A company in Cameron, Wisconsin sells bear bait in 40-pound bags. Printed on the bag, by the manufacturer, in their own words: food product waste. Inedible. Not for human consumption. Guaranteed analysis, one percent protein.

That is what Wisconsin permits people to pour into the woods every year from April 15 until the close of bear season — roughly six months, essentially every waking day of a bear’s year. No permit. No license. No registration. No cap on how many sites one person can run. And every September, the state points at the resulting bear population and issues a record number of kill tags.

This is the story of an agency that has all the science it needs, wrote much of it itself, and refuses to act on any of it. Below: the dead cubs, the peer-reviewed studies, the vote counts the public won and lost anyway, and the one line in the regulations that proves they know exactly how to fix this.

In 2017, researchers at UW–Madison published a study in the Journal of Wildlife Management. One co-author was Dave MacFarland, the DNR’s own large carnivore specialist. They sampled bait and native foods in the Chequamegon-Nicolet National Forest and compared them against tissue from bears killed in the hunting seasons.

The finding: bait makes up more than 40 percent of a black bear’s diet in northern Wisconsin.

Yosemite has a nationally famous problem with bears breaking into cars for human food. Ours eat more of it than theirs do — because ours is delivered.

The researchers noted bait could be playing a role in the high bear density up north, and that female bears eating bait show increased fertility. Follow that circle: dump millions of gallons of sugar in the woods, bear numbers rise, point at the higher numbers to justify a bigger quota, sell more licenses, dump more bait.

Bob’s Bear Bait · Wisconsin

Bob’s Bear Bait · Wisconsin

Theobromine, the stimulant in chocolate, is toxic to bears. The DNR’s own Black Bear Plan states it is toxic to a wide diversity of wildlife species, that it can have sublethal impacts on bear health, and — critically — that impacts on other species that may ingest chocolate at bear baits have not been examined in Wisconsin.

Wisconsin’s own dead: a cub in Bayfield County, necropsied after eating a mix of corn, molasses, cookies, blue frosting and chocolate shavings, with theobromine and caffeine concentrations in its liver within the range toxic to bears. Two more probable in Washburn County. Randy Johnson, the DNR’s large carnivore specialist, has acknowledged those verified deaths on the record.

Elsewhere: in New Hampshire in 2014, two adult females and two cubs were found dead within 50 feet of a site where a hunter reported placing 90 pounds of chocolate and doughnuts. Necropsy at the University of New Hampshire confirmed heart failure from theobromine. The state’s bear project leader called it an awful way to die and said there is no way to control how much chocolate a bear will consume at a bait site. Michigan recorded a cub death in 2011, along with raccoon deaths. Both states banned chocolate. Wisconsin did not.

The peer-reviewed literature is settled: Beringer, Timmins & Hiller, Wildlife Society Bulletin 40(2), 2016, documenting methylxanthine toxicosis in black bears from chocolate-based baits.

Here is the part that ends the “we can’t regulate bait content” defense. Wisconsin regulates bait content constantly. Under NR 10.07(2m), bear bait may not contain animal parts or by-products — the DNR lists honey, bones, fish, meat, solid animal fat, animal carcasses, and bacon grease. Bait may not be in or contain metal, paper, plastic, glass or processed wood. Ten gallons per site. It must be enclosed in a hollow log, hole or stump.

What bears get instead is one sentence: hunters are encouraged to minimize or avoid chocolate.

Citizen Resolution #133022, filed by Jean Voss of Stoughton, states it plainly: any amount or type of chocolate may legally be used as bear bait, ten gallons are allowed at a single site, and the number of bait sites per person is not restricted.

Resolution #410721 goes further — Wisconsin has no baiting registration requirements at all, and wardens have admitted they cannot devote the time or manpower to investigate the volume of baiting violations reported to the DNR hotline. Minnesota, by contrast, requires an outfitter license to bait for compensation and requires every site to be registered and tagged with the licensee’s name and number.

So when the state says no mortalities have been verified, understand what that means: nobody is looking. The DNR’s own documents concede that undetected mortality may be occurring.

Jean Voss reported the statewide spring hearing results in a 2021 letter to The Capital Times:

Roughly 85 percent support, three years running. And the committee that reviews those votes? Voss reports that the Wisconsin Conservation Congress Bear Committee requires its members to support and promote bear baiting as a core value. That is the body advising the Natural Resources Board on the will of the public.

A study on chocolate baits was proposed in the Wisconsin Bear Management Plan. It was never mandated. The agency then cites the absence of Wisconsin-specific research as the reason it cannot act.

Documented in Wisconsin

Everything does. Skunks, fishers, mink, pine marten — a state-endangered species — white-tailed deer, ravens, jays, squirrels. Anyone who has stood at one of these sites has seen it.

The federal record backs this up. The U.S. Forest Service’s 1993 Biological Assessment concluded bear baiting may adversely affect the northern bald eagle, the gray wolf, the grizzly bear, the North American wolverine, and the fisher. In March 1994, the first wolf known to roam wild in northern New England was drawn to a bear bait station and shot by the hunter.

And the deer contradiction is written into Wisconsin’s own rule. Deer baiting is banned outright in counties with confirmed CWD. Bear baiting is not. The state’s entire disease safeguard is a requirement that bait be enclosed — a rule whose stated purpose is to keep deer out. A hollow log with a rock on it, in the counties where they’ve decided deer congregation is dangerous enough to outlaw.

Peer-reviewed, in PLoS ONE: the probability that a wolf kills a bear-hunting dog increases with the duration of bear baiting — producing a relative risk 2.12 to 7.22 times greater in Wisconsin than in Michigan. Hound hunters start their dogs at bait sites roughly 90 percent of the time. The longer bait sits, the more wolves associate with and defend those sites.

The authors state that management options exist to reduce this conflict, including adjusting baiting regulations, and that actions other than reducing wolf abundance could achieve the goal.

Wisconsin has the longer baiting season. That is the variable driving the risk. That is the variable the state controls. Instead, we killed wolves and paid compensation claims.

We file. We show up. We put the agency’s own findings in front of the Natural Resources Board and make them explain, on the record, why peer-reviewed research co-authored by their own staff has produced zero regulatory change in nine years.

We are entirely volunteer-run. No paid staff. No corporate funding. Outspent by thousands. The good news is that we are in the right, and now we have their paperwork.