LSBA Secretary, Dora Cook, and I will be attending the meeting tomorrow at Sam Houston National Forest office in New Waverly. The following is the LSBA's letter concerning this issue:
May 18, 2014
Mark Van Every Via email:
mailroom_r8_texas@fs.fed.us
Forest Supervisor
NATIONAL FORESTS AND GRASSLANDS IN TEXAS
2221 North Raquet Street
Lufkin, Texas 75904
Warren Oja Via email:
woja@fs.fed.us
District Ranger
SAM HOUSTON NATIONAL FOREST
394 FM 1375 West
New Waverly, Texas 77358
RE: Expiration of Order 08-13-00-09-06
Dear Sirs:
The Lone Star Bowhunters Association is the state bowhunting organization of Texas, which has been preserving and promoting bowhunting since 1974. It is my understanding that Order 08-13-00-09-06, which prohibited dispersed camping in the National Forests and Grasslands (except Wise Co.) from September 15th - January 15th except in designated campsites only, expired on February 1, 2014. In addition, the order also prohibited possessing a loaded firearm within or on a motor vehicle, in a designated campsite, a designated vehicle parking area, a designated boat launching facility or area, a Texas Parks and Wildlife Department or U.S. Forest Service Check Station, a designated archery-only area, except the possession of a handgun by a person who holds a valid Texas CHL and prohibited being under the influence of alcohol or consuming alcoholic beverages while engaged in hunting activities or publicly consuming or displaying an alcoholic beverage.
It is the Lone Star Bowhunters Association’s (hereinafter referred to as “LSBA”) position that Order 08-13-00-09-96 be reinstated as previously written, in its entirety, for the safety and welfare of all users, both hunting and recreation, of the National Forests and Grasslands of Texas and in the interest of public safety. By allowing dispersed camping from September 15th – January 15th, both hunters and other recreationists will be put in harm’s way, not only from hunters and other recreationists on the public Wildlife Management Area of the Sam Houston National Forest, but also hunters and target shooters on private land adjacent to the National Forest. While it is the responsibility of the hunter to identify their target prior to releasing a shot, there are other instances such as pass-throughs, misses, ricochets, etc., that must be considered, as well as a camper being startled by an early morning or late evening encounter with a hunter passing by their campsite on their way to and from their stand. Safety is the number one concern of the LSBA. This past hunting season, a Texas State Game Warden, who was off duty and bowhunting on public land at the Cooper WMA was shot and seriously injured by target shooters, who were on private property. Just as I would not send my child to a summer camp that offered camping, hiking, pack-backing, etc., while others were hunting, I would expect and encourage the National Forests and Grasslands of Texas to do the same with the general public that utilizes the public land in different ways. One preventable injury or death is one too many.
Texas Parks and Wildlife has 49 Wildlife Management Areas encompassing some 769,242 acres of land and dispersed camping is prohibited 365 days a year, except in units 901, 902, 903, 904 and 905, which are units in the National Forests and Grasslands of Texas. Obviously, there is a reason that dispersed camping is not allowed in TPWD WMAs and I believe that it has to be because of safety.
The Eastern National Forests and Grasslands, which includes Texas, started out as the lands that nobody wanted and have developed into the lands wanted by many multi-users of the public land system. Unfortunately, the great state of Texas ranks 47th out of 50 in the amount of public land owned by the State and/or Federal Governments. Texas has approximately three percent (3%) public land and 97% is privately owned. The National Forests and Grasslands are the only opportunity many hunters have to hunt white-tail deer, hogs, turkey, squirrels, etc. Each hunter must purchase a $48.00 Annual Public Hunting (APH) permit to hunt Wildlife Management Areas in Texas. Other recreationists are not required to have any type of permit. According to Texas Parks and Wildlife,
“The entire Sam Houston National Forest is designated as a wildlife management area through a cooperative agreement between Texas Parks and Wildlife Department and the U.S. Forest Service. This special designation provides benefits to those who use the Sam Houston National Forest, including hunters, and to the wildlife that live or forage there. Extra fees paid by the hunters who use wildlife management areas are collected by Texas Parks and Wildlife Department and are returned to the Forest Service for use in those areas. These funds pay for a variety of programs to improve wildlife habitat and other enhancement programs such as wild turkey restoration, creation of wildlife openings and additional law enforcement. They can be used to gather and analyze data to improve wildlife habitat. Those who wish to hunt deer or small game in the Sam Houston National Forest must purchase the appropriate wildlife management area hunting permit available where state hunting licenses are sold…”
The LSBA respects and understands that public lands are for the use of many recreationists. Many of our members utilize the public lands for other activities other than hunting. Currently, the Lone Star Hiking Trail and the other trails in Sam Houston National Forest, as well as fishing, wildlife viewing and camping, etc., are open 365 day per year, including hunting season, to all recreationists. A biking trail was recently built in Compartment 57, which is the archery-only area. The Lone Star Hiking Trail also runs through this compartment. If dispersed camping is allowed from September 15th – January 15th in the archery-only compartment and other areas of Sam Houston National Forest, it will give very little if not any room for bowhunters and some firearm hunters to have an opportunity to successfully hunt. As per 36 CFR Ch. II §261.10(d)(1), The following are prohibited: discharging a firearm or any other implement capable of taking human life, causing injury, or damaging property as follows: In or within 150 yards of a residence, building, campsite, developed recreation site or occupied area, or…” There will be a 150 yard buffer zone from any dispersed campsites, which could prevent hunters, who have spent time and money scouting and setting up in an area from being able to hunt it on any given day of hunting season, if a camper chooses to set up in the area. On August 29, 2007, a Memorandum of Understanding was signed by Joel D. Holtrip, Deputy Chief for National Forest System and John C. Twiss, Director of Law Enforcement and Investigation, that’s purpose was to revitalize the relationship with the Shooting Sports Roundtable and bring additional resources to bear on problem solving, and identify opportunities for shooting sports enthusiasts. Signatories included the Bureau of Land Management, U.S. Fish and Wildlife Service and the 40 hunting/conservation organizations of American Wildlife Conservation Partners. Shooting sports are long standing and appropriate uses of National Forest System lands. With ever increasing population, use, and urban interface development affecting the National Forest System lands, we must, now more than ever, work with our partners to facilitate safe and responsible use. Again, the LSBA is requesting that the National Forests and Grasslands of Texas reinstate Order Number 08-13-00-09-06, in full and as previously written for the safety and welfare of all users of the National Forests and Grasslands System.
Looking forward to the proposed 10 and 20 year trail plans of the Sam Houston National Forest, it would seem that the trails that are being considered, will close or preclude many areas from hunting because of the 150 yard buffer zone mentioned previously. From the announcement of the launch of the Sam Houston Trail Coalition, it discusses the mapping process of additional trails. It goes on to state that Sam Houston National Forest is 161,154 acre pine forest enjoyed by fishermen, swimmers, and canoe and kayak paddlers. It seems that the one group who contributes money through the purchases of their hunting licenses and taxes on hunting gear and equipment, in addition to the APH permit, for improvement to wildlife habitat and other enhancement programs and additional law enforcement is not being considered in the future plan of the National Forest.
Currently, the fifth largest national forest in the United States, Tonto National Forest, in Arizona, is considering closing areas to hunting and shooting because of the urbanization of the forest and the 5.8 million multi-users, who utilize the three million acres. The LSBA does not want to see this happen with the National Forests and Grasslands of Texas and asks that all hunters and recreationists be considered in revision plans, so that we can all safely and responsibly continue to utilize the natural resources of the great state of Texas.
In addition, dispersed camping will also make it more difficult and dangerous for law enforcement to enforce rules and regulations. Currently, federal and state game wardens can enter into the designated campsites and/or stop the vehicles entering or leaving the Sam Houston National Forests to check for violations. Dispersed camping will make it easier for homesteading of land, harassment of hunters and other illegal activity. Again, dispersed camping will make the National Forests and Grasslands unsafe and dangerous for the multi-users and law enforcement.
The traditional and popular pursuits of hunting and shooting are public values that must be protected and the Lone Star Bowhunters Association is asking that Order Number 08-13-00-09-06 be reinstated as is for the safety of hunters, multi-use recreationist and the general public.
However, should the order not be reinstated as is, the LSBA is asking that scoping meetings and public comment be a requirement through the NEPA process as the WMA area will be greatly impacted by additional campers and less wildlife being taken from the WMA.
Thank you for your consideration. If you have any questions or comments, please do not hesitate to contact me.
Yours in bowhunting,
Dena Kana
President
Lone Star Bowhunters Association
xc: Carter Smith Via email:
carter.smith@tpwd.texas.gov
TEXAS PARKS & WILDLIFE DEPARTMENT
Bill Adams Via email
robert.adams@twpd.texas.gov
TEXAS PARKS & WILDLIFE DEPARTMENT
National Forests & Grasslands in Texas~Changes Affecting Bowhunting/Hunting
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