Trappers,

I write you today to share with you some more knowledge of how the government works, because it's obvious that we as a community are lacking a bit in some of the tips and tricks for how most state agencies conduct business. I want to be clear on how this works. The Legislatures pass laws, the state agencies have to pass rules that are supposed to "interpret and implement" said laws. This doesn't always happen, and is one of the tricks to the trade of willful refusal to play ball in terms of a state or federal government agency. For example, say in another world that New Mexico's legislature passed a law that allowed for cougar trapping and hunting specifically; If the NM Game and Fish's executive staff, and/or person inside the agency does not like that, they will make a half-hearted rule that doesn't even mention cougar trapping. This allows them to just not deal with it, no matter what you, me or all trappers of the USA know the real reason is. Another method of this, is to work retroactively, so say somebody comes in the staff that feels a certain way about things, well, they can work to "scrub" the rules even though the law hasn't changed at all. In any case, the result is the same and they no longer have to authorize it, talk about it, respond to questions about it outside of "current rules don't allow for it". Now this also works the other way in that if the law is "vague", then the state agency can make a rule based on their interpretation and this does happen in our favor sometimes too. This is not some magical industry secret, but it does seem to allude the trapping community for reasons unknown to me. Now with that said, do you know that you the trapper can make an interpretation of the law and initiate a rule change based on your own interpretation? You just need to make sure that there is a law that would authorize what you are trying to change or atleast an interpretation yours or somebody else's, along with the full rule change of the specific part of the administrative code you are trying to promulgate a rule about. This will need to be sent certified mail to the state agency that is over the rules you are trying to get changed and they have an allotted period of time to respond with a denial letter and/or an initiation letter of the rule promulgation. Every state's laws basically have a guide on how to do this, but think of this as of a science project; the more scientifically sound data, studies, letters, views, official letters of support, and anything else you want to include in the package, the higher chance of success for the rule to be promulgated.


Specifically, I am asking for a plain jane NM trapper and/or a non-resident trapper that has traveled to NM to specifically trap cougar to initiate the cougar trapping rule. I have re-typed some of the previous rules that were repealed by the Game Commission, but they are not complete. I am not familiar with cougar trapping in New Mexico, somebody who has actually done it would be better suited at finishing the portion of the rule change petition, but I did make some intentional changes that I hope you keep. I will be honest in that based off my own experience, I do not think that NM trappers have enough data to succeed, however if there are trapper initiated studies on effects on trapping cougar in NM I was not able to find them on the internet. I would recommend using a method that is easily understandable, repeatable and provides protection against any doubt of the way that you are counting the different cougars trapped for the study. . I would also initiate an application for the scientific study that is allowable by the Game Commission, this provides more official, documented, indisputable evidence that things have been done in good faith with plenty of documentation. If you need help, there are other states in which some of these studies have been done, but I will warn you that you need to do a New Mexico specific study. Along with this, NM trappers need to do some real on the ground work in the community by volunteering their time to show the general public how traps work and how to free animals from the traps. I also recommend doing a door to door inquiry on what the community knows about cougar and ask them how they feel about hunting and/or trapping cougars. This is enough to keep you guys busy for at least a year, should be far longer than that, but this is the bonafide, real, proven, low cost solution that will eventually get Cougar Trapping allowed back in New Mexico eventually.

For everybody else, this is a basic blueprint of how to make change happen on the Administrative side of things, it's not all encompassing, it's not the end all be all, there are far more tricks then I listed here, but it should be a good start for those of you who are affected by rule changes. I recommend using it, because everyday it's used against the trapping community on the federal level, on the local level. Things to pay closely attention to are studies on short and long term budget impacts for rule change promulgation as well as environmental impact statements and studies.

One thing anyone can use as nm based study is the harvest report info online. Very few years do all zones have the harvest met by any legal means.

MattLA, you never have answered my questions and now BMP certified traps(going all Canadian?), yet another question. Why do you post things like this, being someone who joined a year ago here and as a self proclaimed newbie to trapping? How is it that you make the post you do, what's your angle?

Good Lord.

What rule says the have to respond to your proposal? Seems like they can just trash them.

I thought your plan was to amend the U.S. Constitution to protect trapping by promising to feed homeless people coyotes and clothe them in possum fur.

I did respond to you, I didn't respond in the other threads because you put me on ignore. First BMP has nothing to do with Canada, they have a Fur Institute that does all certifications for Canada to meet AIHTS requirements. Best Management Practices certified traps is the USA's response to the AIHTS legislation which started in 1997, since the way Canada does it would never work for the USA do to our structure. Just about every trap that you have been using since 1997 is likely BMP certified, there are over 600, which the studies were done by the Association of Fish and Wildlife. There is no angle catch22, I don't do things half hazard, I go all in, find out as much as I can about the topic and either get bored and move on or add it to a permanent hobby. I post these things because I have a lot more experience with dealing with the government in terms of administrative moves and dealing with the nuances between 3 branches. I don't need to be a master trapper to understand how to protect trapping and make it anti-trapping proof. I love trapping and want to see it around for the years to come, and for everybody in the USA to be able to trap with the same equity across the board.

Tell it to the judge.

I post these things because I have a lot more experience with dealing with the government in terms of administrative moves and dealing with the nuances between 3 branches.

A lot more experience than who?

The same law that provides the ability to initiate the rule change, says the agency has to provide a reason for the denial. They "can" just trash them, but they have to give you a reason for thecertainly get favorable initial judgement in the form of an injunction among other things. denial. Even if you get denied, each time it should provide the path towards victory and let the agency know you mean business. If they DONT respond, then it's an easy lawsuit victory

@Blaine, yes my goal is still that in due time. This was for the NM trappers and everybody else who wants to make change in their own states who might not know about this procedure. Again it's not universal to every state, but most of them it is. It's also how things work for the federal government....aka BLM managed land and other federal agencies.

Another fair question presented. Another one would be is this your job? Do you advocate for a group of people in which your not one of?

I was there when trapping cougars was legalized, I didn't see you. I was in Albany NY when Clevland Amory was at the hearing, I didn't see you. I have been to Sante Fe numerous times, I didn't see you. I have been to numerous trapper meetings from the 70's on, I didn't see you, or hear from you.

Start getting involved in the fight on your own if you want to help trapping. Until then im going to be very suspicious of ya