The Wisconsin Department of Natural Resources (WDNR) is seeking public comments on the 2019-2029 Black Bear Management Plan recently revised by the Bear Advisory Committee (BAC). Comments can be submitted until midnight April 14, 2019. The WDNR’s Bear Advisory Committee is comprised almost solely of bear hunters with many of the same people as members of the WDNR’s Wolf Advisory Committee.
Wolf Patrol has attended the BAC’s annual meetings in recent years and seen first hand how trophy hunting organizations like Safari Club International and the Wisconsin Bear Hunters Association set the agenda for any public policy on wolf and bear management in the state of Wisconsin. Its time to voice your opposition before its too late!

A regular visitor to Wisconsin, this bear hunter is currently facing multiple felonies for illegal bear hunting practices in Florida.
While the revised management plan references public concerns with unlimited bear baiting and the annual depredation of bear hounds by wolves, it offers no real remedies other than to study the problem and increase public acceptance for bear baiting and hound hunting as an integral part of bear hunting in Wisconsin.
A major shortfall in the WDNR’s revised Black Bear Management Plan is any recommended action to address Wisconsin’s extremely liberal bear baiting season and regulations. This despite the repeated acknowledgement that 40% of a northern Wisconsin bear’s diet is comprised of artificially fed bait and that the chocolate used in Wisconsin’s bear baits is toxic to bears and other wildlife.
FROM THE REVISED BLACK BEAR MANAGEMENT PLAN:
“Hunting regulations allow for the baiting of black bears. Unfortunately, much of what we know about the health effects of food items utilized as bait is based on simple observation or research studies on domestic animals. Research on the specific effects of items normally used as bait on wildlife species, including black bears, is generally lacking. However, there is ample evidence to suggest that bears are susceptible to the toxic effects of chemicals found in chocolate. Michigan, Wisconsin, and New Hampshire have all identified theobromine in dead bear cubs at levels consistent with those known to be toxic to dogs.” (page 40)

Chocolate cookies in a Wisconsin bear bait in a 2017 WDNR Wolf Caution Area.
“Currently, it is legal to bait bears with chocolate in Wisconsin. Chocolate contains theobromine, a compound known to be toxic to a wide diversity of wildlife species, including black bears. Chocolate consumed at bait sites has caused the deaths of one black bear cub in Michigan and 2 cubs, one subadult female, and one adult female in New Hampshire. Theobromine toxicity was also the presumptive cause of death for one cub (Bayfield County), and the probable cause of death for 2 other cubs (Washburn County), submitted for necropsy in Wisconsin in 2011. In response to concerns about theobromine toxicity, Wisconsin has included a warning about the toxic effects of chocolate in the Bear Hunting Regulations since 2013, and no mortalities due to theobromine toxicosis have been verified since.
However, undetected mortality may be occurring, theobromine can have sublethal impacts on bear health, and impacts on other species that may ingest chocolate at bear baits have not been examined in Wisconsin. Gathering data on the amount and type of chocolate in bear baits and documenting potential mortality and health impacts for black bears and other wildlife constitutes an important research objective.” (page 19)

A Wisconsin bear baiter preparing his bait.
While the WDNR’s Bear Advisory Committee fails to make any recommended change to Wisconsin’s bear baiting regulations, it argues that there is a lack of scientific evidence on any negative impact of baiting on a bear’s reproductive cycle as well as on other wildlife, and that the subject warrants further research.
“Recent research has indicated that supplemental food provided by bear and deer hunters (“bait”) accounts for 40% or more of the black bear diet in northern Wisconsin. As supplemental feeding of bears has been documented to alter bear activity patterns, movements and reproduction, and may increase levels of human-bear conflict, further research on the impacts of baiting on black bears in Wisconsin is warranted.” (page 3)
“Recent evidence that a high proportion of the black bear diet in northern Wisconsin is composed of supplemental food (i.e., bear and deer baits) and the stability of this food source across years raises the possibility that supplemental food may be decoupling annual black bear reproductive measures from variation in the abundance of natural foods. Better understanding the demographic impacts of bait on Wisconsin’s black bear population would be an important area for future research.” (page 4)

The chocolate filled bear bait in a 2017 WDNR Wolf Caution Area.
“In Wisconsin, baiting for deer and bear hunting provides high-calorie foods from mid-April up to the denning period, though the impact of this supplemental food on movements and habitat use has not been evaluated.” (page 5)
“…While no evidence exists that current baiting regulations are causing health issues for black bears, or influencing population dynamics, potential effects should be investigated to both protect bear health and provide accurate information (e.g., average litter size) for population models.” (page 19)
“…no obvious inferences can be made between current baiting practices and bear nuisance activity. Clarifying the potential impact of current baiting practices on nuisance bear activity is a potential area for further research.” (page 19)

Wolves feeding from northern Wisconsin bear bait in 2018.
Following all of the above-mentioned pronouncements by WDNR’s Bear Advisory Committee, the revised bear plan defends the lack of limits on bear baiting and hound training and offers no changes, despite acknowledging the scientifically proven negative impacts of feeding bears and other wildlife.
“The harvest season is preceded by periods during which hunters are allowed to establish and maintain bait sites (beginning 15 April and running through the harvest season) and train hounds (July 1st– August 31st) each year. These periods are longer than similar baiting or dog training periods in other states where baiting and/or the use of hounds is legal, and the public has periodically expressed concern about the potential impacts of these activities. In addition, there is no limit on the number of bait sites hunters may maintain, though individual bait sites may contain no more than 10 gallons of bait… (page 18)
…Public concern about Wisconsin’s liberal baiting regulations focuses on 4 potential impacts: 1) the high availability of calorie-rich processed foods may have health impacts for bears and other wildlife species, 2) acclimation to supplemental foods provided by humans may increase nuisance issues, 3) theobromine contained in chocolate is known to be toxic to bears and other wildlife species, and 4) baiting may increase wolf depredation of hounds… (page 18)
…Regardless, bait does constitute a high proportion of the black bear diet in Wisconsin, and diets high in sugar and complex carbohydrates can lead to several health issues for other mammal species, including increased blood glucose, high blood pressure, heart disease, altered function of the liver and pancreas, and altered composition of the gut microbial community” (Lindsey Long, WDNR State Veterinarian, personal communication). (page 18)

2013-2018 Wolf depredations on hunting hounds in red.
The revised Bear Management Plan also lacks any real action to address the conflict bear hunters create when their baiting attracts wolves and they run their dogs in active wolf territory where it is likely that they will be depredated. Instead, WDNR’s Bear Advisory Committee states the following:
“While the link between baiting and wolf depredation on hounds therefore remains unclear, promoting current (e.g., depredation caution areas) and developing new (e.g., using trail cameras to monitor wolf activity near bait sites) tools to minimize hound-wolf contact will be beneficial.” (page 19)
“Evaluate methods for reducing hound depredations by wolves and educate hunters about means to minimize wolf – hound encounters. Wolves were responsible for the deaths of 19 hounds per year, on average, from 2008 – 2017, with a high of 41 hounds killed in 2017. Evaluating current (e.g., wolf caution areas) and new means of reducing wolf– hound encounters would be beneficial. Educating hunters about means of identifying wolf use in their hunting area (e.g., trail cameras on bait sites), as well as continuing to promote wolf caution area maps likely provide the best opportunities to minimize encounters and protect hounds.” (page 56)
Unfortunately, educating bear hunters and promoting online maps is NOT the best way to minimize deadly conflicts with wolves, restricting bear hunters from continuing to bait and run dogs in Wisconsin’s Wolf Caution Areas and denying financial compensation after a depredation occurs would be a much more effective measure.

A non-resident bear hound trainer challenges Wolf Patrol monitor to a fight in 2017.
In addition, no attempt was made by WDNR or the BAC to quantify the impact of Wisconsin’s two-month Summer bear hound training season, when anyone, resident or non-resident, can bait for bears and run their dogs. According to WDNR, only 11% of licensed bear hunters train their dogs during the training season, meaning most hound trainers are non-residents bringing their dogs from other states to chase bears in Wisconsin. Most depredation of bear hounds occurs in the Summer training season.
Another concern expressed but not addressed in the revised plan is the threat of Sarcoptic mange in black bears which can be transmitted by mites that travel on bear hounds entering Wisconsin from Pennsylvania and Virginia. There are virtually no restrictions on bear hounds from these states being allowed to chase bears every Summer in Wisconsin.
“Develop outreach documents for hunters, to educate them about existing or potential health threats…Material should include a warning to hound hunters that hunt in other states (e.g., Pennsylvania or West Virginia) that the mite causing scabies-associated bear mortality in Pennsylvania can survive and be introduced to Wisconsin on hunting dogs.” (page 48)

Non-resident bear baiter/hounder during Wisconsin’s bear hound training season.
The revised plan also cites a study whereby radio-collared bears where monitored after having been chased during the Summer bear hound training season, yet no statistics are available on the actual number of hound hunters training bear dogs in the Summer since there is no license required to train bear hounds in Wisconsin since the Wisconsin Bear Hunters Association (WBHA) lobbied successfully to have the requirement removed in 2016.
“While this (above-mentioned study) suggests that hound training and hunting activities do not have significant impacts on bear health in Wisconsin, additional study is needed to verify these conclusions.” (page 18)
![0910:070817:62F:2882:CAMERA1:4E[132:0108]G[008:0x0006]](https://wolfpatrol.files.wordpress.com/2019/03/non-res-hounder-on-691.jpg?w=676)
Non-resident hounder operating in 2017 WDNR Wolf Caution Area.

Wisconsin bear hunters and hound in 2017.
“Current harvest methods, including baiting and trailing with dogs, allow both high hunter selectivity and success, and have allowed quotas to be regularly achieved in most zones. Hunting, inclusive of bait and dogs, should be maintained both for the population management capabilities and nature-based recreational opportunity it provides.” (page 44)
“Support development of ethical guidelines for hound hunting and develop outreach tools to increase the public’s understanding of current harvest methods. Public antipathy toward hound hunting may engender campaigns or legislative efforts to curtail or eliminate the activity; this antipathy often arises in response to illegal or unethical behavior by a minority of hound hunters- especially if this behavior is communicated on social media.” (page 44)

A Wisconsin hounder selfie with live coyote.
“WDNR staff should support current partner-driven efforts to develop and promote guidelines for the safe and ethical use of hounds to pursue black bears. These guidelines will both promote responsible behavior on the part of current and new hunters and provide an effective tool to educate the public about hound hunting. Additional outreach tools should be considered that provide an honest and factual depiction of bear hunting and highlight its numerous social, economic, and management benefits.” (page 44)
Clearly, Wolf Patrol is responsible for much of the backlash experienced by bear hunters in Wisconsin as we continue to highlight hunting practices that are not only unethical, but often illegal. You only need to scroll through this website to see the reason why improving the public image of Wisconsin’s hound hunters is an objective of the WDNR’s revised bear management plan. But what’s really necessary is strong action on the part of Wolf Patrol’s supporters, reminding WDNR that its not only bear hunters interests they should be concerned about!

A Wisconsin bear bayed during the summer hound training season in 2017.
Wolf Patrol’s Recommended Changes to 2019-2029 Revised Black Bear Management Plan
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Require registration & limit of bear baits.
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Prohibit the use of chocolate and xylitol in bear baits.
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Require license for non-resident bear baiting & hound training.
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Prohibit bear baiting & hound training in active WDNR Wolf Caution Areas.
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Shorten bear baiting & hound training season to one month before kill season.
$25 worth of old Hostess products used for bear bait.
The revised bear management plan specifically cites a need for further research and data on the impact of bear baiting. Currently, WDNR has no means to quantify the number of bear baits used annually by hunters other than through occasional surveys. Requiring registration and limiting the number of baits an individual can use, allows resource managers and conservation officers the ability to monitor and measure the impact of bear baiting in Wisconsin.
Banning the use of known toxins such as theobromine and xylitol in artificial feed given to bears and subsequently, other wildlife is the most effective and proven method to address poisoning in bears and other canids. Prohibiting the use of chocolate and xylitol would put Wisconsin more in line with other states such as Michigan which recently banned the use of chocolate in bear bait.

Bear hound injured in wolf depredation in 2018.
The revised bear management plan also states the need for data on bear baiting and hound training in the summer months, which is essential to quantify the number of non-residents participating in bear baiting and hound training activities. Such data can only be collected through a reliable registration or licensing system. The increased threat of introduction of disease by bear hounds traveling from Pennsylvania and Virginia also warrants greater regulation of non-resident bear hound trainers and baiters.
Once the depredation of a bear hound by a wolf has occurred, WDNR establishes Wolf Caution Areas in an effort to prevent further depredations. Unfortunately, many bear hunters will continue to bait and run dogs in areas with recent depredations, often leading to further depredations. The simplest way to address these preventable conflicts is to place limits on bear baiting and hound running once a depredation has occurred and a Wolf Caution Area established.
According to the revised bear management plan, A survey of bear hunters in 2014 suggested that 97.3% of hunters had not yet initiated baiting activities by May 1st. Only by August 9th (less than one month prior to the harvest season) had 75% of hunters that utilized bait begun baiting. Thus, shortening the baiting & hound training season to one month before the kill season would impact less than 25% of bear hunters while also helping mitigate the large number of bear hound depredations that occur in summer months.
If you agree with Wolf Patrol that its time to reign in Wisconsin’s bear hunters and limit baiting and hounding practices that are causing conflicts with people, wolves and wildlife, send your comments to WDNR before midnight, April 14, 2019:
DNRBearPlanComments@wisconsin.gov
To read the complete Revised Black Bear Management Plan:
https://dnr.wi.gov/topic/Hunt/documents/BearPlanFinalDraft.pdf