The following are written comments submitted by Wolf Patrol’s campaigns director, Rod Coronado to Wisconsin’s Department of Natural Resources Bear Advisory Committee in response to the 21-day comment period for the Revised Draft Bear Management Plan, which closes April 14, 2019.
Since 2014, Wolf Patrol has been investigating and monitoring bear hunting practices that create conflicts with gray wolves in Wisconsin. Our citizen monitors have visited over 32 WDNR designated Wolf Caution Areas, where wolves have depredated bear hounds, and over 90% of these areas were inundated with unregistered bear baits used by hound hunters to draw bears close to roads where their hounds can pick up their scent.

Illegal drag used by bear hunter in 2016 WDNR Wolf Caution Area.
The 2019-2029 Revised Draft Bear Management Plan fails to recommend even minimal changes to bear baiting and hound training practices that it recognizes are cause for great concern. Has the WDNR’s Bear Advisory Committee become just another sub-group of the Wisconsin Bear Hunters Association? You read the draft bear plan and then tell WDNR…
https://dnr.wi.gov/topic/Hunt/documents/BearPlanFinalDraft.pdf
SEND YOUR COMMENTS: DNRBearPlanComments@wisconsin.gov

Wolves visiting a bear bait in Wisconsin during the 2016 two-month bear hound training season.
Public Comments on 2019-2029 Draft Revised Bear Management Plan
Dear Members of theWisconsin DNR Bear Advisory Committee,
I would like to first thank all of you for the hard work and dedication you have put into this revised bear plan, such an effort demonstrates your commitment to fulfill the DNR’s mission to protect and enhance our natural resources, which includes black bears as well as so much other wildlife in Wisconsin. While I am not a Wisconsin resident, I have spent much of my life hiking, camping and exploring the many national forests in this country. The last five years that I have spent exploring Wisconsin’s national forests have left me feeling very concerned about the future of Wisconsin’s wildlife.
I grew up hunting in California, including for bear, but none of what I saw as a youth hunting can compare to bear hunting practices I’ve witnessed for five years now in mostly the Chequamegon-Nicolet National Forest. Contrary to what others think, I am not opposed to hunting, including the hunting of bears and even wolves. But regardless of the species, I’ve always believed that hunters should only ever bring benefits to wildlife, not negative impacts that also effect other wildlife as well.

Non-resident hounds baying a Wisconsin bear during the 2017 two-month summer bear hound training season.
In the fall of 2014, I began exploring and investigating both wolf and bear hunting practices in Wisconsin. By the following summer in 2015, I was exploring areas of the Chequamegon-Nicolet National Forest where wolves were reportedly fighting, killing and eating bear hunting hounds in increasing numbers. It didn’t take long to figure out that wherever depredations of bear hounds was occuring, especially in summer months, was also where bear hunters were baiting bears and running hounds.

Bear hound/wolf fights 2013-18 in Bayfield County alone…the Wisconsin Bear Hunters Association might as well sell tickets…
Wolf Patrol’s own response to the increased wolf predation on bear hounds was to get as close as we could to the actual depredation sites once they were reported by WDNR, and then begin to count the number of bear baits in the immediate area. After personally investigating over 28 bear hound depredation sites, I think only twice did we NOT find bear baits in the immediate area.
I have also personally reported dozens of bear baiting violations to WDNR, many of these were again discovered because we were investigating wolf depredations on bear hounds. I’ve also seen hundreds of bear baits that were in compliance with WDNR regulations, but I’ve never understood how there could be virtually no limits on the number of baits a person could maintain. I want to keep my comments directed towards bear baiting and hound training specifically, although I will comment on wolf depredations that occur during the kill season as well.

Small bear killed in 2017 WDNR Wolf Caution Are by Bayfield County hounder.
Part of the stated program goal of the bear management plan is to minimize bear and human conflicts.
Such conflicts are not only between bears and humans, but bear hunter’s dogs and other wildlife, and people as well. When wolves kill bear hounds, bear hunters want to kill wolves. That is a conflict that should be prevented if at all possible, and it is, only nothing is offered in the revised plan other than further research and development of outreach tools. Maps and flyers are not what are needed, but real tangible action to limit bear hunting activity like baiting and hounding in areas where wolves are killing bear hounds.
I’ve heard it said that legislative action would be necessary to limit any kind of hunting activity, but for the WDNR to suggest no action in response to what has become the annual slaughter of bear hounds by wolves in Wisconsin is irresponsible and not in keeping with the mission of the DNR to protect and enhance our natural resources.

Four bears feeding at Wisconsin bear bait during bear hound training season.
Five specific objectives are identified in the revised bear plan as program goals, and Objective E in particular is of great concern, which is “Identify important information needs and conduct research as necessary to address issues impacting black bears and hunting opportunity in Wisconsin”
As is later echoed throughout the revised bear plan, conducting research on the impacts of baiting bears from April to October with an unlimited and unknown number of baits clearly sounds like a priority. I counted 14 times within the revised plan when mention was made of possible negative impacts related to Wisconsin’s bear baiting practices, but not once is there any suggestion to limit or even register bear baits.

Bear eating donuts at a Wisconsin bear bait site during 2014 bear hound training season.
Much is spoken about the documented and proven dangers of theobromine poisoning that can occur when bears and other animals ingest chocolate contained in bear baits, but there is a failure to suggest banning toxic ingredients in bear bait like chocolate and xylitol, and that is contrary to the stated mission of WDNR. More research is needed, but not before responsible action by WDNR to limit the feeding of toxins to bears and other wildlife.

Documented bear baits in 2017 WDNR Wolf Caution Area in Bayfield County, Wisconsin.
Evaluating methods for reducing wolf depredation of hounds is another part of Objective E and the entire plan that is hollow of any real action. As I stated earlier, educating bear hunters about WDNR Wolf Caution Areas will not reduce depredations, limiting baiting and hounding in those areas will.
While the WDNR’s Gray Wolf website with information on depredation is a valuable resource, it alone is not enough. Let me give this example. Currently, WDNR is suggesting no new action to address the annual slaughter of what is estimated to be 19 hunting dogs by wolves this year. Accepting this conflict with bear hunters and wolves is again a contraction of the bear plans objective to “minimize bear human conflicts.”

Wolf Patrol monitor watering hound wandering 2017 WDNR Wolf Caution Area in Bayfield County, Wisconsin.
In regards to the lack of any recommended action to curtail or limit what is admittedly an unlimited bear baiting season, I just want to say that such absence of responsibility stinks of the influence that certain members of the WDNR’s Bear Advisory Committee have on the WDNR’s ability to maintain its mission.
For organizations responsible for stated dangers and threats to Wisconsin’s bear population, like the Wisconsin Bear Hunters Association (WBHA), to make no recommendation to limit their members baiting or hounding activities, makes me believe that the Bear Advisory Committee is nothing more than a rubber stamp for anything bear hunters want to do in Wisconsin.

Wolves at bear bait in 2018 WDNR Wolf Caution Area, Sawyer County, Wisconsin.
For example, its a proud fact of the WBHA that the B license requirement was removed in 2016, virtually throwing the barn door open to any hound hunter anywhere who wants to train their dogs to chase bears in Wisconsin, no license required. On page 18 of the revised bear plan, mention is made of research on six radio-collared bears that were chased during the hound training season, but there is no way to quantifying how many hound hunters from Wisconsin and other states are baiting or running dogs in the training season, since the removal of the B license requirement.
In addition, there is no acknowledgement that hound hunters from North Carolina, Virginia, Pennsylvania, Florida and other states regularly haul dogs to Wisconsin to be trained in the summer bear hound training season. Wolf Patrol monitors numerous hound hunting pages on Facebook, and every year hunters who run their dogs on hogs and deer in their own home states annually travel to Wisconsin to train dogs as well. There is mention however of the threat of disease transmission by bear hounds from affected states like Pennsylvania and Virginia, yet no recommendation of a system to regulate hound hunters from those states.

This non-resident, Bo Wood was indicted in 2018 on multiple felony counts of animal cruelty in Florida and regularly trained hounds in Wisconsin.
For five years now, I have observed how black bears and wolves are managed in Wisconsin. And while I have much criticism of bear hunting practices, I still believe there is a way that bear hunting could be sustainable and culturally acceptable. But not without improvements to the way bears are hunted in Wisconsin. If I was speaking solely for myself, I’d be submitting a much shorter comment, simply asking that all bear baiting and hound hunting be banned on public lands. But that’s not realistic. What I believe is realistic is to make a comment that recommends action within the realm of possibility and fairness.

A Wisconsin bear chased during the 2017 bear hound training season.
In closing, I would like to make five recommendations that I believe begin to address objectives identified as priorities in the WDNR’s revised bear management plan while also serving to fulfill the stated mission of the WDNR:
- Require registration & limit to bear bait sites.
- Prohibit the use of chocolate and xylitol in bear baits.
- Require license for non-resident bear hound training & baiting.
- Prohibit bear baiting & hound training in WDNR Wolf Caution Areas.
- Shorten bear baiting & hound training season to one month before kill season.
As I have stated to the Bear Advisory Committee before, what Wolf Patrol and many Wisconsin citizens want is the responsible management of the black bear population, which includes the management of bear hunting practices where there isn’t any. What we are asking is for bear hunters to be more responsible, so that their sport does not negatively impact others.
Thank you for accepting my comments on the 2019-2029 Bear Management Plans,
Rod Coronado

Wisconsin bear hound killed and eaten by wolves in 2016.