USDA Wildlife Services: setting requirements for a new EA on predator-damage management in Nevada

Post date: Nov 7, 2016 5:17:27 PM


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:

    1. "After reviewing the list of environmental issues we will examine in the EA, are there other issues that you believe should be evaluated in the EA?"
    2. "After reviewing the alternatives that may be included in the analysis, are there other approaches that would address the need to manage predator damage that you would like to see considered?"
    3. "Do you have other comments about the scope of analysis of the EA, or relevant information that you would like to contribute to the analysis?"

My responses to Question 1.

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.

My response to Question 2

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.

My response to Question 3

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 &quot;Invitation for Public Involvement, Scoping: Predator Damage Management in Nevada.&quot; Docket ID: APHIS-2016-0077.