Western Watersheds Project PO Box 1770 Hailey, ID 83333 tel: (208) 788-2290 fax: (208) 475-4702 email: wwp@westernwatersheds.org web site: www.westernwatersheds.org Working to protect and restore Western Watersheds and Wildlife March 28, 2017 Jason Suckow Director, Western Region USDA-APHIS-Wildlife Services 2150 Centre Avenue, Bldg. B Mail Stop 3W9 Fort Collins, Colorado 80526-8117 Dear Mr. Suckow: Pursuant to 5 U.S.C. § 555(e), Western Watersheds Project, Predator Defense, WildEarth Guardians, the Center for Biological Diversity, Friends of the Clearwater, Alliance for the Wild Rockies, Western Wildlife Conservancy, Nevada Wildlife Alliance, Gallatin Wildlife Association, Environmental Protection Information Center, the Wolf Conservation Center, Wilderness Watch, Klamath Forest Alliance, Northeast Oregon Ecosystems, Yellowstone to Uintas Connection, Footloose Montana, Animal Legal Defense Fund, Project Coyote, Voices of Wildlife, and the Mountain Lion Foundation petition the Animal and Plant Health Inspection Service (“APHIS”) and Wildlife Services (“WS”) to: 1. Cease all use of M-44 explosive cyanide devices on all land ownerships in the State of Idaho, and 2. Immediately remove any and all M-44s currently deployed on all land ownerships in Idaho. As the recent tragedy involving the killing of a pet dog and the injury of a minor child near Pocatello, Idaho on March 16th, 2017 has shown, these devices are indiscriminate in their lethal effects, and cannot be rendered safe for non-target wildlife, domestic pets, and local residents. This incident shows that Idaho Wildlife Services’ 2016 commitment to cease using M44s on public lands in Idaho is inadequate to protect public safety and wildlife. The deployment of the device within ¼ mile of three homes also violates the 2016 BLM Idaho Falls District workplan with Wildlife Services that directs employees to place these devices more than a quarter mile away from residences. Either the commitment is not being followed by Wildlife Services personnel, or older M-44s are still planted on public lands and have not been removed. In any case, the situation must be rectified with further action. This was not an isolated incident, but instead the latest in a long string of unintentional pet killings and human poisonings resulting from the deployment of M-44s on lands of varying ownerships. Appendix A of this letter contains a litany of specific incidents of injuries and pet killings resulting from the deployment of M-44s by Wildlife Services. Appendix B summarizes the number of dogs killed each fiscal year based on reporting by Wildlife Services. Based on public statements from former Wildlife Services employees, fatal incidents with domestic dogs and other non-target species commonly go unreported, so these figures should be treated as conservative estimates. It is clear from this litany of poisonings that the standard operation procedures used by Wildlife Services in the deployment of these potentially deadly chemical landmines are not sufficient to prevent accidental deaths and injuries, and with the receipt of this letter Wildlife Services cannot claim that it is unaware that its actions are placing the public at risk of injury and loss of pets as a direct result of the use of M-44s. M-44s are indiscriminate killers, killing non-target wildlife such as hawks and eagles, wolverines, lynx, and other species (Marks and Wilson 2005). Earlier in 2017, an M-44 killed a wolf in northeastern Oregon despite an agreement with state agencies that these types of lethal devices not be set in areas where wolves are known to roam. Since 2000, Wildlife Services has killed more than 50,000 members of more than 150 non-target species, including federally- and/or state-protected animals such as Mexican gray wolves, grizzly bears, kangaroo rats, eagles, falcons, California condors, red-tailed hawks, great horned owls, armadillos, pronghorns, porcupines, long-tailed weasels, javelinas, marmots, snapping turtles, turkey vultures, great blue herons, ruddy ducks, sandhill cranes, and ringtail cats.1 Furthermore, Wildlife Services’ predator killing program is potentially counterproductive. Nonselective predator killing methods (like M-44s) have not been shown to reduce losses of domestic sheep to predators (Conner et al. 1998, Mitchell et al. 2004, Berger 2006). In some cases, predator killing programs actually result in increased livestock losses (Peebles et al. 2013, Wielgus and Peebles 2014). Nor has any agency provided an economically rigorous cost-benefit analysis that indicates that the cost of taxpayer expenditures for predator-killing programs are less than the value of livestock lost to predators occupying their native habitats. Predator control also upsets that natural balance of ecosystems, and has the counterproductive effect of releasing smaller predators to increase in population, which causes systemic ecological imbalances that depress populations of birds and other prey species (see, e.g., Rogers and Caro 1998, Crooks and Soulé 1999, Ritchie and Johnson 2009). Eliminating or suppressing populations of apex predators can result in the proliferations of smaller, predators, sometimes called ‘mesopredators,’ to the detriment of birds and small mammals. In Wyoming, coyote control efforts in the name of sage grouse conservation increased the numbers of foxes and other small predators that pose a 1 Tom Knudson, Suggestions in Changing Wildlife Services Range from New Practices to Outright Bans, SACRAMENTO BEE (May 6, 2012). 2 significantly greater risk for sage grouse (Mezquida et al. 2006). This is particularly important given the West-wide imperative for conservation of sage-grouse populations. Even if M-44s killed only target species, we find the use of lethal methods against native wildlife to be morally reprehensible and scientifically unsupportable. Given the serious negative impacts of these types of predator killing programs on native wildlife, the questionable economic benefits (and in many cases, economic harms) of such programs for the livestock industry, and the clear and present danger that M-44 devices pose to families, their pets, and native wildlife, the use of M-44s on open lands of any ownership is unjustifiable and counter to the public interest. We call upon APHIS and Wildlife Services to clear all lands in Idaho of these dangerous devices at the soonest possible time, and prohibit the future placement of such chemical devices on lands of any ownership. Very sincerely yours, Erik Molvar Western Watersheds Project Signing on behalf of Brooks Fahy Executive Director Predator Defense PO Box 5446 Eugene, OR 97405 Office: 541-937-426 Tom Wheeler Executive Director Environmental Protection Information Center (EPIC) 145 G Street Suite A Arcata, CA 95521 Office: (707) 822-7711 Mike Garrity Executive Director Alliance for the Wild Rockies P.O. Box 505 Helena, MT 59624 Gary Macfarlane Ecosystem Defense Director Friends of the Clearwater PO Box 9241 Moscow, ID 83843 (208) 882-9755 Donald A. Molde, M.D. Co-founder Nevada Wildlife Alliance P.O Box 4049 Incline Village, Nevada 89450 Kirk Robinson Executive Director Western Wildlife Conservancy 1021 Downington Av. Salt Lake City, UT 84105 3 Glenn Hockett Volunteer President Gallatin Wildlife Association P.O. Box 5317 Bozeman, MT 59717 (406) 586-1729 George Nickas Executive Director Wilderness Watch PO Box 9175 Missoula, MT 59807 p- 406-542-2048 Maggie Howell Executive Director Wolf Conservation Center PO Box 421 South Salem, NY 10590 Bethany Cotton Wildlife Program Director WildEarth Guardians P.O. Box 7516 Missoula, MT 59807 Andrea Santarsiere Senior Attorney Center for Biological Diversity P.O. Box 469 Victor, ID 83455 Tel: (303) 854-7748 John Carter Yellowstone to Uintas Connection PO Box 363 Paris, ID 8326 Camilla Fox Project Coyote P.O. Box 5007 Larkspur, CA 94977 Kimberly Baker Executive Director Klamath Forest Alliance PO Box 21 Orleans, CA 95556 Brian Perkes President Voices of Wildlife 1042 E Fort Union Blvd # 341 Midvale, UT 84047 Wally Sykes Co-Founder Northeast Oregon Ecosystems Box 733 Joseph, OR 97846 Lynn Cullens Executive Director Mountain Lion Foundation P.O. Box 1896 Sacramento, California 95812 916.606.1610 Connie Poten Secretary Footloose Montana P.O. Box 8884 Missoula, MT 59807 Sarah Hanneken Litigation Fellow Animal Legal Defense Fund 525 East Cotati Avenue Cotati, California 94931 4 Literature Cited Berger, K.M. 2006. Carnivore-livestock conflicts: Effects of subsidized predator control and economic correlates on the sheep industry. Conserv. Biol. 20: 751-761. Conner, M.M., M.M. Jaeger, T.J. Weller, and D.R. McCullough. 1998. Effect of coyote removal on sheep depredation in northern California. J. Wildl. Manage. 62: 690-699. Crooks, K.R., and M.E. Soulé. 1999. Mesopredator release and avifaunal extinctions in a fragmented ecosystem. Nature 400: 563-566. Marks, C.A., and R. Wilson. 2005. Predicting mammalian target-specificity of the M-44 ejector in south-eastern Australia. Wildl. Res. 32: 151-156. Mezquida, E.T., S.J. Slater, and C.W. Benkman. 2006. Sage-grouse and indirect interactions: Potential implications of coyote control on sage-grouse populations. Condor 108: 747-759. Mitchell, B.R., M.M. Jaeger, and R.H. Barrett. 2004. Coyote depredation management: Current methods and research needs. Wildl. Soc. Bull. 32: 1209-1218. Peebles, K.A., R.B. Wielgus, B.T. Maletzke, and M.E. Swanson. 2013. Effects of remedial sport hunting on cougar complaints and livestock depredations. PLOSone http://dx.doi.org/10.1371/journal.pone.0079713. Ritchie, E.G., and C.N. Johnson 2009. Predator interactions, mesopredator release and biodiversity conservation. Ecol. Letters 12: 982-998. Rogers, C.M., and M.J. Caro. 1998. Song sparrows, top carnivores and nest predation: A test of the mesopredator release hypothesis. Oecologia 116: 227-233. Wielgus, R.B., and K.A. Peebles. 2014. Effects of wolf mortality on livestock depredations. PLOSone http://dx.doi.org/10.1371/journal.pone.0113505 5 Appendix A Specific Incidents of Pet Killings and Human Poisonings Caused by M-44s The list below documents incidents of people and domestic animals injured or killed by M-44 cyanide devices used by USDA Wildlife Services. This list was compiled from agency documents, news reports, and various other sources by the Humane Society of the United States and Predator Defense. It is only a partial account, since many deaths go unreported. March 2017: A dog and a 14-year-old boy triggered an M-44 in Idaho. The boy, along with several emergency personnel, were exposed to cyanide. His dog died in front of him. No warning signs were posted.i March 2017: two dogs were killed in Wyoming by an M-44 during a walk with their family.ii February 2011: An M-44 was placed 918 from a residence without the family's knowledge, killing their dog and violating three EPA use restrictions iii,iv February 2010: A dog was killed in Nebraska by an M-44 set by Wildlife Services on the dog owner’s rangeland/pasture.v April 2010: A dog wearing collar and tags was killed in W. Virginia by an M-44 set on neighboring land. The Wildlife Services agent buried her without notifying the family.vi January 2008: A dog was killed by an M-44 in N. Dakota.vii January 2008: A man in Texas was injured by an M-44 placed without his knowledge on grazing land. February 2008: A beagle was killed by an M-44 in Virginiaviii February 2008: a dog was killed by an M-44 in New Mexico.ix April 2008: A dog in N. Dakota was killed by an M-44 set on rangeland/pasture.x June 2008: A pit bull was killed in Virginia by an M-44 in a livestock pasture/hayfield.xi January 2007: A dog was killed by an M-44 in North Dakota. xii March 2007: A Border collie was killed by an M-44 in Virginia.xiii April 2007: A Border collie puppy was killed by an M-44 in Virginia.xiv,xv 6 May 2007: A worker in Texas accidentally triggered an M-44. The cyanide was ejected into the man’s eyes and he subsequently experienced burning and irritated eyes as well as disorientation.xvi,xvii June 2007: A Great Pyrenees was killed by an M-44 in New Mexico.xviii January 2006: A Golden retriever was killed by an M-44 in Virginia.xix,xx February 2006: A Labrador retriever was killed in Utah when she triggered an M-44 set a foot from a road.xxi April 2006: A young German shepherd was killed when he triggered an M-44 on public land in Utah.xxii,xxiii March 2005: An Australian Shepherd was killed in New Mexico by an M-44 set by Wildlife Services on rangeland.xxiv March 2005: A dog was killed in New Mexico by an M-44 set by Wildlife Services on ranch land.xxv April 2005: A Border collie in New Mexico was killed by an M-44 set on the owner’s ranch property.xxvi,xxvii December 2005: A certified therapy dog who worked with at-risk youth was killed in front of a girl's group by an M-44 set 10 feet from a public road.xxviii,xxix January 2004: A dog was killed by an M-44 set by Wildlife Services i n N e w M e x i c o on the ranch of the dog owner’s relative.xxx February 2004: An Irish setter was likely killed by an M-44 in Virginia.xxxi March 2004: A dog in Idaho was found dead within 200 yards of an M-44 set by Wildlife Services in a nearby sheep pasturexxxii,xxxiii March 2004: A German shepherd was killed by an M-44 i n N e w M e x i c o .xxxiv May 2003: Dennis Slaugh was poisoned and permanently disabled when he triggered an M-44 on public land in Utah. He was forced to retire from his job.xxxv January 2002: A rancher i n N e b r a s k a was injured by the accidental discharge of an M-44 that had been set by Wildlife Services on his property.xxxvi February 2002: A dog was killed by an M-44 set by Wildlife Services.xxxvii 7 February 2002: A Labrador retriever was killed in Virginia by an M-44 set by Wildlife Services on a neighbor’s cattle pasture.xxxviii February 2002: a dog was killed in New Mexico by an M-44 set by Wildlife Services on rangeland/pasturexxxix February 2002: A dog triggered an M-44 in Oregon placed on a neighboring ranch by Wildlife Servicesxl February 2002: A dog was killed by an M-44 set by Wildlife Services xli February 2002: A dog was killed by an M-44 set by Wildlife Services on the farm of the dog owner’s relativexlii February 2002: A dog in Oregon took 8 hours to die after exposure to an M-44 set on property next door to her home and without her knowledge. During a subsequent investigation WS requested that Oregon authorities “consider the info provided during the investigation be confidential and not disclosed as public record [emphasis added].” WS also refused to release a copy of the incident report to the dog's owner.xliii,xliv,xlv April 2002: A dog was killed by an M-44 set by Wildlife Services on a neighboring farm in Virginia.xlvi June 2002: A black Angus cow was killed in W. Virginia by an M-44 set by Wildlife Services in a pasture.xlvii November 2002: A woman was injured after trying to remove an M-44 set by Wildlife Services on her neighbor’s property.xlviii May 2001: A dog in Colorado was killed by an M-44 set by Wildlife Services on a neighboring ranch "outside the provisions authorized by state law".xlix April 2001: A dog in Nebraska was killed by an M-44 set by Wildlife Services on rangeland/pasture.l January 2000: A dog in Oregon was killed after triggering an M-44 set 100 yards from the owner's home. The device was one of eight that had been planted in a tree farm frequented by local children.li,lii,liii February 2000: A dog in New Mexico activated an M-44 set on rangeland/pasture by Wildlife Services.liv March 2000: A dog in Colorado was killed by an M-44 set on private property without the knowledge of the owners. The family, including a three-year-old girl, watched as the dog 8 suffered and died. A state investigation found that Wildlife Services had not only trespassed, but broken a suite of federal rules regulating M-44s.lv May 2000: A Border collie in West Virginia was killed by an M-44 set by Wildlife Services in a sheep pasture.lvi September 2000: A county surveyor in Utah discharged an M-44 after m i s t a k i n g i t f o r a survey marker.lvii March 1999: A man and his three-year old daughter were walking with their dog on their property in Colorado when it triggered an M-44 and later died. A WS staffer had placed two traps on their land, trespassing and breaking a suite of federal rules.lviii April 1999: A dog was killed in Virginia when he triggered an M-44 set by Wildlife Services on a neighboring farm. The owner also found another dog’s body at the device. A third dog also came into contact with an M-44 and returned home with red and swollen eyes as well as a swollen mouth and a peculiar odor. The owner himself likely experienced secondary poisoning.lix,lx August 1999: An individual helping a Wildlife Services employee look for and remove M-44s accidentally fired one of the devices.lxi September 1999: A hunting dog was killed in Virginia by an M-44 set by Wildlife Services. M-44s were not permitted for use in that state from September 1 to January 7, but the Wildlife Services employee had failed to remove them.lxii September 1999: A dog was killed in Oregon by an M-44 set by Wildlife Services.lxiii October 1999: A Wildlife Services employee in Texas accidentally discharged an M44 as he was setting it. He had to be airlifted to a facility for treatment.lxiv October 1999: A dog was killed in Utah by an M-44 set by Wildlife Services.lxv December 1999: Two dogs were killed by M - 4 4 s during a hunting trip in New Mexico on state landslxvi December 1999: A citizen in Nebraska accidentally discharged an M-44 as he attempted to move it with a pair of pliers while he was repairing fence wire.lxvii February 1998: A dog in Utah was killed by an M-44 set by Wildlife Services on BLM land that adjoined the owner's private yard. No one was notified about Wildlife Services' activities.lxviii,lxix,lxx November 1998: A man in Texas, working on private land, was injured when he grabbed what he thought was a rusted metal rod to pull it from the ground and an M44 exploded in his hand.lxxi 9 December 1998: A dog was killed in Oregon by an M-44 set by Wildlife Services.lxxii April 1995: A hunter i n I d a h o accidentally discharged an M-44 that had been set by Wildlife Services.lxxiii Fall 1994: A dog in Oregon was walking with its family when it triggered an M-44 set on the property without their knowledge. The owners, not knowing why their dog was in respiratory distress, attempted mouth-to-mouth resuscitation, resulting in secondary cyanide poisoning. The dog suffered for 15 minutes before dying.lxxiv August 1993: Two bow hunters in Utah pulled M-44s set by Wildlife Services.lxxv April 1990: A dog in New Mexico accompanying a ranch hand triggered an M-44. After attempting mouth-to-mouth resuscitation on the dog, who died within a few minutes, the man quickly experienced loss of breath, a swollen tongue, a fast heart rate, numb lips, and curling fingers on one hand. He was transported to a hospital where he was treated and placed in intensive care.lxxvi 10 Appendix B Wildlife Services Summary Statistics of Domestic Dog Killings by M-44s FY 2016: 22 dogs lxxvii and 7 "domestic animals (pets or livestock)" unintentionally killed by M44s lxxviii. FY 2015: 17 dogs and 6 "domestic animals (pets or livestock)" unintentionally killed by M-44s lxxix . FY 2014: 17 dogs and 7 "domestic animals (pets or livestock)" unintentionally killed by M-44s lxxx . FY 2013: 44 dogs and 2 "domestic animals (pets or livestock)" unintentionally killed by M-44s lxxxi . FY 2012: 27 dogs unintentionally killed by M-44slxxxii. FY2011: Wildlife Services reports 32 dogs unintentionally killed by M-44slxxxiii FY 2010: 40 dogs unintentionally killed by M-44slxxxiv FY 2009 32 dogs unintentionally killed by M-44slxxxv FY 2008 32 dogs unintentionally killed by M-44s lxxxvi FY 2007 50 dogs unintentionally killed by M-44slxxxvii FY 2006 63 dogs unintentionally killed by M-44s lxxxviii FY 2005 92 dogs killed by M-44s (not broken out by intentional/unintentional) lxxxix FY 2004 117 dogs were killed by M-44s (not broken out by intentional/unintentional) xc FY 2003 108 dogs killed by M-44s (not broken out by intentional/unintentional) xci FY2002 120 dogs killed by M-44s (not broken out by intentional/unintentional) xcii 2001 169 dogs killed by M-44s (not broken out by intentional/unintentional) xciii 2000 178 dogs killed by M-44s (not broken out by intentional/unintentional) xciv 1999 228 dogs killed by M-44s (not broken out by intentional/unintentional) xcv 1998 267 dogs killed by M-44s (not broken out by intentional/unintentional) xcvi 11 1997 237 dogs killed by M-44s (not broken out by intentional/unintentional) xcvii END NOTES i Idaho State Journal David Ashbury March 16 2017 Pocatello boy watches family dog die after cyanide bomb explodes. http://idahostatejournal.com/news/local/pocatello-boy-watches-family-dog-die-after-cyanide-bomb-explodes/article_d0003a2f-6b7f5d31-b427-68db03d3b93a.html ii http://www.predatordefense.org/features/m44_WY_Amy_dogs.htm iii Predator Defense, http://www.predatordefense.org/m44s_bella.htm iv Tom Knudson, “Efforts to investigate Wildlife Services' methods continue,” The Sacramento Bee, June 25, 2012. v USDA-APHIS-WS, Adverse Effects Incident Information Report. vi Letter from James R. Gardner to Commissioner Gus Douglas, West Virginia State Department of Agriculture, 21 April 2010. vii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. viii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. ix USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. x USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xi USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xiii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xivxiv USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. 21 USDA-APHIS-WS, Report of Injury or Death of Nontarget Animal. xv USDA-APHIS-WS, Report of Injury or Death of Nontarget Animal. xvi USDA-APHIS-WS, Adverse Effects Incident Information Report and Human Incident Supplemental Report. xvii Brazoria County Sheriff Incident/Offense Report, 22 May 2007. xviii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xix USDA-APHIS-WS, Adverse Effects Incident Information Report. xx USDA-APHIS-WS, Report of Injury or Death of Nontarget Animal. xxi Mike Stark, “Dog died at cyanide trap set in an off-limits area,” Associated Press, 01 June, 2008. xxii Memo from Michael J. Bodenchuk, Utah State Director, Wildlife Services to Ms. Barbara Knotz, 21 June 2006. xxiii “Utah couple challenges USDA use of cyanide bombs,” Associated Press, 20 August 2006. xxiv USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxv USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxvi USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxvii USDA Work Task form, 15 April 2005. xxviii USDA-APHIS-WS, Adverse Effects Incident Information Report. xxix Born Free USA, http://www.bornfreeusa.org/database/trapping_incident.php?id=110 xxx USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxi USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxiii USDA-APHIS-WS, Report of Injury or Death of Nontarget Animal. xxxiv USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxv Christopher Ketcham, “America’s secret war on wildlife,” Men’s Journal, January 2008, p. 49. xxxvi USDA-APHIS-WS, Adverse Effects Incident Information Report and Human Incident Supplemental Report. xxxvii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxviii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xxxix USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. 12 xl USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xli USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xlii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xliii Letter from Danielle Clair to Congressman Peter DeFazio, 18 February 2002. xliv Letter from Mark Jensen, Oregon Assistant State Director, Wildlife Services, to Dale Mitchell, Assistant Administrator, Oregon Department of Agriculture, 15 April 2002. xlv Letter from Congressman Peter DeFazio to Bill Clay, Deputy Administrator of Wildlife Services, 24 May 2002. xlvi USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xlvii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. xlviii USDA-APHIS-WS, Adverse Effects Incident Information Report and Human Incident Supplemental Report. xlix Memo from Craig Coolahan, Colorado State Director, USDA-APHIS-WS to Martin Mendoza, Director, OSS, 16 May 2001. l USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. li USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lii Keri Watson and Greg Hanscom, “Poison traps kill unintended victims,” High Country News, March 13, 2000. liii Predator Defense, http://www.predatordefense.org/docs/m44_article_Buddy_Tippetts.pdf liv USDA-APHIS-WS, Adverse Effects Incident Information Report. lv Keri Watson and Greg Hanscom, “Poison traps kill unintended victims,” High Country News, March 13, 2000. lvi USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lvii Memo from Michael J. Bodenchuk to Michael V. Worthen and Thomas R. Hoffman, 28 September 2000. lviii High Country News 3/1300 Poison traps kill unintended victims https://www.hcn.org/issues/174/5628 lix Written account from Gary Tucker, 20 May 1999. lx USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lxi Accident Report signed by Alan May, District Supervisor, 16 August 1999. lxii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lxiii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lxiv USDA-APHIS-WS, Adverse Effects Incident Information Report and Human Incident Supplemental Report. lxv USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lxvi Keri Watson and Greg Hanscom, “Poison traps kill unintended victims,” High Country News, March 13, 2000. lxvii USDA-APHIS-WS, Adverse Effects Incident Information Report and Human Incident Supplemental Report. lxviii Memo from Nick Sandberg, Bureau of Land Management to Mike Bodenchuck, USDA-APHIS-WS, 19 March 1998. lxix U.S. Department of the Interior, Bureau of Land Management Incident Record, Case No. UT-069-98-03. lxx U.S. Department of the Interior, Bureau of Land Management, San Juan Resource Area, Conversation Confirmation Report, 03 March 1998. lxxi Predator Defense, http://www.predatordefense.org/docs/m44_letter_Guerro_DeFazio.pdf lxxii USDA-APHIS-WS, Adverse Effects Incident Information Report and Domestic Animal, Fauna, or Flora Incident Supplemental Report. lxxiii Memo from Dr. Peter L. Joseph, USDA-APHIS-Biotechnology, Biologies, and Environmental Protection to Mr. Robert A. Forrest, U.S. Environmental Protection Agency, 25 April 1995. lxxiv Predator Defense http://www.predatordefense.org/testimonials.htm lxxv Memo from James A. Winnat, Utah State Director, USDA-APHIS-WS to ADC employees, 09 September 1993. lxxvi Memo from Larry J. Killgo, State Director, ADC, Albuquerque, NM to District Supervisor, ADC, Roswell, NM, 01 May 1990. lxxvii Described as "Feral, Free-Ranging, and Hybrids" by Wildlife Services lxxviii https://www.aphis.usda.gov/wildlife_damage/pdr/PDR-G_Report.php?fy=2016&fld=&fld_val= lxxix https://www.aphis.usda.gov/wildlife_damage/pdr/PDR-G_Report.php?fy=2015&fld=&fld_val= lxxx https://www.aphis.usda.gov/aphis/ourfocus/wildlifedamage/sa_reports/sa_pdrs/sa_2014/ct_pdr_g lxxxi https://www.aphis.usda.gov/wildlife_damage/prog_data/2013/G/Tables/Table_G_Long_Method_Featured.pdf lxxxii https://www.aphis.usda.gov/wildlife_damage/prog_data/2012_prog_data/PDR_G/Basic_Tables_PDR_G/Table_G_Long_Method_Featured.pdf lxxxiii USDA APHIS Wildlife Services Program Data Reports. 2011. https://www.aphis.usda.gov/wildlife_damage/prog_data/2011_prog_data/PDR_G/Basic_Tables_PDR_G/Table_G_Long_Method_Featured.pdf. Accessed 3/26/17. lxxxiv USDA APHIS Wildlife Services Program Data Reports. 2010 https://www.aphis.usda.gov/wildlife_damage/prog_data/2010_prog_data/PDR_G/Basic_Tables_PDR_G/Table_G_Long_Method_Fea tured.pdf 13 lxxxv https://www.aphis.usda.gov/wildlife_damage/prog_data/2009_prog_data/PDR_G_FY09/Basic_Tables_PDR_G/Table_G_ FY2009_Long_Method_Featured.pdf lxxxvi https://www.aphis.usda.gov/wildlife_damage/prog_data/2008_pdr/PDR_G/TableG_long/Table_G_FY2008_by_Species_Alphabetically_AllStates.pdf lxxxvii USDA-APHIS-WS https://www.aphis.usda.gov/wildlife_damage/annual%20tables/2007%20PDRs/FY%202007%20Individual%20PDRs/National%20Tables/PDR_G_FY2 007_National%20by_Species_Alphabetically_All%20States.pdf lxxxviii https://www.aphis.usda.gov/wildlife_damage/annual%20tables/Table%20G,%20FY2006.pdf lxxxix https://www.aphis.usda.gov/wildlife_damage/annual%20tables/TABLE%2010T,%20FY%202005.pdf xc https://www.aphis.usda.gov/wildlife_damage/annual%20tables/TABLE%2010Killed,%20FY%202004.pdf xci https://www.aphis.usda.gov/wildlife_damage/annual%20tables/03table10t.pdf xcii https://www.aphis.usda.gov/wildlife_damage/annual%20tables/02table10t_Sept%2007_TX_correct.pdf xciii https://www.aphis.usda.gov/wildlife_damage/annual%20tables/01table10t.pdf xciv https://www.aphis.usda.gov/wildlife_damage/annual%20tables/Table_10_1998-2000/Table10t_FY2000.pdf xcv https://www.aphis.usda.gov/wildlife_damage/annual%20tables/Table_10_1998-2000/Table10t_FY1999.pdf xcvi https://www.aphis.usda.gov/wildlife_damage/annual%20tables/Table_10_1998-2000/Table10t_FY1998.pdf xcvii https://www.aphis.usda.gov/wildlife_damage/annual%20tables/Table_2_1996-1997/Table2t_FY1997.pdf 14