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Facts Behind Proposed Baiting Prohibition


The Arizona Game and Fish Commission recently approved a Notice of Proposed Rulemaking to amend its Article 3 rules (governing the taking and handling of wildlife) to enact amendments developed during the preceding Five-year Review Report and incorporate recently passed legislation. The document can be viewed at Public comments are now being accepted through Nov. 5, 2012 at

One of the proposed amendments to R12-4-303 pertains to restrictions on using bait to take game (commonly called "baiting"). We understand that this is an important issue to our constituents and have accordingly included some information below that explains the rationale behind the proposed amendments.


The Commission adopts rules with the goal of managing for healthy, robust wildlife. The proposed restrictions on baiting would help keep wildlife healthy and enable the Department to manage for robust wildlife populations.

Proposed Rule Language

R12-4-303. Unlawful Devices and Ammunition
D. The use of edible or ingestible substances to aid in taking big game is unlawful when:
    1. An individual places edible or ingestible substances for the purpose of attracting or taking big game.
    2. An individual knowingly takes big game with the aid of edible or ingestible substances placed for the purpose of attracting wildlife to a specific location.
    3. This subsection does not limit Department employees or Department agents in the performance of their official duties.
    4. For the purposes of this subsection, edible or ingestible substances does not include:
        a. Water,
        b. Salt or salt-based materials produced and manufactured for the livestock industry, or
        c. Nutritional supplements produced and manufactured for the livestock industry and placed during the course of livestock or agricultural operations.

What is “bait”?

For the purposes of this rulemaking, the Commission considers bait to include any food-stuff or ingestible material that has been deposited, scattered, piled, or delivered by a passive or active feeder or feed delivery system so as to constitute an attractant, lure or enticement to wildlife and to influence the movement of these animals for the purpose of harvest by hunters.

“Bait” does not include:

  • Water
  • Salt or salt-based materials produced and manufactured for the livestock industry
  • Nutritional supplements produced and manufactured for the livestock industry and placed during the course of livestock or agricultural operations
  • Decoys
  • Scent lures provided they do not contain cervid urine
  • Chemical attractants provided they are not ingestible
  • Food plots planted within accepted local or regional agricultural guidelines

Wildlife Health

The proposed restrictions on baiting would prohibit the use of edible or ingestible substances, such as placing corn or wildlife feed in the field to attract and take big game. Baiting can create unusually high concentrations of wildlife where disease can spread easily.

However, the proposed restrictions on baiting would not apply to practices that provide essential necessities for wildlife, such as water or salt licks and supplements developed for livestock operations. Greater availability of natural resources, including water and salt, actually promotes broader distribution of wildlife and healthier populations.

A primary concern with baiting is that it results in concentrations of wildlife that may facilitate the transmission of diseases among wildlife or contain toxic contaminants. Baiting and supplemental feeding are linked to persistence and spread of bovine tuberculosis and brucellosis in wildlife and may facilitate the spread of chronic wasting disease. Further, toxins such as aflatoxin may be contained in wildlife feed or may develop after placement in the field. Because many of these diseases, and other wildlife diseases that can be transmitted in similar situations, may pose an economic risk to Arizona, this regulation is deemed critical to managing wildlife and hunting in Arizona. This is also consistent with similar regulations in many other states. Many states have adopted baiting restrictions to avoid high artificial concentrations of wildlife, where diseases can spread easily and quickly. Currently, all but five states located within the United States prohibit or restrict baiting. See map.

Scientific evidence demonstrates that baiting concentrates wildlife at abnormal densities; increases direct and indirect contact among wildlife species; increases likelihood of disease transmission; maintains endemic disease pools that are capable of causing widespread sickness and mortality of wildlife and domestic animals; causes significant habitat damage; and increases intra- and inter- specific competition and stress among and within wildlife populations. Paradoxically, while baiting practices are usually intended for the purpose of attracting or luring a specific species of wildlife, these practices may have significant detrimental effects to non-target species attracted to the bait or feed. Common examples of disease problems associated with baiting to both target and non-target wildlife include histomoniasis and avian pox in wild turkey, bobwhite quail and other birds, bovine tuberculosis and chronic wasting disease in wild and enclosed ungulates such as deer and elk, pseudorabies and swine brucellosis in feral hogs, and rabies and distemper in raccoons, fox, and coyotes. There are numerous other diseases and parasites that can be readily transmitted at baiting sites through direct or indirect contact between animals and the bait or feed.

Although bovine tuberculosis, brucellosis, and chronic wasting disease are not evident in Arizona today, other wildlife diseases can be transmitted in similar situations, and chronic wasting disease has been detected in Utah, Colorado, and New Mexico and may eventually be detected in Arizona.

The proposed baiting restrictions will build on the Department’s history of taking proactive measures to prevent and detect wildlife disease, that already include:

  • Monitoring and testing cervid harvest annually since 1998;
  • Prohibiting the transportation, importation, and translocation of cervids; and
  • Establishing an emergency response plan of action, in the event chronic wasting disease or other detrimental wildlife disease is detected.

In addition to these controls already in place, the Department is also recommending other amendments to Article 3 to remain proactive in preventing chronic wasting disease by:

  • Regulating the importation of carcasses and parts of cervids into the state;
  • Regulating game farms in Arizona on the importation of carcasses and parts of cervids; and
  • Prohibiting the use of lures and scents containing cervid urine

The cost of baiting

The economic costs associated with wildlife disease outbreaks and control can be severe. Costs of disease outbreaks are generally recurring and additive due to annual costs of monitoring and eradicating diseased animals. Wildlife disease outbreaks can cause a significant decrease in hunting license revenue due to increased hunter/public caution and decreased hunter participation. Such loss of hunting-related revenue to rural economies can be disastrous to the state’s economic stability and may decrease operating budgets of state agencies, thus further causing negative impact on wildlife resources. Baiting and feeding of game wildlife species detracts attention, resources, and effort away from wildlife habitat management, which biologists consistently recognize as the foundation of wildlife conservation.

If wildlife diseases are introduced into Arizona and spread to native wildlife, hunters in the state would be adversely affected, as the Department would have to use money that otherwise would have been directed to wildlife management, habitat creation and hunter issues. Further, hotels, restaurants, gas stations, sporting goods stores, and other businesses that draw economic benefit from hunting would also be adversely impacted. The U.S. Department of Agriculture disperses $17 million to $19 million annually to help states look for CWD. A recent detection of chronic wasting disease in Wisconsin has cost the state wildlife agency approximately $250,000 in the first month and the costs continue to rise, with the state estimating that it will need $22.5 million over the next three years to fight the disease. In Colorado, management of the disease required an additional appropriation from the state legislature of approximately $350,000. Simply put, management of wildlife diseases is a tremendously expensive proposition for the state, and measures must be taken to prevent their introduction into Arizona.

Timeline, public comment opportunities for Article 3 “Taking and Handling of Wildlife”

Aug. 3-4, 2012, Public Commission Meeting – Informative briefing only, and limited to matters that are being considered in the rulemaking package for Article 3.

Sept. 7-8, 2012, Public Commission Meeting – Formal presentation to the Commission, with the Department’s recommendation that the formal Notice of Docket Opening and Notice of Proposed Rule Making be filed with the Secretary of State’s office, for publication in the Arizona Administrative Register. Public attendance and comments welcome.

Oct. 5 – Nov. 5, 2012, Public Comment Period – The 30-day public comment period for the proposed rule language. Comments may be submitted via telephone, e-mail, or USPS mail.

Nov. 2012 – Jan. 2013, Agency Evaluation – Agency will evaluate and review comments; consider any changes, impacts, etc.; and provide responses to all comments.

Jan. 11-12, 2013, Public Commission Meeting – Formal presentation to the Commission regarding final package, based on input from the public comment period, and recommendation to submit Notice of Final Rulemaking and Economic Impact Statement to the Governor’s Regulatory Review Counsel (G.R.R.C.). Public attendance and comments welcome.

Feb. 7, 2013, Submit NFRM/EIS to G.R.R.C. – Submission of NFRM/EIS for review and the opening of G.R.R.C. public comment period.

April/May 2013, G.R.R.C. Meetings – Study session and council meetings to finalize input and identify questions and comments needed for final rule approval.

August 2013, Adoption of Rule – New rules qualify to become effective 60 days after approval from G.R.R.C.; however, in some instances rules are not adopted until the beginning of the next calendar year in order to allow time for the Department to prepare for implementation of approved amendments.

To learn more about the State of Arizona’s rulemaking process, visit

For information on Game and Fish rules, visit

To view the proposed rulemaking, visit



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