The governor shapes the direction of state wildlife policy through appointments to the state Fish and Wildlife Commission, and can influence the Commission and the legislature through his leadership. The legislature establishes the governance structure and mandate for the Department of Fish and Wildlife (WDFW), and can choose to pass legislation on virtually every issue within WDFW’s purview.
However, under the current governance structure, the Commission has responsibility for most state wildlife policy. It approves rules to implement legislative direction, sets goals and policy directives, and is the only body empowered to hire, supervise, and, if necessary, fire the WDFW director. The Commission consists of nine volunteers appointed by the governor and confirmed by the Senate, whose only necessary qualification is to “have a general knowledge of the habits and distribution of fish and wildlife.” See RCW 77.04.040. Because it is an unpaid position, most commissioners are retired.
The director runs day‑to‑day operations of WDFW. WDFW is a state agency with more than 2,000 employees and an annual budget of over $360 million, the vast majority of which comes from general taxpayer funds.
WDFW is “not scientific” because its management routinely sidesteps the best‑available science—particularly, and most overtly, when the evidence supports stronger protections or limits on exploitation. Staff scientists have frequently noted this problem:
- In a 2020 survey, only 20% of professional staff reported that upper management regularly makes decisions based on the best available science.
- In a 2021 report by the state auditor, more than two dozen employees said agency management makes political decisions on hot‑button issues that contradict the Department’s own research and expert staff recommendations.
- Former staff have come forward to say that although management pretends its decisions are based on science, it often has an agenda and will “launder the scientific evidence to fit that agenda.”
WDFW’s disrespect for science is systemic and longstanding. For example, the Department: long promoted spring bear hunting as a “management” tool although it lacked science or data showing it served any management need; expanded hunting limits for cougar in excess of what its own staff said was sustainable; advocated for the removal of state and federal protections for wolves while ignoring the science on the status of the population, the likelihood of recovery, and the impact of lowered protections; repeatedly kills wolves on public lands even though science shows this will not reduce conflicts with domestic animals and may even exacerbate them; disregards the science on what is necessary to save the Southern Resident orcas; uses the Southern Residents as an excuse to dramatically expand salmon hatchery production, bypassing required environmental review and ignoring the scientific consensus that hatcheries harm endangered wild fish; and produced a shockingly deficient Game Management Plan that lacks scientific integrity, with insufficient data to support its conclusions, a failure to acknowledge uncertainty or assess risks, a refusal to consider ecological factors, and the absence of adequate monitoring provisions or decision-making triggers for adaptive management.
When WDFW maintains that the “science supports” a particular use of wildlife, it is taking a very limited view of what “science” is relevant. At best, it means that science indicates that the use in question will not directly or immediately lead to the extinction or extirpation of a species. Meanwhile, it routinely ignores science regarding ecological impacts, the implications of climate change, habitat threats, genetic resilience and connectivity, and the importance of factors such as population structure, stability, and diversity. And WDFW never even acknowledges, much less considers, the large and growing body of science establishing that wild animals are conscious, feeling, social individuals who feel joy, pain, fear, sadness, and loss; are capable of reason, generosity, and empathy; and value their own lives and the lives of members of their family and social groups. Likewise, WDFW ignores all science related to how human interventions impact animals’ well-being, including their physical, mental, and social health. The dismissal of such extensive scientific literature is based on, and perpetuates, an archaic, unethical, and unscientific view of wildlife (see discussion below).
WDFW management has an obligation to present all the best-available science to the Commission and the public, be honest when the science or data is incomplete or insufficient, and be transparent about when its recommendations and practices conflict with science. Its willful blindness to the science and data that it deems inconvenient leads to uninformed and misdirected decisions, while camouflaging the real motivations behind its policy choices.
We say WDFW is “not ethical” for many reasons. It evades laws in place to protect wildlife, disregards the safety of its employees, fails to follow its mandate, and makes decisions that are incompatible with its duty to manage wildlife in the public trust for all current and future Washingtonians. But two of WDFW’s core ethical problems are that it refuses to acknowledge the value judgments that shape its decisions and treats wild animals as if they are objects whose sole purpose is to be used and managed by humans.
WDFW management pretends that it manages Washington’s wildlife in accordance with science and does not make judgments based on ethics or values. Nonsense. WDFW management “follows” science only when it aligns with its priorities, deliberately excluding consideration of opposing evidence, and any science on topics it considers irrelevant (see above). Regardless, science does not dictate decisions; it merely informs them. Ultimately, policy decisions, including what information to consider, and whose interests to prioritize, come down to value judgments, whether or not they are explicitly acknowledged.
What WDFW leadership actually means when it says that it does not consider values in setting policy is that it rejects any position that deviates from traditional agency values, which for decades have been centered around the instrumentalization, domination, and exploitation of wildlife. Across programs and in myriad decisions, WDFW prioritizes recreational and commercial exploitation over wildlife protection, the broad public interest, and the intrinsic value of wild animal lives, which the vast majority of Washingtonians now recognize.
Instead of acknowledging that values shape WDFW’s decisions, Director Kelly Susewind’s attitude is that WDFW should “respect” all values, which means “you don’t tell somebody what their values are.” In other words, anything goes: if someone wants to kill a wild animal for any reason, at any particular time, or in any specific way, then WDFW should allow it as long as it deems it to be “sustainable.”
This is, perhaps, the clearest statement of WDFW’s real ethics framework. For WDFW, the paramount goal is to satisfy the desires and demands of the tiny percentage of Washingtonians who wish to kill or exploit state wildlife, in such a way that it does not interfere with the desires and demands of future Washingtonians who wish to kill or exploit wildlife. To WDFW, wildlife is not “life” at all. It does not recognize that wild animals have any value other than as objects for our entertainment or consumption.
But wild animals are living, thinking, feeling beings. That is not a matter of opinion or emotion: it is a scientific fact. Any wildlife policy framework that fails to acknowledge this truth is inherently unethical.
WDFW’s mandate, as stated in RCW 77.04.012, embodies its public trust responsibility to serve all Washingtonians. The mandate’s first commendment is that WDFW must “preserve, protect, perpetuate, and manage” Washington’s wildlife. Accordingly, WAC 220-101-010, which describes the purpose of the department, notes that its “primary responsibility is to preserve, protect, perpetuate, and manage the fish and wildlife species of the state.”
But the Commission and WDFW rarely consider this first obligation. Rather, most of their attention is focused on the fourth component of the mandate, which instructs them to “maximize the public recreational game fishing and hunting opportunities of all citizens.” Their discussions of wildlife policies and regulations thus dwell on recreational “opportunity,” with only limited reference to whether a particular activity is sustainable—which in their view only encompasses the question of whether it will immediately lead to a population loss incompatible with future human use.
WDFW fails to consider the direction to “maximize…opportunities” in the context of the entire mandate, which not only obligates it to “preserve, protect, perpetuate, and manage” fish and wildlife, but also instructs it to “conserve” fish and wildlife “in a manner that does not impair the resource.”
WDFW must synthesize all parts of the mandate; it cannot pick and choose which parts to follow. The mandate must also be read in the context of WDFW’s overarching duty as a public trustee.
Under the law, Washington’s wildlife “is the property of the state,” giving all citizens a vested interest in its protection. WDFW’s duty is thus to care for Washington’s fish and wildlife as a trustee for all Washingtonians, both current residents and future generations.
This means members of the Commission and WDFW management cannot make decisions in order to benefit themselves or to satisfy special interests such as industry or the trophy hunting lobby. It also means that they cannot prioritize the demands of the 2-4% of state residents who hunt over the interests of the rest of the population—such as recklessly allowing the continued killing of vulnerable and declining wildlife, and species for which it has no reliable population information.
An agency that disrespects science, disregards ethics, and discounts the people’s interests and values cannot credibly serve Washington.
WDFW’s governance structure isolates the Commission and the director from political pressure, allowing them to ignore the evolving values of the Washington people. Scientific studies have documented that an increasing proportion of the Washington public values coexistence over domination, viewing wildlife as part of our social community and deserving of at least some rights. Scientific research also highlights the growing values gap between WDFW and the public, with more agency professionals continuing to hold “traditionalist” views centered around domination and exploitation, while the public moves toward a “mutualist” viewpoint that emphasizes ethical consideration and coexistence.
Public polling confirms this dynamic, with 69% of Washingtonians acknowledging that wild animal lives matter in and of themselves, not just because of what they can provide to humans. Polling also shows that Washingtonians care about wildlife, believe all Washingtonians (not just “traditional” consumptive interests) should have an equal say in wildlife decisions, and think that WDFW’s primary goal should be to protect, preserve, and perpetuate fish and wildlife, not preside over their exploitation.
Most Washingtonians are unaware of specific WDFW policies and are often shocked when they learn of what is being done in their name. For example, Washingtonians oppose spring bear hunting, killing wolves on public lands for the beef industry, policies on beavers and coyotes, and the use of taxpayer money to recruit more hunters.
When WDFW sidelines evidence and ethics in favor of narrow recreational and commercial demands, it departs from what the public expects and deserves: an agency that protects wildlife on behalf of all Washingtonians.
Far from it. Most of WDFW’s scientists, enforcement officers, conflict specialists, field staff, and other employees are dedicated, honorable public servants, many of whom are desperate to see change within the agency. In fact, WDFW’s employees bear the brunt of WDFW’s dysfunction. A recent audit of workplace culture at WDFW found a toxic culture where unethical and illegal behavior was common; employees were frequently bullied, often on the basis of gender; employees had little trust in management’s ability to respond to their concerns; and management frequently retaliated against employees for speaking out. In a 2024 letter to Governor Bob Ferguson, the largest union of WDFW employees emphasized management’s failure to follow safety regulations, which recently led to the tragic deaths of two employees. Said the letter: “WDFW management is failing its employees at the most fundamental level, and our members are literally paying for that failure with their lives.”
Our critique targets leadership responsible for management, governance, and policy direction—where transparency, accountability, and ethical guardrails are required but too often missing. We stand behind the employees who are victims of this mismanagement, who understand the need for reform, and who deserve leadership that empowers them.
Because Director Susewind has failed Washington’s wildlife, his employees, and the Washington people. Read about the reasons behind our petition to remove Director Susewind here.
Lasting change will come when the people of Washington learn what WDFW is doing in their name, feel empowered to speak out about it, and join together to demand reform.
Washington Wildlife First is working toward reform on several different levels:
- Our Not My WDFW campaign will educate the Washington people about the fish and wildlife policy pursued in their name and empower them to demand change.
- By filing lawsuits and taking other legal action, we seek to force WDFW to comply with existing laws in place to protect wildlife and the environment.
- Our legislative team works to improve those laws, to reform WDFW’s governance structure, increase its accountability, and put in place greater protections for Washington’s wildlife.
- Our advocacy team serves as a watchdog, tracking agency actions, attending Commission meetings, submitting comments and testimony, and alerting the public when it is time to take specific action.
Washington’s wildlife policy will change when enough Washingtonians demand it. You play a critical role in helping us build that momentum: Become informed, share what you learn, and show up to take action when it matters. Here are the actions you can take today:
- Sign our petition calling for the investigation and removal of WDFW Director Kelly Susewind;
- Subscribe for updates and alerts on when your action is needed most;
- Join our Wildlife Action Team to help expand our reach; or
- Donate to power our advocacy, outreach, and legal work.
