The New York Chapter of Backcountry Hunters and Anglers is a proponent of the North American Model of Wildlife Conservation and the Public Trust Doctrine that defines fish and wildlife resources be managed on behalf of the Public by state agencies entrusted with their stewardship. This proven and successful conservation model is the foundation of science-based fish and wildlife management. We put our trust in New York State Department of Environmental Conservation (DEC) biologists and managers to ensure that decisions and policies that benefit all of New York’s flora and fauna are informed and guided by science. 

The white-tailed deer (Odocoileus virginianus) is as a keystone herbivore in New York State due to direct and indirect impacts deer have on habitats and ecosystems. Effective management of deer populations through sustainable harvesting is essential to ensuring that deer densities remain within both ecological and societal carrying capacities. This practice not only provides a valuable public source of lean, organic protein but also generates significant revenue from hunting activities. These funds are crucial for supporting ongoing conservation efforts to the benefit of all New York wildlife. 

Current law (ECL § 11-0913) authorizes DEC to issue Deer Management Permits (DMPs) on a wildlife management units (WMU) basis in most of New York. DMPs allow for the harvesting of antlerless deer to meet population management objectives established to balance the needs of deer, human, and other wild flora and fauna. However, in 9 of the 92 designated WMUs in New York, which together comprise the Adirondacks WMU Aggregate, current environmental conservation law (ECL) prohibits DEC from issuing DMPs, thereby limiting DEC’s ability to effectively manage deer populations in those WMUs. The Adirondack WMU Aggregate includes the largest WMUs by area and combined encompasses nearly a quarter of the State and half of all State-owned public land. The inability for DEC to scientifically manage deer populations on such a vast and significant area of New York and on such a large portion of our public lands violates several tenets of the North American Model of Wildlife Conservation and is a breach of the Public Trust Doctrine. 

DEC should have authority to manage the antlerless harvest with DMPs throughout the entire State based on the timely, science-based judgments of relevant subject matter experts within DEC. The ECL should be updated to provide for management decisions regarding antlerless deer to be made by DEC at the regulatory level, rather than dictated by legislative actions as currently stands for the Adirondack WMU Aggregate