Dear Virginia Dog Owners,

The question "Is the Virginia Department of Game and Inland Fisheries (DGIF) anti-hunting dog?" requires serious consideration. Historically, such a suggestion would be unthinkable, but times and personnel change. Animal rightist phraseology and politically correct policy statements from DGIF have increased from a zero base. Recent actions and today's proposals against retriever owners and houndsmen may simply be due the fact that virtually no one in authority at DGIF has ever trained a hunting breed or hunted one to any significant degree. If that's the case, such deficiencies may be corrected, with the proper motivation. If the problem is deeper, other remedies will be required. More than 200,000 Virginians hunt with dogs and help fund the agency. It's time that DGIF better understood their sport and one of its principal constituencies.

The last three hunting regulation changes, in 2003, 2005 and 2007, amply illustrate DGIF's ignorance of dog training and hunting. It's personnel may own pets, but know nothing about trained canines. Compounding this concern, DGIF's regulatory process is largely a closed one; key meetings of staff and Board members with non-department personnel and others about specific regulatory changes aren't recorded in accessible dockets. Only a portion of emailed comments are archived. Submitted written regulation comments and data are hidden from view. What should be a completely transparent, fact-based procedure is not. The letter and spirit of the Virginia Administrative Code governing rulemaking procedures appears routinely ignored.

As background, controversial 2003 and 2005 hunting dog regulations included.
2003.
VHDOA's pointing dog winter training request at field trial wildlife management areas - "misplaced."

4 VAC 15-40-284 Restrictions on use of pen-raised training birds and prohibitions on tracking collars; VHDOA filed comment (attached): "Basically your regulations' authors have little understanding of hunting dog training and use and, more disturbingly, may be influenced by animal rightists' anti-hunting dog propaganda.

2005.
4 VAC 15-40-200 Increased use of above ground body-gripping traps in excess of five inches; Technically flawed expansion of Conibear trap use from 5 inches to 6 1/2 inches maximum jaw spread. Significant Threat to Virginia's Hunting Dogs. See VHDOA filed comments at Proposed DGIF Regulation Poses Significant Threat to Virginia's Hunting Dogs
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Current 2007 rulemakings, with comments closing on September 24, 2007.

4 VAC 15-30-10 & 4VAC15-40-70 prohibition on the release of captive waterfowl and captive reared mallards; Prohibits the use of pen-raised mallards by individual dog trainers and at club training days. Specious DGIF rationale based on non-applicable report of regulation violations on licensed "mallard release areas (MRA)" permits licensed preserve and field trial releases, but bans equivalent private and club retriever training.
http://www.dgif.state.va.us/regulations/comment/expand.asp?VAC=030-010
http://www.dgif.state.va.us/regulations/comment/expand.asp?VAC=040-070

4 VAC 15-40-190 Eased restrictions on use of body-gripping traps in excess of 7½ inches.
Currently Conibear traps with jaw openings larger than 5 inches must be totally submerged under water or inside a "dog proof" box. This proposal permits the largest baited traps to be set in water only a 3-4 inches deep, seriously endangering small children and dogs. http://www.dgif.state.va.us/regulations/comment/view-comment.asp?id=459

4 VAC 15-110-10 Closed fox hunting - dogs only season in certain areas. Aligns the season dates for dog only fox hunting on designated public areas with the period when it is lawful to hunt foxes with firearms, severely reducing dog training days on those areas. http://www.dgif.state.va.us/regulations/comment/expand.asp?VAC=040-070

VAC 15 -XX-XX New rules on hunting with hounds. Nine-month DGIF orchestrated policy and regulatory review of bear, deer, raccoon and fox dog hunting and training. Facilitator-led stakeholder group consisting of hunters, dog men and women, landowners, anti-hunting animal rightists and others to develop recommendations for changed hound hunting rules. Hunting Hounds A predetermined result and cosmetic public process window dressing appear likely. VHDOA has very significant concerns with this planned study, its personnel, procedures and oversight. They are described below for your guidance.

----- Original Message -----
From: Bob Kane
To: J Carlton Courter III
Sent: Monday, August 20, 2007 1:17 PM
Subject: DGIF's Hound Hunting Task Force -- VHDOA Concerns

J. Carlton Courter, III
Director, Virginia Department of Game and Inland Fisheries
4010 West Broad Street
Richmond, Virginia 23230

Dear Director Courter,

On behalf of the Virginia Hunting Dog Owners' Association (VHDOA), I must express grave concerns over the nature and direction of the Department of Game and Inland Fisheries' (DGIF) Hound Hunting Task Force. Perhaps this plan is still under development, but Virginia sportsmen are left with the only writing on this subject on your website or in selective press accounts. That outline is most disturbing.

VHDOA's primary concerns are threefold:

1. The regulatory development model previously used by the department for the deer and black bear management plans is in no way appropriate to address the issues surrounding hound hunting. The issues and the proper resolution methodologies are so different, they're profound. The plan and the personnel employed require fundamental change.

2. DGIF's existing rulemaking methodology lacks transparency and the results frequently aren't supported by the available analysis or data. This credibility problem has worsened most recently, as demonstrated by the failure to establish accessible dockets or file (docket) appropriate rulemaking materials, as well as the complete and unacknowledged abuse of DGIF's Internet regulation comment system.

3. DGIF's Board is not sufficiently invested in this process. Without greater evidence that the Task Force process isn't designed to generate a predetermined result, Virginia hunting sportsmen have limited incentive to participate in the currently outlined program or support the Task Force's conclusions.

I proffer these comments based on a twenty-five-year (25) career writing, enforcing and commenting on significant public rulemakings, including nine months participation in an adversarial federal regulatory binding negotiation involving professional facilitators and multiple stakeholders, including those representing the White House. Since retirement, I've devoted countless hours to opposing animal rightists and anti-hunters here in Virginia and elsewhere.

This Hound Hunting Task Force will likely be the defining event of your term as Director. DGIF lost considerable support among Old Dominion sportsmen due the financial and personnel mismanagement of the previous director. In the face of declining numbers of hunters and concerns over the department's priorities and direction, it would be a tragedy to further compound that loss of support.

As in the past, the Virginia Hunting Dog Owners' Association looks forward to working with DGIF to preserve our treasured hunting traditions. Should you wish to discuss these concerns and exchange ideas, I may be reached at 540-543-2312.

Sincerely,

Bob Kane, President
Virginia Hunting Dog Owners' Association

ACTION REQUEST:
Before September 24, 2007
1. Review the four hunting dog proposed regulations above at the cited URLs. File your comments on these proposals, addressing them to RegComments@dgif.virginia.gov and providing your name, address, and telephone number. Copy and paste the following addresses and send cc copies of every docket comment to the DGIF Board and Director.
Mary Louisa Pollard- nnlc@kaballero.com; Richard Railey- raileyrailey@beldar.com; Sherry Crumley- sscrumley@aol.com; John W. Montgomery, Jr.- jmontgomery@jwm-law.com; James W. Hazel- James.Hazel@dgif.virginia.gov; Randy Kozuch- rkozuch@nrahq.org; Charles S. Yates- Charles.Yates@dgif.virginia.gov; Charles T "C.T." Hill- CT.Hill@dgif.virginia.gov; Thomas A. Stroup- tstroup@squareLoop.com; William T. "Billy" Greer- WTGreer@vwc.edu; Ward Burton- Ward.Burton@dgif.virginia.gov; J Carlton Courter III- carlton.courter@dgif.virginia.gov

2. Communicate your concerns with DGIF rulemakings to your personal Delegate and Senator VA Legislator Contacts and request they also file timely opposition comments and supply you with a copy.

Help protect your sport. The Humane Society of the U.S. (HSUS) and its anti-hunting allies have consistently targeted hound hunting for elimination. Make your voice heard in Richmond!

Freely forward and cross post this message.

Sincerely,
Bob Kane, President
Virginia Hunting Dog Owners' Association
http://vhdoa.uplandbirddog.com/