A group representing the interests of snowmobilers across New York State is opposed to a proposed change in state hunting regulations that would create an extra week for hunting deer with bows and muzzleloaders during the Christmas holiday week.
The state Department of Environmental Conservation recently announce it was considering an extension of the fall’s deer hunting season to include a “Holiday Deer Hunt” from Dec. 26 through Jan.1 in the Southern Zone only. DEC is taking public comments on the proposal until Nov. 8.
The New York State Snowmobile Association is opposed to the new season for several reasons, saying it would shorten the snowmobile season by a week and would have “a direct negative impact on rural areas” that depend on revenues from the popular winter sport.
“Many small businesses depend on snowmobile activity for their livelihood. This proposal will result in a one-week delay in that economic activity starting,” said Dominic Jancangelo, executive director of the Snowmobile Association. "We estimate that losing one week of snowmobiling in New York’s Southern Zone may cause a loss of up to $13 million in direct spending by snowmobilers and a potential $1 million dollar loss in sales tax revenue.
“The snowmobile industry has been hurt by the last few years of low snow and frequent winter rain. The businesses associated with our activities are feeling this impact and many are just hanging on.”
In addition, adding an extra week of hunting could have negative impacts on the relationships snowmobilers have with private property owners for access and interfere with snowmobile clubs' efforts to prepare and put up signs for safe snowmobiling on trails, Jancangelo said.
He recommended the DEC delay its decision, conduct public hearings on the proposal and as an alternative try it out a pilot program in the lower Hudson Valley/Catskills area.
The Snowmobile Association advocates on behalf of the more than 220 snowmobile clubs who maintain over 10,400 miles of trails (mostly on private property) on which over 100,000 snowmobilers ride each year. The snowmobile season in the state traditionally starts at the end of the big game hunting seasons each year as a courtesy to landowners and/or the landowners requests.
This year, the late muzzleloading/bowhunting seasons in the Southern Zone span nine days from Dec. 14 to Dec. 22. The special seasons follows the regular firearms season, which is from Nov. 21 to Dec. 13.
According to DEC, the proposal is not being considered in the Northern Zone, as “deer may already be moving to wintering areas by late December. Hunting seasons that occur when deer are migrating or are already concentrated in wintering areas could result in localized over-harvest.”
The following are excerpts from a letter consisting of talking points that Jacangelo sent out to snowmobile clubs, encouraging them to voice opposition to the DEC’s proposal.
1.The proposal will have a direct negative impact on the snowmobile season.
The DEC maintains the proposal will not impact when snowmobile trails will open. “Snowmobile trails are opened following the end of the regular big game hunting season subject to adequate snow cover and local agreements," the agency said in a news release announcing the proposal.
The Snowmobile Association disagrees.
"Each year snowmobile clubs work with thousands of landowners to gain their permission to operate a snowmobile trail on their land. These landowners generously give permission to the clubs and require certain conditions. The most common conditions are to do trail work before Oct. 1 and to not open trails to snowmobilers until deer hunting is over. Therefore, while it is not the direct objective of this proposed regulation, this proposal will in effect shorten the snowmobiling season in the southern zone by one week.
"We, as an organization, have worked diligently to educate riders to not use trails until after Dec. 20. The proposal as presented would require our organization to reeducate riders. Many riders will ignore the wishes of the club and the landowner and jeopardize the use of the private property. It only takes the action of one landowner to permanently shut miles of trail. More than 80 percent of all trails statewide are on private land.
2. The proposal is not timely.
“The proposed rulemaking expressly states that a deer management plan will be released in the latter part of 2020. As the Department will be releasing a complete deer management plan later this year, this proposal should be held until comments are received on the entire proposed plan so that the impacts of all the department’s actions can be collectively analyzed. According to recent DEC press releases, New York has experienced a significant increase in the sale of hunting licenses. The department should take no action on increasing opportunity to take deer until the impacts of increased hunting activities from this year’s high sales of licenses are assessed and publicly released.”
3. The proposal will interfere with clubs' efforts to properly prepare trails for safe snowmobiling and could result in less than optimum trail signing.
“Snowmobile clubs utilize late September to ready their trails for the coming season. They attempt to sign their trails and remove blowdown during this period. Generally, clubs must be out of the trails by Oct. 1, due to the start of hunting season. Clubs then return to their trails in late December when deer hunting season ends to remove new blowdown and to install the remaining signage. If deer hunting season extends into January, many clubs will find it difficult -- if not impossible- to install trail signposts and work through what could be significant snow and frozen ground.”
4. The snowmobiling season is restricted from beginning during hunting season.
The snowmobiling season in New York begins when snowmobile clubs and private landowners agree that the trails are suitable for snowmobile operations. This typically occurs when local areas have a sufficient amount of snowfall. Traditionally, snowmobile clubs, which vary in the geographical areas of trail coverage, do not open their trails until hunting season is over as a courtesy to landowners and at the landowners' request. Many landowners perceive that giving permission for both activities to occur will expose them to litigation should one user injure the other. Given the distance that snowmobilers cover in a riding day, it has become a necessity to keep all trails in an area either open or closed – but they are not required to do so. Since not all clubs and private landowners in the Southern Zone are prohibited from operating in the hunting season, this proposed regulation may create unnecessary risks for snowmobilers and hunters in certain parts of the Southern Zone. For safety, all clubs choose to not open their trails until hunting is concluded.
"During our discussions with the Department on this topic it has been brought up several times why “is this conflict not an issue during small game season.” For the most part small game do not exhibit the same sensitivity to human scent that deer exhibit nor is their flee zone as large as a deer. Landowners who hunt have experienced deer being driven away by uninvited snowmobile use. Hence the interest of both the landowner and the club to keep active snowmobiling away until hunting has concluded.
5. The proposal will have negative impacts on local government.
"Some local governments have adopted local laws establishing a snowmobile season (Oneida County). These local laws were developed in consultation with landowners and the snowmobile community. Most of these local laws refer to the snowmobile season as starting when big game season is over. These local laws do not refer to “regular” big game season. This proposed state regulation would require local governments to amend their local laws reflect this new additional week of hunting and would therefore create additional expenses for cash-strapped local governments, who are already facing significant cost reductions due to the pandemic.
“In addition, some local governments cannot predict if an extended season would change their approach to seasonal roads. They may receive demands to keep roads open and maintained so that individuals can participate in this longbow and muzzle loading season, further exacerbating cost concerns.”
6. NYSSA would like to work with the Department on viable alternatives to this regulatory proposal.
"First, we would recommend that the DEC delay this proposal while it conducts public hearings to address the concerns of stakeholders regarding this proposal. We would (also) recommend that as an alternative, the Department narrow this proposal to those counties in the lower Hudson Valley and Catskill Area (Green, Columbia, Ulster, Dutchess, Sullivan, Orange, Putnam and Rockland counties).
“This would allow the state to provide a meaningful test of the proposal, while not impacting the majority of the State’s snowmobiling industry and the economic impact that snowmobiling attracts.”
**Comments on the DEC’s proposed 'Holiday Deer Hunt’ can be submitted by email (WildlifeRegs@dec.ny.gov and be sure and put “Holiday Deer Hunt Proposal” in the subject box), or by writing to: Jeremy Hurst, NYSDEC Bureau of Wildlife, 625 Broadway, 5th Floor, Albany, NY 12233-4754.