Science is missing from the bear and cougar proposals

By Mary Katherine Ray, Chapter Wildlife chair

After listening to the representative for New Mexico Game and Fish and testimony at Game Commission meetings and reading public comments received by the agency, one thing is clear: Everyone wants the hunting quotas of bears and cougars to be based on science. But what is also clear is that not everyone knows what constitutes actual science.

Some believe that if New Mexico Game and Fish claims a thing to be valid, then it must be valid. This is not science. This is placing a faith or belief in the agency’s claims without scrutinizing its methods or results. Science requires evidence that can be examined by everyone. It requires that calculations and results be transparently obtained.

Let’s examine the science behind the cougar kill quotas, for instance. This is the number of cougars that Game and Fish says can be killed in each “cougar management” zone without harming the cougar population in that zone. In 2010, the agency changed the way it estimated cougar populations based on non-published and non-peer-reviewed methodology that found that cougar densities and thus the cougar population in New Mexico was much higher than previously supposed. Since the kill quotas are based on a percentage of the population, those quotas also went up.

In 2017, the agency used a different methodology to estimate the population in cougar-management zone F. This resulted in a published, peer-reviewed paper — in other words, valid science. This research found that the 2010 estimate of the cougar population in Zone F was too high by 69%. Instead of an intended 25% harvest rate, the quotas had actually been allowing an 82% harvest rate — a severe overkill. In 2019, New Mexico Game and Fish implemented an emergency reduction of the cougar kill quota in that zone.

Then the agency reapplied the new methodology to Zone F and expanded the study area to include Zone B. Not only were the previous results for Zone F verified, but the population of Zone B was found to have been overestimated by 73%. And the kill quotas were actually allowing hunting of over three times the number of cougars that would be sustainable. The agency’s response was to combine zones F and B into one zone (the current Zone B) and reduce the kill quotas to match the new population estimate in that zone.

In 2021, the new, peer-reviewed methodology was applied to cougar Zone Q. Not surprisingly, once again, the cougar population was found to be much lower than estimated using the 2010 model, and thus the kill quotas were again found to be too high. This is why in the new cougar rule being proposed this year, the kill quota for Zone Q is being reduced by 50%.

Thus, three studies in three separate cougar-management zones that all used the same peer-reviewed scientific methods to produce accurate and precise results, all of which were conducted within the last six years, have overwhelmingly demonstrated that the population estimates from 2010 are severely inaccurate, grossly unreliable, and have consistently overestimated local cougar population sizes and the quotas based on these population sizes have been far too high. Yet the agency continues to rely on that unvalidated 2010 methodology that was never externally or independently peer-reviewed to derive cougar population sizes and prescribe hunting limits for the 16 other cougar-management zones. To say that the cougar hunting allowed in these 16 zones is based on valid science, or is conservation-minded, is patently false.

To estimate the population of black bears, New Mexico Game and Fish has begun to use the acceptable methodology of collecting bear hair samples as bears pass through baited stations rimmed with barbed wire set up at intervals in the study area. However, while the methodology is sound, its application may not be. The agency won’t reveal how the density determinations have been used to produce a population estimate. What is the size of the area? Instead, we are told that bear-management Zone 10, which encompasses the greater Gila bioregion, despite the drought and destructive fires of recent years, can support the killing of 35% more bears. The agency is also proposing to allow the killing of 6% more bears in Zone 1 in Northern NM. In neither instance can the public see the scientific details or justifications for these proposals. We are to take them on faith. This is not science.

The hallmarks of science demand that the way population estimates are derived and kill quotas set be transparent. There should be a management plan with clearly stated measurable objectives. It should all be open to external review especially by experts. In the case of the bear kill quotas and most of the cougar kill quotas, these hallmarks are missing. Except for three cougar-hunting zones, everyone who says they support the use of science when it comes to setting bear and cougar kill quotas in New Mexico by definition cannot support what NM Game and Fish is proposing to allow for the next four years.

Take action

The final decision won’t be made until the Oct. 27 Game Commission meeting. To participate via Zoom, go to www.wildlife.state.nm.us/commission/webcast/ for instructions a few days beforehand.
You may also still submit written comments about the hunting proposals until Oct. 27 at DGF-BearCougar-Rules@state.nm.us.

Read more

You are invited to read the highly detailed and referenced comment letters outlining the inadequacy of NM Game and Fish plans both for bears and for cougars submitted jointly by the Rio Grande Chapter of Sierra Club, Animal Protection of New Mexico, and the Humane Society of the US.
Comments on NMDGF’s cougar (Puma concolor) four-year rulemaking process
Comments on NMDGF’s black bear (Ursus americanus) four-year rulemaking process

Science is missing from the bear and cougar proposals