The following comments were submitted by CO BHA in regards to the CO Parks and Wildlife's Draft Mule Deer Strategy.

August 12, 2014

TO:  Colorado Parks and Wildlife

RE:  Comments on Colorado West Slope Mule Deer Strategy - Draft August 9, 2014

Please consider the following comments on behalf of the Colorado Chapter of Backcountry Hunters & Anglers in regards to the West Slope Mule Deer Strategy - Draft Aug.9, 2014.

Backcountry Hunters & Anglers is a grassroots sportsmen conservation organization dedicated to serving as a voice for our wild public lands, waters and wildlife.  We support wildlife and land management plans that are scientifically-based and which balance social demands with biological needs.  Accordingly, we felt compelled to comment on the current effort to draft a West Slope Mule Deer Strategy.

We applaud CPW’s effort, with the able assistance of the independent Keystone Center to carefully gather and analyze comments, concerns, opinions, personal observations and even theories from a variety of stakeholders including sportsmen, outfitters, livestock industry representatives and landowners from around the state regarding the decline of mule deer on the Western Slope of Colorado.  No doubt there is great value in accurately identifying major concerns and opinions of different stakeholders in different regions of the state.  Management decisions regarding wildlife populations need to be made with prudent consideration of social desires and demands.

However, BHA believes that landscape and wildlife management plans must be based first and foremost on the best scientific information available.  CPW and other state and federal agencies have a significant body of credible scientific studies that elucidate the biology, population dynamics, migratory patterns, nutritional requirements and effect of predation, disease and automobile accidents on mule deer in Colorado and surrounding states.  BHA believes that the Wildlife Commission needs to seek the best available scientific consensus from CPW biologists and others with expertise in mule deer population fluctuations in western Colorado and on the adjacent western slope landscapes.  In conjunction with the current extensive effort to gather and analyze public input through the Keystone Center, we urge CPW to gather, analyze and distill current scientific studies to the level of management recommendations for the Commission to consider as part of the decision making process.  At a minimum we urge CPW to present the science behind each of the seven currently proposed strategic priorities to accomplish the goal of stabilizing, sustaining and increasing mule deer populations in Colorado.

The seven strategic priorities presented in the current draft of the West Slope Mule Deer Strategy come from a blend of input from the CPW internal summit work in April 2013, public input as compiled by the Keystone Center August 2014, and further synthesis by CPW.  We appreciate this systematic approach as part of a process to make decisions that attempt to balance the science of managing mule deer populations with social/economic demands.  However, BHA is aware of how political this process can become and how CPW must remember its first and highest commitment should be to “perpetuate the wildlife resources of the state”.

BHA stands eager to comment more specifically on this process as it unfolds but as a general platform regarding wildlife populations and, specifically, mule deer management we believe that:

• Healthy landscapes support healthy, sustainable populations of a variety of wildlife species.  Effective wildlife conservation fundamentally begins with habitat protection.  
• There are many natural, complex and inter-related factors that influence fluctuations in wildlife populations like mule deer including stages of landscape succession, climate and weather changes, wildfire, disease and predation.
• These cyclical fluctuations may occur naturally over years or even decades or longer.   
• Human activities including recreation, oil and gas development, livestock industry practices, hunting, and importantly, habitat destruction and/or fragmentation by a variety of user groups also play a key role in population variations.
• All of the research ever done on mule deer decisively indicates populations are driven by availability and quality of habitat.  With continuous loss of habitat over the last 40+ years, populations have predictably declined, sometimes precipitously despite the best efforts of various agencies.
• With all the habitat changes occurring now on the western slope, future sustainable mule deer populations will likely fluctuate at lower levels than recent peak population eras.   Further declines are likely and realistic projections for herd populations and hunting opportunities need to be presented to the public and the Commission.
• Making key management decisions on this complex issue will be difficult and fraught with the potential for making significant mistakes.  Decisions regarding populations should be made cautiously, yet in a timely manner, as windows of opportunity to implement key management practices may open and close quickly - especially in the face of impending habitat fragmentation and/or destruction on the Western Slope.  As such, proposed management plans should make allowances for timely future amendments as the natural system we are” tinkering with” is likely far more complex than we know and “results may vary”.  The future of mule deer management will likely require more nimble, local adjustments.
• Financial constraints of CPW need to be considered in the process – yet they should not be the primary driver.  This is especially true in regards to expensive new programs like predator control measures mentioned in the draft Strategy.  On a larger scale, loss of revenue for CPW from declining deer hunting opportunities will need to be offset by novel sources of income – another complex issue.   
• Public education on the complexity and inherent vagaries of wildlife management may help temper various user groups’ demands and expectations on a likely declining resource over time.   Perhaps this is a valuable part of the process CPW and the Keystone Center are influencing now.
• Hunters play a critical role in conservation of wildlife populations.  Ethical and knowledgeable hunters must be willing to adjust their hunting expectations to reflect the sustainable carrying capacity of a healthy landscape – even if it means missing a few seasons of hunting opportunity.  The health of the land and wildlife are an ethical hunter’s first concern.

The following are our comments on each strategic priority.  We anticipate that the devil will be in the details in all of these priorities and we stand ready to comment further as things progress.

Strategic Priority #1:  BHA agrees in principle with landscape-scale habitat management to improve or at least maintain habitat quality.   However CPW needs to be realistic in projecting sustainable deer populations in various regions.  For example, largely as a result of policies that have favored fire suppression some regions of a landscape may be in a natural stage of succession that will not easily support more deer.  We support restoring the natural disturbance regimes that mule deer have evolved with where practical (particularly in un-roaded undeveloped landscapes) and using well-planned mechanical treatments where it is not.  Decisions regarding treatment techniques need to be sensitive to the greater health of the habitat of which mule deer are only a part.  Unfortunately, for a variety of reasons (including a projected increase in the state population of one million people by 2020 per GOCO) deer numbers are likely to decline despite management efforts.  Educating the public and setting realistic expectations will be especially important during this process.

Strategic priority #2:  BHA is concerned with the proposed focus on predator control as a means of increasing mule deer populations.  While predators can undoubtedly have localized impacts on populations, a large-scale CPW-funded predator control program is one perceived ‘solution’ to a much broader problem that we strongly oppose. Predators are a vital part of healthy ecosystems and play a key role in keeping ungulate populations “wild” and dispersed.  CPW needs to prove that specific predators have significant and lasting advantage over their prey and represent a long term threat to deer numbers in a specific region before control attempts are considered.  While predator management may have a place in the broader strategy, blaming predators for declines in mule deer populations is often a knee jerk reaction that has many proponents but questionable scientific support.   In addition, predator management can be very costly (a major concern for CPW in light of current financial difficulties) and ultimately damaging to the greater long-term health of the landscape. 

Strategic priority #3:  BHA supports the proposed components to protect habitat and mitigate development impacts to lessen rates of habitat loss.

Strategic priority #4:  BHA supports the proposed components of implementation to reduce the impacts of highways on mule deer survival, movements and migration.

Strategic priority #5:  BHA supports the proposed components to reduce the impacts of human recreation on mule deer.  BHA has consistently supported efforts to limit human activities in critical habitats.  Research has consistently shown that motorized disturbance has a disproportionate impact on big game habitat, thus we urge/expect CPW to provide honest and factual biological where motorized developments pose a risk to habitat.  While motorized impacts on habitat are often most pronounced, we urge CPW to also provide honest assessments on the impacts that other forms of developed recreation and human disturbance have on mule deer habitat (see references below).

Strategic priority #6:  BHA supports the proposed components of implementation to regulate doe harvest and provide youth opportunity.  Limiting doe harvest has been shown to increase deer populations in specific regions with otherwise healthy habitat.  BHA recognizes the need for and supports efforts to encourage youth and new-hunter participation in hunting.

Strategic priority #7:  BHA supports the proposed components to maintain a strong ungulate population and disease monitoring program and conduct applied research to improve management of deer populations.   

Thanks for taking the time to consider our input.   Please don’t hesitate to let us know if there is any clarification needed on our comments.   We look forward to being involved throughout the rest of the process.

Sincerely,

Tim Brass

Southern Rockies Coordinator

Backcountry Hunters & Anglers

[email protected]

Dan Parkinson

Sportsmen Roundtable Member

Backcountry Hunters & Anglers Life Member

References:

Impacts of Recreation on Mule Deer

Boyle, Stephen A., and Fred B. Samson. "Effects of nonconsumptive recreation on wildlife: a review." Wildlife Society Bulletin (1985): 110-116.

Freddy, David J., Whitcomb M. Bronaugh, and Martin C. Fowler. "Responses of mule deer to disturbance by persons afoot and snowmobiles." Wildlife Society Bulletin (1986): 63-68.

Taylor, Audrey R., and Richard L. Knight. "Wildlife responses to recreation and associated visitor perceptions." Ecological Applications 13.4 (2003): 951-963.

Frid, Alejandro, and Lawrence M. Dill. "Human-caused disturbance stimuli as a form of predation risk." Conservation Ecology 6.1 (2002): 11.

Wisdom, Michael J., et al. "Effects of off-road recreation on mule deer and elk." (2004).

Habitat Related Studies:

Sawyer, Hall, Matthew J. Kauffman, and Ryan M. Nielson. "Influence of well pad activity on winter habitat selection patterns of mule deer." The Journal of Wildlife Management 73.7 (2009): 1052-1061.

Wallmo, O. C., et al. "Evaluation of deer habitat on a nutritional basis." Journal of Range Management (1977): 122-127.

Predation:

Ballard, Warren B., et al. "Deer-predator relationships: a review of recent North American studies with emphasis on mule and black-tailed deer." Wildlife Society Bulletin (2001): 99-115.