As Arizona updates hunting guidelines, conservation groups focus on native predators

A mountain lion was captured on a remote wildlife camera operated by Sky Island Alliance near the U.S.-Mexico border at Coronado National Memorial.
A mountain lion was captured on a remote wildlife camera operated by Sky Island Alliance near the U.S.-Mexico border at Coronado National Memorial.

The Arizona Game and Fish Department is updating key hunting guidelines that will set the tone for wildlife management in the state for the next five years.

The process is raising questions among some conservation groups about what hunters are allowed to hunt and how many individual animals can be killed within a given season.

Traditionally, the guidelines review process has been an opportunity to maximize hunting based on hunters' input. But a coterie of groups are hoping their concerns about the way native carnivores are managed will also be considered and given equal weight alongside consumptive users.

Three species fall into this category in Arizona: mountain lions, bobcats, and black bears. According to the groups focused on these species, these animals are mostly hunted for sport, with bobcats an exception. Trappers prize their winter belly fur for sale in the fur trade.

"There are a lot of things we would like to see changed," said Haley Stewart, a program manager with the Humane Society of the United States, one of the groups proposing a slew of revisions targeting these species. "I think, overall, our biggest priority is that the agency manages these three native carnivores using the best available science. That's really what this opportunity is with the hunt guidelines."

Stewart’s organization along with the Center for Biological Diversity and Mountain Lion Foundation, don’t oppose hunting. Rather, they say their recommendations are about ensuring that the guidelines reflect what the latest data tell wildlife managers about animal populations and behavior.

State officials have begun seeking feedback from the public, offering Arizonans the opportunity to weigh in on what changes they'd like to see put into place. The feedback will be factored into revised hunting guidelines. But those involved acknowledge managing what is essentially recreational killing can be tricky.

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What are hunting guidelines?

Hunting guidelines are used by Arizona Game and Fish Department biologists to create recommendations for species such as elk, deer, javelina, turkey and many more throughout the state. They are used to determine how animals can be hunted, the length of hunt seasons, and the limit on how many can be killed.

The update is a part of a cyclical review that happens every five years so the agency can gauge what works and what doesn't in terms of hunting. These revisions will be effective from 2023 to 2028.

After the public comment period ends Jan. 30, the agency will send the feedback to the Arizona Game and Fish Commission for approval, likely sometime this spring. The final guidelines are expected to come out in the fall.

The revised guidelines will be used to issue hunting recommendations, which are updated every two years, and final regulations throughout the five-year period. Recommendations are different from regulations, which are orders set by the wildlife commission.

Mountain lions: Target fewer females

A mountain lion was captured by a remote wildlife camera operated by Sky Island Alliance near Coronado National Memorial in Southern Arizona.
A mountain lion was captured by a remote wildlife camera operated by Sky Island Alliance near Coronado National Memorial in Southern Arizona.

Conservation groups say they would like to see a few suggestions put in place to ensure hunting is managed ethically and sustainably. For mountain lions, one of those is to reduce the number of lions that can be killed.

According to AZGFD, there are 2,000-2,700 mountain lions in the state, a number that includes kittens, which are illegal to hunt. The Mountain Lion Foundation says of that number, between 1,166 and 1,715 are independent, meaning they have left their mothers and are nearing adulthood. On average, the state has allowed just over 300 lions to be killed each year, or about 19-27% of the independent mountain lion population.

Big cat specialists like Richard Beausoleil, who authored a paper on mountain lion behavior and management, argue that this is too high a percentage to maintain healthy populations. What he recommends and what conservation groups would like to see is closer to 14%. Last year, hunters and AZGFD killed 345 mountain lions in the state, nearly 30% of the adult population.

"That harvest limit is inappropriate based on the population of lions in Arizona. Most states apply a 14% harvest limit to the independent mountain lion population," said Logan Christian, a conservation advocate with the Mountain Lion Foundation. "Arizona is applying a 14% harvest limit to their total mountain lion population, which includes kittens and sub-adults who are still with their mothers or getting ready to leave home but haven't yet."

The groups would also like to see a reduction in the number of female lions allowed to be killed each season. Females play a key role in ensuring that populations remain viable and healthy.

Currently, AZGFD allows up to 25% of the total number of mountain lions killed to be adult females over the age of 3. If that level is reached, the agency must reduce hunting permits in subsequent hunting seasons. Advocates, conservation organizations and scientists say the threshold should probably be 20% or less. They also recommend lowering the age limit for what's considered an adult from 3 to 2, since that's when many female mountain lions start reaching reproductive maturity.

Cats in this age range make up the bulk of what hunters kill in Arizona, Christian said. Not properly protecting reproductive females means kittens could be orphaned by hunters and left to fend for themselves, likely leading to starvation or more human-lion conflicts.

The agency has tried to account for this by making it illegal to kill mothers with kittens, but mountain lion mothers often lead hunters away from their kittens as a defense mechanism, so any would-be hunter would have no way of knowing whether they're shooting at a nursing female.

The conservation groups are also asking the agency to move the hunting season to later in the year. It currently starts in August because the agency acknowledges that females are rearing kittens in the summer, but newer research has determined that the nursing season in Arizona can extend well into the fall.

"Adult females have a disproportionate impact on the population. Their survival is critical for maintaining population stability because they're the ones making kittens, and they spend a tremendous amount of effort raising kittens," Christian said. "They're having a litter every other year usually and two or three kittens per litter. They stay with them for 12 to 18 months, so they spend a huge percentage of their life having and raising kittens."

Black bears: End the use of hounds

As with mountain lions, conservation groups say the percentage of black bears killed each season is too high. According to the National Park Service, which keeps the only readily available numbers, there are between 2,500 and 3,500 black bears in the state.

But those numbers are educated guesses at best. The population model currently used is just that: a model and not an exact number. While models are widely used to determine wildlife populations across the country, using one based on how many animals hunters kill means that quotas should be conservative, said Sophia Ressler, a staff attorney with the Center for Biological Diversity.

The current threshold is 10% of the overall population. As with mountain lions, it is illegal to kill cubs and females with cubs, but their numbers are included in the overall hunting quotas. According to research from Julie Benson, who holds a doctorate of philosophy in wildlife biology, the black bear quota should be closer to 4% of the huntable population.

In 2019, at least 324 bears were killed in the state. Fine-grain details such as the difference between adults, sub-adults and cubs are hard to find in Arizona. But given that this is already between 9-12% of the overall population, that rate would only go up once non-huntable cubs and mothers with cubs are factored in.

"Those numbers, however, I believe, are just hunter-reported numbers, as well as any removal by the Department for conflict with humans or property," Ressler said. "So that doesn't count any poaching numbers. My guess would be that that number is probably quite a bit higher."

To help get to more accurate numbers, the groups are hoping AZGFD can also revise the way it assesses populations. The current method for counting bears depends on counting the number killed in each hunting zone each year, overlaid with how much suitable habitat exists. These two data points are combined to make an educated guess on how many bears live in the area.

"I think that just the fact that we both are using that National Park Service number kind of speaks to the fact that Arizona doesn't have a great grasp on what their actual bear population is," said Ressler. "The science doesn't support these kills by agent and hunter kill numbers as reliable ways to determine the population and there's been some exploration into things like hair snag analysis and capturing and recapturing the black bears that would that would provide, likely, more reliable numbers."

Research out of Washington state supports this method of using DNA collection and capturing and releasing bears. Once they're released, the bears can be fitted with GPS collars allowing wildlife managers to track their locations. While it can be time-intensive and costly, these methods seem to offer a better estimate of what populations persist in the wild.

One practice the conservation groups would like to see end is the use of hounds to pursue bears. They say it goes against the ethics of fair chase, which says that hunters should not have an unfair advantage on their quarry. Furthermore, they say it adds stress to both the hounds and the animals they pursue. In some cases, hounds are even killed by bears.

"Animal safety and animal welfare, in general, I think, is one of the reasons that we have concerns over hunting and recreational use of hounds," said Ressler. "And that has to do with obviously, these are high-stress situations, especially for the wild animal being pursued. And oftentimes that can result in conflict between the dogs and the wild animals."

The groups would also like to see an end to the spring bear season because it's when mothers are nursing. While it is illegal to kill mothers with cubs, like mountain lions, sows will often lead hunters away from their cubs, said Ressler, so it's often difficult to tell whether or not a bear has cubs hidden in other areas of the forest.

Already, the AZGFD has proposed shortening the spring bear season from 42-63 days to 35, but advocates say that is still inadequate. There is still a high chance cubs will be orphaned or that animals will be injured since they're just starting to emerge from their dens, half-starved and ill-equipped to fend off threats.

Ressler asserts that the spring bear hunt has no real value other than allowing people to kill bears. It's not the wintertime when their pelts would be sold on the fur trade, so outside of warding off nuisance bears, it's wanton killing.

Bobcats: Address trapping methods

A bobcat captured on a motion-sensor camera installed by Sky Island Alliance at the San Pedro river near the international border in Cochise County.
A bobcat captured on a motion-sensor camera installed by Sky Island Alliance at the San Pedro river near the international border in Cochise County.

Arizona Game and Fish Department officials say trappers have reported taking fewer than 1,000 bobcats each year. Last year, they took 475, according to the agency. But there's no way to really tell. Once a trapper has a trapper's tag, they can trap an unlimited number of animals. The only real constraint is the season, said Stewart, from the Humane Society of the United States.

"Unfortunately, I would say that the agency is currently allowing hunting of these animals at levels that are likely above what is sustainable," said Stewart. "Or they're at least not implementing limits, to prevent that from happening."

Total population numbers aren't widely known either. An AZGFD official said there are approximately 60,000 in the state. But as with black bears, it appears the agency is mostly guessing how many are on the landscape based on piecemeal data points. Conservation advocates say the strategy seems to be that since hunters and trappers are catching them, they must be prevalent throughout the state.

There are some restraints on trapping. Steel-jaw traps are illegal to use on public lands, while snares that choke animals to death or constrict their legs are used throughout private and state lands. The state requires trappers to check their traps frequently but it's hard to enforce, so animals can be left in remote areas where they can starve to death.

"Trapping is pretty horrendous. A lot of different types of traps cause serious injury and stress and cruelty beyond what is necessary or what we should be allowing anywhere for animals to put up with," said Ressler. "It also can harm non-target species. There are examples across the United States of traps killing pets."

Conservation groups would like to see a ban on trapping bobcats in Arizona. Live traps are allowed throughout Arizona, but even these can be cruel, the groups say. The animals are often shot point-blank or bludgeoned to death to preserve their pelts, said Stewart.

What's already in the proposal

In December, the Arizona Game and Fish Department proposed a host of recommendations based on the feedback received last summer, when the agency first announced that the hunting guidelines were being updated.

“What these guidelines do for us is they really set the sideboards under which we start to manage, harvest or take wildlife,” said Amber Munig, big game management program supervisor for AZGFD. “And it tells our wildlife managers, our biologists, when it is appropriate to increase or decrease harvests. And those are based on population parameters.”

One of the top-line updates is an addition that allows the agency to conduct an "off-cycle wildlife survey” during periods of natural stress. This could include, but wouldn’t be limited to, events such as prolonged drought, wildfire or disease. The point is to give wildlife managers the opportunity to assess wildlife populations so they can better gauge how many hunting permits they should allocate.

The most significant proposed changes, by far, are those related to deer hunting, both mule and white-tail. A week is being added to the youth-only deer hunting season. And the agency would also like to have the ability to more finely control the percentage of deer taken by bow and arrow hunters. The agency is also hoping to add some flexibility to when the elk and turkey season occurs.

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Early drafts of the guidelines suggest the agency is trying to pare back the focus on maximizing black bear hunting. For example, the phrase "allow as much bear hunting opportunity as possible" has been changed to "allow for bear hunting opportunity." The word "maximum" has also been scratched from the phrase "providing maximum hunting." And the agency is also aiming to shorten the spring bear season.

The importance of female mountain lions is also underscored by the agency’s addition of a clause that calls for providing hunting opportunities while minimizing the killing of adult females.

Not all conservation groups are calling for changes in the updated guidelines. Jim Unmacht, the executive director for the Arizona Sportsmen For Wildlife Conservation, said his group has not submitted comments for the revisions but is watching the process. As a hunter for nearly 50 years, he credits the agency for leading wildlife management in what he says has always been a science-based decision-making process.

“Our organization supports the scientific assessment and management that the Game and Fish Department utilizes,” said Unmacht.

The Arizona chapter of the Wildlife Federation, a group that engages in conservation across a broad spectrum of considerations ranging from hunting to restoration, did weigh in. Like Unmacht, they echoed the need to lead with science in their letter to the agency.

“The Arizona Wildlife Federation believes that the management of Arizona's wildlife and natural resources should be based on the principles of sound science and best governance, said Glen Dickens, the vice president of the federation. “We support that all wildlife species will be managed by the Arizona Game and Fish Department under the authority of its 5-member Commission. However, our support presupposes that each species will be managed according to the most currently available wildlife science."

Predators, deer and elk

Deer stand in thick vegetation at Cuenca Los Ojos, just south of the San Bernardino National Wildlife Refuge.
Deer stand in thick vegetation at Cuenca Los Ojos, just south of the San Bernardino National Wildlife Refuge.

Unmacht and Dickens said predators should be managed just like any other species in the state. And while Arizona doesn’t include the phrase “trophy hunting” in its regulations, the use of that term really is in the eyes of the beholder, said Unmacht.

“There's no ‘trophy hunting’ in the Arizona regulations, or associated with the Arizona Game and Fish Department,” Unmacht told The Republic. “Both a mountain lion and a black bear are big game in Arizona. If a person is successful in harvesting one of them, they may utilize the skin and they may mount it or make a rug out of it, but they also eat it.”

Drawing on research, most conservation groups say there’s no real scientific need to hunt large predators. As species at the top of the natural food chain, they are capable of self-regulation. In the wild, prey availability, weather, distribution and disease keep their numbers in check. Unlike ungulates, these species have no natural predators.

They play a key role in keeping ecosystems in check by regulating deer and elk populations and even controlling mesopredators, like coyotes, raccoons and foxes, researchers say. Mark Elbroch, an ecologist and lead scientist for the Puma Program at Panthera, concluded that mountain lions are crucial to their environment.

"Mountain lions create more large carcasses than other predators (for example, wolves tend to dismantle prey into many small chunks), which recent research has shown is more important to ecosystem health," wrote Elbroch on his website. "They feed more mammals and birds than any other predator, increasing the number of animal interactions (e.g. links in food webs) so essential to maintaining ecosystem resilience. And they are ecosystem engineers on top of this as well."

For years, wildlife agencies across the country have taken the model used to manage ungulate species like deer, elk and moose and applied it to carnivores. But research increasingly says that isn't the way these species should be managed. Disrupting social structures and leaving young orphaned are just some of the consequences of this type of one-size-fits-all style of management, conservation advocates argue.

In most cases, predator hunting can lead to the opposite of what wildlife managers intend to do. One case is reducing livestock conflicts. When they occur, the agency will often create a predator management zone where increased killing is allowed. But this can backfire, said Stewart. By removing dominant animals in one area, juveniles often come in to take their place. These animals are less experienced and will rely more heavily on livestock rather than wild prey.

What the agency should be doing, say the conservation groups, is looking at the specific behavior of these species and following the research on how to manage them. Incorporating some of their suggestions would be a good start, they say.

"Native carnivores are not deer, they're not elk. And they keep their own populations in check," Stewart said. "They don't need hunters to regulate their population. That's just outdated science that simply doesn't withstand scrutiny anymore. And at the very least, the agency should prohibit the cruelest killing practices. Trapping bobcats for fur and killing mother bears and mountain lions, when they are raising newborn cubs, are not fair chase hunting."

Lindsey Botts is an environmental reporter for The Arizona Republic/azcentral. Follow his reporting on Twitter at @lkbotts and Lkbotts on Instagram. Tell him about stories at

Environmental coverage on and in The Arizona Republic is supported by a grant from the Nina Mason Pulliam Charitable Trust. Follow The Republic environmental reporting team at and @azcenvironment on Facebook, Twitter and Instagram.

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This article originally appeared on Arizona Republic: Too many predators are killed in hunts, conservation groups say