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Public comment requested on MN timber-harvest goals.

posted Dec 23, 2017, 4:52 PM by Scott Slocum   [ updated Dec 23, 2017, 4:56 PM ]

The Minnesota Department of Natural Resources (MN DNR) has been asked to re-examine its timber-harvest goal for the 5 million acres of forests it manages in the state. Based on MN DNR and industry input, the goal is currently set at 800,000 cords per year. At this level of harvest, the forestry industry in Minnesota employs more than 64,000 people, and provides general revenue to the state and School Trust revenue to the schools (MN DNR 2017a). Some legislators would like to boost the industry by increasing the goal to 1,000,000 cords per year. 

As in any change of this kind, there would be both costs and benefits. Costs would include the loss of old-growth forest habitat that's home to many types of wildlife (MN DNR 2017b) and appreciated by many types of people, and the consequent losses in natural resources, outdoor-recreation opportunities, and tourism revenue. The Minnesota tourism industry employs nearly 260,000 people and provides $930 million in sales-tax revenue (Explore MN 2017). Benefits would include an increase in forestry jobs, and increased state revenue.

An analysis of the proposed increase concluded that it would conflict with the conservation of the "non-timber values" of Minnesota forests, including "natural resource economies, biodiversity, water quality, wildlife habitat, and forest health" (MN DNR 2017c, Draft Report, Scenario 2).

If you believe that the current timber-harvest goal of 800,000 cords per year is high enough; and that increasing it to 1,000,000 cords per year would have environmental, economic, and human costs that would outweigh the benefits; then please fill out the public-comment form and ask the MN DNR to leave the goal where it is, at 800,000 cords per year or less.


Explore Minnesota. 2017. "2017 Tourism and the Economy Fact Sheet." 

MN DNR. 2017a. "Sustainable Timber Harvest Analysis."

MN DNR. 2017b. "Importance of old-growth forests."

MN DNR. 2017c. "DNR Sustainable Timber Harvest Analysis."

MN DNR Sustainable Timber Harvest Analysis

Colorado wildlife officials "experiment" with predator-killing programs

posted Jun 7, 2017, 10:07 AM by Scott Slocum   [ updated Jun 7, 2017, 10:46 AM ]

Colorado's "experimental" predator-killing programs may be "experiments" but they're not scientific.

When the most recent of these articles appeared, it wasn't hard to see the pattern: wildlife officials in Colorado (federal, state, and local) are using science as an excuse to do what they've always done: kill the predators and assume that's the best solution to human/wildlife conflict (or whatever).

My comment in 2016:

The State Game & Fish agencies have figured out that they can keep doing this kind of thing forever as long as they call it "experimental." It allows them to deflect criticism that it's not supported by scientific evidence. 

It's not really "experimental," though, because it's only designed to gather information to support its foregone conclusion. This kind of "research" is funded by hunting-license revenue, and by taxes on firearms, ammunition, archery equipment, and fuel. In other words, its pre-project funding and post-project evaluation are controlled by like-minded officials. It's a "good ol' boy" version of "peer review."

Another example of this kind of "experiment": 
"Damage Control: Coyote Trapping - The Management Advantage #59."

And another: 
"Bold, aggressive coyotes targeted as wildlife managers seek peace with people: federal researchers working to eliminate unwanted traits within coyote populations, breeding."

My comment in 2017: 

The article claims that "Scientists... are trying to determine how much of... aggressiveness is rooted in genetics, versus learning..." but the only research mentioned is the observation of coyotes' responses to human objects and presence. That's not genetic research. 

Although the new Denver policy of killing only the most aggressive coyotes seems to be an improvement (vs. the old policy of killing all of the coyotes in the area), it wouldn't be proper to call it "research," or to refer to it as breeding or genetics.

The article doesn't even mention the likelihood that the most "aggressive" coyotes during breeding season are parents with young. Yes, if many of these animals were killed every year, reductions in human/wildlife conflicts could be expected--but how would that change the physical condition, accumulated learning, and behavior of the surviving population? Higher human/wildlife conflict rates? Better reductions could probably be achieved by restricting food sources, hazing, avoiding den areas, improving the supervision of pets, etc.--likely with improvements in the surviving population, including lower human/wildlife conflict rates. Either this article or the urban-wildlife authorities, or both, seem to be ignoring the non-lethal options, despite their potential benefits. 

Why aren't the wildlife authorities more open to non-lethal control? Because, in many ways, killing is easier. There are volunteers, public agencies, etc. eager to handle it in exchange for weapons funding and bragging rights. They're good at convincing policymakers that they're "doing what needs to be done," and that they've got all the information that really matters. On the other hand, there's a relative shortage of non-lethal experts with solid proposals for improved garbage management, monitoring and hazing, den identification and public warnings, and other education on how to keep domestic animals and wild animals separate. 

Why is there a shortage of the non-lethal experts? Because, traditionally, they haven't been so well funded? And/or because they're worn out, trying to broaden the scope of public policy debates. They don't have so many eager, unarmed volunteers and "wildlife biologists" to do the work; and they don't have so much freedom to work independently, "heroically," in such "manly" ways, free of the constraints of community involvement.

Another example of this kind of "experiment": 
"Colorado push to test 'predator control' by killing lions and bears faces barrage from CSU scientists, conservation groups."

Why do feel I'll be commenting again in another six months?

Headline from the Denver Post article "Bold, aggressive coyotes targeted as wildlife managers seek peace with people: federal researchers working to eliminate unwanted traits within coyote populations, breeding." 5/27/2017 by Bruce Finley. Photo by Joe Amon, The Denver Post.
Headline of the 5/27/2017 article by Bruce Finley. Photo by Joe Amon, The Denver Post.

MN bill advances to prohibit MN DNR restrictions on lead shot in hunting

posted Apr 10, 2017, 1:46 PM by Scott Slocum   [ updated Apr 10, 2017, 2:30 PM ]

3/30/2017 news from the MN state capitol on the bill to prohibit the MN DNR from further restricting the use of lead shot in hunting (HF 256 / SF 263):

MN Rep. Jamie Becker-Finn brought an amendment to the House floor to remove the prohibition from the omnibus environment & natural resources finance & policy bill, HF 888. Unfortunately, it failed 50-82 on a roll-call vote.

Video 1: Highlights from the debate of the amendment.

Video 2: Full debate of the amendment.

Snapshot #1 (arguments for the restrictions) from the 1/15/2016 MN DNR presentation on proposed lead shot restrictions on farmland WMAs.

Snapshot #2 (game bird ingestion of lead) from the 1/15/2016 MN DNR presentation on proposed lead shot restrictions on farmland WMAs.
Snapshots from the 1/15/2016 MN DNR presentation on proposed lead shot restrictions on farmland WMAs.

USDA Wildlife Services: setting requirements for a new EA on predator-damage management in Nevada

posted Nov 7, 2016, 9:17 AM by Scott Slocum   [ updated Nov 7, 2016, 12:07 PM ]


To: USDA, APHIS, Nevada Wildlife Services Program (NWSP).

Re: Setting requirements for the new EA on predator-damage management in Nevada

Docket ID: APHIS-2016-0077

Thank you for the opportunity to "get involved in the planning process for the development of the new Environmental Assessment (EA) on predator damage management in Nevada."

You've requested responses to the following three questions:

  1. "After reviewing the list of environmental issues we will examine in the EA, are there other issues that you believe should be evaluated in the EA?"

  2. "After reviewing the alternatives that may be included in the analysis, are there other approaches that would address the need to manage predator damage that you would like to see considered?"

  3. "Do you have other comments about the scope of analysis of the EA, or relevant information that you would like to contribute to the analysis?"

My responses to Question 1.

I've numbered my responses to question 1 to match the list of environmental-impact issues listed in the "invitation for publicscoping" for this Docket ID APHIS-2016-0077. The first part of the number is always 1, which identifies my comment as a response to your question 1. The second part of the number identifies the environmental-impact issue in your (un-numbered) list of eight in the "invitation for public scoping." The third part of the number, if any, identifies one of multiple comments on an environmental-impact issue under question 1. For example, the number 1.1.1 identifies my first comment on the first environmental-impact issue listed in the "invitation for public scoping" in regard to your question 1. The number 1.1.2 identifies my second comment on the same issue. The number 1.2 identifies my comment on the second issue, and so on.

1.1.1 A definition of the term "viability" is needed regarding this issue. The term in this context is too often reduced to an insignificant subset of its meaning, and measured only by numbers such as statewide or regional population size. A more meaningful definition of "viability" should reflect the imperatives of genetic diversity, seasonal and dispersing migration, social stability and inter-generational learning, the balance of ecological services provided and received, and freedom from unreasonable human interaction and interference. All of these are essential to the viability of a wildlife population.

1.1.2 A special emphasis in this issue has been put on "lethal removals." If that emphasis is to remain, then an additional issue should put a complimentary emphasis on "non-lethal controls."

1.2 All that's currently planned for the EA regarding this issue is to list some of the "indirect ecological effects from removing predators." That's a good start, but what's needed then is to evaluate the significance of those effects from the perspectives of the stakeholder groups (including the stakeholder group of "affected wildlife").

1.3.1 The syntax in which this issue is written seems to confuse the question. The overall question should be "What are the effects--on humans, non-target animals, wounded target animals, etc.--of the use of lead ammunition by NWSP?"

1.3.2 A subsequent question would be "What are the potential costs and benefits of switching to non-toxic ammunition in order to mitigate these effects of lead ammunition?"

1.3.3 A subsequent question should be asked for each toxin with secondary effects (i.e. for each toxin that can indirectly poison organisms that come in contact with the poisoned targets).

1.3.4 A subsequent question should be asked for each toxin with primary effects on non-target organisms (i.e. for each toxin that can directly poison organisms other than the intended targets).

1.4 A critical question is asked in this issue about the effects of the NWSP on threatened and endangered species. A subsequent question should be asked about the comparison of the effects of lethal vs. non-lethal control measures (on threatened and endangered species). Without such a comparison, there's the danger that the effects of lethal operations will continue to be written off as losses "incidental" to "necessary" lethal operations. That's an old error of false dichotomy that we need to get out of the habit of repeating: the choices are not 1) "all lethal" or 2) nothing; they're 1) "all lethal" with an unhealthy dose of denial as to the true alternatives, 2) "integrated pest management" as a scientific discipline and best practice, 3) non-lethal as much as possible, or 4) "nothing," the fool's argument in a fallacious construction of a strawman defense.

1.5 A critical question is asked in this issue about effects of the NWSP on wilderness areas. Subsequent questions should explore the effects on whole ecosystems, watersheds, etc. that include wilderness areas mixed with other areas on which agriculture and other uses predominate. For example (#1), the effects of NWSP in areas where agriculture and other uses might be considered by some stakeholders to be suboptimal uses, considering the optimal potential for wilderness restoration in those areas. For example (#2), the effects of providing government subsidies to agricultural producers in the form of lethal wildlife removal in areas where wildlife naturally migrate through patchworks of wilderness alternating with agriculture. For example (#3), the negative potential for artificially "propping up" certain agricultural operations in areas where the public interest would be better served by returning these areas to wilderness (or at least to uses more compatible with the nearby wilderness areas).

1.6 A critical question is asked in this issue about considerations in the NWSP for humaneness and ethics. As in the second issue, what's needed is an evaluation of the significance of these considerations from the perspectives of each stakeholder group (including the stakeholder group of "affected wildlife"), and an evaluation of what is lost by each stakeholder group when their considerations for humaneness and ethics are disregarded, minimized, or insufficiently respected. For example (#1), the high numbers that might be proposed by wildlife advocates--but not accepted by livestock producers--as "acceptable losses" of livestock. For example (#2), the loss of the stable social groups of predators (valued by wildlife advocates, scientists, ecotourists and guides, etc.) as a consequence of the removal of individuals or whole groups through lethal predator control.

1.7 A critical question is asked in this issue about the effects of the NWSP on what might be better phrased as "the public's recreational, scientific, spiritual, aesthetic, etc. relationships with wildlife." A subsequent question should be how those relationships have evolved, or to the contrary how they have been stifled, by past programs of the NWSP (and by the socio-political environment that they've fostered). In other words, not just "What are the effects of the NWSP on how these stakeholder groups are seeing things now?" but "How has the influence of the NWSP kept these stakeholder groups from seeing things more accurately and fully, from their own perspectives and from the perspectives of others?".

1.8 In issues of public safety, including the safety of pets, an unfortunate assumption is sometimes made, that certain stakeholder groups should be more, or solely, responsible for their own safety. For example, trapping advocates have blamed pet owners for bringing their dogs to areas where trapping is legal (even if trapping remains legal only as a consequence of a political negligence or refusal to adapt to changing recreational patterns in contemporary society). This assumption should be explicitly removed from the NWSP EA, so that it cannot be used to evaluate this issue.

My response to Question 2

Alternative 4 in the "invitation for public scoping," would call for lethal action by NWSP only after "reasonable application of non-lethal methods" had been shown to be ineffective. Unfortunately, that kind of wording leaves a number of loopholes through which exclusively-lethal programs may be adopted following the intended failure of token non-lethal methods. What's needed is an additional alternative (to be referred to here as Alternative 4.1) in which the term "reasonable application of non-lethal methods" is replaced by a term like "application of a complete program of non-lethal methods specified by <an independent and peer-reviewed advisory group representing all stakeholders> according to best-available science and reasonable fiscal restraint." Alternative 4.1 should limit lethal actions to those that have been authorized by the advisory group, and to those that are considered necessary to restore the situation to one that can be managed by the underlying non-lethal program. For example (#1), if a predator breaks through a barrier that meets the advisory-group specifications, and if that predator is threatening livestock behind that barrier, then the livestock producer or NWSP agent should be preauthorized to lethally remove that predator ASAP. For example (#2), if a predator is harassing livestock without breaking through the barrier, then the livestock producer should be preauthorized to non-lethally repel (i.e. "haze") that predator and end the harassment. If a specified hazing program fails to end the harassment, then the livestock producer or NWSP agent should be preauthorized to lethally remove that predator ASAP. For example (#3), if a program of non-lethal methods is incomplete, then lethal methods should not be allowed on endangered or threatened predator species, and should not be available as a government subsidy to remove predators of other species. The examples (#4 etc.) for herbivorous species, etc. would be similar.

My response to Question 3

The section "How is NWSP proposing to manage predator conflicts?" in the NWSP "invitation for public scoping" outlines an integrated approach that includes non-lethal cultural practices, non-lethal habitat and behavior modification, and lethal direct control. But in reality, the approach of the NWSP is not truly "integrated." The best that could be said is that it's "mixed." To be truly integrated, it would need to be balanced in a design in which an effective complement of non-lethal practices were encouraged and used scientifically, verifiably, and consistently.

In other words, in the realm of NWSP, non-lethal practices are only used at the option of livestock producers who are willing to pay for them. What's needed is for effective programs of non-lethal methods to be fully recognized, encouraged, and subsidized at no extra expense to livestock producers, compared to the expense of lethal methods.

NWSP needs to use the term "integrated" in its full meaning, as generally accepted by experts and best-practitioners in the discipline of Integrated Pest Management.


Thank you, again, for the opportunity to comment, and for considering my comments. If I can clarify or improve them, please don't hesitate to ask. I'll be happy to do so.

Screenshot of the USDA/APHIS &quot;Invitation for Public Involvement, Scoping: Predator Damage Management in Nevada.&quot; Docket ID: APHIS-2016-0077.

Screenshot of the USDA/APHIS "Invitation for Public Involvement, Scoping: Predator Damage Management in Nevada." Docket ID: APHIS-2016-0077.

Great talk by canid ecologist Chris Schadler about coyotes, wolves, sheep, people, etc.

posted Mar 30, 2016, 11:20 AM by Scott Slocum   [ updated Mar 30, 2016, 11:38 AM ]

Wild canid ecologist Chris Schadler discusses the fascinating ecology and surprising behavior of the eastern coyote, and how we can coexist.

This is not a "sound byte" or thirty-second PSA; it's a pleasantly long and slow talk by a very well-informed scientist and nature lover, interspersed with questions and answers with a curious bunch of Vermont environmental "hippies," bits of humor and affectionate profiles (sexually oriented!) of wildlife living on the human-altered landscape. 

So set aside an hour and a half for the whole talk, or skip through and enjoy parts of it. There are no prerequisites; you can go to any point and enjoy!

Screenshot from the presentation.

Comment on USFWS proposal to delist Greater Yellowstone Area Grizzly Bears

posted Mar 22, 2016, 11:40 AM by Scott Slocum   [ updated Mar 22, 2016, 11:50 AM ]

Please Comment Online

You may submit written comments to the USFWS through 5/10/2016 online as follows: Go to the Federal eRulemaking Portal: http://www.regulations.gov. In the Search box, enter "Docket No. FWS-R6-ES-2016-0042" and search. On the search-results page, you should see the document "Endangered and Threatened Wildlife and Plants: Removing the Greater Yellowstone Ecosystem Population of Grizzly Bears from the Federal List of Endangered and Threatened Wildlife." If not, please verify that the Proposed Rule" check-box is checked in the Search panel on the left. You may submit your comment on the proposal by clicking on the blue "Comment Now!" box to the right of the document. 

To: U.S. Fish & Wildlife Service (USFWS)

Re: Proposed delisting of the Greater Yellowstone Ecosystem Population of Grizzly Bears. (Docket No. FWS-R6-ES-2016-0042)

I oppose the delisting of Grizzly Bears in the Greater Yellowstone Ecosystem (GYE). Their population has recovered to what appears to be a stable point at which it's able to sustain itself. Many would like to see it expand further, for reasons of population health and viability. 

With food supplies limited and natural migration and reproductive imperatives and behaviors what they have always been (and hopefully what they always will be), they need room to roam outside the borders of Yellowstone National Park. And we need to continue to conserve their habitats in that broad range.

Grizzlies and other large predators are essential to their ecosystems. This is how nature was created, and this is how it should be conserved and restored under our stewardship.

Recreational hunting in the GYE is not needed as an additional source of mortality to control their numbers. Furthermore, recreational hunting is not well suited to use as a wildlife-management technique targeted at the attainment of ecosystem-based management objectives; to the contrary, it tends to be directed at the taking of "trophy" animals rather than problem animals, or the young, old or otherwise weakened individuals that tend to suffer the highest mortalities in nature.

Hikers, campers, and visitors to the off-trail areas of GYE are generally well aware of the need to be alert and avoid encounters with wildlife. Those that are not need to improve; we should not enable their ignorance or stubbornness by imposing it on their natural surroundings.

Although there is something to be said for providing recreational opportunities to the sporting community, there is more to be said for moving more toward the ecosystem-based management that a growing number of U.S. environmentalists, students, tourists, etc. are learning to understand, appreciate, and enjoy. 

Human society's way into the future will be less about making the outdoors our drop-off points for human-centered recreational activities; and more about supporting and enjoying our wild ecosystems for what they are in their own right. As a strong step forward into that future, let us continue our protections of GYE Grizzlies under the U.S. Endangered Species Act.

#DontDelistGrizzlies Please be their voice! Their lives, their future, depend on you!
Poster from Save Bears Now: #DontDelistGrizzlies.

Night-Vision Scopes, Poachers, and Shooting in the Dark

posted Mar 20, 2016, 9:52 AM by Scott Slocum   [ updated Jan 17, 2019, 9:54 AM ]

This article is about a series of bills that were introduced from the 2016 session of the Minnesota Legislature to the 2018 session to allow (variously, according to each bill) the use of night-vision sights, thermal-imaging sights, and/or artificial lighting in the hunting of foxes and coyotes, or all predators, or all unprotected animals.

Proponents skipped over the issues of public safety and law enforcement, and testified in favor of the bills on the basis of hunter convenience and the desire of predator hunters to kill more predators.

Opponents pointed out the serious problems that the bills would introduce for public safety and law enforcement. 

Problems for public safety: the proposed technologies for identifying a target at night don't identify what lies beyond the target. Of course, a basic rule of weapons safety is to "know your target and what lies beyond it." This is especially important for high-powered rifles, which can be deadly at long distances.

Problems for law enforcement: the proposed bills would make things easier for poachers, and harder for law enforcement.

In order to understand what the proposed bills would change, here's a quick summary of current Minnesota Statues regulating night hunting (see the Statutes for full details):
  • Section 97B.075 does not restrict the night-time hunting of unprotected wild animals, including coyotes.
  • Section 97B.075 restricts the night-time hunting of protected wild animals to the following:
    • Hunting raccoon or fox.
    • Hunting big game or wolf from 1/2-hour before sunrise until 1/2-hour after sunset.
    • Hunting waterfowl from 1/2-hour before sunrise until sunset.
  • Section 97B.621 sets the following requirements for the night-time hunting of raccoons:
    • The hunter must be on foot.
    • Artificial lighting is allowed only if hunting with dogs.
    • Rifle or handgun cartridges may only be rimfire .17 or .22 caliber.
    • Shotgun shells may not fire shot larger than No. 4.
  • Section 97B.086 prohibits the use of night-vision or thermal-imaging equipment in hunting.
  • Section 97B.081 (among other prohibitions) prohibits the use of artificial lighting in hunting, with the following exceptions:
    • An unarmed person may use artificial lighting from two hours after sunset until sunrise to locate a wild animal.
    • An unarmed person, on foot, may use artificial lighting to retrieve a wounded or dead big-game animal.
    • Artificial lighting may be used to hunt raccoon according to Section 97B.621.
    • Artificial lighting may be used to tend traps according to Section 97B.931.
    • Hand-held artificial lighting may be used to hunt fox or coyote from January 1 to March 15 by a hunter on foot, using a shotgun and a calling device, not in a road right-of-way, and not within 200 feet of a motor vehicle.

In order to understand what the proposed bills would change for coyote hunters, here's how current Minnesota Statues "boil down" for them:
  • Night-time coyote hunting with a rifle under natural light is allowed because it's not prohibited by Section 97B.075 (or any other Section). It's generally assumed, but not required, that this is the equivalent of "hunting under a full moon."
  • Night-time coyote hunting with a shotgun and hand-held artificial light is allowed according to Section 97B.081.

Please scroll down to see the 2016-2018 updates in chronological order.

Letter to Minnesota Legislators: 3/20/2016.

rep.tom.hackbarth@house.mn, rep.dale.lueck@house.mn, rep.tom.anzelc@house.mn, rep.mark.anderson@house.mn, rep.jack.considine@house.mn, rep.tony.cornish@house.mn, rep.rob.ecklund@house.mn, rep.jerry.hertaus@house.mn, rep.brian.johnson@house.mn, rep.deb.kiel@house.mn, rep.eric.lucero@house.mn, rep.denny.mcnamara@house.mn, rep.carly.melin@house.mn, rep.jason.metsa@house.mn, rep.barb.yarusso@house.mn

Cc: Committee staff and bill authors.

Stephanie.Lamphere@house.mn, Claire.Leiter@house.mn, Janelle.Taylor@house.mn, Christopher.Kleman@house.mn, rep.steve.drazkowski@house.mn, rep.chris.swedzinski@house.mn, rep.josh.heintzeman@house.mn

Re: Night-Vision Scopes and Wildlife Vigilantes (Opposed to HF 2819 & HF 3160)

Get ready for some wild-west, Minnesota coyote-cowboy, vigilante, American-sharpshooter, marketing hype! "It's comin' yer way!"

Proposals to allow hunting with military-style night-vision optics:

These bills are on a fast track at the MN House of Representatives. They were introduced on 3/10/2016 and 3/16/2016, with hearings promptly scheduled for 3/22/2016.

Why? Because we're afraid of predators? Because we hate those dirty prairie dogs?

To put this in perspective: if the DNR were to propose a coyote-extermination program, we would ask them for their references, and they wouldn't be able to produce them. The proposal would fizzle out. Ill-advised. No scientific merit.

But cloak this "killing for the sake of killing" in a slick marketing package, and its base motivations might start to look more like the manly weapon toting that's portrayed in the sales videos: rescues and security.

Minnesota legislators, we need you to see through the hype and examine the issues. Minnesota does not have, and should not have, a coyote-extermination program. When the proponents of these new technologies say they need them to kill more coyotes, ask them for their references. There won't be any. Killing more coyotes isn't the answer to any problem in wildlife management, livestock-depredation control, or public safety. The proposal is ill-advised. No scientific merit. Please oppose HF 2819 and HF 3160. 


This is what the view through a thermal-imaging scope looks like: screenshot from a promotional video for the "Armasight Zeus Thermal Imaging Weapon Sights for the Sporting, Law Enforcement and Military markets."


This is what the view through a thermal-imaging scope looks like: screenshot from a promotional video for the "ATN ThOR640 Thermal Imaging Weapon Sight - 5x, 640x480, 30Hz"

Update: 3/22/2016.

The MN House Committee on Mining & Outdoor Recreation Policy heard two bills (in order, HF 3160 and HF 2819) to allow the use of thermal-imaging weapons sights in recreational hunting at its 3/22/2016 meeting. Committee Chair Rep. Tom Hackbarth, on a unanimous voice vote, passed the first bill (HF 3160) on to the House floor; and without a vote laid-over the second bill (HF 2819) for possible inclusion in the Game & Fish Bill HF 2844.

Background: MN Statutes Section 97B.086 prohibits an individual or group from possessing night-vision or thermal-imaging equipment while taking wild animals, or while in the possession of an uncased-and-loaded hunting weapon. It makes an exception for law-enforcement and military personnel. Thermal-imaging equipment was added to it in the 2014 Game & Fish Bill.

Testifying against both bills, Col. Rodmen Smith, MN DNR Director of Enforcement, cited the same concerns for enforcement (poaching) and firearms safety that led to the 2014 prohibition. First, that enforcement is difficult when thermal-imaging devices are in use: poachers use them to conceal their activities at night. Second, that, depending on the level of technology, the image of the target is not necessarily sufficient for positive identification. Third, that the background image is not sufficient to show what lies beyond the target. 

Testifying in support of the first bill (HF 3160), Bryan Peterson, a representative of Federal Ammunition, Anoka, MN, described the bill as a "technical fix" intended to allow staff to carry out research & development of the company's military and law-enforcement products. Somewhat to the contrary, he pointed out that Federal Ammunition's subsidiary (under the "Vista Outdoors" umbrella) Bushnell Night Optics is now marketing the devices to consumers. He said they're becoming more and more of an "everyday-type technology." He showed an iPhone case outfitted with a thermal-imaging device.

Col. Smith pointed out that the bill, as written, was not just a technical fix for research & development, but would open up the devices to general recreational hunting. He offered to work with the author and Federal Ammunition to make the necessary adjustments to allow for research & development.

The first bill was forwarded, without amendment, to the House floor. This was done in a hurry, in a short session, not fully respecting the objections of the MN DNR or fulfilling the committee's responsibility to approve of the bills that it sends to the House floor. Presumably, but not necessarily, the bill will be amended on the floor by the author, in agreement with the MN DNR.

Testifying in support of the second bill (HF 2819), farmer and coyote hunter Charles DeWitz described how for ten years, up until the 2014 prohibition, he had used a thermal-imaging sight for coyote hunting. He runs a cow-calf operation, and he's had a couple of problems with coyotes. He didn't say so, but apparently that's another reason he hunts them. He doesn't want to set traps around the farm, and he doesn't want to disturb the neighbors by hunting with a light at night. He said the target image you see through a thermal-imaging sight is better and safer than the eyes you see in a light, or the dark shape you see in the moonlight.

The second bill was laid-over, without amendment, for possible inclusion in the MN House Game & Fish Bill (HF 2844). Rep. Hackbarth did not give any indication that he would amend the second bill in the manner that he had directed for the first bill (the MN DNR opposed both bills on the same grounds, and the second bill on additional grounds). The Game & Fish Bill is an omnibus bill, on which Members may (if they're strongly motivated) offer amendments, but may not otherwise vote on individual sections of the bill. It can provide a kind of "safe haven" for controversial bills like this, that most Members are not strongly motivated to oppose.

In summary: these two bills, contrary to the advice of law-enforcement and contrary to existing Statute, were launched on separate tracks, apparently in the hope that at least one of them would avoid or survive examination and opposition.

3/22/2016: please write or call your Representative

Your Member of the MN House of Representatives needs to know where you stand.

Please ask your MN Representative to follow the MN DNR's advice on firearms safety and law enforcement regarding night-vision and thermal-imaging equipment:
  • Research & Development--no problem.
  • Law-enforcement & Military use--no problem.
  • Hunting--no night-vision or thermal-imaging equipment.
If changes to the MN Hunting Regulations are proposed...
  • In the thermal-imaging equipment bill HF 3160.
  • Or in the Game & Fish Bill HF 2844.
Please vote no!

In the News: 3/30/2016.

Good article:

Orrick, Dave. 2016. “Would Night Vision Make Coyote Hunting Safer? Divisions Arise.” Twin Cities, March 29. 

Only one sentence correct:

"The DNR says the bill would make hunting more dangerous at night, and would lead to more poaching."

Kolls, Jay. 2016. “Night Goggle Hunting of Coyotes in Minnesota Proposed.” KSTP.com. March 30. 

Update: 4/1/2016.

Good news: the called-for fix (for equipment testing only) was made to the MN House Game & Fish Bill HF 2844 on 4/1/2016

The credit for this change probably goes to the MN DNR Division of Enforcement.

With the 4/1/2016 fix, the MN House Game & Fish Bill would allow R&D personnel to test night-vision or thermal-imaging equipment, but would not open up the equipment for use in recreational hunting (as introduced by Reps. Anderson and Drazkowski on 3/22/2016).

Update 5/22/2016

For some reason--confusion, drama, nutty politics, or something--the 2016 Game & Fish Bill HF 2844 / SF 2758 wasn't passed. Thus the use of night-vision scopes and thermal-imaging devices in Minnesota remains in the realm of military weaponry.

Part of the story appears in the article "Pared-down game and fish bill, as amended, moves on." By Jonathan Moore, Session Daily 5/22/2016.

In short, several sections of the Game & Fish Bill were moved around to other bills (e.g. HF 2845 / SF 2759), and although some of those might have passed, this one didn't.

Update 2/13/2017.

Bad news: the original proposal--to allow anyone (for any ill-advised purpose) to use this military technology to kill coyotes--has been reintroduced in the bills HF 1163 / SF 1235.

Why use military technology? Because it's "cool." Why kill coyotes? Because they don't like them, they don't understand their role in nature (and they don't have to listen to anybody explain it to them), because coyotes make "exciting" moving targets, and because coyotes aren't protected as "game" animals. Why aren't coyotes protected as game animals? See the answer to "why kill coyotes" above.

They've disregarded the testimony, discussions, and resolutions of last year, and are just "taking another run at it." Not a lot of deep thinking involved.

House authors: Drazkowski ; Hertaus ; Green ; Whelan

Senate authors: Lang ; Ingebrigtsen ; Schoen ; Utke ; Koran

Update: 3/27/2018

The movement for "shooting in the dark" moved into the visual spectrum in 2018.

On 3/27/2018, the MN House Environment & Natural Resources Policy & Finance Committee met on 3/27/2018 to hear HF 2858, a bill that would allow the hunting of coyotes and foxes at night with rifles and artificial lights.

Supporters of the bill explained that predator hunters want to increase game-bird production by killing more coyotes. They didn't mention the other goals of predator hunters, including operating like amateur snipers (Outdoor Life 2011); competing for cash and prizes (Slocum 2016); and/or, for whatever reasons, enjoying the experience of killing coyotes.

Picture a night-time countryside lit by vehicle-mounted spotlights and the flash of rifles, the air buzzing with ricocheting bullets. Wounded animals evading capture. Immobilized animals dying slowly of their wounds. Bloody carcasses strapped over the frames of trucks and off-road vehicles. Dog owners afraid to go out, or traumatized by the loss of their dogs to night-time shooters (Adreatta 2017, KSHB 2017, R. Schultz 2017).

Given the committee's current political climate (not really open to concepts like ecosystem-based management), the only concerns that were voiced in the hearing against the bill were those of firearms safety and law enforcement. 

Concerns that went unspoken included those of all-around environmental conservation, including high-quality habitat, predators, and prey. For example, the National Wild Turkey Federation (NWTF) recommends habitat improvement, while leaving predators alone (Hart 2016, Kennamer 2016). Somehow, though, the NWTF chapter president in Marshall, MN doesn't subscribe to that advice, preferring to host coyote-hunting tournaments and testify in support of killing more coyotes.

Proud of his role in setting the committee's political climate, chairman Rep. Dan Fabian wrapped up the bill's hearing, ignoring everything but his support for increasing game-bird production by killing more predators:

"[To the author of 2018 MN HF 2858], I appreciate you 'shining the light on predators.' This is something that we need to really start tackling across the state of Minnesota with regards to these egg-eating and chick-eating machines out there: skunks and raccoons, and in this case coyotes and fox. If we want more ducks, and if we want more pheasants, we're going to have to come to the realization that we have far too many of these other predators. So with that, the bill is laid over, thank you." --Rep. Dan Fabian, 3/27/2018, in support of HF 2858.

MN hunting regulations currently allow night-time hunting of coyotes and foxes using either 1) a rifle and natural lighting (ideally, moonlight on a cover of snow, but that's not mandatory), or 2) a shotgun and "handheld" artificial lighting (apparently to prohibit "shining" with headlights or rack-mounted spotlights of trucks or off-road vehicles).

Predator hunters have been trying to expand night-time shooting. In previous years, they've asked for thermal-imaging and night-vision scopes on rifles. Although they've had the support of certain legislators and committee chairmen who didn't want to follow MN DNR advice on public safety and law enforcement; behind the scenes, reason seems to have prevailed, and they've been held to the regulations.

About omnibus bills.
When the chairman said "this bill is laid over," he meant that he's planning to include it in his "omnibus environment & natural resources policy bill." This, he can do even without a committee vote; with the possible result that the bill could be passed into law without ever facing a single vote--and without any legislator going on record as a supporter. This is common practice at the MN legislature, although it's arguably unconstitutional (Anderson 2010, Davies 2015, D. Schultz 2017).

Adreatta, David. 2017. "Coyote Hunters Shoot Man in Town of Sweden, NY." Democrat & Chronicle, February 20, 2017. http://www.democratandchronicle.com/story/news/2017/02/20/man-shot-coyote-hunters-sweden/98183206/

Anderson, Gordon L. 2010. "The Single-Subject Rule and Omnibus Legislation." Legislative Evaluation Assembly of Minnesota (LEA). http://mnlea.org/articles/the-single-subject-rule-and-omnibus-legislation/

Davies, Jack. 2015. "Legislators, Please Stick to One Subject." Star Tribune, August 14, 2015. http://www.startribune.com/legislators-please-stick-to-one-subject/321927701/

Hart, David. 2016. "Coexist with Predators." National Wild Turkey Federation (NWTF). 2016. http://www.nwtf.org/conservation/article/coexist-predators

Kennamer, James Earl. 2016. "Wild Turkeys and Predators: What's the Real Problem?" National Wild Turkey Federation (NWTF). 2016. http://www.nwtf.org/conservation/article/wild-turkeys-predators-problem

KSHB. 2017. "Man Mistakes Dog for Coyote; Kills Family Pet in Front of 2 Boys." KSHB News. December 29, 2017. https://www.kshb.com/news/crime/man-mistakes-dog-for-coyote-kills-family-pet-in-front-of-2-boys

Outdoor Life. 2011. Bryce M. Towsley, John B. Snow, John Taranto, Bob Butz, and Brian Downs. "Guns, Gear and Tactics for Coyote Hunting." Outdoor Life, January 26, 2011. https://www.outdoorlife.com/photos/gallery/hunting/predators-small-game/predator-techniques/2011/01/hunt-hunters

Schultz, David. 2017. "Preventing Legislative Mischief with the 'Single-Subject' Rule." Pioneer Press, May 21, 2017. https://www.twincities.com/2017/05/21/david-schultz-preventing-legislative-mischief-with-the-single-subject-rule/

Schultz, Rob. 2017. "Split Verdict for Coyote Hunter Who Shot and Killed 2 Dogs." Wisconsin State Journal, December 20, 2017. http://host.madison.com/wsj/news/local/courts/split-verdict-for-coyote-hunter-who-shot-and-killed-dogs/article_2c24206f-8230-5ff5-8f4a-074d3937986f.html

Slocum, Scott. 2016. "Hunting Contests." SS-Slocum.info, 2016-2018. http://www.ss-slocum.info/home/WKCs

Update: 5/23/2018

As Rep. Hansen and Col. Smith pointed out in the 3/27/2018 MN House ENR Committee hearing on HF 2858, an artificial light can allow a hunter to identify a target at 300 yards, but the hunter's high-powered rifle can be deadly quite a bit farther out than that, at distances that aren't illuminated by the artificial light.

As Rep. Becker-Finn pointed out in that same hearing, 1) artificial lights are used by poachers, (2) one of the ways that poachers are caught by law-enforcement officers is through their use of artificial lights, and 3) loosening the regulations on the use of artificial lights would make things easier for poachers, but more difficult for law enforcement.

A hunter in that scenario wouldn't "know his target and what's beyond it."

The bill's nominal author, Rep. Swedzinski, and coyote-hunting contest promoter and weapons-sales representative Ty Brouwer tried to talk around these points, and to confuse them with their own personal desires for hunter convenience and high-volume predator elimination--without, of course, establishing anything other than their own personal desires.

This bill was included in the "omnibus environment and natural resources policy and finance bill" HF 3502 to allow the use of an artificial light with a shotgun (but not a rifle). That at least blunted the bill's threat to public safety. 

The environment & natural resources omnibus bill was later bundled into the "omnibus supplemental budget bill" SF 3656. Bundling policy like this into a budget bill is a questionable practice, and it looks like it didn't work out for the legislators who were trying to avoid a vote on this undesirable policy change by slipping it in with necessary government funding.

In summary, from January first through March fifteenth, a hunter in Minnesota on foot and meeting several other requirements may hunt fox or coyote with a shotgun using a handheld artificial light. See the Minnesota Hunting & Trapping Regulations for the details.

MN SF 2238 / HF 2605: Please add Reimbursement for Non-Lethal Beaver-Damage Avoidance

posted Mar 15, 2016, 3:13 PM by Scott Slocum   [ updated Mar 15, 2016, 3:20 PM ]

To: MN Legislators

Re: 2015 bill SF 2238 / HF 2605: Please Add Reimbursement for the Costs of Non-Lethal Beaver-Damage Avoidance.

Beaver-damage control is important, and beavers are important. New non-lethal options can allow both. 

In cases where landowners and land managers want to pursue non-lethal options, they should receive the same support, or I would argue, greater support in order to encourage them to design and implement programs with better ecological benefits.

As I understand it, a growing number of landscaping companies are now equipped with plans and experience to design, construct, and maintain "flow devices" with brand names like "Beaver Deceiver," "Pond Leveler," "Castor Master," etc. High-value trees can be protected by fencing, or by beaver-repellent surface applications. The idea is to leave the beavers where they are (in places where they can be valuable additions to the wetlands), but keep them from causing damage to roads and other property.

Compared to the annual costs of beaver trapping and dam removal, there can be financial advantages to flow devices. 

In areas where ecotourism is a known or potential benefit, flow devices (and live beavers) can provide additional social, financial, and ecological benefits. In communities with booster clubs for local natural areas, volunteer assistance can be available to help with design, construction, and annual maintenance.

I hope you'll consider adding the option to SF 2238 / HF 2605 to reimburse the cost of flow devices.

Opposed to MI DNR Proposal for "Liberalized" Nighttime Coyote-Hunting Allowances

posted Feb 29, 2016, 1:15 PM by Scott Slocum   [ updated May 16, 2016, 8:37 AM ]

Update: 4/27/2016

The Michigan Natural Resources Commission expanded nighttime hunting for coyotes, opossum and raccoons as proposed.

Matheny, Keith. 2016. "State Approves Year-Round Coyote Hunt in Michigan." Detroit Free Press. April 27. http://www.freep.com/story/news/local/michigan/2016/04/26/state-approves-year-round-coyote-hunt-michigan/83553624/.


To: Michigan Natural Resources Commission (Cheryl Nelson, nelsonc@michigan.gov)

From: Scott Slocum

Re: Opposed to the proposal to liberalize night-time coyote-hunting regulations.

I am writing in opposition to "Wildlife Conservation Order: Amendment 4 of 2016," which would extend the Michigan daytime and night-time coyote-hunting seasons, and expand the season in which artificial lights may be used at night.

[I had missed a third change due to my misunderstanding of the meaning of the font-strikeout and bolding of old and new language, respectively, on the amended Wildlife Conservation Order. The third change was to allow larger shot in shotguns in night-time hunting. Two larger sizes of shot were allowed: #4 and #3 buckshot.]

I understand that the public has the opportunity to write in about this subject ahead of the 3/10/2016 meeting of the Natural Resources Commission.

Problems with the expansion of night-time hunting

Even with powerful spotlights, hunters have poorer views of 1) their targets, and 2) what lies beyond them.

The first problem (poor identification of targets at night) is that it would be likely to result in an increase in the incidental shooting of wolves and domestic dogs, due to hunters' reduced ability to distinguish them from coyotes.

The second problem (poor identification of what lies beyond the targets at night) is shown in the current regulations, which limit the size of shot in order to limit the damage that might be done in unseen areas beyond the targets. That says something about the danger of shooting at night. It also says something about the willingness of the MI DNR to allow the use of loads with less power to deliver quick, humane kills of coyotes. [In other words, the proposed allowance for larger shot would make night hunting even more dangerous.]

Problems with lengthening the duration of the hunting seasons

Hunting ethics generally call for hunting seasons to end before the mating season, in order to avoid the inhumane starving of infant and young wildlife orphans. This humane concern should apply to all animals, even if some special-interest groups feel it should not be extended to coyotes.

Wolves are harder to distinguish from coyotes when they're young.

Many dog owners are already avoiding coyote-hunting areas in season for fear of incidental shootings of their dogs. By extending the season, those dog owners would be further stressed and deprived of the pleasure of their outdoor recreation with their dogs.

Problems with pursuing an ineffective management strategy

The 2/16/2016 cover letter correctly points out that the proposed liberalization would not be expected to have "significant biological impact" in lowering the overall coyote population long-term. It neglects to mention the likely negative impacts of responses of the coyote population to the increased hunting: increased reproductive rate, and in areas with sheep, increased livestock depredation. The proposed liberalization is thus not justified in terms of overall wildlife management.


The proposed liberalization has many problems and few benefits. It would fail to benefit the general public interest, and would be likely to be contrary to it. Apparently, the only interest it would serve would be that of the predator-caller association and the industries and members it represents. It's a bad idea.

Michigan Department of Natural Resources letterhead.

"Alarming response" (moved)

posted Feb 5, 2016, 1:49 PM by Scott Slocum   [ updated Feb 29, 2016, 10:28 AM ]

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