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Sam Parks

Submit your comments to demand coexistence for native wildlife

Your voice is needed to protect carnivores across the West

Wildlife Services is seeking public comments on their proposed environmental analysis documents in the states of Montana and Oregon. Please see below for links to submit comments and relevant deadlines by state. We encourage you to submit comments for each state, whether or not you live in that particular state. You must submit separate comments to each link in order for your comments to be included.

We’ve provided talking points below to help guide you in writing your comment letters to Wildlife Services. Please use these talking points as a guide for drafting your individual comments; however, what’s most important is that your voice and your reasons for protecting native carnivores come through. So please speak in your own words, but make sure to emphasize the fact that Wildlife Services should adhere to the following principles in conducting wildlife management:

  • Any environmental analysis conducted by Wildlife Services must comply with the best available science on the environmental impact of removing native wildlife from ecosystems, particularly the removal of native carnivores.
  • Wildlife Services must place value on peer-reviewed studies that can be replicated, are objective, and have been published within the last decade. The body of internationally-recognized, quality, modern science demonstrates that nonlethal technical tools are more effective at preventing livestock conflicts than killing carnivores.
  • Wildlife Services must consider the cumulative impact of killing carnivores in its analysis, including the lasting impacts to biodiversity and the unintended consequences of such killing to nontarget species.
  • Wildlife Services should prioritize nonlethal “predator damage management” when responding to requests for conflict assistance by promoting better husbandry practices, range riding, guardian animals, fladry/turbo fladry, and RAG devices. Wildlife Services should only use lethal management, if at all, after all nonlethal methods have been fully exhausted.
  • Wildlife Services should not use any tools to cull general populations of carnivores—such as aerial gunning or indiscriminately placed traps—as such methods are proven to not be effective long-term in managing wildlife conflicts and are unnecessarily cruel.
  • Sodium cyanide devices (“M44s”) and Compound 1080 are indiscriminate, dangerous poisons that pose a public safety risk and should not be used on any state or federal public lands.
  • Wildlife Services should not engage in carnivore killing on public lands as these lands are held in trust for the public at large, the majority of whom prefer animals alive.

 

Comment Links and Deadlines

Montana, Draft Environmental Assessment (due February 19, 2021):
https://www.regulations.gov/commenton/APHIS-2021-0002-0001

Oregon, Environmental Impact Statements (due February 22, 2021):
https://www.regulations.gov/commenton/APHIS-2019-0076-0002

 

Sample Comment Letter:

The environmental analysis presented by Wildlife Services disregards the values of the general public and defies the best available science. In fact, multiple peer-reviewed studies have concluded that nonlethal carnivore coexistence techniques are far more effective at reducing livestock losses than lethal control. However, this document reaffirms that the program plans to continue killing coyotes, foxes, black bears, and cougars at the behest of the livestock industry using cruel and indiscriminate tools.

In moving forward, the program should prioritize nonlethal “predator damage management,” saving lethal control as an option only after ALL nonlethal methods have been exhausted and if the predating animal can be the only target. It is time for the killing culture of Wildlife Services to change and begin to represent the values of the states in which they work.

Thank you.

Sincerely,

 

To learn more about the taxpayer funded war on wildlife visit our site: www.endthewaronwildlife.org