- Language proposed is overly broad in nature, specifically "reasonable efforts".§ 18.2-132.1 already addresses the intentional release on private property,

      - Reasonable efforts proposal is geared towards bear and deer hound hunting and is prejudice in nature. Does not apply to bird, small game or shed hunting with dogs.

      - Presumption that reasonable efforts are not being taken will be simply garnered on a "whim" and will be falsely complained to achieve the 2+ instances (as seen in the past) and opens hunters further false claims and harassment.

      -  The semantics of the rationale data presented falsely exaggerate an assumption of hounds posing a transgression 2,002 times for calls for service. Majority of the 2,002 calls are merely complaints with little alleged violation 

            (which can be falsely inflated, as those who are pushing these proposals have boasted on social media and videos to "call and complain as much as you can", which may account for most of the 699 placed non violation calls)

             4,126 of 6128 calls did not involve hunting dogs. Hunting Dog violations are not in the majority of complaints.  

            Rationale Rephrased:  Total alleged violation call complaints involving dogs were 188 out of 6,128 total call for service complaints fielded by DWR

 

      - Hunters already attempt to deter their dogs from entering undesired landowner property prior to lawfully retrieving their animal from said property. Normally dogs are called out on an adjacent property where permissible to return to owner if they are not able to prevent the crossing.

                

  - "Reasonable efforts" for hunters is hindered when the landowner has unlawfully detained the animal ( § 18.2-102)., intentionally preventing its willing return to its owner on said adjacent property. Instances of verbal abuse and threats on the hunter have been observed when lawfully retrieving unlawfully detained animals.

                             

Any person who shall take, drive or use any animal, aircraft, vehicle, boat or vessel, not his own, without the consent of the owner thereof and in the absence of the owner, and with intent temporarily to deprive the owner thereof of his possession thereof, without intent to steal the same, shall be guilty of a Class 6 felony, provided, however, that if the value of such animal, aircraft, vehicle, boat or vessel shall be less than $1,000, such person shall be guilty of a Class 1 misdemeanor. The consent of the owner of an animal, aircraft, vehicle, boat or vessel to its taking, driving or using shall not in any case be presumed or implied because of such owner's consent on a previous occasion to the taking, driving or using of such animal, aircraft, vehicle, boat or vessel by the same or a different person. Any person who assists in, or is a party or accessory to, or an accomplice in, any such unauthorized taking, driving or using shall be subject to the same punishment as if he were the principal offender.