At Backcountry Hunters & Anglers, conservation is the cornerstone of our volunteer efforts, advocacy, and even our long-term enjoyment of the outdoors. While many of us are hunters and anglers first, just as many members and volunteers consider themselves to be primarily conservationists.

In this regard, the Washington Chapter has a keen interest in the Washington Fish and Wildlife Commission’s proposed Conservation Policy. As a chapter, we have been actively engaged throughout the development of this policy, providing formal comments when opportunity is provided, speaking on it at Commission meetings, and working with other conservation stakeholders to suggest improvements and necessary edits.

The Washington Chapter of Backcountry Hunters & Anglers believes this policy fails to demonstrate good governance, respect for stakeholder engagement, or collaborative intent in policymaking. We believe the best course of action for the Commission would be to abandon its current efforts and restart the process anew to create a conservation policy that is inclusive and impactful for the benefit of all Washingtonians.

Disappointingly though, the Commission does not appear willing to change course on this policy. As a result, the Washington Chapter must instead focus on mitigating the worst aspects of this policy. To do so, we have identified key concerns and concepts within the draft Conservation Policy that should be addressed by the commission before the final vote and adoption. 

While there are many places within the document that conservationists, sportsmen and sportswomen, and other invested communities may find critique, we suggest individuals focus their public comments on the following issues with the intent to foster necessary improvements to the current draft if the Commission declines to restart and re-engage in policy drafting:

• The Conservation Policy must recognize invested stakeholders and historic partners in agency efforts and success
  • The role of sportsmen and sportswomen in conservation has been monumental in the conservation of natural resources. Other traditional stakeholders, including commercial fishers, environmental conservation groups, and timber producers have been vital partners for the department and its many successes in recovering and sustaining wildlife species and habitats. Failing to recognize and champion previous success and partnerships, establishes an inaccurate historical context for natural resource conservation and inhibits future support, collaboration, and mutual accomplishments that may come from working with these valued stakeholders.

• The Conservation Policy must be rooted in respecting Tribal Treaty Rights and the informed perspectives of Tribal natural resource managers
  • Federal treaties are a cornerstone of our nation and should be respected as such in policy development. Additionally, we recognize that many Washington Tribes have contributed significant effort and knowledge to the sustainable use of our natural resources including wildlife. That does not mean we all have to agree on Tribal management priorities and perspectives, but it does obligate the Commission to intentional, good-faith engagement and consideration in policy development that has not been demonstrated thus far.

• The Conservation Policy must acknowledge the disparity between preservation and conservation and accurately reflect the tenets of conservation
  • Whereas some Commissioners have argued that the difference between preservation and conservation is a false dichotomy and not a valid criticism of the document, this is wildly inaccurate. As noted on the National Park Service and  US Forest Service websites, there is a clear disparity between preservation and conservation definitions that should not be synonymized in the conservation policy. The draft policy must reconcile that these terms are not uniform and should apply the concepts of conservation within the framework of this document if it is to serve as a “Conservation Policy” without subverting it for other purposes.

• The Conservation Policy must acknowledge limitations of the the Commission, the Agency, and the State of  Washington to accomplish its intended goals
  • The Department of Fish and Wildlife and the Fish and Wildlife Commission do not have sole control or authority over the challenges or success of conservation in the 21st century. Climate change and biodiversity loss are global crises and will manifest in unique and unpredictable ways within Washington state, often outside the purview of this Policy. The Commission and the Department of Fish and Wildlife cannot reverse long-term droughts that impact populations, adjudicate energy development projects that can impact migration corridors, or dictate wildfire response strategies on federal lands that drastically alter habitat. For the policy to be actionable, it must recognize the capacity in which it can operate, as well as the factors over which it does not have authority.

• Policy is not the place for ambiguous and aspirational language, it must be rooted in concrete and measurable actions and outcomes
  • The draft fails to articulate how it will accomplish or implement the guidelines within it and does not have a revenue stream or agency manpower solely dedicated to implementation. The policy fails to outline consequences for failing to adhere to its guidelines objectively, consistently, or holistically, resulting in a policy that can be subjectively and selectively applied.
    
    

The Washington Chapter believes that these critiques are not only valid but appropriate and should be levied by invested members of the public when possible, including during the current public testimony period that closes on January 12th. On behalf of the Chapter, the Washington BHA board will submit a letter to the Commission regarding these issues. We hope that individuals interested in the Commission Policy will exercise their right to provide comments on the current policy draft and that these outlined concerns may be beneficial in crafting your statements.

To provide public comment regarding the Conservation Policy by January 12th, please email your thoughts to [email protected].