The Danger Of Disinformation: Why Washington Cougar, Bear Petition Should Be Denied

By Jillian Garrett

In October 2023, a coalition of special interest groups including Washington Wildlife First, Mountain Lion Foundation, Center for Biological Diversity and The Humane Society of the United States submitted a petition for consideration to the Washington Fish & Wildlife Commission. The 76-page petition essentially sought to reverse much of the commission’s recent decisions pertaining to bear and cougar hunting regulations. It also asserted that “the Commission approved rule changes to … bear and cougar hunting that were based on politics, not science, disregarding the professional judgement of its own experts to respond to ‘social political stress’ from a small group of Washington residents.”1 


The irony in that statement will be apparent to those hunters familiar with the loss of the spring bear season.

In short, the petition demanded the following actions:

(1) reverse the decisions made in 2019 and 2020 to increase bear and cougar hunting to unsustainable levels;

(2) compensate for the dramatic increase in the “management” kills of cougars by ensuring that all sources of human-caused mortality are considered when calculating cougar hunting guidelines;

(3) provide for the immediate closure of cougar hunting once total mortality has reached the maximum hunting guideline in each PMU;

(4) standardize bear hunting seasons statewide to run from September 1 through November 15, and institute a statewide “bag limit” of one bear per hunter;

(5) provide for better compliance with mandatory reporting rules; and

(6) specify that the new rules will sunset at the conclusion of the 2026-27 hunting season, to ensure that cougar and bear hunting levels will be reexamined during the next three-year season-setting process.2

THE PETITION MADE REPEATED ASSERTIONS that bear and cougar hunting is currently set at “unsustainable” levels, which is an inaccurate description, given that bear populations have been deemed by biologists to be relatively stable or potentially even increasing, and assessment of harvest trends – a good indicator of population levels – do not show signs of overharvest within management units.3 

The same could also be said for the state’s cougars. In addition to showing signs of a healthy population, cougars are extremely difficult to hunt and wide-ranging in nature, meaning that (in the words of one biologist) they “cannot be persecuted enough to extirpate them from the landscape,” because there will always be surrounding source populations to draw from which will migrate in and repopulate an area.

Cougars are generally solitary animals, with adult males maintaining and defending large territories. This type of social structure helps to keep out the juvenile male dispersers that are more often associated with conflict/depredation complaints. Killing an adult male does temporarily increase cougar density within that given area as subadult males arrive to try and lay claim to the newly vacated territory. It’s a bit like what happens when an apartment becomes available in New York City – everyone wants to try and rent the space. 

The bigger issue is not necessarily the arrival of subadult males into an area, but rather the development and encroachment of humans into cougar habitat, which greatly increases the chance of possible conflict (in addition to increased nonharvest mortalities such as roadkill). This situation is further exacerbated by the fact that the “edge habitat” created by housing developments generates an ideal habitat for prey species such as deer, increasing the likelihood of human-cougar conflicts. In this consideration, the social carrying capacity of cougars on the landscape may be reached long before their biological carrying capacity – meaning that the limit of public tolerance for conflicts may be reached even if the available habitat can still support more cougars. Surpassing the limits of social tolerance can have devastating effects on current cougar populations, resulting in more agency lethal removals as well as unreported kills by residents dealing with increased conflict. Walking the line between biological population goals and social carrying capacity is a delicate one.

At least one of the studies relied upon by the petition, which asserts that hunting has an adverse effect on the number of livestock depredations and conflict complaints, further implying that each cougar killed increased the odds of conflict by 50 percent or more,4 was later shown to contain inaccurate conclusions by a scientific review team. “Most results were, however, uninformative because papers were based on convenient but questionable data, design flaws, or misapplied methods; the papers offered few compelling insights into the effects of recreational harvest and agency removals on interactions between cougars and people,”5 according to a scientific review of relevant available literature (of which this study was included in the assessment). Furthermore, because the study did not hold up under peer review, it would also not count as the best available science.

Cougar mortalities related to conflict removals were originally built into the state guidelines used for harvest. In recent years, the number of conflict-related mortalities has risen and may necessitate reexamining in the future. However, these conflict mortalities are not necessarily associated with an increase in hunting pressure, but rather an increase in social pressure – the social carrying capacity of the landscape as mentioned earlier.

As a population, cougars are difficult to count because they are highly mobile and range frequently across large territories. Density estimates (the number of cougars within a set area) are conservative and are currently used to approximate population size, but these can be more of a point-in-time estimate as opposed to a static count. To help account for this, the state is broken into smaller population management units (PMUs) for cougars – as opposed to larger regional management units – which has the added benefit of maximizing hunting opportunity while decreasing hunting pressure (by dispersing hunters more evenly across the landscape, even after a PMU closes) and therefore maintaining more of a sustainable harvest. 

The cougar season is currently broken up into two separate timelines: a fall “general” season spanning September 1 to December 31, and a “late” spring season running from January 1 to April 30. Current hunter success rates for cougars tends to be low, and over the past five years, an average of 74 percent of the PMUs have remained open through the end of the late (or spring) general cougar season.6 One reason to keep PMUs open during the general fall season – even if the harvest guideline is reached – is to maintain the mandate for increased hunting opportunity as well as better hunter reporting. Many hunters are already out during this time hunting deer and elk, where cougars are often harvested as a byproduct of that time in the woods and are not the main target. These hunters, often spending a week or more in remote areas, may not have cell service or internet to check if a PMU is still open or to immediately report a cougar harvest. During the late season, fewer hunters are in the woods, and those who are tend to be stay out for shorter spans and are specifically targeting cougars, thus making it easier to have stricter reporting guidelines.

THE GOAL OF THE 2020 DECISION-MAKING PROCESS on cougar regulations sought to honor the Washington Fish & Wildlife Commission’s mandate to provide – or in this case, maximize – hunting opportunity (something the petition conveniently left out when referring to the commission’s legal mandate). The commission had asked state biologists to come up with options for increasing cougar hunting opportunity while still maintaining reasonable population goals. Before 2020, all cougars except kittens (classified as any animal younger than 18 months) were counted as part of the harvest guideline. The goal was to maintain adult cougars on the landscape. As subadults tend to be more migratory in their efforts to establish their own territory, they contributed little to that guideline, and on average only made up about 30 percent of the overall harvest. The 2020 management decision changed the harvest guidelines to only include adult cougars, classified as age 24 months or older – a mere 6-month age difference between the old and new guideline models. In addition, Washington requires hunters to submit harvested cougars for a mandatory inspecting and sealing of the pelt, as well as collection of a tooth to help determine the age of the animal. When the harvested cougars are brought in for the initial inspection, it is often easy to mistake a subadult animal for an adult one, an oversight that works in favor of the cougars when it comes to hitting adult-only guidelines.7

Politics began to direct cougar management in 1996, when Washington voters approved Initiative 655, which banned the use of dogs for hunting cougars. The petition made the statement that, upon the passing of I-655, the “WDFW immediately engineered a backlash … by taking steps to increase cougar mortality.” This statement is not only insulting to the hard work of state biologists, but willfully misleading. 

With the use of dogs banned and understanding that harvesting cougars is extremely difficult without it, there was an anticipated decrease in the number of cougar harvests, which could negatively impact management goals. As a result, WDFW replaced the limited permit-only season with a general season, increased the season length from 7.5 weeks to 7.5 months, and decreased the price of cougar tags. Prior to the I-655 ban, an in-state cougar tag cost $24 and an average of 1,000 tags were sold per year (1980-1995), resulting in an average harvest of 121 animals over a span of a seven-and-a-half-week season.8 This netted $24,000 in annual tag sales, or nearly $200 per harvested cougar.

When the cost of in-state cougar tags was decreased from $24 to $5 following the ban, tag sales increased to an average of 59,000 per year (1996-2011), yet harvest only increased to an average of 160 animals/year over a much longer seven-and-a-half month hunting season. Even if you assume that the number of tags sold only included in-state ones (nonresident cougar tags being far more expensive), this would still translate into a generated revenue of $295,000, or around $1,800 per cougar harvested. If you want to talk about hunters funding conservation, this is an excellent example. Interestingly, while tag sales spiked drastically (especially in the 2020-2022 seasons), hunter harvests and overall mortality numbers (which included lethal conflict removals) did not, potentially supporting the idea of just how difficult it is to successfully hunt cougars. 


MOVING ON TO BEARS, THE PETITION’S REQUEST to “standardize” the fall bear hunting season is misleading, as the season was already standardized statewide in 2019 to begin on August 1. This allows bear hunters to be out in the woods before the start of other hunting seasons, making it a safe and enjoyable activity and way to get an early start on filling the freezer. The true point of the petition’s request is instead to decrease the amount of time that hunters are allowed to harvest bears each season. Bears are already challenging to hunt, with hunter success in the fall ranging from 6 to 10 percent.9 Decreasing the season length would negatively impact a hunter’s ability to harvest an animal and could potentially lead to a decrease in selectivity as a result. Most bear hunters seek to harvest a mature and preferably male animal, which provides a maximum amount of meat and does not negatively impact the long-term population goals.

The second part of the petition’s request regarding bear management is to cap the annual statewide bag limit to one bear per hunter. This would reverse the 2019 decision, where WDFW increased the bag limit from one to two bears in Eastern Washington, and thus standardized a two-bear-per-hunter fall season limit. In 2019 and 2020, the fall general bear harvest increased approximately 40 percent statewide (from the previous 5-year span) before returning to the average harvest range in 2021. It is unclear if the addition of the second tag or the extended season length affected this temporary increase, but given that the harvest numbers eventually returned to a more normal range, should not be used as an argument for decreasing tag allotment or season length. Overall, the data indicates a growing bear population, as evidenced by increasing hunter success rates and decreasing days hunted per harvest, according to state wildlife biologists.

The one area of truth in this petition is the need for better hunter compliance when it comes to mandatory reporting, especially with black bear harvests. Hunters have been shamefully remiss in this, with general harvest reporting at only 65 percent, and a mere 25 percent of hunters comply with the mandatory tooth submission for black bears. In this, hunters are only doing themselves, and the wildlife they cherish, harm. Tooth submissions are a vital tool to help state biologists estimate bear populations and set hunting regulations. “Collecting teeth from harvested black bears is one of the least expensive and {most} time efficient tools managers have available to aid in harvest evaluation, and it fosters a working relationship with the hunting public, through engaging partners in management.”11 Hunter harvest submissions help support the argument that hunters play a crucial role in managing wildlife, by aiding state biologists with their data collection. Failing to comply with the mandatory reporting only hinders hunting as a viable management tool for the future. Yet the answer to increasing compliance isn’t necessarily stricter penalties, but better informational awareness campaigns and ways of making submissions easier (such as including tooth submission envelopes with bear tags at the time of purchase).

THE FINAL ACTION DEMANDED BY THE PETITION is the return of an end date to the bear and cougar hunting rules, so that the regulations will be re-examined in the next three-year season-setting process. The removal of those end dates (known as “sunset” dates) from the hunting regulations does not imply that it is a permanent law never to be reviewed. Game regulations are extensively reviewed on an annual cycle, in a process that begins with the district biologist, moves on to the regional managers, and then to the game section managers, the division manager, and the program director. If a conservation concern arises, the regulation will be opened and re-examined, regardless of when the concern is identified during the season-setting cycle. 

The fact that there is no sunset date to the regulations does not mean that they are enshrined in stone. In fact, the demand for the addition of sunset dates to the bear and cougar seasons should be deeply concerning to hunters. Spring bear season was ended by the Washington Fish and Wildlife Commission when it failed to renew the sunset date on the regulations. By demanding a return to the sunset date clause on predator hunting, this petition potentially pursues another tool to end hunting seasons without public notice, allowing history to repeat itself. 

At the end of the day, this petition seeks to drown out reason with verbiage, citing studies whose conclusions have since been shown to be inconclusive or inaccurate, and utilizes terms (such as “unsustainable”) that mislead the reader as to the true state of bear and cougar populations and their management. It unfairly attacks the very biologists and staff tasked with keeping our wildlife populations healthy, and it is yet another disinformation campaign that should be filed in the trash bin where it belongs.

Editor’s note: Filed in late October, the petition will likely be up for a commission decision on whether to begin rulemaking or not in late December 2023. Author Jillian Garrett is a hunter, farmer and conservationist living in Northeast Washington. She and her husband operate a regenerative farm with a focus on wildlife conservation through responsible land stewardship. Jillian’s writing and photography have also appeared in Sports Afield, Bear Hunting Magazine and Blue Ridge Farmer Magazine. A member of First Hunt Foundation, she remains passionate about the importance of mentorship within the hunting community.

Sources Referenced:

1,2 Washington Wildlife First, Mountain Lion Foundation, Center for Biological Diversity, & The Humane Society of the United States. “Petition to amend the Washington Administrative Code to reverse unscientific 2019-21 rule changes jeopardizing state bear and cougar populations.” PDF. October 2023.*barac5*_gcl_au*NTI2OTY2NDAxLjE2OTkwNDY5MDU. Assessed October 30, 2023.

3,9 Washington Department of Fish & Wildlife. “Responses prepared by WDFW staff to Commissioner Questions after on the Black Bear Spring Special Permit Rule.” PDF. November 2021. Assessed October 2023.

4 Peebles, K. A., R. B. Wielgus, B. T. Maletzke, and M. E. Swanson. 2013. “Effects of remedial sport hunting on cougar complaints and livestock depredations.” PloS One 8: e79713.

5 Human-Cougar Interactions Science Review Team. “Human-Cougar Interactions: A

Literature Review Related to Common Management Questions.” PDF. 2022. Assessed October 30, 2023.

6,11 Washington Department of Fish and Wildlife. 2022. 2022 Game status and trend report. Wildlife Program, Washington Department of Fish and Wildlife, Olympia, Washington, USA.

7 Aoude, Anis. Personal interview. 3 November 2023.

8 Beausoleil, R., Koehler, G., Maletzke, B., Kertson, B., and Wielgus, R. “Research to Regulation: Cougar Social Behavior as a Guide for Management.” PDF. 2013. Assessed October 30, 2023.