Protect the Adirondacks!
PO Box 4124
Schenectady, New York 12304

New York State Department of Environmental Conservation
Bureau of Wildlife
625 Broadway
Albany, New York
By e-mail

RE: Bobcat Management Plan

To Whom it May Concern:

Protect opposes implementation of the “management Plan for Bobcat in New York State 2012-2017” because it is not based on a “scientifically sound” study of the state’s bobcat population, as required by the DEC Bureau of Wildlife’s own mission statement. We ask that this study be completed before any further plan to manage bobcat is considered.

The DEC study only solicited trappers and small game hunters to gain preliminary input regarding the future management of the bobcat species, according to its own admission (Bobcat Management Plan, at 6). They are then using this data as the entire base of their plan to manage the bobcat “resource”. This is simply bad science. This research promotes a skewed approach to data collection: by their own admission this data is misleading (at 10) because trapping efforts vary greatly with factors such as pelt prices and environmental factors. In addition few hunters have the skills or inclination to hunt bobcat, meaning that hunting results are not statistically reliable when such small numbers are involved.

There can be no question that there are scientific methods that wildlife experts use to collect data on bobcats, such as motion sensor camera traps, live cage traps to provide evidence of predator/prey interactions and population changes before making such determinations on population control by hunting and trapping. Similar strategies are being employed by other states such as New Jersey, and with great success.

In addition to the draft plan being in conflict with the Bureau of Wildlife’s own mission statement, it completely analyzed the bobcat outside of the place it holds in the complex ecosystems of New York State. The bobcat is a major predator and has clear impacts on other wildlife populations. In addition, the Adirondack Park, home to the DEC estimate of 3000 bobcats, 60% of the states total population, is mosaic of distinct ecosystems, managed around core wilderness areas that are constitutionally protected as “forever wild” under Article 14. The clear meaning of “forever wild” is that these ecosystems maintain dynamic populations of each of the species that contributes to these unique environments. This plan contains not only no data about this, but not even any discussion. Moreover, a good part of the remaining bobcat population, only 2000 statewide based on this unscientific DEC estimate, is related to this wilderness ecosystem. Indeed, among the reasons for the increase in bobcat populations in the southern tier is an increase in population in neighboring Pennsylvania, another related ecosystem that is not evaluated at all in this plan.

The bias and lack of scientific study in the plan is revealed by its operational conclusions, increased hunting and trapping. Indeed, the “benefit of “greatly simplify hunting and trapping season dates by making them consistent throughout much of the state” is absolute nonsense. The state has long been divided for purposes of wildlife management into various zones, with hunting and trapping permitted on one side of a highway and prohibited on the other. While doubtlessly this annoys some people, not one can contest the fact that it is necessary in the management of wildlife, given the wide range of habitats in such a large and diverse state. It is absolutely not a significant problem for hunters and trappers to face different bobcat seasons in different parts of the state. That this should be flaunted as some “benefit” in the plan greatly exaggerates the convenience of hunters and trappers over sound scientific management of bobcats. Indeed, parks, “forever wild” and “wild forest” designations are completely ignored.

The Draft Plan does not explain with any scientific evidence how the number of bobcats harvested has been directly correlated to a proven increase in population densities: we cannot scientifically accept hunting and trapping reports as the sole source of this data. The Plan then overstates assumptions in this data. In fact, for the Adirondack Region the data is even less meaningful due to lower current population densities of bobcats (5 per 100 square miles). Due to this, the Park’s regions are listed as a continued harvest area, but the Plan offers no scientific data to support a continued harvest given such low densities – in areas that include wilderness. Is it not logical to require that harvesting in this area should be further restricted, to permit an increase in bobcat populations, instead of simply maintaining existing population levels? If we have lower bobcat population in the Catskills and Adirondacks might this not indicate a problem with current management strategies based on hunting and trapping? Without careful scientific study, how does the DEC even know?

To entirely focus the report on making the bobcat “resource” increasingly available for harvest by hunters and trappers rather than on scientific study of conservation strategies also denies the history of bobcat destruction in New York and the rest of the United States. The species was hunted and trapped to near extinction, leading to banning of both practices. Fortunately for all, the species has recovered, but it is still listed as endangered in Appendix II of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). This recovery cannot be assumed to be permanent, nor complete. It is only careful scientific study of the current bobcat population that can adequately supervise this continuing recovery.

Somewhat cynically the Draft Plan calls for “minimizing the damage and nuisance” caused by bobcats. It then reports that there were absolutely no negative contacts between bobcats and humans and 13 permits issued to kill “nuisance” bobcats around domestic animals. If “nuisance permits” are the best means to address so few animals statewide, the reliance on hunting and trapping is completely misplaced – aimed at the entire population of bobcats and not narrowly focused on nuisance animals. And, of course, in wilderness areas there are no nuisance bobcats at all, so the lack of specificity in the plan is glaring.

The entire role of the DEC in meeting the public desire for enjoyment of wildlife somehow merges with the interests of the few bobcat hunters and trappers. To see a bobcat in the wild is a rare and memorable achievement for any hiker, snowmobiler, or motorist. Reducing populations reduces the chance for such a sighting.

Bobcats are top end predators on the ecological food chain. The fact is that bobcats pose no threat at all to humans and serve a vital role in managing populations of rats, mice, and deer in the Adirondacks that, again, has not been scientifically studied in this Draft Plan. The DEC should be doing ecological research to better understand bobcat habitat needs and requirements, rather than promoting an indiscrimant plan to decrease overall numbers statewide, regardless of local ecology. Bobcats and other top predators usually sustain increases in population as a result of increases in available prey.

Warmer winters as a result of climate change have shifted deer and other prey populations and allow conditions that favor bobcats which may be causing some local increases in population. This is a natural response and allows for the control of ecological habitat destruction vector born diseases caused by over population of nuisance species such as rodents and under story browsers such as deer. Left to nature, the species will self regulate once the natural balance is restored. Increases in road kills, decrease of habitat and natural predation by larger birds of prey, such as owls, larger hawks, and eagles, and coyotes will, in turn, control the population of bobcats, if increases should occur. Some research suggests that the bobcat population is already stabilizing in areas such as parts of Ontario as a result of natural balance.

The goal of any statewide plan for the management of any wildlife species must be to move toward a natural balance of species, consistent with a wide range of ecological conditions that can include human needs, but this has to be base on careful scientific study, taking full account of the vast range of ecological conditions that exist in New York State. This study completely fails to either use a scientific method or take even a rudimentary account of the ecological factors that should influence bobcat management. We ask first, that a moratorium on all hunting and trapping of bobcat be implemented in New York State pending a scientific study of New York State’s bobcat population, or, in the least that such a moratorium be put in place in the Adirondack Forest Preserve, second, we urge using this study as a basis for developing a future bobcat management plan that meets the requirements of the law.


Sid Harring
Conservation Advocacy Committee

Filed; Feb. 16, 2012