URGENT: Call To Action For North Carolina Bears
It is time for the next phase in reversing the North Carolina Wildlife Resources Commission (NCWRC) newly adopted rule that opens up the Pisgah, Panthertown-Bonas Defeat, and Standing Indian Bear Sanctuaries (92,500 acres) to bear hunting, hunting with dogs and changes the term "designated bear sanctuary" to "designated bear management area."

Join our online event for reminders and a quick guide on how to write an objection letter.

Next steps
The Rules Review Commission (RRC) reviews and either approves or disapproves rules adopted by state agencies. The next meeting is scheduled for Thursday, April 21, 2022, at 9:00 am. If the RRC receives ten or more letters objecting to a rule, it is subject to a delayed effective date and legislative review.

You can send written letters via mail or email.
The RRC requests the following when submitting a letter via email, attach it as a Word or PDF file or copy and paste the contents of the letter into the body of an email (follow the template).

Use the address below to send letters via mail, delivery service, or in-person.
Office of Administrative Hearings
1711 New Hope Church Rd.
Raleigh, NC 27609.

Use the email addresses below to submit your objections electronically.
Copy the agency's Rulemaking Coordinator on your emails (Dana McGhee).

rrc.comments@oah.nc.gov
oah.rules@oah.nc.gov
dana.mcghee@oah.nc.gov

You can also sign up to speak at the meeting by emailing the staff attorney (Lawrence Duke) handling the rules by requesting to speak and stating whether they are for or against the rule.

lawrence.duke@oah.nc.gov

Below we have included the format in which all objections must be written. You DO NOT have to be a North Carolina resident to submit an objection. If you own a business that relies on tourism, explain how allowing bear hunting in the three bear sanctuaries will deter people from visiting and, therefore, negatively impact your business. If you travel to North Carolina, state that you will not return until the rules are reversed. All comments and objections must be received five business days (April 14th) before the next RRC meeting.

Objections must adhere to the statutory rules put forth by the RRC.
The Commission shall not consider questions relating to the quality or efficacy of the rule but shall restrict its review to the determination of the standards outlined in this subsection. The Commission may ask the Office of State Budget and Management to determine if a rule has a substantial economic impact and is therefore required to have a fiscal note.

Use the format below for writing your objection letter.

[Name]
[Address]

[Date]

N.C. Rules Review Commission
1711 New Hope Church Rd.
Raleigh, NC 27609

Re: [15A NCAC 10D .0106] Bear Sanctuaries

Members of the Commission:

I request that the above rule(s) be reviewed in the upcoming legislative session as set out in N.C.G.S. 150B-21.3. I further request that the rule(s) be subject to a delayed effective date as set out in that same provision.

The North Carolina Wildlife Resources Commission's recently adopted rule that allows bear hunting and hunting with dogs in the Pisgah, Panthertown-Bonas Defeat, and Standing Indian Bear Sanctuaries along with a change in the term "designated bear sanctuaries to "designated bear management areas" is not clear and unambiguous for the following reasons;

1. The NCWRC's basis for the rule was that the U.S. Forest Service (USFS) requested that they open up the sanctuaries to hunting due to increased bear-human conflicts. It is important to note that there is no scientific evidence to support claims that hunting reduces bear-human conflicts. The opposite has been proven. The NCWRC also failed to mention that the USFS request was made in 2018, and the request was solely for Panthertown. Additionally, the problem with bear-human conflicts has since been subsequently resolved by introducing bear-proof food lockers in 2020. Over the past two years, the U.S. Forest Service (USFS) has not received any complaints regarding bear-human conflicts, and there are plans to install more food lockers as a proactive measure in preventing future bear-human conflicts.

2. The NCWRC also claims that the bear population is growing and needs to be managed. Bears regulate their own populations through a process called delayed implantation. This process prevents bears from populating beyond their environmental carrying capacity.

3. The NCWRC also stated that hunters pressured them to open up the sanctuaries for more hunting opportunities. However, the North Carolina Wildlife Resources Commission met with stakeholders on April 5, 2022, at the Tri-County Community College in the McSwain Building Lecture Hall to discuss the recently adopted rule. The entire room was full of hunters and non-hunters. State Representative Karl Gillepsie was in attendance. He asked everyone in favor of the rule to raise their hands. Not a single person raised their hand, including the hunters that the NCWRC alleges have been pressuring them to open the three bear sanctuaries to hunting.

4. The NCWRC has not clearly defined the details of the rule. There is no definitive answer to the number of permits to be issued to hunters, the cost of permits, or the number of bears allowed to be killed. They have adopted a rule that is not clearly defined.

The rule is not reasonably necessary because of the following (also see above);

1. Since the bear-proof food lockers were installed, there are no longer bear-human conflicts occurring. There have been no bear-human conflicts for the past two years, and more food lockers are being installed to prevent future conflicts.

2. Hunting does not reduce bear-human conflicts.

3. Bears manage their own populations through delayed implantation.

4. The majority of the NCWRC's stakeholders oppose opening the sanctuaries to hunting, including the hunters they claim have been pressuring them. During the NCWRC's public comment period, 86% of comments were opposed to the rule.

The rule will have a negative impact on the state's economy (economic impact);

1. The Pisgah, Panthertown-Bonas Defeat, and Standing Indian Bear Sanctuaries are revered destinations for residents and tourists alike. People travel from all over the world to enjoy the serene, peaceful environment and the prospect of seeing bears.

2. The tourism and outdoor recreation industries are significant contributors to North Carolina's economy.

3. The bear hunting season is a popular time for tourism (leaf season).

4. Bear hunting, especially bear hunting with dogs, puts tourists and residents in danger of being accidentally shot or attacked by hunting dogs, which has previously happened in the state when a woman and her two dogs were viciously attacked by hunting dogs while camping.

5. Under North Carolina law, dogs "being used in a lawful hunt" are exempt from rules that otherwise require owners to take steps to prevent their animal from harming a person or another animal. This rule endangers the public, pets, and private property owners. Tourists and residents will think twice before bringing their families to a place where they can be potentially shot or attacked by hunting dogs. Learning that hunting dogs/dog owners are exempt from laws that protect people and their pets will only further deter people from visiting these areas.

6. This rule will negatively affect businesses located around the sanctuaries impacting the livelihood of local residents. The more than 45,000 small businesses across North Carolina heavily rely on tourism, everything from lodging and dining to transportation, recreation, and retail.

7. According to the Department of Natural and Cultural Resources data, 22.8 million visitors entered the system's 41 parks, recreation areas, and natural areas in 2021. Pisgah receives 5.5 million annual visitors and Panthertown sees more than 35,000 visitors a year.

For all of the reasons listed above, I request that [15A NCAC 10D .0106] Bear Sanctuaries not be approved by the Rules Review Commission.

Thank you for your consideration.

[Name]

[Signature]