Texas Parks and Wildlife Department

Public Testimony – Managed Lands Deer Program
August 20, 2015

Good afternoon Chairman Friedkin, commissioners, and staff.  My name is Patrick Tarlton and I am the newly appointed Executive Director for the Texas Deer Association. I have been on the job a total of two days and hope that our next meeting will be over a cup of coffee or tea rather than me speaking to you on the dais. 

As a matter of background, the Texas Deer Association and its members are faithful advocates for the Managed Lands Deer Program.  The current MLD Program has been extremely successful in encouraging best-practices in deer management, harvest, and habitat conservation. Many of our members utilize this program to effectively manage their herds and private property. The MLD Program has been incredibly valuable tool for landowners of all sizes and shapes.

Recently, when Parks staff proposed to make changes to the current system, our members were overwhelmingly supportive. The original intent of the changes seemed to stem from the increase in administrative workload placed on field biologists. No longer were the biologists focused on the management of herds and resources in the field, but they were seemingly saddled with more and more paperwork in the office.  Our members saw the proposed changes to the rule as a way for field biologists to once again return to their focus on field management and their core duties outside of the office – working hand in hand with landowners across the state.

However, through the course of the proposed changes to the rule, Parks formed a working group designed specifically to tackle handle the management of the rules changes. From our perspective, when the working group was formed all transparency ceased. From that point forward, public participation and small landowner interests diminished.

The product from that worked group is very different than the perceived intent of previous discussions regarding changes to the MLDP program. We believe the proposed changes will not in fact alleviate administrative workload for the filed biologists. In fact, the proposed changes create a disincentive for landowners who had hoped to use the automated system for faster and more efficient tag processing. 

The automated option penalizes small acreage landowners by not allowing for early season buck harvest. It also does not consider factors such as deer densities when calculating the number of tags to be issued. In our opinion, the automated system must consider early season buck harvest back and allow small landowners to carry heavier deer population densities.

 Additionally, we urge the Commission to keep the original Oct. 1^st to Feb. 28^th harvest dates by “any legal means and methods”. These dates should not be changed and the proposed “archery only” requirements should be removed. This is indicative of the 46 comments submitted in favor of this option, but 131 submitted against.

 We also would like to ensure that ALL approved survey methods under the conservation option are applied consistently and equitably throughout the state. These survey methods should not be based on local field staff bias, and every private property owner should have the right to use them regardless of whether they live in Fort Stockton or Beeville. We also must stress that the application deadline should not be moved earlier. In fact, this deadline should remain at August 15^th or possibly be moved later in order to encourage and accommodate new landowners’ participation in the program.

 We cannot stress enough the importance of continuing to allow private property owners, particularly small landowners, the ability to fully manage their herds and habitat.

 I appreciate your time and would be happy to answer any questions you may have.