Post date: Jun 27, 2015 7:35:32 PM

To: USDA Wildlife Services.

Re: Predator Damage And Conflict Management In Idaho.

Document ID: APHIS-2014-0105-0072.

Document URL: http://www.regulations.gov/#!docketDetail;D=APHIS-2014-0105

Introduction

Thank you for the opportunity to provide feedback on the draft Environmental Assessment (EA) on Wildlife Services operations in Idaho.

I won't attempt, here, to respond to the entire document, but I do have a response to an overall aspect of it: its natural bias for "business as usual" and against a thorough examination of the problem and the potential for Integrated Pest Management (IPM) to solve it. It's a complex problem that calls for a complex solution. This draft EA attempts to offer oversimplified solutions so that it can conclude that they won't work, and that no changes should be made.

Options oversimplified

This draft EA attempts to reduce a complex situation to a few, oversimplified alternatives--all but one of which would be unworkable--in order to arrive at the predetermined conclusion that Wildlife Services should continue to operate as it has in the past, without integrating new policies or practices.

IPM Ignored

This draft EA ignores the complex alternatives and potentials of Integrated Pest Management (IPM, or as it's referred to here, "integrated PDM" or "integrated predator damage management").

As I understand IPM, it's a combination approach that's taken when there's more than one solution to different aspects of a problem in agricultural management. IPM applies the most effective combination of solutions, in their most effective sequence and schedule, in order to optimize the cost/benefit ratio of the management program.

For example, the lethal and non-lethal approaches to minimizing human/coyote conflict include the following:

Lethal depredation control:

• Degree of targeting in predator removal:
• Taking out known individuals in response to specific depredations.
• Taking out a large percentage of the predator population annually.
• Methods of removal:
  • Trapping.
  • Poisoning.
  • Land-based shooting.
  • Aerial shooting.
  • Removal agents:
  • Wildlife Services agents.
  • Predator-control contractors.
  • Livestock producers.
  • Recreational sportsmen.

Non-lethal depredation control:

• Predator-deterrent fencing:
• Especially at the most vulnerable times: birthing, Spring, early Summer, dusk, dawn.
• Especially in the most likely places: near cover, near den, etc.
• Mobile, as part of a rotational-grazing program.
• Carcass disposal:
  • Buried on-site.
  • Protected by predator-deterrent fence on-site.
  • Contracted off-site.
  • Electronic alarms:
  • Radio-collared predators (location).
  • Radio-collared livestock (heart rate, motion).
  • Radio-collared livestock-guardian animals.
  • Motion detectors.
  • Video monitoring.
• Physical interaction with predators.
  • Range riders driving rotational grazing.
  • Livestock-guardian animals herding and moving with livestock.
  • Human response to electronic alarms.
  • Human response to livestock-guardian animals.
  • Motion-sensitive lighting.
  • Deterrent lighting.
• Animal husbandry.
  • Regular, personal supervision.
  • Monitoring for health.
  • Protecting and treating weakened individuals.

This is just the quick list that came to my mind as I thought about it today. I'd expect this EA to be more exhaustive and integrative than this, but I see that it isn't. That's a problem.

It seems to me that in drafting this EA, Wildlife Services has oversimplified the situation in order to make the predetermined conclusion seem more obvious. It has ignored the IPM approach, and attempted instead to make the situation look like an "either-or" choice between one narrow-minded approach or another (e.g. either all status quo, all advice and no action, all private, or all non-lethal).

Non-lethal cost/benefit ratio and subsidy options neglected

In addition to neglecting the analysis of cost/benefit ratios among the alternatives (essentially leaving that analysis to the private sector), the draft EA doesn't sufficiently explore the following non-lethal options:

• Requiring non-lethal precautions before subsidizing lethal control.
• Subsidizing non-lethal precautions.

The arguments of the draft EA against the subsidy of non-lethal options are not convincing. Agreed, most livestock producers do take various non-lethal precautions at one level or another. Agreed, they don't all take the same level of precautions. But that doesn't mean that fair government subsidies for non-lethal precautions would favor some producers more than others, or that fair subsidies would interfere with existing programs.

Agreed, for livestock producers who have taken appropriate non-lethal precautions, it's in the public interest to provide compensation for the loss of livestock and the expense of lethal control. But that doesn't mean that the only funding option for non-lethal control would be the end of funding for lethal control, or that such a radical shift in funding would be in the public interest. The common-sense option, here, is to integrate government funding in the most effective way along the lines of IPM.

It's not acceptable for this draft EA to set up such a "straw man" argument for a funding shift, and then attempt to dismiss it with an irresponsible statement like "this proposal will not be considered in detail because of the problems associated with unequal access to federal fiscal assistance."

Conclusion

The draft EA needs to be more open-minded in regard to the alternatives. Agreed, that's not simple to do; but given the public interest in wildlife and environmentally-oriented agriculture, and the considerable budget of Wildlife Services operations in Idaho and nationwide, it would be appropriate.