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LWF Objects To Wildlife Commission Action
The Louisiana Wildlife Federation (LWF) has asked the Louisiana Wildlife and Fisheries Commission (Commission) to revise its proposed modification of the Deer Management Assistance Program (DMAP) rules and to adopt operating procedure to prevent the enactment of last minute changes to hunting seasons and other regulations. In a letter to the Commission, LWF President E. R. "Smitty" Smith of New Iberia asked the Commission to back off of the DMAP rule change that would allow some hunters to harvest more than the season limit of six deer. Smith said that the proposed rule is a significant policy change that has the potential effect of giving certain hunters an excessive or disproportionate share of the resource and is fundamentally discriminatory. "The authorization to harvest the legal limit of deer in Louisiana is conveyed to the individual through the issuance of a hunting license, not through enrollment in a deer management program or even by virtue of property ownership," Smith wrote in his letter. Under the proposed rule, a hunter taking doe deer according to the rules on DMAP lands could legally harvest more than the standard 6 deer per season.
The LWF's second recommendation was provoked by the unusual action the Commission took at its July meeting when it made substantive changes to several of the proposed hunting season dates and then adopted those changes as law. "By presenting and ratifying critical changes affecting the hunting public, at one meeting on one day, without prior notice or ample opportunity to comment, the Commission acted contrary to the spirit of public participation in the rulemaking process as envisioned by the Louisiana Administrative Procedures Act," Smith said. The LWF recommended that the Commission adopt a policy to refrain from making any substantive adjustments to a proposed rule at the same meeting when the rule is finally ratified, except when warranted by a real emergency or in light of substantive and compelling biological or economic information that has just recently become available and that would make it prudent to adjust the rule before final ratification.
The LWF also recommended that the Louisiana Department of Wildlife and Fisheries review the feasibility of advancing the rulemaking process for establishing the seasons and bag limits for fall-hunted resident game species so that such rules are adopted at least 6 months prior to the onset of the seasons. According to Smith, that would avoid short-notice changes in seasons that disrupt vacation and hunt plans of sportsmen, many of whom have to schedule their vacations well in advance of the fall hunting seasons.