the local area being discussed. Over the last few years there has been increasing national focus and discussion over severely declining moose populations. This has been covered in major newspapers and national television coverage. For example, CBS News reported that Minnesota has lost 50% of its moose population since 2010 (Feb. 18, 2014). The New York Times published an article entitled “Moose Die-Off Alarms Scientists (Oct. 14, 2013). In the article it is reported that moose populations in Montana, British Columbia, New Hampshire, and Minnesota are in sharp decline. In the Missoulian (Sept. 19, 2012) a headline states: “Montana, Wyoming investigate plummeting moose populations.” In all these reports there is no one cause of the declines cited. In fact, speculation includes climate change, brain worms, liver flukes, ticks, wolf predation, and heat stress. There certainly is no reason to believe that Colorado will remain free of these concerns in the near future.
Since several of the potential causes for the moose population declines are parasite related, it is no surprise that some biologists have proposed that the key to maintaining healthy populations is to keep the populations at lower levels, since such factors have a density–dependent aspect, i.e., the higher the population the greater the decline potential. For example the last sentences in the New York Times article quotes an official in New Hampshire: “The solution to the tick problem might be, paradoxically, more moose hunting. It’s up to the public, she said. We could kill more if we want healthy moose.”
Another density–dependent aspect of sound moose management relates to maintenance of habitat. At overly high population levels moose potentially can have a major negative impact upon the habitat they occupy. Specifically, they can over utilize willows – a key food element for them. This in turn can have a harmful population impact on other species that rely upon the willow habitat. It also can negatively impact moose populations via poor nutrition related to inadequate food levels and quality. This habitat concern may be especially important along our Front Range where willow habitat in this area does not appear to be as extensive as in many other key moose areas, i.e., compared to the wide willow bottoms in nearby areas such as North Park – where moose were reintroduced initially in Colorado. It should be noted that in the key moose viewing area at Brainard Lake there are several moose feeding regularly on one relatively small patch of willows. This all needs to be put into the context of the current statewide moose population estimate. Since the initial reintroduction of moose in 1978, the population has grown to an estimated 2300 in 2013 (the stated objective is 1700-2200).
The point of the preceding two paragraphs is that sound management is the critical foundation for the moose population. Without proper management to ensure the health of the moose population the entire discussion is moot. We cannot agree with the statement in the Issue paper that” if we continue to allow hunting at the lake, within just a few short years the big bull moose will be nonexistent…” In fact, one of the points of the above paragraphs is to illustrate that just the opposite is most likely true – managed harvest likely is a key element of maintaining the moose population. In fact, with only five licenses, including bull and cows, for three large management units, overharvest is not an issue.
Therefore, we think the challenge is how to maintain managed hunting in the area while reasonably reducing the potential for conflict with other interests. The proposed one- mile total hunting closure is overly restrictive for this objective. For example, the moose closure along Highway 14 that is mentioned in the Issue paper is only one quarter mile from the road and this includes key moose viewing areas with a moose viewing interpretive center. If Parks and Wildlife proposes a similar moose only hunting closure because of the specific special situation at Brainard Lake, we would certainly support it and would like to have input on where the closure line is drawn.
We suggest that a fundamental part of the solution should be education. Namely with such a small number of hunters involved it would be easy for Parks and Wildlife to directly contact the hunters before the season. The hunters could be made aware of the importance of the concerns related to the Brainard Lake area and the need to address these responsibly. We also see potential with the proposal to alert other users of the area when hunting is scheduled for the area and the boundaries of the closure. This could be done via signage and various media outlets. Additionally, the Forest Service volunteers that work at the site could help non-hunter users become aware of the hunting seasons.
Another educational opportunity would be to develop interpretive information at the site. This could include information on moose biology and related management challenges and the role of hunting in this regard. It also could address the proper ways of approaching moose for viewing and photography so as to not overly disturb the moose or have them present a danger to the viewers. It also would be an opportunity to address the history of moose in Colorado, including the role of the Colorado Parks and Wildlife agency and their license buyers.
We look forward to being involved in the discussions that ultimately lead to some key decisions on this issue. We are especially eager to see the Commission do the right things here. This is because what you do may set a precedent for other situations. Thus, the impacts are potentially broader than at this one site.
Thank you for the opportunity to comment on this very important wildlife management decision.
Kent Ingram, Chairman
Colorado Wildlife Federation