Chapter 2: Conserving the Future

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• Shari Welsh April 14th 2011 at 11:55 am   #     

  A refuge is a place of safety and that is much needed in America as wildlife is under siege. Hunting and fishing should not be allowed on refuges and wildlife is not anyones property. State and federal fish and wildlife services have been and are now not protecters of wildlife but prolific killers and accomplices to the killing of wildlife. I also don’t feel like witnessing our wildlife being murdered and my children and I being shot by hunters while visiting refuges.”About Wildlife Services
  Wildlife Services is the only federal program that kills native predators at the request of ranchers and state wildlife management agencies. Wildlife Services’ predator control program is a primary focus of Predator Defenses’ legislative work. Scroll down this page to learn more.

  In the News
  Men’s Journal article – “America’s Secret War on Wildlife: A federal agency keeps the West safe for cows by killing coyotes, wolves, bears–and pet dogs” – by Christopher Ketcham, January 2008
  Your Tax Dollars at Work
  The following pictures show animals injured as the result of Wildlife Services’ methods.WARNING: These pictures are very graphic and may not be suitable for children.

  Nine fox kits orphaned by USDA’s Wildlife Services – Photo | Story
  Domestic cat injured in leg hold trap set by Wildlife Services. Leg was later amputated.
  Young puppy suffers after being caught in Wildlife Services’ necksnare. The puppy was discovered by area residents and the photo was taken after one week of healing.
  Coyote caught in Wildlife Services necksnare
  Warning signs required to be posted by Wildlife Services.
  Often the signs are not posted or are missing.
  School children in Montana pose with wolves that Wildlife Services killed with aerial gunning in 2004. Seven wolves were killed in this incident.
  Cougars killed by Wildlife Services. This infamous photo of the severed heads of 11 mountain lions was taken by an outraged employee of the Arizona Game and Fish Department. These animals were among 24 lions killed by the federal agency Animal Damage Control (now called Wildlife Services) in the Galiuro mountains of Arizona, a wilderness area North of Willcox. All were killed on federal lands on the Coronado National Forest over a six-month period from December 1988-May 1989. While it is uncertain whether any of these cougars ever preyed on livestock, the ostensible purpose of the killings was to protect cattle that were grazing on public lands. This type of indiscriminate lethal predator control continues in almost all of the states where mountain lions occur. California is an exception in that only specific mountain lions documented to have killed livestock or threatened people are subject to lethal control by wildlife agencies. Also, in California no sport hunting of mountain lions is allowed.

  Introduction
  Wildlife Services (formerly Animal Damage Control) is a program of the United States Department of Agriculture, Animal and Plant Health Inspection Service. Every year, Wildlife Services spends millions of dollars to kill thousands of predators—coyotes, wolves, bears, mountain lions, and many others—as a subsidy for the livestock industry. The animals are shot, poisoned, gassed, snared, and caught in leghold traps. Wildlife Services programs operate on both private and public lands.

  USDA Wildlife Services’ data on number of animals killed and expenditures
  Wildlife Services policies and procedures have been questioned almost since the inception of the program. Although livestock damage is a valid concern, Wildlife Services also kills animals for eating flowers and pet food, digging in gardens, frightening people, and other concerns that could easily be addressed by nonviolent methods. And Wildlife Services runs programs to control bird damage, primarily in the eastern U.S. and at airports, as well as programs to remove damaging non-predatory wildlife.

  In addition, Wildlife Services wastes millions of taxpayer dollars by spending far more to kill predators than the actual damage those predators cause. Scientific proof that Wildlife Services practices control livestock damage is markedly lacking.

  Despite the opposition of environmentalists and a series of scathing advisory reports over the years, Wildlife Services has survived and prospered, primarily as a pet program of the powerful livestock industry. In recent years, Wildlife Services has been branching out to increase its programs to remove wildlife from urban areas and to promote itself to the public and to schools and other organizations.

  History
  Animal Damage Control began in 1886 as a program to advise people on how to control damaging birds. It began killing predators in 1914 and has continued to do so ever since.

  ADC has been the subject of scathing reviews by many bodies: the American Society of Mammalogists in 1930, the Advisory Board on Wildlife Management for the Department of the Interior in 1963, the Advisory Committee on Predator Control for the Department of the Interior in 1971,and the Animal Damage Control Policy Study Committee for the Department of the Interior in 1978.

  While these hearings have been harshly critical of ADC’s predator-killing policies, little substantive change has resulted. For a time, poisons were banned, but the bans have been rescinded for the most part, with only widespread broadcasting of Compound 1080 and strychnine still unpracticed. ADC’s response to anti-poison campaigns in the ‘80’s was to facilitate its move from the Department of the Interior, U.S. Fish and Wildlife Service, which livestock owners felt was too soft on predators, to the presumably less “predator-friendly” Department of Agriculture.

  Wildlife Services Chronology
  1886 – USDA creates the Branch of Economic Ornithology and Mammalogy, after interviewing farmers about bird damage. Programs concentrate on bird damage and control, and researching poisoning of house sparrows. No direct work conducted.

  1890 – Name changed to Division of Ornithology and Mammalogy

  1896 – Name changed to Division of Biological Survey

  1905 – Name changed to Bureau of Biological Survey. Advice on coyote and wolf control becomes a priority.

  1913 – Direct control efforts begin, controlling plague-bearing rodents.

  1914 – Direct predator control work begins.

  1915 – Congress allots $125,000 for predator control.

  1916 – Eradication Methods Laboratory opens in Albuquerque for poison research.

  1921 – Laboratory moves to Denver, CO. Years later, it becomes the still existing Denver Wildlife Research Center, which still invents new wildlife killing poisons and devices.

  1924 – Name changed to Division of Predatory Animal and Rodent Control (PARC).

  1930 – American Society of Mammalogists issues a paper condemning PARC. This paper almost lead to $1 million in Federal funds being canceled. Congress holds hearings on PARC.

  1931 – After the hearings, President Hoover signs the Animal Damage Control Act of 1931, which authorizes direct and cooperative control programs by PARC. This is still the primary statutory law under which ADC operates today.

  1934 – Name change to Division of Game Management, Section of Predator and Rodent Control.

  1936 – Pocatello Supply depot, which manufactures poisons, traps, etc., opens in Idaho.

  1938 – Name change to Division of Predator and Rodent Control (PARC).

  1939 – PARC is transferred from USDA to the Department of the Interior, Fish and Wildlife Service.

  1948 – Name change to Branch of Predator and Rodent Control.

  1963 – After growing criticism from environmental groups, Secretary of the Interior Stewart Udall appoints the Advisory Board on Wildlife Management to look into predator control in the U.S.

  1964 – “Predator and Rodent Control in the United States”, usually referred to as the Leopold Report, after advisory committee member A. Starker Leopold, is published. The report was sharply critical of predator control as being indiscriminate, nonselective, and excessive. The report led to only minor, primarily administrative, changes in predator control practice. Another name change made, this time to the euphemistic Division of Wildlife Services.

  1970 – Faith McNulty writes “Must They Die?”, which criticizes ADC’s role in endangering the black-footed ferret.

  1971 – “Slaughter the Animals, Poison the Earth”, a book highly critical of ADC, by Jack Olsen is published. Lawsuits from animal welfare groups over excessive poison use lead to the appointment of the Advisory Committee on Predator Control, headed by mammalogist Stanley Cain.

  1972 – The Cain report is published. It calls for an end to the use of poisons, and states that the benefits of predator control programs are highly exaggerated. 15 recommendations were made, including banning poisons. As a result, President Nixon signed Executive Order 11643, which banned the use of poisons by Federal agents and on Federal lands. The Environmental Protection Agency cancels all registrations for Compound 1080, thallium, sodium cyanide, and strychnine.

  1973 – The Endangered Species Act is passed.

  1974 – Name changed to Animal Damage Control.

  1975 – Gerald Ford amends the Executive Order to allow usage of M 44’s.

  1976 – Gerald Ford amends the Executive Order to allow usage of sodium cyanide.

  1978 – Yet another committee is appointed by the Department of the Interior to study ADC—the Animal Damage Control Policy Study Committee. The report was extremely critical of the ADC program, and called for it to be terminated. The Department of the Interior then issued “Predator Damage in the West A Study of Coyote Management Alternatives”.

  1979 – The report leads to an order from Secretary of the Interior Cecil Andrus to stop denning and research on Compound 1080 and to consider non-lethal control methods. ADC issues its firs Environmental Impact Report.

  1980 – “Incident at Eagle Ranch” by Donald Schueler, a book exposing unethical and illegal predator control practices in Texas, is published. The Western Regional Coordinating Committee, composed of ADC employees and University Extension personnel who used ADC services, opposes Andrus’ policy and calls for a transfer of ADC to USDA, saying that the Department of the Interior does not respect the needs of the livestock industry.

  1981 – The EPA holds hearings on ADC. Secretary of the Interior James Watt rescinds the ban on denning. President Reagan signs an executive order revoking President Nixon’s ban on poisons.

  1985 – Pressure builds to return ADC to USDA.

  1986 – Legislation passes and ADC returns to USDA under the Animal and Plant Health Inspection Service (APHIS). Yet another panel is formed by the USDA to study ADC–the National Animal Damage Control Advisory Committee. Out of 20 members, one is an environmentalist and one an animal welfare advocate. Among other panelists are representatives of the livestock, timber, and fur industries.

  1989 – ADC begins official claims that its policy is “integrated pest management”.

  1990 – The U.S. Fish and Wildlife Services Law Enforcement discovered Wildlife Services’ illegal trade of poisons, including Compound 1080. This investigation was called the “Wyoming Sting”.

  1990 – Draft Environmental Impact Statement is issued. GAO report finds that ADC kills coyotes even when damage has not occurred.

  1993 – Environmental Impact Statement issued.

  1994 – GAO investigation finds that ADC uses primarily lethal control methods.

  1998 – For 24 hours Wildlife Services’ Lethal Control Program was in jeopardy of being completely eliminated. A bill introduced by Congressman Peter DeFazio of Oregon passed in the House that would have cut all federal funding for lethal predator control. The amendment passed 229 to 193. Unfortunately, after passage, powerful Republican house members Bob Smith of Oregon and Joe Skeen of New Mexico worked the phones overnight with the help of the American Farm Bureau to invalidate this vote. In an unprecedented move, they called for a revote the following day based on a technicality in amendment wording. In the revote the bill failed 232 to 191.

  2006 – An audit conducted by the USDA Office of Inspector General found that biological agents and toxins used by Animal and Plant Health Inspection Service to kill wildlife they consider a nuisance are poorly safeguarded. (Wildlife Services is a branch of APHIS.) The audit faulted the agency for: 1) failing to keep accurate inventories of agents or toxins, 2) not restricting access to agents or toxins, and 3) not having complete security plans. Auditors visited 10 of 75 registered entities where agents are kept and found that none of the 10 complied with security regulations.

  Financing
  Wildlife Services costs Americans millions of tax dollars annually to kill thousands of predators using methods that are ineffective and cruel.

  Who benefits? Many western ranchers enjoy this subsidy but they are under no obligation to change their livestock management practices to reduce predator conflicts.

  Methods
  Leghold traps

  Leghold traps work by catching the target animal by the toes, foot or leg with a tightly-gripping metal trap, usually chained to a stake in the ground. The trap may be lightly padded. Trapped animals suffer severe injuries, exposure, thirst, and hunger.

  Conibear Traps

  Conibear traps are a “quick-kill” trap that crushes an animal to kill it. They are primarily used for water animals such as beaver and muskrat. Pets have been found in these traps–some still alive.

  Snares

  ADC uses two types of snares, which are not differentiated in the statistics. Foothold snares are designed to catch large animals by the foot and hold them. They pose less of an injury risk than legholds, although there are still problems with exposure, etc. This type of snare is used mainly on bears and mountain lions, and occasionally coyotes.

  The other type of snare is a killing snare, which is designed to catch an animal by the neck and strangle it. These snares also catch animals around the body, with lethal results. These are used to catch many types of smaller animals and coyotes.

  Cage traps

  Although cage traps may seem innocuous, it must be noted that the majority of animals Wildlife Services traps in them are killed, not released. Wildlife Services uses cage traps primarily for “cosmetic” and liability issues in urban areas.

  Aerial gunning

  Wildlife Services kills thousands of coyotes and red foxes by chasing them down and shooting them from helicopters and fixed-wing aircraft.

  Shooting

  Many predators are killed by calling and shooting, which is the use of a call making a sound resembling a prey animal to lure predators in close enough to be shot. Others are simply shot outright.

  Hunting dogs

  Some dogs are used to track and tree raccoons, bears and mountain lions. Others kill animals such as coyotes. “Decoy dogs” are also used to lure coyotes in to be shot.

  Compound 1080

  Compound 1080, whose chemical name is sodium fluoroacetate, is a tasteless, odorless, colorless poison that is especially lethal to canines but is extremely poisonous to all mammals.

  In the past, large chunks of meat were baited and left out where they killed any predator or scavenger that ate them. At present, the only legal use of Compound 1080 is in “livestock protection collars” (LPC’s), which are rubber bladders that are filled with a water solution of 1080 and placed around the necks of sheep or goats. However, ADC employees have been convicted in the past for illegally trading in 1080. There is a widespread belief by federal investigators that a black market for both still exists.

  Coyotes normally attack sheep by biting them in the neck. When a coyote punctures an LPC, a few drops of the poison enter the coyote’s mouth. The remainder drips onto the wool and into the torn flesh of the target sheep (which invariably dies) and onto the ground or plants where the sheep is attacked.

  The poisoned coyote can take hours to die. While in most species 1080 kills by causing ventricular fibrillation or other cardiac problems, in canines death is preceded by vomiting, convulsions, severe abdominal pain, staggering, whimpering, and drooling. The meat that poisoned coyotes vomit up is extremely toxic to scavengers. In the days when 1080 was used to bait carcasses and frequently poisoned dogs, the vomit from one dog sometimes wiped out whole packs of hunting hounds.

  While Wildlife Services is required to attempt to find poisoned coyotes, less than 10 percent are recovered. These carcasses serve as poison bait stations to scavengers, as does that of the dead sheep, which under regulations can remain on the range as long as a week. In addition, the collars are often punctured by barbed wire or vegetation, or simply fall off the sheep.

  According to the Predator Project (now Predator Conservation Alliance, a wildlife advocacy group in Bozeman Montana), “Historically, there has been insufficient monitoring and record-keeping of the LPC [Livestock Protection Collar]. Texas was one of the first states to reissue the LPC and is its greatest proponent. In a report issued by the Texas Center for Policy Studies (“TDA’s Failed Enforcement for Predator Poisons,” April 1995), the Texas Department of Agriculture (TDA) was found to be keeping inconsistent and contradictory records of LPC use within the state. The Texas Center for Policy Studies (TCPS) found that 1) in 1994, TDA did only 50% of the required inspections of LPC users, and 2) TDA has not done any of the required inspections during any of the last 4 years. TCPS concludes that without the inspections, the public and the EPA cannot be assured the Compound 1080 is being stored, used, and disposed of properly; and TDA cannot carry out enforcement against misuse of these dangerous poisons. This pattern of inadequate supervision cannot be assumed to be specific to Texas as much as it may be specific to use of the LPC.” There is no antidote for Compound 1080 poisoning.

  M-44’s

  M-44’s are spring-propelled sodium cyanide cartridges. A small pipe is spring-loaded with the cartridge then pounded into the ground and topped with an absorbent wick scented with carrion, musk, etc. When an animal pulls on the wick, the spring propels the cyanide charge into the animal’s mouth. The animal can die within minutes or it can suffer as long as eight hours.

  M-44’s are primarily used for coyotes and, to a lesser extent, red foxes. They have one of the largest percentages of non-target kills of any device, as any animal that is attracted to the scent of carrion can be lured and killed.

  Sodium cyanide is extremely lethal to humans as well. Wildlife Services employees and anyone else who places or services M44s is supposed to carry amyl nitrate to counteract the cyanide. Hikers, children, or others who stumble across such a device will have no such protection. Cyanide is lethal and can kill within minutes.

  The Myth of Selectivity
  Wildlife Services repeatedly claims that its methods are “selective”, implying that they only remove animals actually causing damage. For example, the Wildlife Services customer-service brochure states that, “We will support the most humane, selective, and effective control techniques.”

  However, the reality is that most Wildlife Services methods are nonselective, in the sense that they will kill many animals apart from the ones doing damage. Coyotes, the predator killed in the greatest number by Wildlife Services, make a good example. Approximately 75,000 to 90,000 coyotes are killed every year by Wildlife Services—vastly more than are reported as problems.

  Selectivity of Lethal Control Methods

  Shooting from fixed-wing aircraft and helicopters is not selective. With this method aircraft fly over a large area and all coyotes observed are shot.

  Shooting is selective if the animals are shot in the act of doing damage. Shooting coyotes on sight is not selective.

  Leghold traps and snares are somewhat selective in cases where an animal actually killed by a coyote is used as the bait. However, in most cases bait or lures are used to attract the coyotes, which makes these methods non-selective. Many non-target animals are caught with this method.

  M-44 cyanide ejectors are not selective. Any animal attracted to carrion, or other scent, used to attract coyotes will be affected.

  Calling and shooting are not selective. Any coyote within range that responds to the call will be shot.

  Hunting with dogs can be selective. In coyote hunting, dogs are often used to lure parent coyotes away from dens regardless of whether these coyotes have done damage. Their use in such a fashion is not selective. More often Wildlife Services uses dogs to hunt cougars and bear.

  In short, most of the above methods will be used against all coyotes in a given area, not against specific coyotes causing damage.

  Wildlife Services’ Poisons Arsenal
  The use of poisons to control predators is as old as the West. Trappers, ranchers, and Wildlife Services agents all use a myriad of poisons on both public and private lands. The poisons that are used are delivered by different mechanisms.

  The deadly “tools” of USDA’s Wildlife Services include:

  Alpha Chloralose
  Aluminum Phosphide
  Aminopyridine, Avitrol, 4-AP
  Bone Tar Oil
  Brodifacoum
  Cholecalciferol (Quintox)
  DRC-1339
  Fenthion
  Immobilizing/ Euthanizing Agents
  Mineral Oil: Petroleum Distillates
  Glyphosate
  Polybutene
  Sodium Cyanide
  Sodium Fluoroacetate
  Sodium Nitrate
  Strychnine
  Zinc Phosphide

  Alpha Chloralose (C8H11Cl3O6): Immobilizing agent used on waterfowl and other birds. Classified as a soporific, which is a central nervous system depressant designed to immobilize target species at sublethal levels. The compound is slowly metabolized, resulting in a recovery within a few hours from ingestion. Possible accumulation in species that have undergone multiple treatments. Secondary risks to predators a factor if target species not removed promptly after administration of the compound. FDA classified as a narcotic. Primary and secondary toxicity listed as low when the target species is removed. There is no probable aquatic risk due to the use pattern and lack of solubility in water.

  Aluminum Phosphide – AIP (55% or 57%) Also known as Fumitoxin, Phostoxin and Detia-Rotox: The compound is registered as a fumigant designed for the control of burrowing rodents. To be used by certified personnel only. Target rodents include pocket gophers, prairie dogs, moles, ground squirrels, muskrats, marmots, voles, and Norway rats. The compound is not persistent in soil due to the conversion to deadly phosphine gas when in contact with moisture, and ultimately (in several days time) to inorganic phosphate. The EPA has placed this compound in their highest toxicity category. The chance of non-target toxicity to burrowing animals is extremely high in targeted areas, and any animal coming in contact with the poison gas will likely be killed.

  4-Aminopyridine (C5H6N2), Avitrol, 4-AP: Lethal frightening agent used on grain baits for killing house sparrows, pigeons, blackbirds, and starlings to safeguard public health and safety and to protect against property damage caused by those species. Can be used only by State-certified pesticide applicators. Acutely toxic to both avian and mammalian species. Compound is very water-soluble. It is also highly mobile in soils and has the potential to leach to the ground water. Aquatic organisms are acutely affected at low levels. Biodegradation of the compound is slow in soil and water? its soil half-life extends up to 22 months. Non-accumulative in tissues, and is generally rapidly metabolized by many birds. Secondary poisoning, known for magpies and crows, is a potential.

  4-Aminopyridine (Avitrol Concentrate; 25%): Same as above except for the concentration. Used to control gulls. Primary and secondary poisonings probable unless each targeted species is gathered.

  Bone Tar Oil (Magic Circle Deer Repellent; 93.75%): Used as an odor repellant to deer. There is no probable risk to primary, secondary, or aquatic toxicity.

  Brodifacoum (Weather Blok) ( C31H23O3Br; 0.005%): Federally registered for the control of the Polynesian rat in Hawaii only. The “second generation” anticoagulant compound is contained in a rodent specific application box, so primary, secondary and aquatic toxicity potentials are all low due to the design of the applicator.

  Cholecalciferol (Quintox) (C27H44O; 0.075%): Also known as vitamin D3, which is used by humans for dietary supplementation. The compound is used in the control of rodents. As above, this compound is applied in a target-specific box which results in “target only” toxicity. The compound is not mobile in soils. There is little chance of bioaccumulation in plant or animal tissue. The primary, secondary, and aquatic toxicity potentials are all low.

  DRC-1339 (C7H9NCL2): Slow-acting avicide used widely throughout the United States. Lethal in a single feeding. Concentrate may only be used by APHIS Wildlife Services personnel trained in bird damage control or persons under their direct supervision. Commercially available avicide may be used by Wildlife Services personnel as well as others who are State certified in pesticide application. Highly toxic to starlings, blackbirds, and magpies and other birds. More toxic to birds than to mammals. DRC-1339 (98% Feedlots): Used to control blackbirds, starlings, pigeons, crows, cowbirds and grackles. 0.1% concentration tarlicide is a brand name for this: Similar to above, but is not a restricted use pesticide. Federally registered for the control of starlings and blackbirds. Could affect non target species. DRC-1339 (98% Eggs and Meat bait): Similar to above, but in a powder that is applied to bait (eggs and meat). Used primarily to prevent livestock depredation by ravens. Could affect any non-target species that were to consume the poison.

  Fenthion (C10H15O3S2P), also known as Rid-A-Bird: Organophosphate compound used on bird perches to poison birds which land or come in contact with it. Also used as an insecticide (mostly mosquito control). Toxic to all avian species. Affects non target species that come in contact with it. Could potentially affect peregrine falcons and other raptors, which are all particularly sensitive to fenthion contamination. Estimated to break down in a week or so under normal conditions.

  Immobilizing/ Euthanizing Agents (Ketaset, Beuthanasie-D, Rompun): These are several drugs used by Wildlife Services to target individuals for sedation or death. They are normally injected directly into the animal, so the chance of non target toxicity is negligible.

  Mineral Oil: Petroleum Distillates: A petroleum product that is highly lipophilic and easily bioaccumulates in tissues, especially fat tissues. Used primarily for the control of gulls. The product is sprayed on the gull eggs to asphyxiate the embryos. Claimed to be non-toxic to hatched birds as a result of limited studies. Secondary and aquatic toxicity both claimed to be low due to the low degree of toxicity.

  Glyphosate (C3H8O4PN): Nonselective herbicide for use in aquatic environments. Designed for control of cattails where blackbirds roost. Used primarily in the summer when the cattails are more affected by the herbicide. It is moderately persistent in soils (50% lost in 60 days). It has a low mobility, but translocates easily into foliage. Low risk of toxicity to animals because the compound was designed as a herbicide. Claims to have no potential risk to primary, secondary, or aquatic species.

  Polybutene (80%) also known as Eaton’s 4-the-Birds: A transparent, sticky compound that is designed to discourage birds from roosting or perching on treated ledges. Primary, secondary, and aquatic toxicity none due to the non-toxic product. This product can be lethal if applied incorrectly. There are instances where birds will suffer from an excess of the adhesive on their wings and feathers. This compromises their temperature regulation and usually results in death from exposure.

  Sodium Cyanide (NaCN): M-44 Cyanide Capsules, 88.62%. Found in a 1 inch tall by 0.44 inch diameter (M-44) ejector mechanism. When in contact with moisture, as when the M-44 ejects the sodium cyanide into the oral cavity, the compound reacts to form a gas, hydrogen cyanide. Hydrogen cyanide is the actual toxicant that causes asphyxiation when inhaled. Specifically developed for the control of coyote depredation on livestock. The devices are to be checked weekly at the very least. The compound is highly mobile in soil. Primary toxicity is a serious potential for non target species. Secondary toxicity is thought to be unlikely due to the nature of the compound and its limited ability to assimilate into tissue.

  Sodium Fluoroacetate (FCH2COONa; Compound 1080, 1.04%): Used and modified for the control of coyote depredation to livestock. Originally designed for rodents, but the nontarget effects from the primary and secondary toxicities caused the compound to be cancelled. It was registered again for use in 1985 only in a device called the Livestock Protection Collar (LPC). This is a velcro harness for small sheep and goats with two rubber bladders on each side of the throat which contain a one percent solution of the compound. That amounts to approximately six lethal doses for coyotes. Primary nontarget hazards could result from any animal that comes in contact with the poison or poison-carrying device. Secondary nontarget hazards could arise from any animal coming in contact with an infected organism.

  Thought to only attract target species such as coyotes and other canines, Wildlife Services records show a surprising number of other species have succumbed to the poison. Raptors in particular need several days to recover from a sub-lethal exposure to the compound, and have died from lethal doses. There are several raptors and scavenging birds for which compound 1080 poses a serious threat. The compound remains in the tissues of species exposed to the poison. There are also instances of poisoning of domestic animals due to ruptured poison bladders on the collars from vegetation or fencing. An animal that even so much as licks the wool or fur of an infected carcass could receive a lethal dosage.

  Unfortunately, little is known about the environmental fate of the compound. It is known that the compound is extremely soluble in water. The potential of plants bioaccumulating the compound in their cells is high. Compound 1080 represents one of the most harmful compounds that Wildlife Services uses. It is an indiscriminate killer. The lethal dose for most animals is around a milligram per kilogram of body weight. There are several threatened or endangered species that could be affected. Since the location of infected animals is seldom known (coyotes and other victims are seldom found), the potential for any of a number of non-target species to come in contact with an infected carcass is incredibly high. After ingesting the poison, it may take up to six hours for death to occur, so the victim can be miles away.

  Sodium Nitrate (NaNO3): A pyrotechnic fumigant that emits toxic fumes when burned. If not ignited, the compound is relatively nontoxic. Has been manufactured for more than 40 years. Used mostly in coyote dens. The product is highly mobile in soils. There is little potential for bioaccumulation. When ignited, the gas emitted is carbon monoxide, which causes death by asphyxiation. It has been placed in the highest toxicity category due to the inhalation hazard. Primary toxicity is high. Secondary toxicity is potentially low.

  C21H22N2O2: Historically used in the control of vertebrate pests. It is currently restricted to below ground applications in burrows and runways for killing rodents. Can only be used by state-certified pesticide applicators. The compound has moderate mobility in soil. There is a half life of 28 to 112 days depending on conditions (more oxygen = higher rate of biodegradation). This would then be classified as having a moderately low persistence. There is a high primary toxicity in both birds and mammals. There is also a good chance that secondary toxicity may occur to predators and scavengers. Aquatic toxicity is potentially high due to the nature of the poison. This compound is highly toxic to almost anything it may come in contact with. There are several variations of the formula that are designed to target specific species such as pocket gophers, ground squirrels, marmots, woodchucks, and prairie dogs.

  Zinc Phosphide (Zn3P2): One of the most widely used rodenticides in the world. Has the ability to kill in one dose, but normally that option is not available due to the offensive taste and odor. Can only be used by state certified pesticide applicators. Primarily used on state owned range land and private lands. Not likely to be mobile in soil, but is fairly persistent. The compound has not been known to bioaccumulate in plant or animal tissues. There is a high avian toxicity, a potential for secondary toxicity due to the persistence of the compound in the gut, and a varying aquatic toxicity.

  Kill Data
  The following charts on kill data are sourced directly from USDA Wildlife Services:

  Wildlife Services Mammaliam Kill Data for 2007
  Animals Shot from Aircraft by Wildlife Services, 2001-2007 ”

  http://animal-cruelty-awareness.piczo.com/hunting?cr=7&linkvar=000044
  “Hunting, the stalking and killing of animals, has been an American tradition most likely since the Ice Age when plant food became scarce. Today it exists as a “sport”; even when the animals’ flesh is eaten, there is no excuse or justification for stalking and killing an animal in his or her habitat. Nevertheless, people not only engage in hunting but strongly defend it as their right to do so. With an arsenal of rifles, shotguns, muzzleloaders, handguns, bows and arrows, hunters kill more than 200 million animals yearly – crippling, orphaning, and harassing millions more. The annual death toll in the U.S. includes 42 million mourning doves, 30 million squirrels, 28 million quail, 25 million rabbits, 20 million pheasants, 14 million ducks, 6 million deer, and thousands of geese, bears, moose, elk, antelope, swans, cougars, turkeys, wolves, foxes, coyotes, bobcats, boars, and other woodland creatures. (Compiled by The Fund for Animals with data from the U.S. Fish and Wildlife Service and state wildlife agencies.)

  Less than seven percent of the U.S. population hunts. Hunting is permitted on 60 percent of U.S. wildlife refuges and in many national forests and state parks. On federal land alone (more than half a billion acres), more than 200 million animals are killed every year.

  Hunting by humans operates perversely. The kill ratio at a couple hundred feet with a semi-automatic weapon and scope is virtually 100 percent. The animal, no matter how well-adapted to escape natural predation, has virtually no way to escape death once he/she is in the cross hairs of a scope mounted on a rifle. Nature’s adaptive structures and behaviors that have evolved during millions of years simply count for naught when a human is the hunter. Most deer, for example, would not perceive anything that is within the effective range of a big game rifle (up to 400 yards) as a predator or a source of danger. A wolf at that distance, even though detected, would be totally ignored. Even the much smaller range of bow-hunter (about 50-75 feet) is barely of concern to deer. Deer may start to keep an eye on a hunter at that distance, but the evasion instinct doesn’t kick in until it’s too late.

  The stress that hunting inflicts on animals–the noise, the fear, and the constant chase–severely restricts their ability to eat adequately and store the fat and energy they need to survive the winter. Hunting also disrupts migration and hibernation, and the campfires, recreational vehicles, trash, and other hunting side effects endanger both wildlife and the environment. For animals like wolves who mate for life and have close-knit family units, hunting can severely harm entire communities.

  Hunters and hunting organizations, including state and federally funded sponsors like Fish and Wildlife Services and departments of environmental conservation, promote supposed justifications as to why hunting is necessary. One of these justifications is that if certain animals were not hunted, they would slowly die of starvation and thus the lesser of the two evils is to humanely kill them. There are problems with this logic.

  When hunters talk about shooting overpopulated animals, they are usually referring to white-tailed deer, representing only 3 percent of all the animals killed by hunters. Sport hunters shoot millions of mourning doves, squirrels, rabbits, and waterfowl, and thousands of predators, none of whom any wildlife biologist would claim are overpopulated or need to be hunted. Even with deer, hunters do not search for starving animals. They either shoot animals at random, or they seek out the strongest and healthiest animals in order to bring home the biggest trophies or largest antlers. Hunters and wildlife agencies are not concerned about reducing deer herds, but rather with increasing the number of targets for hunters and the number of potential hunting license dollars. Thus, they use deer overpopulation as a smokescreen to justify their sport. The New Jersey Division of Fish, Game and Wildlife states that “the deer resource has been managed primarily for the purpose of sport hunting,” (New Jersey Division of Fish, Game and Wildlife, An Assessment of Deer Hunting in New Jersey, 1990).

  Hunters also shoot nonnative species such as ring-necked pheasants who are hand-fed and raised in pens and then released into the wild just before hunting season. Even if the pheasants – native to China – survive the hunters’ onslaught, they are certain to die of exposure or starvation in the nonnative environment. While hunters claim they save overpopulated animals from starvation, they intentionally breed some species and let them starve to death.

  Hunters and hunting organizations also promote the idea that hunting is necessary for “wildlife management” and “conservation.” “Wildlife management” and “conservation” are euphemisms used to describe programs that ensure that there are always enough animals for hunters to hunt. Because they make their money primarily from the sale of hunting licenses, the major function of wildlife agencies is not to protect individual animals or biological diversity, but to propagate “game” species for hunters to shoot.

  State agencies build roads through our wild lands to facilitate hunter access, they pour millions of tax dollars into law enforcement of hunting regulations and hunter education, and into manipulating habitat by burning and clear-cutting forests to increase the food supply for “game” species such as deer. More food means a larger herd and more animals available as targets. Hunting programs also cause wildlife overpopulation by stimulating breeding by conducting “buck only” hunts, which can leave as many as six does per buck; pen-raising quail, grouse, and pheasants for use as hunters’ targets; transporting raccoons, antelopes, martens, wild turkeys, and other animals from one state to another to bolster populations for hunters; and exterminating predators like wolves and mountain lions in order to throw prey populations off balance, thereby “justifying” the killing of both “dangerous” and “surplus” animals.

  Hunters claim that they pay for “conservation” by buying hunting licenses, duck stamps, etc. But the relatively small amount each hunter pays does not cover the cost of hunting programs or game warden salaries. The public lands many hunters use are supported by taxpayers. U.S. Fish and Wildlife Service programs, which benefit hunters, get most of their funds from general tax revenues, not hunting fees. Funds benefiting “non-game” species are scarce. Hunters kill more animals than recorded tallies indicate. It is estimated that, for every animal a hunter kills and recovers, at least two wounded but unrecovered animals die slowly and painfully of blood loss, infection, or starvation. Those who don’t die often suffer from disabling injuries. Because of carelessness or the effects of alcohol, scores of horses, cows, dogs, cats, hikers, and others are wounded or killed each year by hunters. In 1988, 177 people were killed and 1,719 injured by hunters while walking through the woods or on their own property.

  Hunters say that they are “ethical” and follow the concept of “fair chase.” What is fair about a chase in which the hunter uses a powerful weapon from ambush and the victim has no defense except luck? Furthermore, despite the hunting community’s repeated rhetoric of “hunting ethics,” many hunting groups have refused to end repugnant practices that go above and beyond the cruelty inherent in all sport hunting. There is clearly no “fair chase” in many of the activities sanctioned by the hunting community, such as: “canned hunts,” in which tame, exotic animals – from African lions to European boars – are unfair game for fee-paying hunters at private fenced-in shooting preserves; “contest kills,” in which shooters use live animals as targets while competing for money and prizes in front of a cheering crowd; “wing shooting,” in which hunters lure gentle mourning doves to sunflower fields and blast the birds into pieces for nothing more than target practice, leaving more than 20 percent of the birds they shoot crippled and un-retrieved; “baiting,” in which trophy hunters litter public lands with piles of rotten food so they can attract unwitting bears or deer and shoot the feeding animals at point-blank range; ‘hounding,” in which trophy hunters unleash packs of radio-collared dogs to chase and tree bears, cougars, raccoons, foxes, bobcats, lynx, and other animals in a high-tech search and destroy mission, and then follow the radio signal on a handheld receptor and shoot the trapped animal off the tree branch.

  Some hunters say hunting with a bow and arrow avoids using high tech equipment that might make it an unfair chase. Bow hunting is one of the cruelest forms of hunting because primitive archery equipment wounds more animals than it kills. Dozens of scientific studies indicate that bow hunting yields more than a 50 percent crippling rate. For every animal dragged from the woods, at least one animal is left wounded to suffer – either to bleed to death or to become infested with parasites and diseases. “

• Shari Welsh April 14th 2011 at 12:01 pm   #     

  Oh and no areas are beyond repair, and get all welfare cattle and sheep off all our public, refuge and any other of OUR lands. State and Federal Fish and Wildlife agencies again are accomplices in murdering wildlife and destroying our lands, water , wildlife, soil, native plants and causing noxious weed explosion by allowing millions of privately owed welfare cattle and sheep on to our lands.

• Shari Welsh April 14th 2011 at 12:05 pm   #     

  http://animalrights.about.com/od/wildlife/f/HuntingAccident.htm
  ” Question: How Many People are Killed or Injured in Hunting Accidents?
  Answer:
  According to the International Hunter Education Association, approximately 1,000 people in the US and Canada are accidentally shot by hunters every year, and just under a hundred of those accidents are fatalities. Most victims are hunters, but non-hunters are also sometimes killed or injured. Although some other forms of recreation cause more fatalities, hunting is one of the few activities that endangers the entire community, and not just the willing participants.

  The Committee to Abolish Sport Hunting maintains the Hunting Accidents Center site, which collects news stories about hunting accidents throughout the United States. Although the list is long, it’s not comprehensive, and not every hunting accident is reported in the news. If you’ve seen a newspaper article about a hunting accident that is not included in the site, you can submit a report. “

• Tara Wertz April 19th 2011 at 2:38 pm   #     

  p7, L 10: I don’t believe it is “difficult” for land managers to identify those lands you reference. The difficulty lies with actually implementing the action needed on the landscape.

  p8, L 39-41: I think we should be careful not to limit ourselves too much in what we can protect. Key pieces may never come up for protection and we should not pass up lesser valued pieces today when in fact these piecse could be keystone pieces in the future when everything else has been irrevocably harmed.

  p9, L 37: Please identify the “others” you are referencing here, even it is just an example and how their models are success stories.

  p12, L 32-41: Good job

  p 13, L23-30: While the policy may have good intentions, the reality is that managers and staff are often asked to be silent and/or temper comments to the point of having not effect on issues outside of the boundaries for a variety of reasons including political ramifications. At the same time, actions on the refuges can be stopped or greatly reduced when they negatively affects or are even perceived to be an impact on neighbors. The Policy needs to meld this disconnect toward an achievable goal for filed staff.

  p 14, L 17-44 This is good.

  p15, L 42-43: I like this recommendation

  p16, L 40-41: I like this recommendation

  p19, L 14-25: While I enthusiastically support the Farm Bill programs and the great work we have done working together on these projects, most require non-federal matching money/in-kind contributions. While some are easily found, many big projects are never able to come up with those $$. There needs to be some mechanism where the dollars can be found from either another agency willing to chip in or perhaps add dollars to the completed project such as in maintenance or monitoring.

  p20, Invasive species section: I would urge this section be beefed up both is scope and effort to join with resource agencies as well as Port Authorities, Border Patrols, Homeland Security, and Defense Department

  p21, L 5: I will send you a truckload of expensive dark chocolate to remove “untrammeled”.

• Anonymous April 22nd 2011 at 6:22 pm   #     

  I was re-reading “Keeping Every Cog and Wheel: Reforming and Improving the National Wildlife Refuge System” this afternoon and was struck by this Draft Vision document’s silence on mineral (including oil & gas) extraction. Of course, others have noticed this too and indeed, one of the leading vote-getters in the Bold Ideas forum is to “Prohibit Mining and Oil Exploration on National Wildlife Refuges.” Since it would never be politically feasible to do this outright, perhaps the NWRS should consider the recommendation as posed in “Keeping Every Cog and Wheel”:

  Improve the management and oversight of mineral extraction. New regulations should be promulgated that establish a detailed and precautionary approach to the approval and subsequent management of mineral activities.

  In any case, the NWRS should NOT be silent in this issue within their Vision document.