Voices of Wildlife on June 1, 2020 submitted a rulemaking petition letter to NH Fish and Game to REPEAL Fis 806.05, the F&G rule that allows beagle dog clubs to live capture wild snowshoe hares and use them for their hunting dog training. To see the letter read below. If you agree that this is a practice that F&G needs to end please send your comments to them and let them know you agree with the Voices of Wildlife letter. Please put Snowshoe Hare Rule in the subject line of your email and send your comment to firstname.lastname@example.org . Thank You!
June 1, 2020
RULEMAKING PETITION to Glenn Normandeau, NH Fish and Game Executive Director
We petition the NH Fish and Game Department to Repeal Fis 806.05 Snowshoe Hare Live-Capture Requirements.
Reasons to Repeal Fis 806.05:
Violations of RSA Section 644:8
Wild animals in captivity are protected by the NH Cruelty Statute, RSA 644:8, that states it is cruelty to act in any way that is ”injurious or detrimental to the health, safety or welfare of any animal.”
• The clubs release groups of beagles on the properties to chase the hares for what they call hare trials. As is commonly known, the sustained flight response in a hare can result in death.
• For training purposes, they put a young beagle in a smaller enclosure with a hare. The hare, being a flight prey animal is terrorized, but unable to flee.
• The clubs are attempting to propagate the hares but with little success, as is seen in the propagation reports they are required to fill out and submit. That the hares do not breed as would be expected is an indication that there is a problem with their care and/or their environment.
Violations of Fis 804.09:
The snowshoe hare live capture rule Fis 806:05 states – (p) Snowshoe hares kept either for this program or for propagation shall be held in compliance with Fis 804.09(b)
Fis 804:09 states that enclosures must, (2) Protect the wildlife from all other animals, domestic or wild.
• We learned at the June 20, 2018 rulemaking hearing there is predation on the captive wild snowshoe hares at the beagle clubs. The club members admitted they do not protect the captive hares from bird predation.
• The clubs state they set up feeding stations for the hares. Who are they feeding, the hares or the hawks? As we know, predators learn very quickly when there is an easy lunch to be had.
• What is happening to these birds of prey, who are protected by the Migratory Bird Treaty Act, when they consume a snowshoe hare, or bring the hare back to a nest, that has been dusted in the toxic pesticide of Sevin. Dusting the captured hares with Sevin is a known practice of the clubs.
Misuse of a Public Good: As New Hampshire wildlife, snowshoe hares are a public good. Private clubs should not be able to freely take a public resource for their exclusive use. Since no one is allowed on their properties who is not a member, this transfer of public goods to private use is both unjust to everyone in NH and it is unaccountable. The private nature of the clubs prevents the public being able to provide oversight on the conditions of the snowshoe hare populations at the clubs. That a veterinarian inspects one hare of the club’s choosing per year is not good enough. The one hare is most often brought to the veterinarian’s office so the beagle club facilities are not inspected. Is there even running water at these club’s remote locations?
Un-sustainable relocation of a wild animal: Relocating wild animals is not recommended by NH Fish and Game. But that is exactly what is happening to these captured hares. They are relocated far from their homes, in perhaps unsuitable habitat for snowshoe hares. Relocated animals are particularly vulnerable to predation as they are searching for shelter in a new environment. Snowshoe hare habitat has special requirements such as heavy thicketed areas to escape from predators. They avoid open areas. Do these beagle clubs have habitat that a snowshoe hare would seek out in the wild? Why would beagle club snowshoe hare populations not be self-sustaining? Is a contributing factor to the high mortality rate that they are being relocated into unnatural and unfamiliar terrain that leads to damaging stress and increased predation?
Negative Ecological Impact: Snowshoe hare are a keystone species and serve as important prey for the Canada lynx and American marten (both species are rare and protected in NH), as well as other species. Most snowshoe hare captured for the beagle clubs are from northern NH where Canada lynx have been sighted and where the American marten resides. Fis 806.05 is potentially a violation of the Endangered Species Act because Canada lynx are listed as threatened under the Endangered Species Act.