The Humane Society of the United States sent letters to both Washington Governor Jay Inslee and the Washington Department of Fish and Wildlife calling an annual bear hunt on timber farms "illegal." They're threatening to sue unless changes are made quickly.

"HSUS is prepared to seek judicial review of this matter, but we are hopeful that the Department will immediately halt the Program and utilize a collaborative effort involving input from stakeholders and the public to develop a sound process for addressing any timber damage caused by bears," the letter to WDFW Director Jim Unsworth reads.

KING 5 asked WDFW for comment but the agency declined.

The letters come six months after KING 5's year-long investigation, The Bear Hunt. After combing through more than a thousand internal documents requested through public disclosure, KING found the Bear Timber Depredation Management (BTDM) program violates state law.

Related: Loophole allows illegal bear hunt involving dogs every year

Twenty years ago, voter initiatives 655 and 713 outlawed hunting bear with the use of dogs as well as bait. Those practices continued on timber farms, however, often kept secret from the public. Bait and hound hunting are used by timber farms across western Washington in the spring when bears peel trees to reach the sugary syrup under the bark. Timber farmers argue the bears hurt their bottom line.

A loophole allowed for the hunting practices to continue for damage control targeting problem animals, but KING found the program focused on generally reducing the number of bears on timber. According to documents we obtained, bears are often killed for being in the wrong place at the wrong time. Hunters tell KING that more bears are killed than permits even allow, and in areas outside permitted hunt zones.

"Moreover, as Department employees have acknowledged, the bear-killing program is ineffective and imprudent, taking the lives of bears not causing any problems. It's a program that seems geared more toward amassing a body count than meaningfully reducing economic damage caused by bears," writes HSUS CEO Wayne Pacelle to Governor Inslee. "I respectfully request that you utilize your executive powers, to the maximum extent allowed under the law, to see that the Department remedies its legal violations."

KING 5 also learned about a supplemental feeding program, where hundreds of thousands of pounds of feed are put out to deter bears from eating the trees. However, the state has very few rules around the feeding program and rarely enforces the rules it does have. The feed is allowed out until the minute hound hunters begin, and has been found dumped on the ground and left out during hunts. One forester added cat food and a sticky syrup, despite warnings, but never faced consequences. WDFW has no rules about what is allowable supplemental feed.

Many offenses are not prosecuted because the rules are too inconsistent, KING 5 learned.

Related: Bear feeding program criticized for baiting

HSUS says the BTDM program violates I-655 and I-713 in the following ways: state law only allows baiting and hound hunting by agents of the state but WDFW allows timber farms control of nearly every aspect of the hunts, like choosing hunters; the program authorizes baiting, hounding, and trapping for unlawful purposes like population control and a recreational hunt without targeting problem bears; the program unlawfully uses supplemental feed as bait; the program fails to require reasonable exhaustion of nonlethal methods.

The letters also say that significant changes to the program have not gone through a formal rule-making process as required by law.

One major criticism is that hound hunting and baiting bears are only allowed by "agents of the state," according to the law. HSUS argues that WDFW considers hunters contractors, however, as hunters answer to timber farms and not the state.

"The Department chose to move forward with the illegal Program despite this knowledge, even outwardly acknowledging that it considers certain unlawful behavior acceptable. Therefore, the Department must immediately cease and desist issuing permits that allow persons who are neither agents nor employees of the state from baiting and hounding black bears, as required by state law," the letter to Unsworth continues.

HSUS is demanding a stakeholder group be formed, similar to the Wolf Advisory Group created to deal with wolf conflict. If not, the letter says, HSUS is prepared to sue. WDFW recently began the process of forming such a group, but admits it's moving slowly due to several challenges like finding a facilitator.

"We urge the Department to take immediate steps to come into compliance with the law. HSUS strongly urges the Department to convene a stakeholder advisory group to develop non-lethal management strategies to prevent and mitigate timber damage, and is glad to see that the Department has taken first steps toward that end," the letter ends.

HSUS Letter to Gov Jay Inslee by KING 5 News on Scribd

HSUS Letter to WDFW director by KING 5 News on Scribd