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Antler Restriction Legislation

CFAB Correspondence

The following is a HTML version of the correspondence letter; a PDF version (26 KB) is also available to view.

August 11, 2011

The Honorable Andrew M. Cuomo
Governor of New York State
NYS State Capitol Building
Albany, NY 12224

RE: Antler Restriction Legislation

Dear Governor Cuomo:

The Conservation Fund Advisory Board (CFAB), which oversees the expenditures of Conservation Fund revenues for the care, management, protection and enlargement of the fish and game resources of the State and which advises the Department of Environmental Conservation (DEC) and the Governor on matters that may affect future sporting license sales strongly opposes Assembly bill A394A and Senate bill S5601 regarding the imposition of "antler restrictions" in selected Wildlife Management Units (WMUs). This proposed legislation circumvents the normal regulatory process guided by the State Administrative Procedures Act (SAPA) and in effect seeks to undermine the DEC's management authority for the State's fish and wildlife resources as per §11-0303 of the Environmental Conservation Law. The regulatory process currently in place has worked successfully for many years. It allows for the give-and-take of open public comment and for meaningful input from a wide variety of individuals and interest groups, not just a single vocal political constituency group.

The change from the current open and fair regulatory process to one of using legislation to address the concerns of special interests would, necessarily, harm the interests of the majority of the public who would be denied the ability to openly and fairly debate a law and who would be denied the right to have meaningful input into the development of fish and wildlife management practices. Additionally, sound fish and wildlife management depends on the expertise of the agency statutorily charged with carrying out the mission of protecting and preserving our natural resources. This legislation sets a very bad precedent in regard to sound management and sound government.

It is the opinion of this board that if a desired outcome cannot survive the current fair and open regulatory process it should not be imposed by means of legislation.

Sincerely,
Jason Kemper
Chairman, NYS Conservation Fund Advisory Board

Cc: Joe Martens, NYSDEC Commissioner

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