NYSTA position re: proposed mink, muskrat, beaver season changes

To whom it may concern,

The New York State Trappers Association (NYSTA), as a major representative of New York’s fur trappers, would like to herewith provide our official comments regarding the Department’s Proposed Rule Making changes to 6 NYCRR Parts 6.1 and 6.2, ECL Sections 11-0301, 11-0303, 11-1101, and 11-1103 regarding the amendments to change trapping season dates in New York State for mink, muskrat, and beaver as published in the New York State Register on June 3, 2020.

The NYSTA and the NYSTA Joint Trapping Initiative Committee would first like to express our sincere appreciation for the expenditure of time, energy, and resources that the Department’s Furbearer Management Team (FMT), biologists, and all other Department personnel committed to the research that led to the development of this proposal.  We do have serious concerns that quite possibly, due to the Covid 19 virus effects on everything in our world today, that the Department may not receive an adequate quantity of responses to this proposed rule making from New York’s trappers.  Our concerns are based upon the great restrictions on social activity placed on all of us, beginning well before the publication of this proposal in the New York State Register.  We hope that this is an incorrect assessment and that the Department receives a significant number of responses upon which to base a sound final decision regarding these important proposed changes.
We applaud the Department’s decision to, wherever supported by sound science, align the opening and closing dates of all water seasons for the reasons stipulated.  Trappers, as true conservationists, are especially pleased that fur quality and primeness are being taken into account in the decision making processes that determined the results.  As true stewards of our natural wildlife resources; population management, conservation, the wise and responsible harvest and use of our valuable and abundant furbearer species is of utmost importance to the NYSTA and it’s membership.
Regarding the proposed changes to Part 6.1 outlining changes to the trapping season dates for beaver in New York:
We completely support all of the proposed changes to Part 6.1 with but one exception.  At the time of the joint meeting between our JTI Committee and the Department’s Furbearer Management Team on September 24, 2019, we were told that the proposal for the beaver trapping season in the Northern Zone WMUs  of 5A, 5C, 5F, 5G, 5H, 5J, 6A, 6C, 6F, 6G, 6H, 6J, 6K, and 6N would run completely concurrently with the mink and muskrat trapping seasons in those WMUs.  The proposed opening date presented to us was November 1 and the proposed closing date presented was April 15.  The JTI and FMT members unanimously agreed that was a very smart change, based on sound science and wildlife management principals, that supported the best interests of all concerned parties.  This would completely align all water trapping seasons in those WMUs, providing consistency, lack of confusion, and more opportunity for fur trappers to harvest and utilize beavers that otherwise are likely to be removed and destroyed under nuisance permits.  The NYSTA would ask that the Department and the FMT reconsider utilizing April 15 as the closing date of the beaver trapping season in the aforementioned WMUs for the reasons already presented.
Regarding the proposed changes to Part 6.2 that provide for changes to trapping season dates for mink and muskrat in New York:
1. The NYSTA fully supports the opening date of November 1 and closing date of April 15 that the Department has proposed for mink and muskrat trapping seasons in WMUs 5A, 5C, 5F, 5G, 5H, 5J, 6A, 6C, 6F, 6G, 6H, 6J, 6K, 6N, and 7A.  The current opening date of October 25 has, for far too long, allowed the harvesting of mink and muskrats that were of unprime and inferior quality.  We are very pleased to see that the Department has proposed this change of season dates which better promotes responsible and wise harvesting and utilization of our abundant furbearer resources here in New York.
2. The NYSTA completely agrees with the Department’s decision to make no changes to the current opening and closing dates of mink and muskrat trapping seasons in the WMUs where the seasons are currently November 10 – April 7.   (Southeastern NY)
3.  The input the NYSTA received from Central and Western Southern Zone mink and muskrat trappers was divided Regionally.  In the Southern Zone Region 7 WMUs of  7F, 7H, 7J, 7M, 7P, 7R, and 7S the majority of member trappers supported the Department’s proposal for opening mink and muskrat trapping seasons on November 10 with a closing date of February 15 which would align the mink and muskrat season opening dates with that of the beaver trapping season.  The NYSTA supports this position for our trapper members of the above listed WMUs.  We would like the Department to note that from those same trappers there was much discussion about why the Department had not proposed a completely concurrent trapping season for mink, muskrat, and beaver of November 10 – April 7 which would align those season dates, helping to eliminate confusion and eliminate most of the law enforcement challenges.
4. The NYSTA, based on considerable feedback from the Western Southern Zone Region 8 and Region 9  mink and muskrat trappers, cannot support the proposed opening date of November 10 for the mink and muskrat trapping seasons in Western New York without violating the trust our member trappers have placed in us to represent them.  The Department is well aware that Western New York mink and muskrat trappers have been requesting both the Department and the NYSTA to pursue a longer trapping season for mink and muskrat in those regions for many, many years.  Most have requested only two additional weeks, mainly because of the very unpredictable weather and the fact that those trappers have a much shorter harvest season than the rest of the state.  However, after recently discussing this proposed change directly with numerous trappers in that area of New York State once again, there is a consensus of opinion that those trappers are only interested in changing the present season structure by changing the closing date to February 28 while maintaining an opening date of November 25.  Although those trappers would enjoy seeing two additional weeks of opportunity to trap mink and muskrat, and they genuinely appreciate the Department’s attempt to provide that, those trappers stated they could NOT support the proposed earlier opening date of November 10.  Each trapper emphatically stated that given only the options of leaving the mink and muskrat trapping season as it is currently or changing it as proposed, they would have to choose no changes to the current opening and closing dates in Western New York.  As previously stated, if the Department was to offer the Western New York mink and muskrat trappers a two week longer season that would extend their seasons until February 28, while maintaining the current opening date of November 25, all of the trappers we spoke with would offer their full support for such a change and the NYSTA would support that change as well.  Several of the trappers who voiced their opinion sited the potential for difficult, and even dangerous, conflicts with other sportsmen such as waterfowl and deer hunters that would be afield in the marshes at the same time as trappers (sited from personal past experiences).  Most also stated that they didn’t want to see mink and muskrat harvested when the fur was yet unprime and the young of the year muskrats had not been allowed to grow nearer their full adult size.
The New York State Trappers Association would like to sincerely thank the Department for providing this important opportunity to submit comments on these proposals.
Respectfully submitted for the New York State Trappers Association,
John Rockwood
JTI Committee Chairman
New York State Trappers Association
114 County Route 30A
Williamstown, NY 13493
Phone: 315-415-4946