April 10, 2012
Sergeant Carl Klein
WASHINGTON DEPARTMENT OF FISH AND WILDLIFE
600 Capital Way N.
Olympia, WA 99501
Re: WDFW Hunter Education Draft Instructor Policy Manual
Dear Sgt. Klein
This letter presents the Richland Rod and Gun Club (RRGC) Hunter Education Instructor Team’s concerns about the proposed “WDFW HUNTER EDUCATION DRAFT INSTRUCTOR POLICY MANUAL”.
Its general tone, when combined with specific points, impugns the integrity, skillfulness and dedication demonstrated in the volunteer work currently performed by certified hunter education instructors and registered hunter education volunteers throughout Washington State.
The Richland Rod and Gun Club initiated Hunter Education Training in the Tri-City area in 1957, shortly after the original law mandating firearms safety training was enacted. Instructors associated with the club have taught classes every year since, successfully training more than 17,000 students, one member has taught for 56 years. There has never been an accidental firearm discharge in our classrooms. Neither to our knowledge has there ever been any accidental firearm discharge associated with hunter education firing range or classroom instruction in Washington State. Overall, the changes proposed in the draft Manual substantially reduce realistic, “hands-on” experience with firearms, compromising effective training to the students’ detriment.
This “Policy Manual” demonstrates a complete lack of trust in certified instructors to teach firearm usage in a safe manner. Additionally, it proposes to confiscate property without just compensation. This is not public property that the WDFW can arbitrarily usurp. These firearms, and related educational materials, have been acquired over the years by the various hunter education teams. They were paid for out of the instructors’ personal funds, other private donations and/or grants from a variety of charitable organizations. They are not the property of the State of Washington
The “draft policy manual” needs to be completely rewritten and a new one developed consistent with common sense and realistic application. The proposed mandates (presented as policies) preclude more than they include. It is a manual of what one may not do when teaching, and what one must do, regarding reports and organization. The “draft policy manual” effectively precludes vital interaction with students. If interaction is necessary or desired the instructor must first reduce the request to writing, have it signed, and then have a second instructor on hand to witness the interaction. Such restrictions are clumsy, impractical, and insulting, needlessly undermining instructor/student trust.
The “draft policy manual” states that the Hunter Education administration will provide all the materials and additional policies and instructions in the next few months. Unfortunately, we have heard this one too many times. We (the RRGC instructors) cannot envision ourselves being able to effectively teach safe firearm handling in the environment that will result from these “draft policies”. Hunter Education is not a “for credit” university semester course. It is a 10 hour program tightly focused on safe firearms handling. The “draft policy manual” proposes to micro-manage and control everything from what may be worn, to what may (and may not) be said. It is a draconian solution in search of a problem!
The restrictions and limitations proposed in the “draft policy manual” will result in under-trained students. They will have substantially less “hands-on” experience; less “muscle-memory”, and inadequate opportunity to build safe gun handling habits. This will result in increased – and entirely avoidable – frequency of accidents with firearms.
In 2010 the RRGC Hunter Education program boasted the largest team-teaching group in SE Washington: 17 certified instructors and 25 registered volunteers, who were supported by four private organizations and two conservation groups. Since the start of these policies, and the subsequent meetings to include the most recent IST, 10 instructors have already resigned. The registered volunteers feel exposed and decline to participate, the organizations that have supported our team threaten to cease providing critical facilities and materials, including classrooms and firing ranges. Unless the “draft policy manual” is thoroughly revised to be more realistic, practical and oriented to safe firearms handling practices, the members of the RRGC team will withdraw from the Washington State Hunter Education Program as will the RR&GC, the Connell Gun Club, and the Tri-City Metallic Silhouette Association
We (the RRGC instructor team) have attached several proposed revisions. These are intended in good faith as just a few examples of the most important kinds of practical, “real world” changes that will need to be made. We have many other recommendations, but they are too numerous to address in the context of this letter.
Because the proposed draft policy manual is so controlling and unreasonable it will lead to the resignations of many more hunter education instructors. This will result in the substantial loss of hunter education opportunities for students. The wholesale departure of experienced, qualified instructors will leave many areas of the state without any program. This in turn will lead to the reduced sale of hunting licenses, reduced grant income to the State and reduced support for the conservation and wise use of State resources. Eventually, it will be easier for many to travel to Oregon, Idaho or Montana and take their hunter safety program, receiving better, safer instruction, while obtaining the same certificate. This entirely avoidable loss would be a profound shame!
Appropriate, effective hunter education is too important to our community for us to stand idly by and allow it to occur. We remain ready and willing to help improve the hunter safety education program.
Jeff Gardner, President
Richland Rod & Gun Club
Gaylord Baker, President
Tri-Cities Metallic Silhouette Association
Don Board, Instructor
The policy draft can be found at http://wdfw.wa.gov/hunting/huntered/instructors/index.html for your reference.