3/30/2017 news from the MN state capitol on the bill to prohibit the MN DNR from further restricting the use of lead shot in hunting (HF 256 / SF 263):
MN Rep. Jamie Becker-Finn brought an amendment to the House floor to remove the prohibition from the omnibus environment & natural resources finance & policy bill, HF 888. Unfortunately, it failed 50-82 on a roll-call vote.
Video 1: Highlights from the debate of the amendment.
Video 2: Full debate of the amendment.
proposed lead shot restrictions on farmland WMAs.
To: USDA, APHIS, Nevada Wildlife Services Program (NWSP).
Re: Setting requirements for the new EA on predator-damage management in Nevada
Docket ID: APHIS-2016-0077
Thank you for the opportunity to "get involved in the planning process for the development of the new Environmental Assessment (EA) on predator damage management in Nevada."
You've requested responses to the following three questions:
I've numbered my responses to question 1 to match the list of environmental-impact issues listed in the "invitation for publicscoping" for this Docket ID APHIS-2016-0077. The first part of the number is always 1, which identifies my comment as a response to your question 1. The second part of the number identifies the environmental-impact issue in your (un-numbered) list of eight in the "invitation for public scoping." The third part of the number, if any, identifies one of multiple comments on an environmental-impact issue under question 1. For example, the number 1.1.1 identifies my first comment on the first environmental-impact issue listed in the "invitation for public scoping" in regard to your question 1. The number 1.1.2 identifies my second comment on the same issue. The number 1.2 identifies my comment on the second issue, and so on.
1.1.1 A definition of the term "viability" is needed regarding this issue. The term in this context is too often reduced to an insignificant subset of its meaning, and measured only by numbers such as statewide or regional population size. A more meaningful definition of "viability" should reflect the imperatives of genetic diversity, seasonal and dispersing migration, social stability and inter-generational learning, the balance of ecological services provided and received, and freedom from unreasonable human interaction and interference. All of these are essential to the viability of a wildlife population.
1.1.2 A special emphasis in this issue has been put on "lethal removals." If that emphasis is to remain, then an additional issue should put a complimentary emphasis on "non-lethal controls."
1.2 All that's currently planned for the EA regarding this issue is to list some of the "indirect ecological effects from removing predators." That's a good start, but what's needed then is to evaluate the significance of those effects from the perspectives of the stakeholder groups (including the stakeholder group of "affected wildlife").
1.3.1 The syntax in which this issue is written seems to confuse the question. The overall question should be "What are the effects--on humans, non-target animals, wounded target animals, etc.--of the use of lead ammunition by NWSP?"
1.3.2 A subsequent question would be "What are the potential costs and benefits of switching to non-toxic ammunition in order to mitigate these effects of lead ammunition?"
1.3.3 A subsequent question should be asked for each toxin with secondary effects (i.e. for each toxin that can indirectly poison organisms that come in contact with the poisoned targets).
1.3.4 A subsequent question should be asked for each toxin with primary effects on non-target organisms (i.e. for each toxin that can directly poison organisms other than the intended targets).
1.4 A critical question is asked in this issue about the effects of the NWSP on threatened and endangered species. A subsequent question should be asked about the comparison of the effects of lethal vs. non-lethal control measures (on threatened and endangered species). Without such a comparison, there's the danger that the effects of lethal operations will continue to be written off as losses "incidental" to "necessary" lethal operations. That's an old error of false dichotomy that we need to get out of the habit of repeating: the choices are not 1) "all lethal" or 2) nothing; they're 1) "all lethal" with an unhealthy dose of denial as to the true alternatives, 2) "integrated pest management" as a scientific discipline and best practice, 3) non-lethal as much as possible, or 4) "nothing," the fool's argument in a fallacious construction of a strawman defense.
1.5 A critical question is asked in this issue about effects of the NWSP on wilderness areas. Subsequent questions should explore the effects on whole ecosystems, watersheds, etc. that include wilderness areas mixed with other areas on which agriculture and other uses predominate. For example (#1), the effects of NWSP in areas where agriculture and other uses might be considered by some stakeholders to be suboptimal uses, considering the optimal potential for wilderness restoration in those areas. For example (#2), the effects of providing government subsidies to agricultural producers in the form of lethal wildlife removal in areas where wildlife naturally migrate through patchworks of wilderness alternating with agriculture. For example (#3), the negative potential for artificially "propping up" certain agricultural operations in areas where the public interest would be better served by returning these areas to wilderness (or at least to uses more compatible with the nearby wilderness areas).
1.6 A critical question is asked in this issue about considerations in the NWSP for humaneness and ethics. As in the second issue, what's needed is an evaluation of the significance of these considerations from the perspectives of each stakeholder group (including the stakeholder group of "affected wildlife"), and an evaluation of what is lost by each stakeholder group when their considerations for humaneness and ethics are disregarded, minimized, or insufficiently respected. For example (#1), the high numbers that might be proposed by wildlife advocates--but not accepted by livestock producers--as "acceptable losses" of livestock. For example (#2), the loss of the stable social groups of predators (valued by wildlife advocates, scientists, ecotourists and guides, etc.) as a consequence of the removal of individuals or whole groups through lethal predator control.
1.7 A critical question is asked in this issue about the effects of the NWSP on what might be better phrased as "the public's recreational, scientific, spiritual, aesthetic, etc. relationships with wildlife." A subsequent question should be how those relationships have evolved, or to the contrary how they have been stifled, by past programs of the NWSP (and by the socio-political environment that they've fostered). In other words, not just "What are the effects of the NWSP on how these stakeholder groups are seeing things now?" but "How has the influence of the NWSP kept these stakeholder groups from seeing things more accurately and fully, from their own perspectives and from the perspectives of others?".
1.8 In issues of public safety, including the safety of pets, an unfortunate assumption is sometimes made, that certain stakeholder groups should be more, or solely, responsible for their own safety. For example, trapping advocates have blamed pet owners for bringing their dogs to areas where trapping is legal (even if trapping remains legal only as a consequence of a political negligence or refusal to adapt to changing recreational patterns in contemporary society). This assumption should be explicitly removed from the NWSP EA, so that it cannot be used to evaluate this issue.
Alternative 4 in the "invitation for public scoping," would call for lethal action by NWSP only after "reasonable application of non-lethal methods" had been shown to be ineffective. Unfortunately, that kind of wording leaves a number of loopholes through which exclusively-lethal programs may be adopted following the intended failure of token non-lethal methods. What's needed is an additional alternative (to be referred to here as Alternative 4.1) in which the term "reasonable application of non-lethal methods" is replaced by a term like "application of a complete program of non-lethal methods specified by <an independent and peer-reviewed advisory group representing all stakeholders> according to best-available science and reasonable fiscal restraint." Alternative 4.1 should limit lethal actions to those that have been authorized by the advisory group, and to those that are considered necessary to restore the situation to one that can be managed by the underlying non-lethal program. For example (#1), if a predator breaks through a barrier that meets the advisory-group specifications, and if that predator is threatening livestock behind that barrier, then the livestock producer or NWSP agent should be preauthorized to lethally remove that predator ASAP. For example (#2), if a predator is harassing livestock without breaking through the barrier, then the livestock producer should be preauthorized to non-lethally repel (i.e. "haze") that predator and end the harassment. If a specified hazing program fails to end the harassment, then the livestock producer or NWSP agent should be preauthorized to lethally remove that predator ASAP. For example (#3), if a program of non-lethal methods is incomplete, then lethal methods should not be allowed on endangered or threatened predator species, and should not be available as a government subsidy to remove predators of other species. The examples (#4 etc.) for herbivorous species, etc. would be similar.
The section "How is NWSP proposing to manage predator conflicts?" in the NWSP "invitation for public scoping" outlines an integrated approach that includes non-lethal cultural practices, non-lethal habitat and behavior modification, and lethal direct control. But in reality, the approach of the NWSP is not truly "integrated." The best that could be said is that it's "mixed." To be truly integrated, it would need to be balanced in a design in which an effective complement of non-lethal practices were encouraged and used scientifically, verifiably, and consistently.
In other words, in the realm of NWSP, non-lethal practices are only used at the option of livestock producers who are willing to pay for them. What's needed is for effective programs of non-lethal methods to be fully recognized, encouraged, and subsidized at no extra expense to livestock producers, compared to the expense of lethal methods.
NWSP needs to use the term "integrated" in its full meaning, as generally accepted by experts and best-practitioners in the discipline of Integrated Pest Management.
Thank you, again, for the opportunity to comment, and for considering my comments. If I can clarify or improve them, please don't hesitate to ask. I'll be happy to do so.
Screenshot of the USDA/APHIS "Invitation for Public Involvement, Scoping: Predator Damage Management in Nevada." Docket ID: APHIS-2016-0077.
Wild canid ecologist Chris Schadler discusses the fascinating ecology and surprising behavior of the eastern coyote, and how we can coexist.
This is not a "sound byte" or thirty-second PSA; it's a pleasantly long and slow talk by a very well-informed scientist and nature lover, interspersed with questions and answers with a curious bunch of Vermont environmental "hippies," bits of humor and affectionate profiles (sexually oriented!) of wildlife living on the human-altered landscape.
So set aside an hour and a half for the whole talk, or skip through and enjoy parts of it. There are no prerequisites; you can go to any point and enjoy!
To: U.S. Fish & Wildlife Service (USFWS)
Re: Proposed delisting of the Greater Yellowstone Ecosystem Population of Grizzly Bears. (Docket No. FWS-R6-ES-2016-0042)
I oppose the delisting of Grizzly Bears in the Greater Yellowstone Ecosystem (GYE). Their population has recovered to what appears to be a stable point at which it's able to sustain itself. Many would like to see it expand further, for reasons of population health and viability.
With food supplies limited and natural migration and reproductive imperatives and behaviors what they have always been (and hopefully what they always will be), they need room to roam outside the borders of Yellowstone National Park. And we need to continue to conserve their habitats in that broad range.
Grizzlies and other large predators are essential to their ecosystems. This is how nature was created, and this is how it should be conserved and restored under our stewardship.
Recreational hunting in the GYE is not needed as an additional source of mortality to control their numbers. Furthermore, recreational hunting is not well suited to use as a wildlife-management technique targeted at the attainment of ecosystem-based management objectives; to the contrary, it tends to be directed at the taking of "trophy" animals rather than problem animals, or the young, old or otherwise weakened individuals that tend to suffer the highest mortalities in nature.
Hikers, campers, and visitors to the off-trail areas of GYE are generally well aware of the need to be alert and avoid encounters with wildlife. Those that are not need to improve; we should not enable their ignorance or stubbornness by imposing it on their natural surroundings.
Although there is something to be said for providing recreational opportunities to the sporting community, there is more to be said for moving more toward the ecosystem-based management that a growing number of U.S. environmentalists, students, tourists, etc. are learning to understand, appreciate, and enjoy.
Human society's way into the future will be less about making the outdoors our drop-off points for human-centered recreational activities; and more about supporting and enjoying our wild ecosystems for what they are in their own right. As a strong step forward into that future, let us continue our protections of GYE Grizzlies under the U.S. Endangered Species Act.
To: MN House of Representatives, Committee on Mining and Outdoor Recreation Policy.
Cc: Committee staff and bill authors.
Re: Night-Vision Scopes and Wildlife Vigilantes (Opposed to HF 2819 & HF 3160)
Get ready for some wild-west, Minnesota coyote-cowboy, vigilante, American-sharpshooter, marketing hype! "It's comin' yer way!"
Proposals to allow hunting with military-style night-vision optics:
These bills are on a fast track at the MN House of Representatives. They were introduced on 3/10/2016 and 3/16/2016, with hearings promptly scheduled for 3/22/2016.
Why? Because we're afraid of predators! And we hate those dirty prairie dogs!
No, not really; most of us aren't, and we don't. We're learning how to live with them. We're not buying the old misinformation.
To put this in perspective: if the DNR were to propose a coyote-extermination program, we would ask them for their references, and they wouldn't be able to produce them. The proposal would fizzle out. Ill-advised. No scientific merit.
But cloak this "killing for the sake of killing" in a slick marketing package, and its base motivations might start to look more like the manly weapon toting that's portrayed in the sales videos: rescues and security.
Minnesota legislators, we need you to see through the hype and examine the issues. Minnesota does not have, and should not have, a coyote-extermination program. When the proponents of these new technologies say they need them to kill more coyotes, ask them for their references. There won't be any. Killing more coyotes isn't the answer to any problem in wildlife management, livestock-depredation control, or public safety. The proposal is ill-advised. No scientific merit. Please oppose HF 2819 and HF 3160.
To: MN Legislators
Re: 2015 bill SF 2238 / HF 2605: Please Add Reimbursement for the Costs of Non-Lethal Beaver-Damage Avoidance.
Beaver-damage control is important, and beavers are important. New non-lethal options can allow both.
In cases where landowners and land managers want to pursue non-lethal options, they should receive the same support, or I would argue, greater support in order to encourage them to design and implement programs with better ecological benefits.
As I understand it, a growing number of landscaping companies are now equipped with plans and experience to design, construct, and maintain "flow devices" with brand names like "Beaver Deceiver," "Pond Leveler," "Castor Master," etc. High-value trees can be protected by fencing, or by beaver-repellent surface applications. The idea is to leave the beavers where they are (in places where they can be valuable additions to the wetlands), but keep them from causing damage to roads and other property.
Compared to the annual costs of beaver trapping and dam removal, there can be financial advantages to flow devices.
In areas where ecotourism is a known or potential benefit, flow devices (and live beavers) can provide additional social, financial, and ecological benefits. In communities with booster clubs for local natural areas, volunteer assistance can be available to help with design, construction, and annual maintenance.
I hope you'll consider adding the option to SF 2238 / HF 2605 to reimburse the cost of flow devices.
To: Michigan Natural Resources Commission (Cheryl Nelson, firstname.lastname@example.org)
From: Scott Slocum
Re: Opposed to the proposal to liberalize night-time coyote-hunting regulations.
I am writing in opposition to "Wildlife Conservation Order: Amendment 4 of 2016," which would extend the Michigan daytime and night-time coyote-hunting seasons, and expand the season in which artificial lights may be used at night.
[I had missed a third change due to my misunderstanding of the meaning of the font-strikeout and bolding of old and new language, respectively, on the amended Wildlife Conservation Order. The third change was to allow larger shot in shotguns in night-time hunting. Two larger sizes of shot were allowed: #4 and #3 buckshot.]
I understand that the public has the opportunity to write in about this subject ahead of the 3/10/2016 meeting of the Natural Resources Commission.
Problems with the expansion of night-time hunting
Even with powerful spotlights, hunters have poorer views of 1) their targets, and 2) what lies beyond them.
The first problem (poor identification of targets at night) is that it would be likely to result in an increase in the incidental shooting of wolves and domestic dogs, due to hunters' reduced ability to distinguish them from coyotes.
The second problem (poor identification of what lies beyond the targets at night) is shown in the current regulations, which limit the size of shot in order to limit the damage that might be done in unseen areas beyond the targets. That says something about the danger of shooting at night. It also says something about the willingness of the MI DNR to allow the use of loads with less power to deliver quick, humane kills of coyotes. [In other words, the proposed allowance for larger shot would make night hunting even more dangerous.]
Problems with lengthening the duration of the hunting seasons
Hunting ethics generally call for hunting seasons to end before the mating season, in order to avoid the inhumane starving of infant and young wildlife orphans. This humane concern should apply to all animals, even if some special-interest groups feel it should not be extended to coyotes.
Wolves are harder to distinguish from coyotes when they're young.
Many dog owners are already avoiding coyote-hunting areas in season for fear of incidental shootings of their dogs. By extending the season, those dog owners would be further stressed and deprived of the pleasure of their outdoor recreation with their dogs.
Problems with pursuing an ineffective management strategy
The 2/16/2016 cover letter correctly points out that the proposed liberalization would not be expected to have "significant biological impact" in lowering the overall coyote population long-term. It neglects to mention the likely negative impacts of responses of the coyote population to the increased hunting: increased reproductive rate, and in areas with sheep, increased livestock depredation. The proposed liberalization is thus not justified in terms of overall wildlife management.
The proposed liberalization has many problems and few benefits. It would fail to benefit the general public interest, and would be likely to be contrary to it. Apparently, the only interest it would serve would be that of the predator-caller association and the industries and members it represents. It's a bad idea.
This blog entry is in response to the article "Coyote hunting contest draws complaints from groups" by Lee Bergquist, Journal-Sentinel, 1/21/2016
That article covered the controversy over wildlife-killing contests and the Argonne, WI Predator Hunt at Main Street Ed's on 1/23/2016. The actual theme of the contest: "Come for the bloody carcasses, stay for supper!"
They way the houndsmen's spokesmen describe it, though, it seems far-off and wonderful. They love the chase, following their hounds across the countryside through their cries, barks, and bays. For someone who loves their dogs and doesn't give a thought to the wildlife, apparently there's nothing like it. The houndsmen can follow the location, direction, speed, proximity to target, stage of the chase, and conclusion, in which the quarry is treed. They say they don't know anyone who wants to see an animal die inhumanely; or see a wolf be shot. If a stranger tries to bursts their bubble, they try to denounce the stranger. They say he'll never understand, and they settle back into their comfortable ways of thinking (and lack thereof).
But the "world" they describe only exists in their minds. Wildlife live in reality, and in that reality, the wild families are being terrorized. For those who know them, they're not "quarry," but mother, father, family member--ally in a wild struggle to survive. They're tracked and run to exhaustion by hounds, mauled if caught, killed if necessary, or released to recover or die. If they're spared, they're chased another day. If they're killed, they're killed inhumanely; if they're wounded and left to live or die, they're wounded inhumanely. If they're misidentified as "coyotes," they're shot without caring that they're wolves. If they're not identifiable, they're shot without knowing that they're dogs, or men. If their movements, from a distance, looked like coyotes, or if they ended up by dumb luck in the line of fire of high-powered rifles and low-recognition minds.
Taking things even farther, contest promoters enter the scene, encouraging participants to gear up, take those long shots, and bring in those prizes. They puff-up their participants' pride to the point that they see themselves as--who knows--deputies in "predator management?"
Here's the reality, stated in this article by spokesmen not for themselves or their own lives, but for the reality of wildlife: "This is gratuitous killing." "Killing for prizes or trophies is unjustified and unsportsmanlike." "Indiscriminate killing is ineffective" in controlling livestock losses or regulating deer populations.
We need to know the reality, and we need to act accordingly. We're won't be able to do that as long as we subscribe to the fantasies of these houndsmen's spokesmen, of these contest organizers and weapons salesmen, of these contest participants, so easily flattered and convinced.
We need to end these contests, reform these hunts; and address our wildlife and agricultural programs to the job of effective predator management. In doing so, we'll be both more effective and more humane. We can still spend the money on weapons if we want, on shooting ranges, with targets in our sights instead of living beings.
Announcement of Argonne Predator Hunt at Main Street Ed's, Argonne, WI, 1/23/2016.
To: NY DEC, Joe Racette. email@example.com
Thank you for the opportunity to comment on the proposed rulemaking for Big Bore Air Rifles (Part 1, Section 180.3).
Only a lawyer could love the ambiguous language of the proposed rules. They would allow that a big bore air rifle "...may be used to take big game or wildlife that may legally be taken with a rimfire rifle." This statement is impossible to decipher, either due to poor grammar or poor logic. If it's the grammar at fault (specifically, the use of the word "or" followed by a complex statement), then it conceals an alarming, new allowance--that should not be made--for hunting big game with a big bore air rifle. On the other hand, if it's the logic at fault, then it contradicts itself.
The NY DEC summary of big-game hunting regulations (i.e. "deer and bear hunting regulations," http://www.dec.ny.gov/outdoor/8305.html), says that "It is unlawful to hunt big game with a firearm using rimfire ammunition." Working from this point, using plain logic, (with or without a knowledge of rifle ballistics) the natural conclusion would be that it should therefore be unlawful to hunt big game with a big bore air rifle.
Let me guess: of the following three alternatives, which one was the intended meaning of the proposed rulemaking?
Whichever meaning was intended, (or if some other meaning were intended), the proposed rulemaking should specify the minimum weight of an allowable bullet at 650 fps. It would be negligent and inhumane without that restriction.