05/08/2026
Just sayin".....
"Dear Nevada Wildlife Commissioners,
I have raised these concerns before this Commission on prior occasions, and they have gone unaddressed. I present them again with the hope that the scientific evidence regarding the health of Nevada’s bear population will finally be given the weight it deserves.
Biological Reality of the Fall Hunt
From October through December, hounding imposes a severe metabolic penalty. Bears lack sweat glands and are prone to hyperthermia during high-intensity pursuit. Most critically, this window overlaps with delayed implantation. A sow’s body only permits a pregnancy to proceed if she has reached a nutritional threshold of roughly 19% body fat. Chasing bears during this pre-denning window triggers metabolic stress that can cause the body to reabsorb embryos, terminating pregnancies. Research shows that 60% of pregnant females forced to change dens due to human disturbance emerge in the spring without cubs, compared to only 6% of those left undisturbed.
Hounding Serves No Conservation Purpose
The Commission should also consider what the data from other states makes plain: hounding does not meaningfully change kill ratios, especially in a small male dominant edge population. Pre- and post-hounding harvest records across multiple states show no significant difference in kill ratios when hounds are permitted versus when they are not. The bears taken are roughly the same in number and demographic composition either way. This leads to an uncomfortable but unavoidable conclusion — hounding is not a population management tool. It confers no biological benefit to the population. What it does do, with certainty, is impose physiological harm on individual bears and reproductive risk on the population as a whole. A practice that offers no conservation upside but carries documented biological downside cannot be reasonably justified on wildlife management grounds. It exists purely for the recreational satisfaction of a narrow subset of hunters. Should that be sufficient for policy that affects a vulnerable and ecologically important species?
Statistical Significance and the Matrix
Our reliance on a three-year harvest matrix is statistically unsound for a population this small. Nevada’s harvest averages just 14 bears per year. In a sample that tiny, the harvest of a single reproductive female can shift your “percentage of females” metric by over 7%. That isn’t a population trend; it’s statistical noise. A three-year window has such low statistical power that by the time a decline is caught by the matrix, the population may have already suffered an irreversible collapse.
Recommendation
I urge the Commission to reduce the bear harvest quota to a negligible number and hold it there until the Nevada Administrative Code governing hounding can be formally amended. This is also consistent with the will of Nevadans — the 2018 Nevada Wildlife Values report made clear that hunters and non-hunters alike do not support the use of hounds for bear hunting. The Commission has the power to correct this failure of stewardship of Nevada’s bears.
Please add these comments to the record.
Thank you for your time and consideration,
Cathy Smith
